Commissioner for Personal Data Protection
The Company has appointed a Commissioner for Personal Data Protection who you can contact regarding all issues related to the processing of your personal data and the exercise of personal data protection rights.
Tel: +385 21 796 413
Purpose of collecting personal data and legal basis of processing
The purpose and methods of personal data processing may be determined by the Company or by one of the Company’s partners with whom the Company has a contract related to the processing of personal data or they may do so jointly.
When the Company determines the purpose and means of personal data processing, it is the head of personal data processing.
When the Company, as the head of personal data processing together with one or more partners as the head (s) of data processing, determines the purpose and means of personal data processing, they are joint heads of personal data processing.
When the Company processes data on behalf of the controller, then the Company is the executor of personal data processing and processes data in accordance with the requirements of the controller. In that case, the processing manager determines which personal data and to what extent the Company, as the executor of processing, should collect from the respondents. You will be notified at the time of collecting personal information.
The main purpose of collecting personal data is to present and offer and carry out other preparatory actions related to the loan agreement or take action at your request before concluding a contract or legal obligation of the Company (especially obligations related to prevention of money laundering and terrorist financing). The scope of personal data we collect depends on the type of loan agreement you intend to enter into or enter into, or your request or the Company’s statutory obligations. Providing your personal data is necessary to establish a business relationship and enter into and fulfill a loan agreement, and if you do not provide the information necessary for a particular type of loan agreement we will not be able to mediate in this regard. Providing information about your union membership is not a condition for concluding a contract, but is the basis for certain benefits that you can get when concluding a loan agreement, and we collect information about your union membership solely on the basis of consent you can express by your statement or action. which is the provision of evidence of union membership).
Acting on your request before concluding a contract involves checking your requirements and needs, all with the aim of providing a service.
In the event that we need certain personal data that we need to provide the requested service, we will inform you about it in a timely and appropriate manner.
When browsing the Company’s website, the Company does not collect your personal information such as name, address, telephone number, e-mail address and the like. When you visit the Company’s website, your personal information remains confidential, unless you wish to disclose it voluntarily.
In certain places within the Company’s website (“contact”, “inquiry”, “questionnaire” or similar) we collect your personal information (name, surname, address, telephone number, e-mail address,…) that you give us by filling out the subject questionnaire on the website. This information will be used for the purpose of contacts, answering your inquiries, providing information on your request and records of users of the website, and are necessary for us to answer your inquiry and provide the service. In that case, when you enter your personal data in the designated place on the Company’s website, you confirm and give your consent that your personal data is voluntarily made available to the Company and that you allow it to be used for the purpose as stated. .
The Company will also process your personal data in order to fulfill the Company’s legal obligations, such as (but not limited to) obligations prescribed by the Anti-Money Laundering and Terrorist Financing Act and international tax regulations (FATCA, CRS, etc.) or those prescribed by the Consumer Credit Act. and the Housing Consumer Credit Act and regulations enacted under those laws. If you do not wish to provide us with this information, we will not be able to provide you with the service.
The legal basis for the aforementioned data processing is Article 6 (1) (b) and (c) of the General Regulation on Personal Data Protection. conclusion of the contract, processing is necessary to comply with the legal obligations of the processing manager).
Society has legitimate interes carry out the processing of personal data necessary for the purpose of preventing fraud, and the legal basis for this is Article 6 (1) (f) of the General Data Protection Regulation (processing is necessary for the legitimate interests of the controller or a third party, except when these interests are stronger than the interests or fundamental rights and freedoms of the respondent which require the protection of personal data, especially if the respondent is a child).
If none of the above purposes and grounds exist for the processing of your personal data, we will only process your personal data if you have given your voluntary consent. The legal basis for this is Article 6 (1) (a) of the General Regulation on Personal Data Protection (the respondent has consented to the processing of his personal data for one or more specific purposes).
Recipients or categories of recipients of personal data
We will provide your personal data, which we process as a personal data processing executor, to the personal data processing manager (credit institution), in accordance with the purpose of personal data processing determined by the personal data processing manager and the rules of the personal data processing manager. This includes personal data that we collect in order to fulfill legal obligations prescribed by the Law on the Prevention of Money Laundering and Terrorist Financing and international tax regulations (FATCA, CRS, etc.).
