Privacy Policy
The privacy of customers' personal data is important to Xolo. This Policy describes the rules according to which Xolo processes the personal data of any person using Xolo's website www.xolo.io/it-en, mobile apps and any services offered by Xolo.
The use of this website implies their acceptance of this Privacy Policy.
Xolo adopts the necessary measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016. Through the registration forms on this website or by sending an email, personal data of each client are collected and processed, which are necessary for the management and maintenance of some of the services provided and whose treatment is governed by this Privacy Policy.
1. General Definitions Xolo
Service provider who needs to process customer’s personal data for the provision of service:
Xolo Italia S.r.l., a single shareholder company with registered office in 20144 - Milan (MI), at Via Tortona no. 33, VAT number and Tax ID: 12134920961, PEC (certified email): xoloitaliasrl@pec.it,
Xolo OÜ, registry code 12844111, address Paju 1a, Tartu, 50603, Estonia, who provides platform services
Affiliate of the service provider whose company information is provided in the respective service agreement
2. Policy Applicability
This Policy applies to Personal Data Processing where Xolo acts as a Controller. Any personal data Processing conducted on behalf of the Customer or his legal entity is subject to an additional data processing agreement signed between Xolo and the legal person controlled by the Customer.
3. Personal Data being collected
Xolo Processes the following Personal Data about the Customer:
Personal Details – full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal addrits, e-mail addrits, mobile phone number, bank where the personal bank account exists;
Identification Data – data retrieved from the copy of a passport, such as document number, issue date, expiry date and issuing entity, photo, URL of a Portfolio or LinkedIn profile;
Verification Data – data which Xolo collects for the purpose of conducting Customer due diligence under applicable anti-money laundering laws and the financing of terrorism -in particular, Law 10/2010 of April 18 on the prevention of money laundering and financing of terrorism
Background and Profile Data – Customer’s Google profile data, such as name, e-mail addrits, language preference and profile picture and also data Xolo collects and Procitsit for the purpose of conducting Customer adverse media checks via open sourcit;
Payment Data – data concerning payments for Xolo’s Service and state feit, such as account number (IBAN), account holder name, bank name, transaction details.
Businits related Data – in the course of providing certain Servicit Xolo collects and Procits the businits ditcription provided by the Client;
Device Data – information regarding the device on which the Customer is using the Xolo’s website/app, including the device’s model, name or any other identifier and the IP addrits;
Preference Data – Customer’s preferencit in the Xolo’s website/app;
Customer Support – Data – communication between Xolo and the Customer (inquiriit submitted via the website, email, social media or chat);
Usage Data – data about Customer’s interaction in Xolo’s website/app.
Sensitive Data – for the purposes of completing and submitting the Spanish income tax return (RENTA), Xolo may collect data relating to the Customer’s family members, such as the tax identification number, date of birth and family relationship of the spouse and/or dependent children, which may constitute sensitive data under GDPR and applicable Spanish tax law.
4. Sources of Personal Data collection
Majority of Customer’s Personal Data Processed by Xolo is collected directly from the Customer. However, Xolo may collect Customer’s Personal Data also from third party sources, such as databases of financial sanctions and people subject to international financial sanctions and databases of politically exposed people. Some of these databases are publicly available and some of them are not.
5. Purposes for collecting and Processing Customer's Personal Data
Personal Data collected by Xolo is Processed for the purposes established in the law or as described herein, including but limited for the following purposes:
Contractual Purpose – Xolo needs to Process Customer’s Personal Data in order to enter into service agreement with the Customer and to provide Service to Customer;
Compliance Purpose – Xolo needs to Process Customer’s Personal Data in order to perform obligations under applicable laws, such as to comply with anti-money laundering requirements, and combat fraud, ensure the fulfilment of international financial sanctions, comply with the lawful inquiries and orders of public authorities with whom Xolo is obligated to cooperate;
Analytical Purpose – Xolo needs to Process Customer’s Personal Data in order to manage, analyse and improve the Service, website and app;
Marketing Purpose – Xolo needs to Process Customer’s Personal Data in order to send relevant promotional information to the Customer about Xolo services and the related offerings by third parties we work with, if the Customer has granted an explicit consent to use his/her Personal Data for this purpose;
Customer Engagement Purpose – Xolo may process Personal and Sensitive Data in order to send personalised congratulatory messages, small gifts and other gestures celebrating Customer’s personal milestones for the purpose of enhancing customer relationship, if the Customer has granted an explicit consent to use his/her Personal Data for this purpose;
Personalization Purpose – Xolo needs to Process Customer’s Personal Data in order to personalize the Service and the content provided to the Customer;
Communication Purpose – to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;
Business Continuity Purpose – Xolo needs to process personal details during any means of financing process to ensure business continuity;
6. Automated decision making
Xolo is providing certain Services for the Customers active in the certain field of activities. Not all fields of activities are supported by Xolo’s services. Xolo is using automated decision making in the pre-contractual Processing in order to establish sufficiently whether the Customer is eligible to use Xolo’s services.
