This privacy policy describes how LTD New Value (hereinafter "company" or "We", registered with the Armenian Ministry of Economics and located on Kotayk Marz Street, Hrazdan, Armenia) treats the personal data of its users (hereinafter, "You") in relation to the use of your website easynaya.com / (hereinafter, the "Website") and of the Services offered by company. In this sense, the company acts both as responsible for your personal data, taking care of their treatment. The purpose of this privacy policy is to explain how the company collects, uses and shares your personal data and what are the rights you have regarding your data.
The terms in capital letters used and not expressly defined in this privacy policy will have the meaning attributed in the General Conditions of the Services offered by company and failing that designated in the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of these data and repealing Directive 95/46 / EC).
Collection of personal data. We collect your personal data:
when you provide them to us directly through the forms on our Website (e.g. when creating an Account, completing a loan application or in any other way);
when provided by an advertiser on whose website you have provided your personal data (e.g. by filling out a loan application);
when they are provided to us by third parties (e.g. from your Instantor account statement if you have accepted it, data from the creditworthiness evaluation performed by a lender, data on whether the loan was granted by a lender or credit records of ASNEF);
obtaining them from various public sources (e.g. public profiles of social networks such as Facebook or LinkedIn);
automatically through the use of computer tools (e.g. information related to their behavior on our Website obtained through the Hotjar tool).
Processing of personal data: purpose and legal basis. We treat your personal data in accordance with the following legal bases and for the following purposes:
Treatment subject to the execution of the contract signed between you and the company. Given that the basis of our Service consists in selecting the Lender (s) who, based on the information obtained in relation to the loans they offer, the aforementioned sources and the credit profile that we have created in accordance with the aforementioned sources (see also the section “Profiling and automated decision making” that can be found below) would grant you a loan, we treat your personal data with the main purpose of fulfilling the Agreement signed with you. This includes finding a suitable Lender, as requested, that suits your needs, as well as pre-completing the loan application in case it is repeated, and improving your credit profile and scoring if you already had One account. This also includes providing support to the customer and contacting them as stated on the Website. It also includes the adoption of necessary measures prior to the conclusion of the Agreement (e.g. verification, based on your DNI and address, that you are authorized to use our Services under our General Conditions). To avoid any doubt, we keep the personal data processed when using our Services. Taking into account the above and in accordance with the Services we provide, we treat the following personal data:
- Identification data (e.g. name, D.N.I., sex, marital status);
- Contact information (e.g. email address, phone number, address);
- Labor data (e.g. information on the current employer, type of employment relationship, date of salary payment, amount of salary);
- Educational data (e.g. training level);
- Financial data (e.g. income, expenses, bank account, if you own a car);
- Communications data (e.g. emails, messages sent to us);
- Account login data (e.g. password to access the customer area of our Website);
- Data related to the use of the Website and the Services (e.g. interaction with our Website, the IP address of your Internet connection);
- Other data related to the loan (e.g. the purpose of the loan).
Treatment based on legitimate interest. We process the data generated in the use of our Website and the Services (e.g. information on how you navigate and use our Website)
To improve the user experience in the use of the Website and Services, with the aim of making it more intuitive. The legal basis of the above lies in our legitimate business interest to improve the Website and the user experience. Taking into account the nature of the data and that we use it in aggregate, as well as your fundamental interests or rights and freedoms, they do not nullify our legitimate interests.
Likewise, we treat the data received from your use of our Website and our Services (eg information on how you navigate and use our Website) with the aim of preventing fraud and misuse of our Services (eg avoiding the use of Website and Services by robots). The legal basis of the above lies in our legitimate business interest to improve the Website and the user experience. Taking into account the nature of the data and that we use it in aggregate, as well as your fundamental interests or rights and freedoms, they do not nullify our legitimate interests.
We may need to process your data to make inquiries in the solvency files in order to assess your financial solvency in accordance with applicable regulations. Without carrying out this treatment, we cannot offer you our Services. Your interests or fundamental rights and freedoms do not nullify our legitimate interests. We may also process your personal data to safeguard our rights (e.g. establish, exercise and defend legal claims, debt collection). The legal basis of the above lies in our legitimate business interest to improve the Website and the user experience. Taking into account the nature of the data and that we use it in aggregate, as well as your fundamental interests or rights and freedoms, they do not nullify our legitimate interests.
To the extent required by the applicable data protection regulations, you have the right to object to the processing of your personal data on the basis of a legitimate interest (see also the section "Your rights" below) .
