Privacy policy

We respect our users’ privacy. This Privacy Policy clarifies the following:

1. What personal data is collected by the owner of this website or provided by you as a result of our interaction and the use of our website (www.creditron.org) and software applications?

2. How will your personal data be used? Where and how long will your personal data be stored? How are your rights to this data protected?

Please read this Privacy Policy.

DEFINITIONS AND INTERPRETATION

The following definitions are used herein:

"Data Controller" means a person (acting independently or jointly with others) that determines the purpose and procedure for processing certain personal data.

"Data Handler" with respect to personal data means any person (other than the Data Controller) that processes the data on behalf of the Data Controller.

"You", "Your", or "Data Subject" means:

- Our site visitors;

- Users of all services offered on our website;

- Users of our applications;

- Potential or existing clients communicating with us by phone, via email or otherwise

Data Controller, “we,” “us,” and “ours,” means:

SIA "LeadProm Media" (Matīsa iela, 61 - 31, Rīga, Latvia, LV-1009), its affiliates and data handlers;

"Personal Data" means all information on an identifiable person which can be identified directly or indirectly by reference to an identifier.

“Web Site” means

This term identifies various personal identifiers that constitute personal data, including the name, identification number, location data, or network identifier which reflects changes in technology of personal data collection used by various organizations. The term (where applicable) includes the definitions given in the EU General Data Protection Regulation (GDPR).

PRIVACY POLICY CHANGES

We reserve the right to revise this Privacy Policy from time to time. You should check this Privacy Policy for changes on a periodic basis. If you do not accept the terms of the updated Privacy Policy, stop using this website.

ABOUT US (DATA CONTROLLER IDENTIFICATION)

SIA “LeadProm Media” is registered at: Matisa Street 61 - 31, Riga, LV-1009, Latvia, conducts its business as Creditron.org together with its affiliates, subsidiaries, data handlers (jointly www.creditron.org).

Personal Data we can receive from you:

PERSONAL DATA PROVIDED TO US

We collect the information provided by you to ensure continuous operation and use of our website, products and services at the highest level. By completing the contact forms on our website, creating an account on our website, or by contacting us by phone, via email or otherwise, you provide the relevant information on a voluntary basis.

This information includes the data provided by you when you subscribe to any of our services offered on our website, send your requests or feedback, join mailing list, send to the website your requests, participate in the forum discussions, advertising promotion or analysis or use other social network functions on our website, or report any problem emerging on our website.

Personal Data	When We collect	How We use	Why We use
Last name, name, login, password resident address	In registration procedure	We use Your personal and contact information to register You as a User and identify You in Our Services. Login and password You can use to log in	Necessary for the performance of a contract with you
Information about your age	In registration procedure	We need to make sure that Your use of Our services is legal	Necessary to comply with a legal obligation
Email, phone number	In registration procedure	Use email to restore Your account. We use it to notify You about changes to Our Terms or Privacy Policy; to communicate with you.	Necessary for the performance of a contract with you
Email, phone number	In registration procedure	We use Your e-mail address to inform You about the latest updates of Our Services and other products You may like. If You have subscribed to Our newsletter, We may send You marketing communications and information that will create an excellent customer experience	Only with Your explicit consent
Information in application form	In application form	We Use this information for a single application for prompt interaction with credit institutions	Necessary for the performance of a contract with you
Name, surname, patronymic, residential address	In registration procedure	We use Your personal data as part of Our due diligence / KYC procedure on Our “Know Your Customer” KYC portals and to identify You in Our Services	Necessary to comply with a legal obligation
Data on the use of Our services, links	When You use Our services	We use it to improve Your customer experience and provide bespoke services that satisfy Your needs and preferences	Necessary for Our legitimate interests
Unique identifiers, browser type and settings, device type and settings, operating system, mobile network information. We also collect information about the interaction of Your browsers and devices with Our services, including OS, IP address, URL of Your request	When You use Our services	We use it to optimize Our service and to improve Our Website, services, direct marketing, User relationships, behavior profiling and experiences	Necessary for Our legitimate interests
Financial data, which includes Credit Card Number, Expiration Type, CVV (3 numbers on back) of the credit card and transactional information from your use of our services.	When You use Our services	We use them to provide you with our Services as specified in the Public Offer. The use of your financial information is necessary to provide you with subscription-based Services. Please review our Tarif and Return Policy by entering Your Financial data	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests

CONSENT TO PERSONAL DATA PROCESSING

By accepting this Privacy Policy, you approve to have reached the age of majority or the legal age in your jurisdiction (generally 18 or older), are solely responsible for all your actions, and fully understand the statements, outlined in this Privacy Policy.

If you are an EU Person and to process your Personal Data We need to receive your consent, as it is prescribed by GDPR, We will process your Personal Data only in the case We have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).

