Tola Privacy Policy

Last updated: March 1st 2022

Introduction

Tola Inc. (“Tola”, “we”, “us” or “our”) provides a digital bill payment solution for small businesses. This Privacy Policy describes our practices concerning the information we receive or collect when you visit our website located at https://tolahq.com (“Website”) or access our online platform through the website (collectively, “Services”). Specifically it describes how Tola collects, uses, shares, transfers, stores, retains, or otherwise processes your personal information.

By using the Services after being provided with this Privacy Policy you consent to Tola’s practices and policies as described herein.

Information Collection

Account information. When you sign up for a Tola account or register as a Tola User, we collect information about you, including but not limited to: your name, your phone number, your email, your Tax Identification Number or Social Security Number (collectively, “TIN”), your date of birth, your government-issued identification and Organization information, such as company name, address, phone number, business email address, formation documents, business license and tax documents. We ask you to choose a strong password and may require you to provide contact information to receive multi-factor authentication. We collect information from you when you use the Services, provide us with feedback on the Services, or contact us for support. As we introduce new products or features, we may collect new and different types of information from you when you use the Services or contact us in connection with your account.

Financial information. When you use the Services to make or receive payments, we collect certain financial information from you, such as bank routing and account information, including bank statements and verification of bank account ownership, and/or a credit or debit card to bill Services Fees. We may also collect information to verify financial condition and creditworthiness.

Payment transaction information. When you request, receive, record, or process a payment through the Services, we collect information about the payment transaction and the transacting parties, including but not limited to the date, time and location of the transaction, identifying information of the sender and recipient, the payment or transfer amount, bank account information for the sender and/or recipient and other transaction metadata.

Information about your Clients and Suppliers. We may collect information from you about your Clients and Suppliers, including but not limited to name, email address, address, phone number and financial information, based on your use of the Services and payment instructions.

Feedback. We collect information that you choose to provide to us in connection with your feedback about the Services.

Device information. We collect information about your device when you install, access, or use the Services on that device. We collect information including but not limited to IP address, hardware model, operating system, app version, browser information, and mobile network. Your device may also allow us to collect information such as your contacts, camera, or photos, based on your device settings.

Geolocation information. We collect the location of the device that you are using to access the Services.

Information from third parties you interact with the Services. We collect information about you from third parties with whom you interact through the Services, including but not limited to your Clients or Suppliers. We may also collect information about you from third party services that are supported by, or sync or integrate with the Services, including but not limited to third-party data entry services or accounting software providers.

Identify verification. We collect information about you from third parties as required and permitted by law, including but not limited to for purposes of verifying your identity, “know your customer” regulations, complying with anti-money laundering and anti-terrorism financing laws and OFAC sanctions requirements.

Compliance and fraud. We collect information about you from third parties for purposes of fraud detection and prevention, in connection with certain types of investigations, or as otherwise permitted by law to ensure the safety and security of the Services.

Other. When you use the Services, visit our Website or otherwise engage with Tola, even if you do not establish or use a Tola account, we may collect information about you, such as name, email address, phone, and mailing address.

Information Use

We use your information as necessary for the performance of our Services; for complying with applicable law, our interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our customer service, marketing and support, and protecting and securing our users, ourselves, and members of the general public.

Specifically, we use your information for the following purposes:

  • To facilitate, operate, and provide our Services
  • To authenticate the identity of our users, and to allow them to access and use our Services
  • To provide our users with assistance and support
  • To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences, and difficulties
  • To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity
  • To contact our users with general or personalized service-related messages (such as “forgot my password” functionalities) or with promotional messages (such as newsletters)
  • To enforce any agreements between you and Tola
  • To comply with any applicable laws and regulations

How We Share Your Information in Connection with the Services

Clients and Suppliers. In connection with the Services, we may share some of your information with the business with which you are transacting in order to effect your transaction.

Tola Service Providers. We may engage selected third party companies and individuals to perform services complementary to our own including but not limited to hosting services, fraud detection and prevention services, data analytics services, marketing and advertising services, cyber security services, payment processing services, e-mail and SMS distribution and monitoring services, session recording, and our business, legal and financial advisors (collectively, “Service Providers”). These Service Providers may have access to your information depending on each of their specific roles and purposes in enhancing our Services, and may only use it for such purposes.

In connection with business transactions or corporate changes. The information that we collect in connection with the Services is a business asset. As a result, we may share or transfer your information if we enter bankruptcy or are party to a business transaction, such as a merger, acquisition, reorganization, or asset sale.

Legal Compliance. We may disclose or allow government and law enforcement officials access to certain information as required by law..

With Your Permission. We may share your Personal Information pursuant to your explicit consent.

How long we retain information

We will retain your information in accordance with our internal records retention and management policies and procedures, including as necessary to provide you with the Services or administer your Tola account, or as long as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and reserve our legal rights.

Cookies and third party technologies

Tola and our third-party service providers set and use cookies and similar technologies to store and manage user preferences, enable content, gather analytic and usage data, and deliver advertising.

Cookies are typically assigned to one of the following categories, depending on their function and intended purpose:

  • Essential cookies enable you to navigate our Website and to use the Services. Without these cookies, our Website will not perform as smoothly for you as we would like, and we may not be able to provide certain functions and features.
  • Analytics cookies collect information about the use of our Website and application, and enable us to improve the way our Services works.

We use third-party service providers, including but not limited to Google Analytics, to analyze the use of our Website.

Most browsers are set up to accept cookies automatically. You can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Some browsers have “Do Not Track” features that allow you to tell websites not to track you. Tola does not respond to “Do Not Track” signals.

Managing Your Preferences

We may use your information to provide you with marketing or other promotional communications via email. If, at any time, you would like to stop receiving these promotional emails, please follow the opt-out instructions contained in the email. It may take up to ten (14) business days for us to process opt-out requests.

Other Websites and Businesses

This Privacy Policy covers the privacy practices of Tola only. This Privacy Policy does not apply to the practices of third party websites, services, or applications, including third parties that we partner with. These third party services are governed by their own privacy policies.

Your California Privacy Rights

California law provides California residents the right to request from Tola:

  • A list of the categories of information that we have disclosed to third parties for direct marketing purposes
  • The names and addresses of all such third parties.

If you would like to request this information, email your request to support@tolah.com. In your request, specify that you want “Your Tola California Privacy Rights Notice”.

Please allow thirty (30) days for a response.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically. When we do, we will also revise the “last updated” date at the top of this page. If there are material changes to our Privacy Notice, we will post a notice on our website and/or provide other notice as required by law. If you object to any changes to this Privacy Notice, you can cancel your account at any time.