Your personal data may be disclosed to other recipients in order to fulfill our legal obligations, ie at the request of a state body (such as the Personal Data Protection Agency, the Office for the Prevention of Money Laundering and Terrorist Financing, the Financial Inspectorate, the Ministry of Finance, the Tax Administration and Fig.). Also, your personal information may be disclosed to courts, notaries, lawyers, auditors, court experts and other persons, if this is necessary to make, exercise or defend legal claims, whether in court or administrative proceedings or any out-of-court proceedings. .
With your consent, we process your personal data for marketing purposes in terms of informing about the offers, products and services of the Company and its partners. The data we process for this purpose are: name and surname, full address (street, house number, staircase, apartment, postal code, city, state), telephone number, e-mail address and mobile phone number (if applicable), date birth. Consent also refers to the fact that your personal data is processed by one or more partners of the Company and that the partner of the Company addresses you directly.
If you have given your consent to the processing of your personal data for the purpose of advertising and market research, you may revoke your consent at any time by notifying the Company in writing: by e-mail or by post to the Company’s address. Partial revocation of consent is not possible. Revocation of consent does not affect the lawfulness of the processing of personal data which, on the basis of consent, has been carried out until the moment of revocation of consent.
If you have not given your consent or revoked it, we will not use your personal information for marketing purposes.
The legal basis for this is Article 6 (1) (a) of the General Regulation on Personal Data Protection (the respondent has consented to the processing of his personal data for one or more specific purposes).
Information on the intention to transfer personal data to the recipient in a third country or international organization and whether there is a decision on appropriateness
The Company does not intend to transfer your personal information to a recipient in a third country or international organization, unless there is a legal obligation to do so.
Period of storage of personal data and criteria for determining that period
We will store your personal data for as long as necessary to fulfill the purpose for which we process them, and the criterion for determining that time is the purpose of their collection, statute of limitations required by law or a specific provision of another law that requires us to keep your personal time. data.
Your rights in relation to personal data
In order to ensure fair and transparent processing of your personal data, we refer you to your rights:
- right of access – you have the right to contact us at any time and obtain information on whether and to what extent your personal data is processed and, if such data is processed, to request access to personal data and information to which you are entitled in relation to personal data protection. The Company provides you with a copy of the personal data being processed, and for any additional copies you request, we may charge you a reasonable fee based on administrative costs, if you apply electronically, unless you request otherwise, we provide information in the usual electronic form;
- right to rectification – if we process your personal data that is inaccurate, you can at any time ask us to correct it, and if it is incomplete, you have the right to supplement it;
- right of deletion – you have the right to ask us to delete personal data relating to you if we process it illegally or if personal data are no longer necessary for the purpose of processing, etc. Please note that there are reasons that prevent immediate deletion, for example to set, implement or defend legal claims, and we will inform you in detail in relation to each individual claim;
- the right to limit the processing – you can ask us to limit the processing of your data: if you dispute the accuracy of personal data during the period that allows us to verify the accuracy of this data; if the processing is illegal but you oppose the deletion and instead seek to restrict the use of that data; if we no longer need the data for processing purposes, but are looking for them in order to set, implement and defend legal claims; if you have objected to the processing;
- right to data portability – you have the right to receive your personal data provided to us in a structured, commonly used and machine-readable format and you have the right to transfer this data to another controller, if the processing is based on consent or contract and is carried out automatically;
- right to object – you can object to the processing of your personal data at any time, if the processing is based on our legitimate interests, including the creation of a profile or if we process your data for direct marketing purposes;
- right to compensation – if you have suffered (non) property damage due to violation of relevant legal provisions, you are entitled to compensation for damage suffered by the Company or the processing manager if the Company is the executor of processing.We will respond to your request within a reasonable time, and no later than one month from the date of receipt of the request, unless a longer period of time is requested for the same, in which case the same period may not exceed 2 months.
This document on the processing of personal data is regularly updated, and its latest version is always available on the Company’s website