1. Who we are

Netlo is a trading name of Peak Goods Ltd (PEAK GOODS LTD), a company registered in England and Wales (company number 15851595). Registered office: 60 Tottenham Court Road, Suite 4890a, Fitzrovia, London, W1T 2EW.

Open Banking services are provided by Finexer Ltd, which is authorised and regulated by the Financial Conduct Authority (FRN 925695) under the Payment Services Regulations 2017. Peak Goods Ltd acts as an agent of Finexer Ltd.

Peak Goods Ltd is the data controller for the personal data described in this policy. We are registered with the Information Commissioner's Office (ICO), registration number ZC273044.

If you have any questions about this policy or your personal data, email support@netlo.app or write to us at the registered office above.

2. About this policy

Netlo is a personal budgeting app that is still in development and is not yet available. This policy covers the personal data we handle today: when you visit our website at netlo.app and when you contact us.

Before the Netlo app launches, we will publish an updated policy explaining how the app uses personal data, including bank transaction information accessed through open banking with your consent.

Your use of this website is also covered by our Terms & Conditions.

3. Information we collect

When you visit our website. Like most websites, our hosting provider automatically records technical information when pages are requested, such as your IP address, browser type, the pages you visit and the date and time of your visit. We do not use this to identify you.

When you email us. We receive your email address, your name if you include it, and anything you choose to tell us in your message.

We do not ask for any financial information through this website, and the website has no accounts, forms or sign-ups.

4. How we use it and why

UK data protection law requires us to have a legal basis for each way we use personal data. We rely on the following:

What we doInformation usedLegal basis
Keep routine website security and diagnostic logsWebsite technical informationLegitimate interests (UK GDPR Article 6(1)(f)): maintaining the security of our website, preventing misuse and resolving technical issues
Respond to general enquiries you send us by emailYour email and its contentsLegitimate interests (UK GDPR Article 6(1)(f)): responding to people who contact us
Correspond with you where needed to provide a service under a contract with youYour email and its contentsContract (UK GDPR Article 6(1)(b))

We have assessed these legitimate interests and are satisfied they are not overridden by your rights and interests. You can object to this use at any time (see section 10).

Marketing. We do not send marketing emails. Replying to your enquiry is not marketing. If we ever send marketing in future, we will only do so with your consent where the law requires it, and you will be able to opt out at any time.

We do not sell your personal data, and we do not use it for advertising.

5. Who we share it with

We use the following service providers, who handle personal data on our behalf and only as we instruct:

ProviderWhat they doInformation involved
NetlifyHosts the netlo.app websiteWebsite technical information
HostingerProvides email for netlo.appEmails you send us and our replies

We may also disclose personal data where the law requires it, for example to a regulator or law enforcement body, or to protect our legal rights. If Peak Goods Ltd or Netlo is ever sold or restructured, personal data may transfer to the new owner, who would have to keep protecting it in line with this policy.

6. International transfers

Our service providers may process personal data outside the UK. Where they do, we make sure it is protected as UK data protection law requires, for example by relying on UK adequacy regulations or approved contractual safeguards.

7. How long we keep it

  • Website technical information is kept by our hosting provider for a limited period under its own retention policy.
  • Emails are kept for as long as we need them to deal with your enquiry and any follow-up, and then deleted.

8. Cookies and analytics

Our website does not use cookies, analytics or tracking tools. If we add any in future, we will update this policy and, where the law requires, ask for your consent first.

9. Keeping it secure

Our website is served over an encrypted (HTTPS) connection, and access to our email account is restricted to the people who need it. No system is completely secure, but we take reasonable steps to protect the personal data we hold.

10. Your rights

Under UK data protection law you have the right to:

  • access the personal data we hold about you
  • correct data that is inaccurate or incomplete
  • delete your data in certain circumstances
  • restrict how we use your data in certain circumstances
  • object to our use of your data where we rely on legitimate interests
  • data portability, in certain circumstances

To exercise any of these rights, email support@netlo.app. We may need to confirm your identity. We will respond within one month, which may be extended in some circumstances as the law allows. There is usually no charge.

11. Complaints

If you are unhappy with how we have handled your personal data, please contact us first at support@netlo.app so we can try to put it right.

You also have the right to complain to the Information Commissioner's Office, the UK data protection regulator: ico.org.uk/make-a-complaint, telephone 0303 123 1113.

12. Changes to this policy

We will update this policy as Netlo develops, and before the app launches. The "Last updated" date at the top shows when it last changed.