You may give your consent by ticking the respective box when you register for an account with our Service. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that We shall be entitled to process your Personal Data as it is indicated by your Consent.

You may give your consent to the processing of your Financial data by checking the appropriate CoF (Credential on File) box when you place an order for the Services. If you check the appropriate box, you irrevocably and unconditionally agree that we are entitled to process your personal data in accordance with your Consent, as well as the other provisions of the CoF (Credential on File). Please read its provisions before ordering Services

Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.

If you are not an EU Person, by transferring to Us your Personal Data via the Software or otherwise, you irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Policy:

● to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which We collect automatically and/or from other sources); and

● to use cookies and web beacons (pixel tags) to collect your Personal Data.

CHILDREN

We never sell any goods or services to children. If you are under 18, you can use our website only under the supervision of a person performing parental duties. We never intentionally collect Personal Data from children under 18 without the consent of a person performing parental duties.

INFORMATION ON OTHER PEOPLE YOU REPRESENT

By providing Personal Data of other persons (for example, the person on whose behalf you create an account or subscribe to our advertising campaigns) you confirm that you have notified them of 1) the purposes of using their data, 2) the recipients of their Personal Data, and 3) how they can access and make changes to the data. You also confirm that you have obtained all necessary permissions from them.

COOKIE FILES POLICY

A cookie is a small file, usually consisting of letters and numbers, that is downloaded to the device when a user visits a particular website. Cookies allow a website to recognize a user's device.

Why does www.creditron.org use cookies?

Cookies help us improve the content, functionality and loading speed of websites, their ability to track data also helps us understand what you like and dislike. This means that we can respond quickly and customize the website accordingly.

We can use cookies to identify you when you visit our website or use our services, keeping in mind a customized approach:

Cookie for authentication. If you enter the Services section, these cookies help us display relevant information and personalize your activities.

Session cookies. These cookies store the user session identifier. A cookie is set when a user logs in and used to resume a session without entering personal data.

Cookies for security. We use cookies for security and malware detection.

Selected options, functionality and services. These cookies help us adapt to your preferences, such as language, communication settings and faster completion of forms.

Performance, analytics and research. These cookies help us analyze the performance of our website. We use cookies to improve our products, features and services, including for the purpose of keeping logs and records when visiting our website.

Cookies and third parties. Creditron.org sends cookies to your computer; Some third parties may send cookies to your computer. The purpose of this data processing is to track conversions and data transfer to related parties. This is necessary in order to perform the agreement concluded with third parties (our related parties) that use our services (Art. 6, part 1, lit. b) of GDPR Regulation). Our legitimate interests constitute a legal basis for such processing. Note: We never share personal information with third parties.

We use the following cookies: session (temporary), permanent and external advertising, including cookies of our partners and service providers:

What to do if you do not want to set cookies or want to delete them?

Most browsers automatically accept cookies, but some users do not. You can change the security settings of your browser in order not to receive or save cookies on your device, to receive and store cookies from your favorite trusted websites, or receive notices before receiving cookies. You can also delete cookies stored in your browser at any time. The information stored in these cookies will be deleted from the device. However, such settings may adversely affect the usability of websites.

Browser manufacturers usually provide cookie management help pages for their products. See the Links below for more information:

- Google: https://support.google.com/chrome/answer/95647?hl=en-GB

- Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies

- Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

- Safari (desktop): https://support.apple.com/kb/PH5042?locale=en_US

- Safari (mobile): https://support.apple.com/en-us/HT201265

- Application (Android): https://support.google.com/nexus/answer/54068?visit_id=1-636585517588941681-639659396&hl=en&rd=1

- Opera: https://www.opera.com/help

- Opera Mobile: https://www.opera.com/help/mobile/android#privacy

See Browser Manufacturer's Documentation for information on other browsers.

You can opt out of third-party Google Analytics cookies on their website.

You can opt out of personalized targeting provided by participating ad servers through Digital Advertising Alliance. In addition, you can change the device settings on your iPhone, iPad or Android to avoid personalized ads.

INFORMATION ON THIRD PARTIES WE CAN RECEIVE.

We can receive information on third parties that is not their identification information. We protect data received from third parties in accordance with the procedure described in this clause and any additional restrictions provided by the data source.

We can place advertising on the partner websites, social or advertising networks that can group users of pages with similar characteristics or interests in segments not related to Personal Data, and offer such segments to our clients, visitors and subscribers. For example, if you are interested in clothing or cosmetic products, you can see an ad linking to the website of the same service provider.

We can receive and record information on advertising requests or impressions: the number of requests / impressions, geographic targeting data (which do not contain an IP address or location data allowing us to identify a person) and all user activities related to the ad or activities on the website where it appears. Such information is used to analyze, report and correct deficiencies. We do not profile our guests' activities.

Where do we store information?

We respect our clients' privacy and take care of their security. We are constantly striving to protect the personal information that you provide to us. To protect your Personal Data from unauthorized access, use or disclosure, we use a combination of reference technologies, procedures and administration security.