Automated decision making refers to a decision which is taken solely on the basis of automated Processing of Customer’s Personal Data. This means Processing using, for example, software code or an algorithm, which does not require human intervention. During onboarding process, the Customer is being asked for the field of activity of the service provided in course of using Xolo’s services. The automated decision making is necessary for entering into agreement with Xolo. The automated decision making is used in order to accept or reject the Customer’s application to enter into a service agreement with Xolo. In case the field of activity which the Customer wishes to act is not supported by Xolo’s services, then the Customer’s application will be rejected. Upon rejection, Xolo will inform the Customer by e-mail about the reasoning for rejection. The Customer is entitled to request human intervention or object to the decision by contacting Xolo.
7. Technological aspects of our Service provision and development
To improve on how the Controller provides the Services, Xolo may use automatic algorithms, machine learning, large language models (LLMs) and similar solutions. These tools help us recognize patterns in data, make informed predictions, and generate contextually accurate outputs.
Machine learning involves the use of algorithms and statistical models that allow computer systems to learn from data and improve over time without being explicitly programmed. It helps us automate decisions, reduce human error, and enhance the precision of our Services.
Large language models (LLMs) are a specific type of machine learning system designed to understand and generate human language. They are trained on large amounts of text data to identify linguistic patterns and relationships, allowing them to produce coherent and relevant responses based on user input. Both machine learning models and LLMs are continuously monitored and adjusted both automatically and by real people to ensure they remain accurate, fair, and effective.
All models are trained and tested on real or anonymized datasets and their performance depends heavily on the quality of this input data. These processes are conducted solely for internal development purposes and always under a valid legal basis and contractual agreement with our Customers. Xolo is committed to using machine learning and LLM technologies in an ethical, secure, and transparent manner. We ensure that the outcomes support fair and responsible service delivery.
Xolo may use machine learning and LLM technologies to understand and classify Customer communication and suggest appropriate responses for the appropriate Xolo employee, train to recognise patterns in Customer’s platform usage to develop and enhance Service provided to Customers, to automate data extraction, and to screen transaction, invoice-related data and other documentation to ensure accuracy and limit human errors.
8. Legal grounds for Processing
Xolo is relying on the following legal grounds when Processing Customer’s Personal Data:
Processing is necessary for the performance or entry into a contract between Customer and Xolo (GDPR article 6 (1) (b)), Xolo is Processing Personal Data for Contractual Purpose under contract entered into between Xolo and Customer;
Processing is necessary for compliance with a legal obligation to which Xolo is subject (GDPR article 6 (1) (c)). Xolo is Processing Personal Data for Compliance Purpose under legal obligations to which Xolo is subject to;
Processing is necessary for the purposes of the legitimate interests pursued by Xolo (GDPR article 6 (1) (f)). Xolo is Processing Personal Data for Analytical, Personalization or Business Continuity Purpose under legitimate interest;
Customer has granted consent to the Processing of his Personal Data (GDPR article 6 (1) (a)). Xolo is Processing Personal Data for Marketing Purpose under Customer’s consent.
