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1. „Klear Lending“ AD will process personal data to the extent necessary to achieve the purposes below as the case might be:
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a. Fulfilment of legal obligations:
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general and special regulation for our business including for
- preparation, conclusion and execution of consumer credit agreement, payments, debt sale agreements, including storage of related information;
- identity confirmation trough: collection, usage, storage of personal data, including documents, information records which confirm identity necessary for actions like request for credit, assignment agreement or other products and services;
- creditworthiness assessment, credit risk analysis based on enough information sourced by the Central Credit Register with the Bulgarian National Bank and/or other data bases used in Republic of Bulgaria for consumer creditworthiness assessment, lists (registers) per Anti Money Laundering Act and Counter Terrorism Financing Act;
- access, usage, upload and amendment of data and information by „Klear Lending“ AD to national data bases for credit obligations per the rules for the lending activity.
- security measures, fraud prevention and investigation actions per the Bulgarian criminal law;
- surveillance, detection, authentication/correct execution and reporting of transactions, including ones deviating from standard models;
- processing and security of your personal data per the requirements of the applicable law;
- execution of sanctions/embargos, anti - money laundering measures/counter terrorism financing, tax fraud, evasion, control, notification requirements and accounting obligations;
- assignment of receivables per Contracts and Obligations Act including data processing by each new creditor;
- reply of your request/complaint or request by a competent state/public authority, court;
- debt collection of granted credits, including litigation, court decision enforcements;
- personal data processing per the applicable legislation requirements;
- execution of regulatory procedures/supervisory requirements, reporting and archiving;
The execution of a legal obligation which is not stated in the current Information will not constitute omission of „Klear Lending“ AD’s obligations under the statements herein.
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b. Credit Application study and granting, assignment of rights to receive proceeds from a credit or other services:
- presentation of our products/services per your preferences;
- assessment (including trough automated decision) to offer a product/service and the applicable conditions;
- to acquire additional personal data to be used as confirmation, including trough social media.
- ID documents validity checks;
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to contact You or third persons for which You have given us data:
- identity confirmation
- answer Your inquiries or offer assistance by presenting necessary information including for agreements we are party of, or their status;
- confirmation, check, analysis, usage, storage of information/documents containing information for Your incomes/payments, employment source by NOI, NRA, lists (registers) Anti Money Laundering Act/Counter Terrorism Financing Act, system for citizen registration, Your employer, the Registry Agency, the Business Register, etc.
- storage of all acquired information and documents: for your credit application for 1 year term per the agreement with NOI and Personal Data Protection Commission statement reg. № II-6838/2012 and not less than ten years following the termination/expiration for agreements/other product services, on electronic, paper or other carriers
- Upon its own discretion at any time during the duration of the credit to check the information for updates, accuracy, consistency including through independent sources and registers as but not limited to NOI, tax authorities, systems for citizenship information, Business Register, etc.
- Credit management and other services
- Records updates of information on electronic, paper or other carrier;
- assignment of receivables to third parties;
- services related to correspondence;
- checks in registers – private and state personal data administrators in the country or the EU in relation with fraud prevention.,AML/CFT, credits or debt collection
- Creation of individual statistical models for credit risk management based on transaction analysis;
- execution of rights and obligations of contracts we are party of;
- to execute network, informational, physical security, prevention of unauthorized access to electronic communication networks, IT management, infrastructure management (e.g. shared platforms), Business Continuity Plan.
- To use User information for studies including publication or sharing with third parties (e.g. partners/advertisers) for scientific, historical, academic, marketing and/or promotional purposes, but only to the extent/way where the User or third party shall not be identified.
c. „Klear Lending“ AD Legitimate interest
We use Your personal data, to position and develop our products and services, to improve the risk management and to protect our legitimate interest by statistical data, tests, models, surveys and research for risk management improvement, to create/improve products/services.
d. Personal Data Disclosure
We collect and process personal data which are required condition and mandatory requisite for preparation, conclusion, execution of credit agreements, user agreements, payments, assignment agreements and/or other products/services offered by/trough us;
We cannot provide the service requested unless You provide us the necessary data.
In some case of additional processing we will require Your additional consent, for which we will inform You promptly.