We work with a number of authorized service providers (data processing) whose services and solutions complement, facilitate and improve our own services and solutions in accordance with written confidentiality agreements. We guarantee compliance with the requirements of applicable laws and standards. Data Handlers work only in accordance with our documented instructions. They have direct obligations in accordance with the GDPR Regulation. In the event of failure to fulfil such obligations, they may be punished or pay a fine.

These may include: services from hosting providers, information technology providers, data protection and cybersecurity service, web analytics services, mailing and email monitoring, marketing services.

Such Data Handlers may receive, in whole or in part, or otherwise have access to your identifying and non-identifying Personal Data, depending on the specific function and purpose of each of them, in order to ensure the operation and improvement of our Services or business. However, they may use this data for this purpose only. In no event Data Handlers may use the data for their own purposes.

Your Personal Data may be stored and processed at the destination point in the European Economic Area.

Upon the conclusion of the agreement, the Data Handler returns data to us or transfers it to another handler designated by us, deleting all copies that he/she owns. However, Data Handlers may store data in a secure manner if they bear administrative or procedural liability.

DATA STORAGE

Subject to your consent (unless otherwise stated), you will receive information from us about the products or services we offer, the products or services that, in our opinion, may spark your interest, or similar to those that you have already bought or requested information thereon.

To make a purchase, we assume that you have no objection to our storing your Personal Data collected by us. We may store your Personal Data (contact details) while your account is active, or provide information about our services in other cases. As a Data Subject, you have the rights related to your Personal Data processing and possibility to withdraw your consent to receive inventory notices at any time. See Your Rights section.

LEGAL FRAMEWORK AND OBJECTIVES FOR USING YOUR PERSONAL DATA

If you are located in, all processing of Personal Data is performed in accordance with all national regulations and rules.

If you are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the .

We process Personal Data as a Controller, as defined in the GDPR.

Legal basis:

i)the performance of Our contract with You (i.e. the provision of Our Services to you);

ii)our legitimate business interests (i.e. for fraud prevention, maintaining the security of Our network and services, seeking to improve the Services that We provide and Your interaction with us). Whenever We rely upon this lawful basis We assess Our business interests to make sure that they do not override Your rights. Furthermore, in some cases You have the right to object to this processing;

iii) with Your consent for direct marketing purposes so that We may keep You fully up to date with other products and services that We supply and think may be of interest to you. Where We rely upon consent, We will need Your explicit consent, which may be removed at any time;

iv) law purposes.

The main purposes of using the collected data are described in more detail below.

1. We will use the information provided by you for better performance, and we will do our best to process your request. The Agreement and your consent constitute a legal basis for data processing.

1.1 At the request of the Data Subject, complete a number of steps before providing the requested service:

1.2 Coordinate interaction with you, analyze application and profile data, comply with the terms and conditions of our agreement and send your Personal Data to private lenders

2. Upon termination of our contractual relationship, we can store your information as long as possible to fulfill our obligations and legal obligations in accordance with our legitimate interests as the Data Controller. Legal obligation constitutes legal basis for such information storage. As the Data Subject, you have the rights related to your Personal Data storage and processing. See Your Rights section.

3. Develop and conduct marketing activities; find out how customers use products and services provided by us and other organizations; discuss our products and services with you. Our legitimate interests and your consent constitute legal basis for such data processing.

3.1 If you do not want to receive such advertising emails, you may withdraw your consent at any time by contacting us as described in Your Rights section or by clicking "Unsubscribe" following the instructions or instructions you receive from advertising materials. However, in this case, we will not be able to perform our agreement and properly inform you about loans available.

4. Website Improvement

For example, we can automatically use the data collected, such as IP address and browser data, to improve our website:

4.1 For the website administration and internal operations, including data protection, diagnostics, testing, statistics and analysis;

4.2. To ensure the content presentation on the website in the most effective way for you and your device. Our legitimate interests constitute a legal basis for such data processing.

INFORMATION DISCLOSURE TO THIRD PARTIES

We never lease out, sell or transfer your Personal Data to other individuals or entities without your consent, unless it is necessary to provide products or services at your request, with your consent or in the following cases:

1. We provide information to trusted partners listed in the Trusted Partners section (Data Handlers) that provide to us services under confidentiality agreements, act on our behalf in accordance with confidentiality agreements, and may store or process data. Such entities have no autonomous right to disseminate this information.

2. We may disclose your information to third parties if, in our reasonable opinion, it is required by law, and to investigate, prevent or take action regarding alleged or actually prohibited acts, including fraud and potential threat to physical safety of any person.

3. In the event of purchase of our company, its relation with an external company or any other changes in the management structure, we reserve the right to transfer any information to the next company, including any Personal Data identifying and not identifying a person. In this case, we will notify you via electronic means before sending your personal information and developing another privacy policy.

