Shoal - Earn with Shoal Savings Pots

Thank you for using the Shoal Platform. The Shoal Platform is provided to you by Shoal Limited (“Shoal” a company incorporated and registered in England and Wales under company registration number 13846154).

Your Personal Data is important to us. We are committed to maintaining the confidentiality, integrity, and security of all personal information you provide to us, or we collect about you.

This privacy notice (“Notice”) outlines how we collect, manage, and store your Personal Data in compliance with applicable laws and regulations. This Notice should be read alongside all other terms and privacy policies that together make up your Terms.

This Notice came into effect on 1 September 2024. It is your responsibility to remain up to date with this Privacy Policy and those of our Partners, with whom you may directly interact through the Shoal Platform and who may provide services to you from time to time. Shoal and our Partners’ privacy policies, and their past versions, are available through the Shoal App or can be obtained by contacting Customer Support (using the details below). Privacy Policies for parties whose account access is not directly integrated into the Shoal App (i.e. Partners to whom you are merely introduced through the Shoal App) are not retained by Shoal.

This Privacy Policy remains in place until such time that either you or Shoal terminates your Shoal Platform User Account and / or you no longer make use of the Platform, the Website or the Shoal App.

This Notice must be read alongside any other terms and notices that together make up your Terms.

Across all this Notice,

“we”, “our” and “us” refer to Shoal, and “you” and “your” refer to the User of any part of the Shoal Platform, the Shoal App, the Website, any of the Shoal Services, or any of Shoal’s Partner / Third-Party Service Provider’s services
Shoal and the User shall as the context so requires, be individually referred to as a "Party" and collectively as the "Parties".
All capitalised words found in these Terms are defined in the Glossary. Definitions apply both to the singular and plural use of the defined terms included in the Glossary.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your Personal Data more generally, please contact the Shoal customer support team through the Shoal App or using the details provided below:

In App: Go to the ‘Support’ section, accessible at the bottom right of the menu bar
Online: https://help.shoalapp.com
By email: support@shoalapp.com

You also have the right to complain to the UK Information Commissioner’s Office (ICO) about the way in which we process your Personal Data. You can contact the ICO at https://ico.org.uk/make-a-complaint.

1. What Personal Data may Shoal collect and hold
1. 1.1. We may collect the following Personal Data from you when you use the Shoal Platform or engage with any of Shoal’s or our Partner Services. We may also collect this data from any Third-Party Service Providers or Partners that we rely on for the provision of the Shoal Platform or our or our Partner Services to you.
  1. (A) Identity Information – including name, gender, date of birth, official ID numbers, digital copy of official IDs (passport, driver’s licence or similar) and photo image.
  2. (B) Contact Information – including current and past email addresses, current and past mobile phone number, current and past addresses.
  3. (C) Employment Information – which may include salary level, employer name, employment position/title.
  4. (D) Financial Information – including bank account details (account number and sort-code), balances and transaction information related to any of the Services you access through the Shoal Platform.
  5. (E) Technical information – including geo-location, IP addresses, device tokens, and device type information.
  6. (F) Profile Information – including your username, password, PIN, preferences, any product or feature survey responses you provide
2. 1.2. If you do not provide us with the Personal Data we or our Partners need to provide you with the Services requested through the Platform or for us or our Partners to meet our / their legal and regulatory obligations, we or our Partners may not be able to provide you with the products or services you have requested.
3. 1.3. Where relevant, before engaging with any of the Partner Services available through the Shoal Platform, you will be prompted to accept their privacy policy. Additionally, by accepting the Partner’s privacy policy, you give Shoal permission to share any relevant information with the Partner to speed up your service onboarding process. We will always remind you of this at the time you are asked to accept the Partner’s privacy policy. The information that Shoal will share with the Partner will be limited to need to know information only (e.g., your name, date of birth, country of residence, your address, and your current contact details).

2. How will Shoal use my Personal Data
1. 2.1. We will only collect, use, and disclose your Personal Data for the purposes set out in this Notice or for purposes of which you have been notified and consented to at the time of sharing this Information, or which are otherwise permitted under applicable laws and regulations.
2. 2.2. We will not sell, rent, or give away Personal Data to third parties for commercial purposes without your consent.
3. 2.3. We (including our Third-Party Service Providers and Partners) may collect, use, disclose and process your Personal Data for the below purposes:
  1. (A) To fulfil any of the Shoal or our Partners’ Services in accordance with the terms you have signed up or registered for through the Platform (together “your Terms”);
  2. (B) To comply with our or our Partners’ legal or regulatory duties arising from or connected to services you have requested, including to perform Know-Your-Customer (KYC) obligations, complying with and monitoring of compliance with applicable laws and regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body;
  3. (C) Based on our legitimate interest, including:
    - In line with voluntary codes and / or in compliance with internal policies (including that of our Partners and Third-Party Service Providers), contractual obligations (including between us and our partners and service providers) and good practice standards;
    - For our internal analytical or statistical purposes or where it is necessary for the proper functioning of the Platform and Shoal’s ability to communicate with you and our customers,
    - In connection with any legal, regulatory and / or law enforcement proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising, or defending our legal rights; or
    - To provide you with relevant information you may need to continue to make use of those Services you use through the Shoal Platform already; and
  4. (D) where you provide us with specific and informed consent, we will process your Personal Data to:
    - Register you for our newsletter and mailing list;
    - Send you updates and offers relating to our existing and future product offering;
    - Reserve your place in line to receive our future products;
    - Gather your feedback on, and other information in relation to, the development of the Platform, and;
    - Invite you to participate in competitions and prize draws.