Data processing based on consent. compan may process your personal data on the basis of your consent when advertising offers are sent, including at the end of the contractual relationship, by any means, through electronic communications or related products and services, whether offered by us or by the following Lenders. In addition, provided you authorize it, we may communicate your personal data to third parties, so that they may send you commercial communications about your products or services.
When the processing of personal data is based on your consent, it may be withdrawn at any time by clicking on the “unsubscribe from the list” / “unsubscribe” link at the end of each of the e- mails Please note that the withdrawal of consent does not affect the legality of the data processing performed prior to said withdrawal.
Data processing based on our legal obligation. We may also process your personal data to comply with our legal obligations (e.g. in our obligation to share your personal data with the relevant authorities and to comply with our obligations regarding Money Laundering Prevention and Terrorism Financing). This type of processing is based on compliance with our legal information obligations.
We do not process any special type of personal data, nor do we process personal data related to criminal records or data related to minors.
Profiling and automated decision making. We use profiling and automated decision making as follows:
Profiling and automated decision making as part of our Service: taking into account your preferences to contract a loan with us and the personal information that You have provided us with the creation of your Account or by completing the loan application form, the information obtained from the sources listed above, and your history of use of our Services (eg if you have been granted a loan and who has granted it), we prepare or complete your credit profile and “scoring” later assigning the results obtained to your Bill. We compare your profile with the conditions established by each of the Lenders for your clients, and taking into account the results of this comparison we offer the Lender or the relationship of Lenders with those who are most likely to have the loan granted, in the conditions you have pre-selected. Our The results are based on the information we have received from the Lenders in relation to the conditions they offer to their clients, as well as our best estimate of the previous behaviors maintained by the Lenders. As a result of our comparison, the list of potential Lenders can be very numerous or on the contrary contain one or no potential Lenders, this depends on how many Lenders, according to our best estimate, would be willing to grant loans to people with profiles similar to yours. To understand the preferences of each of the Lenders, please consult the privacy policies of the Lenders.
The credit profile and scoring assigned to your Account will be complemented by us taking into account your subsequent credit behavior based on the information about You to which we have had access. A higher credit profile and scoring will allow you to obtain better conditions when formalizing a loan contract. Please note that at any time you can delete your credit profile and scoring by deleting your Account.
Since the automated profiling described in this Privacy Policy is the basis of the content of the Service we provide to our clients (including You), such profile is necessary to be able to execute the existing Agreement between us (see also our Terms of Service) .
As a result of such automated profiling, we may conclude that there are no Lenders willing to initiate pre-contractual negotiations with You, based on your pre-contractual preferences. Keep in mind that, in these cases, you can change the terms of the loan sought (e.g. lower the principal), which could allow us to find you a potential Lender. Therefore, the results of our profiles cannot be considered to significantly affect you or your interests, including the deprivation of your chances of obtaining a loan. You have the right to obtain human intervention, to express your point of view and to challenge the decision.
Development of profiles for commercial purposes. We also prepare profiles of our users to be able to provide them with those offers, both ours and our partners, which we believe might be interesting. To do this, we prepare your profile by taking information related to your use of our Website and your personal data (mainly your age and sex). Please note that we request your explicit consent to carry out this mode of profiling and marketing and that at all times you have the right to withdraw, through your Account or by contacting us, the consent given for the treatment of your personal data for these purposes.
Exchange of your personal data. We only share your personal data when we have a valid reason for it and when said exchange is legally protected.
Responsible for the treatment. We have carefully selected those in charge of the processing of your personal data. We only contract with service providers that provide sufficient guarantees to implement the appropriate technical and organizational security measures to protect your personal data. We have signed appropriate data treatment agreements with our service providers and we will be responsible for your actions regarding the processing of your personal data.
We catalog those in charge of the treatment in the following categories: commercial service providers via email, email and SMS sending platforms, website analysis service providers, data hosting service providers; social media marketing platforms.
In case you need detailed information regarding the service providers related to the processing of your personal data, please contact us at the contact information provided at the end of this Privacy Policy.
Third parties. In some circumstances, we also share your personal data with third parties who act as independent persons responsible for the processing of data with regard to your personal data. We only share your personal data with third parties if stipulated or required by applicable law at any time (e.g. when we are required to share personal data with the authorities) or with your consent.