4. If you agree and give your permission, we will exchange your data with private creditors, as described in LEGAL FRAMEWORK AND OBJECTIVES FOR USING YOUR PERSONAL DATA section.

For example, when you fill out a single questionnaire and choose to "send", we transfer your data specified in the questionnaire to credit institutions in accordance with your instructions.

Law enforcement, protection of rights and obligations:

We may disclose or otherwise permit other people to access your Personal Data (with or without notice) on the basis of legal acts, such as summons, lawsuit, search warrant or court order, or in accordance with applicable law, if we assume in good faith that it is required by law. Your data may be transferred to the police and law enforcement agencies to detect fraud, prevent crime and ensure national security.

Your rights

In accordance with the EU General Data Protection Regulation and the , you have the following rights:

The following are the specific rights You have over Your personal data We hold and process, namely:

1) The right to be informed about Our collection and processing of Your personal data including without limitation the legal basis for the collection and processing, the categories of data, the methods of data use, the envisaged period for which the personal data will be retained. This Privacy Policy should tell You everything You need to know, but You can always contact Us to find out more or to ask any questions.

2) The right to access Your personal data We collect about you, commonly referred to as “Subject Access Requests”, which provides you, as the data subject, the right to obtain a copy of Your personal data that We are processing for You

Pursuant to GDPR We are required to respond without undue delay to all Subject Access Requests in practice this means We have to respond within 1 month of receipt of the Subject Access Request.

Ordinarily Subject Access Requests are free of charge.

We may extend the time period for responding to a Subject Access Request by a further two months and may charge a reasonable fee if We deem the request to be manifestly unfounded or excessive, however, We are required to advise You of Our intention to do this within 1 month of Your subject access request.

Should You wish to make a Subject Access Request this can be done by contacting the Company using the contact details in Section 9.

3) The right to have Your personal data rectified if any of Your personal data that We collect and process is in any way inaccurate or incomplete.

4) The right of erasure (otherwise known as “the right to be forgotten”), i.e. the right to ask Us to delete or otherwise dispose of any of Your personal data that We process. Please note that this is not an absolute right and We may not be able to comply with Your request as We may be legally obliged to continue to retain Your personal data for a specific period

5) The right to restrict (i.e. prevent) the processing of Your personal data by us.

6) The right to object to Us processing Your personal data for a particular purpose or purposes. Please note that the right to object only applies in certain circumstances and will depend on the purposes or legal basis for the processing.

7) The right to data portability. This only applies where You have provided personal data to Us directly, the legal basis for Us processing Your personal data is i) consent or ii) for the performance of a contract and We are processing Your data using automated means. In such instances You have the right to receive Your personal data (or request that We transfer it to another Controller) in a structured, commonly used and machine readable format.

8) Rights relating to automated decision-making and profiling. We do not use Your personal data in this way.

9) The right to lodge a complaint with any relevant Data Protection Authority, in particular in the member State of Your residence, place of work or the place of processing Your personal data.

If You wish to exercise any of the aforementioned rights, please contact Us. We request that in the first instance You contact Our data protection officer at any time Our on support@creditron.org or by phone +48221530262

We promise to promptly consider Your request and to respond to You in accordance with the requirements of the and GDPR.

CHANGES TO THIS PRIVACY POLICY

Any changes that We make to Our Privacy Policy in the future will be posted on Our app and Website.

Where appropriate, We will notify You of the changes when You next visit Our Website.

This Privacy Policy was last updated on 14.03.2023.

Public offer

SIA “LeadProm Media”

Consent

I hereby express my consent and authorize SIA “LeadProm Media” to collect, store and process my personal data, namely:

● First name, last name

● Mobile phone number

● E-mail address

● Residence address

I give my consent for the following purposes:

o Maintaining contact with me

o Mailing correspondence to the address provided by me

o Communication on the specified phones

o Sending SMS to the specified mobile phone number

o Sending messages to the specified e-mail address: in order to transmit information about new services, update and confirm requests, clear applications and verify information received

I hereby confirm the following:

o Personal data were provided on an informed and voluntary basis;

o The data provided in the questionnaires are true and correct;

o This consent is given for five (5) years with an option of unilateral withdrawal at any time by sending an electronic message to the following e-mail address: support@creditron.org.

PUBLIC OFFER

(Agreement)

for the provision of information services through the use of the Service

1. General Provisions

1.1. This public offer (the “Offer”) for the provision of information services is a public offer provided by SIA “LeadProm Media” (hereinafter – the “Operator”) which determines the terms and conditions of using the website https://creditron.org/ and the provision of the Operator`s Services to the Customer (hereinafter - the “User”) (hereinafter – the “Agreement”).

1.2. The Operator and the User, separately, may sometimes be referred to as the “Party” and jointly as the “Parties” in the following agreement.