3. Shoal may disclose your Personal Data to:
1. 3.1. Our Partners and Third-Party Service Providers anywhere in the world, including any officer, employee, agent, or director of any such party and to provide the Platform and related Shoal or our Partner Services to you and for all parties to meet their legal or regulatory obligations;
2. 3.2. Our professional advisers and service providers, providing Shoal with administrative, financial, legal, accounting, information technology, research, or other services;
3. 3.3. Anyone authorised by you, as specified by you or in any contract with you;
4. 3.4. Any person to whom disclosure is required or permitted under applicable laws and regulations; and
5. 3.5. Anyone we consider necessary to provide services in connection with the Platform.

4. How Shoal keeps your data secure
1. 4.1. Your Personal Data may be transferred to, or stored at, a location outside of the UK, which may not have the same or similar data protection laws as those in the UK.
2. 4.2. We will take such steps as are necessary in accordance with applicable law to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under the UK data protection laws. The security of your Personal Data is important to us. We have technical and organisational security measures in place to safeguard your Personal Data.
3. 4.3. When using external service providers, we require that they adhere to specific security standards mandated by us. We may do this through contractual provisions and/or oversight of the service provider. Regardless of where Personal Data is transferred, we take all steps reasonably necessary to ensure that Personal Data is kept securely.
4. 4.4. Neither Shoal nor its Partners and Third-Party Service Providers – nor any other Party with whom Shoal has shared your information in accordance with this Privacy Policy – can guarantee that your Personal Data is safe from cyberattacks (such as hacking, spyware, and viruses) which Shoal, and any related Party, could not reasonably have been expected or able to prevent. Aligned to the Shoal Platform and General Shoal Services Terms and Conditions, our liability to you is limited may such a breach occur.

5. How long will Shoal & its Partners or Third-Party Service Providers keep your data for
1. 5.1. We retain your Personal Data in line with our legal and regulatory obligations and our business and operational requirements. This means that in most cases we will hold your Personal Data for up to 7 years from the end of your relationship with us, that is from the day you cease being a Shoal Platform customer.
2. 5.2. Our Partners and Third-Party Service Providers may have different retention periods for Personal Data that they have collected about you, through us, or by other means (including from you directly). We refer you to these Parties’ privacy policies and their Terms & Conditions (when available), which you must accept before making use of these Parties’ services through the Shoal Platform.
3. 5.3. Where our Partners or Third-Party Service Providers are not the data controller but are the data processor only, they must and will remove any Personal Data they hold about you from their systems; either at termination of our agreement with them or no later than when Shoal’s retention period ends.

6. What are your rights relating your Personal Data
1. 6.1. In those instances where legitimate interest does not apply or where you have specifically instructed us not to process your data for the purposes of marketing new products and services to you, we will not send you marketing material unless you have specifically asked us to do so.
2. 6.2. When you have asked us to send you marketing material, you have the right to opt-out of receiving such material at any time by sending us an email with a request to unsubscribe you from the marketing list or by clicking the “unsubscribe” link, where available.
3. 6.3. For the avoidance of doubt, any form of communication from Shoal which relates to the proper functioning, operations and security of the services that you have registered for or signed up to through the Shoal Platform are not considered marketing material but are considered operational. Operational messaging falls outside the definition of marketing materials and you cannot opt-out of these types of messages / notifications.
4. 6.4. In accordance with the relevant regulations, you have other rights regarding our, our Partners’ or Third Parties’ processing of your Personal Data.
5. 6.5. To make a request to access, correct, erase or restrict the use of, to exercise your right to data portability, or to object to the way in which we process, the Personal Data Shoal holds about you, or to make a request to withdraw any consent previously given, you can contact our team through the Shoal App or using the details provided under the introduction to this Notice (page 1).
6. 6.6. To make such a request for any Personal Data held by our Partners, who may provide services to you directly or through Shoal, please refer to their privacy policy, which you accepted at the time of entering into the agreement with them and as it may have changed from time to time.
7. 6.7. Please refer to the UK Information Commissioner’s website for further information on your rights (https://ico.org.uk/for-the-public).

7. Updates to this Notice
1. 7.1. This Notice may be updated from time to time and amendments take effect from the date they are placed on this site or made available through the Shoal App. Current and past notices will be available on the Platform.
2. 7.2. You are advised to visit the Shoal App or our Website regularly to check for any amendments. This Notice was last updated on the date indicated under the introduction to this Privacy Policy.