9. Transfer of the Personal Data
Xolo may transfer Customer’s Personal Data to third parties, such as:
legal and regulatory authorities (e.g. commercial register) whom Xolo is obligated to disclose Customer’s Personal Data under the law;
server hosts who host Xolo’s servers;
identification service providers who help Xolo verify Customer’s identity and acquire Verification Data;
communication service providers who facilitate e-mails, calls, SMS messages and other communication between Xolo and the Customer;
customer support and customer management service providers;
marketing service provider;
Xolo’s partner bank who provides banking services to the Customer or to the legal entity controlled by the Customer or any other financial service provider;
Xolo’s affiliate. i.e. any company that directly or indirectly controls Xolo; any company that is directly or indirectly controlled by Xolo; or any company that is controlled, directly or indirectly, by the ultimate parent company of Xolo. Control shall mean owning more than fifty percent of the voting rights in a company or otherwise having the power to govern the financial and the operating policies or to appoint the management of a company;
Other parties involved with the provision of Xolo’s Service (accountants, auditors, lawyers, IT systems suppliers and support, or any other outsourcing providers).
Xolo has taken steps to ensure that these data recipients protect the confidentiality and security of Personal Data, and to ensure that Personal Data is Processed only for the provision of Service and in compliance with applicable law.
10. Security
Xolo will take appropriate legal, organisational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized Processing, disclosure or destruction. Upon transferring Personal Data to third parties, Xolo will apply the following safeguards:
Xolo enters into a data processing agreement with the relevant third party;
Xolo makes sure that such third party undertakes to implement appropriate technical and organizational measures ensuring the Processing of Customer’s Personal Data in accordance with this Policy and applicable law;
Xolo makes sure that (a) the third party is established in a jurisdiction which the European Commission has recognized as ensuring an adequate level of personal data protection, or (b) the Processing of Customer’s Personal Data is subject to other appropriate safeguards stipulated in the GDPR.
11. Integrity and retention of the Personal Data
Xolo will retain Personal Data for the period required or permitted by applicable law, but no longer than is reasonably necessary in order to achieve the purposes for which the Personal Data was collected. Xolo’s general data retention period is 10 years after ending the business relationship with you. This is a statutory data retention period which we have to follow to be compliant with our legal obligations. In some cases we may need to hold your personal data for longer to meet our legal obligations (for example accounting-related data needs to be stored for a statutory time period, typically 7 years) or if we have a legitimate interest (if longer data retention is for example required by our cooperation partners) to do so and in some cases we will hold your data for less time. Data retention details are available in Annex 1 of this Policy.
Xolo takes reasonable steps to ensure that the Personal Data we Process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.
12. Customer’s rights in regarding to the collection of Personal Data
Customer has the following rights in relation to the Processing of his Personal Data:
When the Customer provides Personal Data of their partner, spouse, children, or other relatives, they do so to ensure the accuracy of their tax filings. Xolo processes this third-party personal data solely for the provision of the relevant tax service. We respect the privacy of each Customer’s family members – they are entitled to the same data protection rights outlined above and may contact us at any time to exercise the rights as described in Section 13.
Request information - Xolo has provided all information which the Customer has the right to receive in this Policy. The valid version of the Policy is available on Xolo’s website at any time.
Right to access - Customer has the right to ask Xolo to provide a copy of Customer’s Personal Data which Xolo Process.
Right to Rectification - Customer has the right to ask Xolo to rectify Personal Data in case the data is incorrect or incomplete.
Right to Erasure - Customer has the right to ask Xolo to erase Personal Data, unless Xolo is obliged to continue Processing Customer’s Personal Data under law or under a contract between the Customer and Xolo, or in case Xolo has other lawful grounds for the continued Processing of Personal Data.
Right to Restriction - Customer has the right to ask Xolo to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or in case his Personal Data is Processed unlawfully.
Right to Data Portability - Customer has the right to ask Xolo to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to Xolo and which is Processed in accordance with Customer’s consent or a contract between the Customer and Xolo.
Right to Object - Customer has the right to object to Processing his Personal Data in case there is a reason to believe that Xolo has no lawful grounds for Processing the Personal Data.
Right to withdraw Consent for the Processing of Personal Data - Customer is entitled to withdraw the consent granted for the Processing of Personal Data et any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.
Right to File Complaints - Customer has the right to file complaints regarding Processing of his Personal Data.