1.3. This Offer is addressed to legally capable persons being the Users of the website https://creditron.org/. The Offer is an official public offer made by SIA “LeadProm Media” with the purpose of entering into the Agreement.

1.4. The current version of the Offer is available on the Operator`s Website at: https://creditron.org/ so that the User can read it carefully and with due diligence before accepting the terms and conditions of the Offer. The Tariff and Refund Policy as well as the Privacy Policy are available on the Operator’s Website and shall constitute integral documents of this Agreement.

1.5. This Agreement shall be deemed concluded and effective from the date when the User performs the actions set forth in Clause 3.2 of the Agreement, which means complete and unconditional acceptance by the User of all terms and conditions hereof without any exceptions and / or restrictions.

1.6. Either Party represents and warrants that it has required legal capacity and all rights and powers necessary and sufficient to enter into and perform the Agreement in accordance with the terms and conditions hereof.

2. Terms and definitions used in the Agreement

In this Agreement, the terms below have the following meanings:

Authorization Data shall mean data enabling Authentication of the user. By default, the login and password created by the User constitute the User’s Authorization data.

Authentication shall mean confirmation of the User’s legal capacity to conduct transactions through the use of the Service and / or to obtain information on transactions through the use of the Service in accordance with the procedure established by this Agreement. To conduct a transaction through the use of the Service, the User must authenticate using the Operator`s software based on the Authorization Data entered by the User.

Privacy Policy - shall constitute a policy that regulates the processing and storage of personal and/or any other data of the User and the Operator throughout the performance of this Agreement.

Tariff and Refund Policy shall constitute a policy that regulates the payment method, prices and refund policy and any other data related to the matter of payment by the User for the Operator’s Services. The Tariff and Refund Policy for each type of Services and any other payment information shall be determined, specified and regularly updated by the Operator at the Operator’s Website at the following link:

Request shall mean an electronic document created by the User, with indication of Information to be used by the Service.

Information shall mean data on the preferred characteristics of the loan provided by the User and used by the Operator to prepare the Report, as well as data of the User, including his/her Personal Data.

Lender shall mean a separate (from the Operator) legal entity engaged in microfinance activities which grants a loan to the User on the terms established by the Loan Agreement.

Operator shall mean SIA “LeadProm Media”, which provides the Service to the Users and performs other actions related to the use of the Service.

Report shall mean an electronic document generated by the Operator based on the Request, which contains a list of available offers made by the Lenders providing lending facilities in the region specified by the User, and in accordance with the parameters selected by the latter, based on which the list for the User is created and placed in the user’s Personal Account in the Recommended Offers section. At the discretion of the Operator, it can be supplemented with other offers which, in the Operator’s opinion, may also be of interest to the User.

Right to block the User shall mean the unilateral right of the Operator to block the User from the use of Services in the manner provided by article 5.15. of this Agreement and the Tariff Policy.

User shall mean an individual having his/her own user account and affecting access to the Website, who has completed the registration procedure and received personal Authorization Data.

User form shall mean a page on the Operator’s Website where the User shall enter all relevant registration information before gaining access to the Website in accordance with this Agreement and the Privacy Policy hereto.

Operator’s website (Website) shall mean the Operator’s information resource in the information and telecommunication global network (hereinafter – the Internet) located at: https://creditron.org/, through which the User can use the Operator’s Service.

Service (Services) shall mean the Operator’s following actions:

the provision of access to an informational service (the Operator’s Website) which contains information on loans and credits available to the User in accordance with the User’s Request and the available Lender organizations;

access to the Operator’s technological system available on the Operator’s Website, which enables to create and submit the User Requests for consideration by the Lenders for obtaining a loan by the User;

actions performed by the Operator, including the collection and processing of Information from the Request of the User, aimed at processing the Request and providing the User with information on the Lenders’ offers that meet the requirements specified by the User when using the Service, as well as the provision of the User Requests to the Lenders in order to issue a loan or credit to the User;

Information service shall mean the Operator’s division, which, at the request of the User, provides the latter with information on the use of the Service (by e-mail with the involvement of the Operator’s employee or by any other means available to the Operator).

Tariffs (Tariff and Refund Policy) shall mean the types and methods of payment as well as prices for each type of Services payable to the Operator by the User.

Services Delivery Certificate shall mean a document generated by the Operator and sent to the User’s email after every provision of Services to the User.

Period of Service Provision (Periods) shall mean a time period throughout which Services are provided by the Operator to the User. The types of such Periods are determined at the Operator’s website at the following link: https://creditron.org/en/tariff

3. Scope of the Agreement

3.1. This Agreement shall establish the conditions and procedure for the provision of Operator Services to the User.

3.2. Acceptance of the terms and conditions of this Agreement at the time of registration shall mean the User’s full and unconditional consent to the terms and conditions hereof.