The provision of our Services includes sharing your personal data with Lenders to decide whether or not to grant you a loan and to sign the loan agreement. The list of Lenders with whom we share your personal data may change. Can access er to the current list through the following link. The purpose and legal basis of such personal data exchange is to be able to carry out the existing Agreement between us and the correct provision of our Services. The Lender will use your personal data for the sole purpose of deciding whether or not to grant you a loan. However, keep in mind that once we have transferred your personal data to the Lender so that you can evaluate the possibility of granting a loan or not, the Lender will be solely responsible for the processing of your personal data. So you should familiarize yourself with their corresponding privacy policies. In the event that the Lender decides not to grant you a loan, you must delete or anonymize your personal data, unless there is a valid legal basis to retain them.
We may also need to share your personal information with third parties to protect our legal rights (e.g. lawyers and debt collection agencies). The legal basis of this exchange lies in our legitimate interest in protecting our legal rights, as well as ensuring compliance with the existing Agreement between us. In that case, your interests or fundamental rights and freedoms do not nullify our legitimate interests.
In addition, we may also share your personal data with other third parties in order to comply with our legal obligations (e.g. auditors, authorities). The legal basis of this exchange lies in the need to comply with our legal obligations.
Transfer of personal data to countries outside the European Union. We and our processors (including storage) can transfer your personal data to countries outside the European Union (e.g. United States). In any case, we will only transfer and store your personal data to third countries outside the European Union when there is a legal precept that allows us to, and always taking into account that: (i) the recipient of your personal data must be located in a country that has established an adequate level of protection for its personal data (including the United States if the recipient is part of the “Privacy Shield Program”), or (ii) through means and instruments that guarantee compliance with the European requirements regarding the transfer and exchange of personal data with third countries not members of the European Union.
In the case where you need more detail and information related to the transfer and exchange of your personal data with third countries outside the European Union (eg the data of the recipients and / or the legal basis to carry out such transfer) by Please contact us at the contact information provided at the end of this Privacy Policy.
Security. We have adopted a series of technical and organizational measures to ensure that your personal data is adequately protected, taking into account (i) the state of the technology, (ii) the costs of implementation, (iii) nature, scope and purpose of the treatment, and (iv) possible risks.
Data conservation We retain your personal data for the time necessary to be able to fulfill the purpose for which they were delivered, as well as for the time necessary to protect your rights as required by the applicable regulations. We may keep your personal data for certain years after the end of our relationship in case it is necessary in order to protect your rights in accordance with the provisions of the applicable regulations. In the event that there are different purposes that give rise to the processing of your personal data, they will be kept in accordance with the longer term.
In accordance with the maximum period of limitation for claims arising from these operations, under applicable law, when the obligor intentionally fails to comply with his obligations, we may keep his personal data related to said claims for a maximum of 10 years from the Claim expiration date.
Your rights. As established by the applicable regulations, you have all the statutory rights established regarding your personal data. These rights include, among others, the following:
Request access to your personal data;
Get a copy of your personal data;
Rectify or complete incorrect or inaccurate data;
Delete personal data;
Restrict the processing of your personal data;
Migration of your personal data;
Oppose the processing of personal data, which is based on our legitimate interest and the processing of personal data for direct marketing purposes.
Keep in mind that the rights related to your personal data are not absolute and they will be subject to the considerations allowed by applicable law.
To exercise your rights, please contact us at the contact information provided at the end of this Privacy Policy. Please note that you can exercise some of your rights (e.g. review and update your personal data) immediately by logging into your Account.
If you believe that the rights in relation to your personal data have been infringed, we ask that you please contact us at the contact information provided at the end of this Privacy Policy. Likewise, you also have the right to file a complaint with the Spanish data protection authority (Spanish Agency for Data Protection C / Jorge Juan, 6, 28001, Madrid), the Estonian data protection authority (“Estonian Data Protection Inspectorate” ), Armenian data protection autohrity or go to court.
Modifications. In the event that our personal data processing practices change or it is necessary to modify this Privacy Policy in accordance with the provisions of applicable law, jurisprudence or guidelines issued by the competent authorities, we have the right to unilaterally modify this Policy Privacy at any time. In case the changes are important and impact you in any way, we will notify you by email and you will skip a pop-up (pop-up window) on our Website before these changes take effect.
Contact. In case you have any questions regarding the processing of your personal data by us or if you wish to exercise any of your rights, you can contact us through the following contact information: info@easynaya.com
Privacy Policy valid as of May 25, 2018