In order to exercise any rights referred herein the Customer is required to submit a written application to Xolo (Xolo’s contact details can be found under Section 16). Xolo has the right to decline this application by justifying the reasons for the refusal. According to the article 12(3) of GDPR, Xolo is obligated to respond to the application within 1 month. However, Xolo will make its best efforts to respond to Customer’s request within 1 week.
13. Cookies and tracking technologies
Xolo is using automatically collected information and other information collected within its website through cookies and similar technologies.
Cookies are small text files that a website or its service provider transfers to the Customer’s computer hard drive through his website browser (if Customer allows) that enables the website’s or service provider’s systems to recognize Customer’s browser and capture and remember certain information. For example, cookies may help a website remember certain preferences the Customer has selected on the website, such as language preferences.
Within the website Xolo is using the following types of cookies:
Cookies are being used to serve the following purposes:
The Customer can delete or block cookies through his browser settings at any time. However, some cookies might be necessary for the functionality of the Xolo Services and usage of the website. Therefore, the Customer understands that when blocking or deleting the cookies some features within the website might not function correctly. For more general information about cookies please see http://www.allaboutcookies.org
first-party cookies, which are stored to the Customer’s device by Xolo. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience;
third-party cookies, which are stored to the Customer’s device by other service providers on Xolo’s website. Xolo may use third-party analytics tools (such as Google Analytics), to help us measure traffic and usage trends for the Xolo’s Service. Web analytic service providers analyse the usage of the Xolo website and services so that Xolo could improve and amend our website/app and function thereof.
to store authentication information and protect Personal Data from third parties;
to personalize our Service, help remember Customer’s choices within the website, understand and save Customer’s preferences for future visits;
to provide customized advertisements, content and information;
to track Customer’s entries, submissions, and status in any promotional or other activities on the Service;
to monitor and analyse the effectiveness of the Service;
to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
14. Google Analytics and ads
Xolo have implemented the following Google Analytics features:
Xolo along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding Customer interactions with ad impressions, and other ad service functions as they relate to our website.
Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, the Customer can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on. Xolo is using Google Analytics to measure and evaluate access to and traffic on the public area of our website and create user navigation reports for our website administrators. Xolo takes measures to protect the technical information collected by the use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the website and identify visitor preferences.
Remarketing;
Google Display Network Impression Reporting;
Demographics and Interests Reporting.
15. Commercial Communication
If a Customer receives commercial emails from us, he may unsubscribe at any time by following the instructions contained within the email or by sending an email to <strong>info@xolo.io</strong> The Customer is able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the "Settings" section in the restricted area of the website. The Customer has to be aware that if he opts-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications he receives from us, it may take up to five (5) business days for us to Process the request. Additionally, even after he/she opts-out from receiving commercial messages from us, he/she will continue to receive administrative messages from us regarding the Service.
16. Right to amend this Policy
Xolo is entitled to unilaterally amend this Policy from time to time. In case of significant changes, Xolo will notify the Customer about the changes via e-mail. In case the new terms refer to Processing of Customer’s Personal Data for any new purpose, which requires Customer’s consent, then Xolo will not Process Personal Data for such new purpose, before it has received respective consent.
17. Contact Information
Should the Customers have any questions regarding this Policy or they want to exercise their rights, they are welcome to contact Xolo with requests, inquiries or any complaints via email: <strong>info@xolo.io</strong> clearly indicating (i) your identity, indicating, at least, your full name and the email address you used when registering on the website, and (ii) the right or rights you exercise.
You can also go to the Italian Data Protection Authority (https://www.garanteprivacy.it/web/garante-privacy-en) to request the protection of your rights, if you consider it appropriate.
The exercise of these rights is free, unless manifestly unfounded or excessive requests are made, in which case the interested party may be required to assume the cost of the processing.
18. Confirmation
By accepting this Policy, the Customer confirms that he has familiarized himself with this Policy, understood it and agrees to its terms.
19. Applicable law and jurisdiction
This Policy will be governed by and construed in accordance with Italian law. Without prejudice to any rights the Customer may have to refer a complaint to the authorities, the courts of Italy have exclusive jurisdiction to settle any dispute arising in connection with this Policy and for such purposes Xolo and the Customer will irrevocably submit to the jurisdiction of the Italian courts.
Last updated: March 19, 2026