3.3. The User shall pay for the Operator Services in accordance with Clause 6 of this Agreement and Tariff and Refund Policy available at the Operator’s Website.

4. Legal Framework

4.1. By using Operator`s Services the User gives its consent to receive the information required for Operator`s Services from the respective data base of its partners in accordance with legislation requirements, and the provisions of the GDPR within the framework of contractual cooperation, subject to the consent of the User.

4.2. The legitimate interest bases on provisions of legislation under which banks, credit institutions, non-bank financial institutions, electronic money institutions, payment institutions has the right to receive such information to credit risk assessment, credit health analysis, or in order to achieve a legitimate interest of the User or of the third party to whom the data is disclosed, provided that this interest is not prejudicial to the interests or fundamental rights and freedoms of the person concerned. Also, legitimate interest comes from the need of carrying out responsible crediting activity by complying with the laws on data protection, assessment of credit health, and managing credit risk. Such Services enable interested persons to evaluate their own credit health, by giving the Operator their consent to process their personal data and making a request for such on the provision of the Services, and also to get an offer from the potential Lenders. The Services enable the potential Lenders to evaluate the credit risks of lending to the relevant User and make a business decision on such information, which is a pivotal part of the process under the applicable laws of lending.

4.3. The Operator does not form the User's credit background and is not responsible or liable to Users for a potential Lender's decision based on the assessment of the User's credit health..

4.4. By using Operator`s Services the User gives its consent to receive the information required for Operator`s Services from the respective data base in accordance with the legislation on the protection of individuals with regard to the processing of personal data - to achieve a legitimate interest of the User or third party to whom the data are disclosed and agrees that this interest is not prejudicial to the interests or fundamental rights and freedoms of the User concerned under the applicable provisions of legislation.

4.5. Private data processing is made with a high degree of security, in compliance with the GDPR, and with a high degree of privacy – the information is not public and is available only to the Operator, User and potential Lender if the User makes a request and gives a consent.

4.6. All the matters regarding Your Private Data are governed by Our Privacy Policy and You are giving Your consent to the collection of such information by using the Site; therefore, We recommend You, and You should ensure that You have read the Privacy Policy provisions carefully.

5. Procedure and conditions for the provision of the Service

5.1. Registration on the Website.

5.1.1. To gain access to the Service, the User shall accept the terms and conditions of this Agreement when completing the User Form on the Website. The User’s consent to the terms and conditions of this Agreement at the time of entering his/her data on the Website shall mean the acceptance hereof by the User.

5.1.2. The User shall complete the User Form on the Website by entering the relevant registration information. When entering the data on the Website, the User shall enter his/her full name, date of birth, place of residence, phone number, email address and password.

5.1.3. The User shall provide true, complete and reliable information and keep it up to date. The User shall provide his/her personal data in accordance with Clause 7 hereof and Privacy Policy hereto.

5.1.4. The User agrees that he/she is solely responsible for maintaining the confidentiality of authorization data used by him/her to access the Website. In addition, the User agrees that he/she is solely responsible to the Operator for all actions performed when entering his/her personal data.

5.1.5. If the User becomes aware of any unauthorized use of his/her Authorization Data, he/she shall immediately notify the Operator thereof by contacting the support service by e-mail: support@creditron.org

5.2. During registration on the Website, the User shall not disclose (or, in the case of disclosure, shall be solely and fully responsible) his/her last names, first names, phone numbers, email addresses and other personal data or data of any third parties without their personal consent to such actions, expressly provided by completing the User’s form.

5.2.1. In order to use the Services provided by the Operator under this Agreement, the User shall always follow the Request submission procedure established hereby.

5.2.2. To submit the Request, the User shall provide the Information in accordance with the requirements and give consent by checking the appropriate CoF (Credential on File) box when you place an order for the Services. If you check the appropriate box, you irrevocably and unconditionally agree that we are entitled to process your personal data in accordance with your Consent, as well as the other provisions of the CoF (Credential on File). Please read its provisions before ordering Services.

5.2.3. When creating the Request, the User shall choose the characteristics of the desired loan, namely: the amount, the loan term, his/her name, surname, place of residence and other data required by the Lenders to make a decision.

5.2.4. The Request submission procedure shall be conducted from the User’s Personal Account after the payment transaction carried out by the User for the provision of Services. The User shall pay for the Services under this Agreement in the amount and in the manner specified in Clause 7 hereof.

5.2.5. Upon receipt of the Request, the Operator shall send the Request to potential Lenders for consideration (from the list of Lenders posted on the Website).

5.2.6. The obligations of the Operator under this Agreement shall be limited to the provision of Services for analysis and selection of Lenders’ financial products (offers). If the Lender provides a loan or credit to the User, the Operator shall not be a party to the agreement concluded between the User and the Lender, and therefore, the Operator shall not regulate or control the compliance of the transaction with applicable laws and standards, the terms of the transaction, as well as the acts and consequences of conclusion, performance or termination of the agreement, including regarding the repayment of the loan, and the Operator shall not consider the User’s claims regarding non-fulfilment (improper fulfilment) of the obligations by the Lender under such agreements.