Glossary

Customer Support: means the Shoal Customer Support team, available Monday through Friday from 9AM to 5PM. The Customer Service team can be contacted using the details included under the introduction to this Privacy Policy (see page 1).

Information: means any and all details we hold or collect about you, including your User Data, Personal Data, information relating to your transactions, your financial information, and information about you obtained from you and your interactions and dealings with us and any third party.

KYC: means “know your customer” searches to be conducted by Shoal and / or any other Partner or Third-Party Service Provider by such means as deemed necessary which are required to (provide Shoal or Partner Services to you. Shoal may at its discretion conduct KYC searches on behalf of a Partner or Third-Party Services Provider.

Partner: shall mean third-party partners of Shoal from whom Shoal may obtain certain services in relation to the Shoal Platform and/ or the Shoal Services, including but not limited to financial institutions, credit bureaux, verification companies, information repositories and such other parties as deemed necessary by Shoal to provide the Shoal Services.

Partner Services: are products or services provided to you through the Shoal Platform, but which services and products are provided to you under terms between you and the Partner Service Provider directly, thereby differentiating these services from Shoal Services.

Party/Parties: shall mean, in relation to Shoal, its representatives, agents, and any of their respective officers, directors, equity holders, employees, parent entities, subsidiaries, affiliated entities, representatives, agents and licensors. Parties also include Shoal's Partners and Third- Party Service Providers.

Personal Data/Information: means information collected from you or about you that could be used to identify you, as defined more comprehensively in the Shoal Privacy Policy.

Privacy Policy: shall mean the Shoal privacy policy as provided by us to you when you access the Shoal Website or Shoal App and / or when you register onto the Shoal Platform, and as amended from time to time, or any Partner privacy notice that may apply to you, depending on which services you make use of through the Shoal Platform.

Shoal/Shoal Limited: means Shoal Limited, a private limited company registered in England and Wales under number 13846154 with registered address at No. 1 Spinningfields, Hardman Square, Manchester, England, M3 3EB.

Shoal App: shall mean the mobile application belonging to Shoal which is developed and designed to run on various mobile operating systems, for providing the Shoal Services.

Shoal Platform: means the Shoal App, and any other digital channels through which you can access Shoal, invest in Savings Pots and access any other Shoal or Partner Services that Shoal may create or introduce to you from time to time.

Shoal Platform User Account: shall mean the Platform User Account created by you on the Shoal App after successful completion of registration process and acceptance of the Shoal Platform Terms, the Shoal Account terms and conditions (as included in the Shoal Platform Terms and Conditions) and this Privacy Policy.

Shoal Services: shall mean the services provided by Shoal to Users via the Shoal Platform which may be added to and amended by Shoal from time to time. Shoal Services are created and managed by Shoal, differentiating these services from Partner Services.

“Terms / your Terms” means:

A. The Shoal Platform Terms;
B. The Shoal Savings Pots Terms;
C. Any of Shoal or our Partners’ product-specific Terms and Conditions (as they may apply to you from time to time when accessing these services through the Shoal App), including the Shoal Account Terms;
D. The Shoal Privacy Policy and,
E. Any of our Partners’ or Third-Party Service Providers’ privacy policies (as they may apply to you from time to time when making use of their services through the Shoal Platform).

Third Party Service Providers: shall mean Partners, service providers and such other parties appointed by Shoal to provide services to Shoal and to Users.

Third Party Terms: shall mean the additional terms and conditions that you will have to agree to in order to make use of the Partner Services made available to you through the Shoal Platform’ e.g. the Shoal Account Terms and Conditions included as a schedule to the Shoal Platform terms and conditions.

User: shall mean any individual who accesses the Website, registers on the Shoal App, logs into the Shoal Platform or uses any of the Shoal or our Partner Services.

User Data: shall mean any data submitted by User in relation to the Shoal Services or collected and created by Shoal through the Shoal Platform or any of our Partner Services provided to you; including Personal Data / Information, as mentioned in this Privacy Policy. User data includes also any documents shared by you or collected about you via other means.

User Verification: shall mean the process followed by Shoal to complete KYC and to ensure eligibility of the User to apply for and utilise any Shoal or Partner Services.

Website: shall mean the domain www.shoalapp.com

The Shoal App and Shoal Sustainable Savings Pots are provided by Shoal Limited, registered in the UK with Companies House Number 13846154. Our correspondence address is 22 Upper Brook Street, London W1K 7PZ, UK. Our ICO number is ZB403086. Shoal is not regulated by the Financial Conduct Authority (FCA) nor by the Prudential Regulation Authority (PRA) for the provision of financial services and relies on appropriately regulated third parties to provide its services to you.

The Shoal account is issued by Algbra Group Limited who is authorised and regulated by the Financial Conduct Authority (FCA) with registration number 952360.

The Sustainable Finance portfolio against which your savings are referenced and the membership of the Financial Services Compensation Scheme (FSCS) by virtue of which your Savings Pots are protected are provided by Standard Chartered Bank. Standard Chartered Bank is authorised by the PRA and regulated by the FCA (FRN 114276) and the PRA.

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