The Personal Data We Process
We collect and use Your personal data to extent necessary for our activities as well as to reach high standard of personalized products and services. We collect and process personal data necessary for our activities.
We collect:
Identity Data – names, personal identification number, ID document number (incl. copy of the document0, nationality, place and date of birth, sex, picture, IP address;
Address and phone - telephone numbers incl. of third parties/related persons, postal address, e-mail;
Marital status and related persons - marital status, related persons, number of children;
Employment and education information - education level, employment, employer data, remuneration;
Banking, financial and transactional data - bank account data, payment transfers, declared investment profile, credit history, debts, incomes, CCR checks, assets, etc
Tax status - tax number, tax status;
Data for your consumer preferences and behavior - services usage data, banking, financial and transactional data;
Data for our interaction with You - video interviews, internet pages, applications, social media pages, meetings, calls, chats, phone conversations.
Biometry data and health data will be processed only following Your explicit consent.
Data Sources:
The User;
State/Municipal bodies and institutions (CCR, NOI, MoI , etc);
Third parties – pages in social medias containing published by the consumers information, third persons who gather and present information based on legal regulation, public data bases.
Data received via these sources shall be used to confirm/update the information available for/gathered by the User, for the specific cases of personal data collection, including indirect collection.
Under certain conditions personal data may be gathered and processed for persons with whom we have, could have or we have direct connection with. (e.g. credit applicants).
Due to some reasons we may process information for persons without direct relation. As an example: when employer presents info for an employee, contact data is declared by a User, if you are a family member/attorney/legal representative; payment operations initiator/beneficiary made by/for our customers/ultimate beneficial owners, insurance policy beneficiaries, lessors, shareholders, entity representatives, employee of a services provider, merchant partner.
Third persons access to personal data
Access to personal data under confidentiality as much as it is necessary for the activity of „Klear Lending“ AD, the purposes described herein will be granted only to: „Klear Lending“ AD employees, subcontractors or third parties facilitating the execution of agreement, service providers which provide services for and on behalf of „Klear Lending“ AD including debt collection, financial/judicial/law enforcement/state authorities, persons acting per legal mandate as: lawyers, notaries, state/private enforcers, auditors, etc. to the extent necessary for the activity based on legal grounds.
Transfer of personal data outside the EEA
We may transfer personal data outside EEA to providers we contracted to deliver you the services. We check that these providers have declared to take the necessary safeguards to protect your personal data and match the level of protection required by the European regulation (GDPR).
Personal Data Processing Term
We will process personal data for our users for the duration of the existing agreements plus 10 years following the agreement termination date. Personal data for credit applicants is kept one year.
Your rights:
Right to access: You may receive information related to the processing of Your Personal Data, including copy of Your personal data.
Right to rectify: When You consider that Your data is incorrect or incomplete You may request such data to be rectified;
Right to delete: You may request deletion of Your personal data within the limits provided by the legislation;
Right to restrict processing: You may request restriction of the processing of Your personal data unless this restriction contradicts our legal obligation.
Right to object: You may object to the processing of Your personal data on grounds related to your particular situation. You have the absolute right to object personal data processing related to direct marketing, including to profiling related to direct marketing;
Right to withdraw Your consent:When You have granted a personal data processing consent You may withdraw it any time; Consent withdrawal does not affect the legality of the processing based on the consent given prior the withdrawal and any processing based on different ground;
Right of data portability: Upon legal ground and technical feasibility your data may be transferred to third party;
Right to file a complaint: To the responsible supervisory authority – Personal Data Protection Commission. In cases where for the purposes of conclusion or execution of Agreement You have been subject to decision based solely on automatic processing including profiling, You have the right if You consider necessary to express Your opinion, to object to the decision and to request a human review of this decision.
You can exercise the rights stated herein by sending letter or an email to the addresses below. Be aware we may perform additional identification based on Your request.
Contact us:
Should You have questions related to the processing of Your personal data per the present Information Notice please contact our Data Protection Officer: DPO@klearlending.com or at address: 1784 Sofia, Bulgaria, 115 M Tsarigradsko Shose Blvd., European Trade Center, Building D, 1st Floor