5.2.7. The Operator shall not guarantee the provision of a loan or credit by the Lenders when the User forms the Request, but shall only select the lending options (offers) and send the Request to potential Lenders for consideration. It is the Lender who makes the decision to grant a loan. Data on the Lenders’ financial products (offers) provided by the Operator in the Report to the User shall not constitute an offer for guaranteed provision of financial services.

5.2.8. The Operator shall provide services to the User on a round-the-clock basis. The Operator’s actions for the performance of this Agreement that are not performed automatically shall be carried out on weekdays.

6. Rights and obligations of the parties

6.1. Rights and obligations of the Operator:

6.1.1. The Operator shall provide to the User round-the-clock access to the Website.

6.1.2. The Operator shall have the right to check and pre-moderate the Information disclosed by the User.

6.1.3. The Operator shall consider all the Requests and submit relevant Reports, provided that the User has read and understood the terms and conditions of this Agreement and duly completed the Request.

6.1.4. The Operator shall notify the Users of any changes in the terms and conditions of this Agreement by publishing the latest version hereof on the Website.

6.1.5. The Operator shall have the Right to block the User if the latter fails to perform the full payment of Services in accordance with the provisions of this Agreement.

6.1.6. The Operator may suspend the operation of the Website and / or the Service, as well as hardware and software that ensure interaction between the Parties under this Agreement, in the event of any significant malfunctions, errors or failures, and for the purpose of preventive maintenance and prevention of unauthorized access.

6.1.7. The Operator may limit the User’s requested loan amount to form the Request of Users. Specific limitations under this clause will be displayed on the Website.

6.1.8. The Operator shall have the right to display in the User’s Personal Account other options for loans and credits that fail to meet his/her initially specified requirements as to the amount, the term and other parameters, in order to provide more information on possible loan products.

6.2. Rights and obligations of the User:

6.2.1. The User agrees to comply with the rules of this Agreement.

6.2.2. The User shall further provide reliable information when registering on the Website.

6.2.3. The User shall not reproduce, duplicate, copy, sell or resell, or use any services or parts of the Service for any commercial purposes without the Operator’s written consent.

6.2.4. The User shall obtain access to the Website using his/her Authorization Data only from one device at a time.

6.2.5. The User shall not give access to his account to any third party.

6.2.6. The User shall independently and in a timely manner familiarize himself(herself) with the Information regarding change in Tariffs and the terms and conditions of this Agreement posted on the Website.

6.2.7. The User shall pay for the Services in accordance with the Tariffs, within the time limit and under the terms established by the Operator. The Tariffs for each type of Services shall be determined, specified and regularly updated by the Operator at the Operator’s website at the following link:

6.2.8. The User shall have the right to submit claims to the Operator and shall send requests in the manner and in cases as stipulated by this Agreement.

6.2.9. The User shall have the right to terminate this Agreement at the relevant web-page at the Operator’s website. In case of such termination the User shall lose all access and use the Operator’s website as well as the Operator’ Services without any refund to such User.

7. Value of services and payment procedure

7.1. The Operator shall set the value of the Operator`s Services in Tariffs published on the Website.

7.2. The Operator shall have the right to unilaterally change fully or partially (that is, increase or decrease), establish new Tariffs and / or cancel existing ones. If the User does not agree with the change (entry into force) of new Tariffs, he may unilaterally repudiate this Agreement.

7.3. The Operator shall provide all services on the basis of 100% prepayment. The User shall make 100% payment in advance, during registration on the Service.

7.4. The User shall pay for the Operator`s Services using a bank card through the Website (or through any other means previously agreed with the Operator, including the use of online technologies that are not contrary to the law).

7.5. After the provision of Services the Operator shall provide a Services Delivery Certificate that shall be generated or signed at the discretion of the Operator and sent to the User via e-mail that is specified in the User Form and Authorization Data . The Services shall be deemed to be properly provided and fully accepted by the User unless the Operator has received from the User written reasonable objections to the quality of the Services provided within one calendar day upon the expiration of the service provision period by e-mail: support@leadprom.com. If during the specified period there are no written objections, the Services shall be deemed to be of proper quality.

7.6. In case of termination of this Agreement by the User, such User shall not receive any refund for the remaining unused Period of Service Provision.

7.7. By entering into this Agreement the User gives his/her full express consent and acknowledgement that there shall be no withdrawal period or refund policy rules, except the ones that are stipulated in the Tariff and Refund Policy available at the Operator’s Website. The User expresses his/her consent that he will lose his right of withdrawal once the Operator’s Services have been provided to the User.

8. Personal data

8.1. By placing personal data and any other data on the Website, the User confirms that he/she has read, understood and agreed with the Privacy Policy of SIA “LeadProm Media” available on the Website, and that he/she has provided to the Operator his/her consent to personal data processing in order to perform this Agreement.

8.2. The purpose of processing the User’s personal data shall be provision of services to the User, enabling the User to use the Service, participate in advertising campaigns, target advertising and perform other actions described in the Agreement.

8.3. The User’s personal data shall be processed from the moment the User registers on the Website, or order the Services until the Consent to personal data processing is withdrawn.

8.4. The User agrees that the Operator shall send information on advertising campaigns conducted by the Operator and/or its partners (including Lenders), and any other information not prohibited for distribution, to the email address specified by the User.

8.5. The User understands that in order to perform the Services specified herein, the Operator shall receive personal information specified in our Privacy Policy, including the credit health rate of the User either from the User, other public registers, from Central credit register (if such are) directly from Lenders, or Operator's partners authorized by User consent to process such data.

9. Intellectual property

9.1. The website and all of its components are the sole property of Operator.

9.2. The Operator also retains all rights to confidential information, including commercial and marketing strategies, technological know-how, plans and designs for new products, business practices disclosed by each party, and the content of interactions between the parties.

9.3. The User shall be forbidden to dismantle Services, reverse-engineer it, or engineer it to create competitive services; create a product or services based on ideas, traits, abilities, or designs from the Operator’s website or Services; use without authorization any concepts, features, capabilities, or pictures from Services or website; to take any other action which can infringe the Operator’s intellectual property rights.

9.4. Except for the limited rights expressly granted in this Agreement, the Operator retains all rights, titles, and interests in and to the Services, including all related intellectual property rights. Further, than those expressly granted, the User has no other rights under this Agreement.

9.5. The Operator shall be entitled to utilize and incorporate into its services any recommendations, corrections, suggestions, or other feedback regarding Services by the User.

10. Liability of the Parties

10.1. The Parties shall be liable hereunder for failure to fulfil or improper fulfilment of the provisions hereof.

10.2. The Operator shall moderate the Information placed by the User, however, it is not responsible for the consequences of non-compliance by the User with the requirements set forth in paragraphs 5.1.3-5.1.6 hereof.

10.3. The User agrees that the Services provided by the Operator may be protected intellectual property.

10.4. Text content (articles, publications available on the Website) may be distributed if there is an active link to the Website.

10.5. The Operator shall not be liable for any direct or indirect losses of the User caused by failure to use the Website or some Services of the Website as a result of the User’s bad internet connection, technical difficulties or any other reason whatsoever unrelated to the ability of the Operator to perform duties under such agreement. The Operator shall not be liable for any loss suffered by the User in connection with the use of the Operator’s Services provided under the present Agreement unless such loss arises from bad faith, willful default or fraud on the part of the Operator.

10.6. The Operator shall not be liable for any acts or omission of the Lenders that provided the loan, as well as for any information or data regarding the provision of the loan disclosed by the Lender. The Lenders shall make a decision to grant a loan, the Operator shall not guarantee granting loans or credits, but shall only select to the User the most suitable loan options.

10.7. The Operator shall not be liable for the achievement of any results by using the information disclosed to the User in the Report. The User agrees to use any information on the Lenders’ offers provided by the Operator, at his/her own peril and risk.

10.8. The Operator shall not be liable for the inconsistency of the Service with the User’s expectations and / or his/her perception; such inconsistency with expectations and / or negative perceptions shall not constitute grounds for considering the Services to be of poor or insufficient quality.

10.9. The Services provided “AS IS” and the Operator shall not be liable for the inconsistency of the Service with the User’s expectations and/or his/her perception; such inconsistency with expectations and/or negative perceptions shall not constitute grounds for considering the Services to be of poor or insufficient quality.

10.10. The Operator's liability, including but not limited to the User`s claims of contributions and indemnification related to third party claims arising out of the Services rendered by the Operator, and for any losses, injury or damages, shall be limited to the last payment received by the Operator from the User for the particular Services provided giving rise to the claim. Notwithstanding anything to the contrary in this Public Offer, the Operator shall not be liable for any special, indirect, consequential, lost profits, or punitive damages. The User agrees to limit the Operator’s liability to the User and the Operator shall not be liable for any Lender actions, any damage on account of any error, omission or negligence.

10.11. The User explicitly agrees that the Operator does not form the User's credit history and is not responsible or liable to the Users for the potential Lender's decision based on the assessment of the User's credit health.

11. Force majeure circumstances

11.1. The Parties shall not be held liable for any delays in the performance or for nonperformance of their obligations under the present Regulations if the delay or non-performance was due to circumstances or reasons beyond the control of the Parties, such as a war (including civil war), riots, sabotage, embargo, fires, floods or other acts of God, explosions, actions or omissions of government authorities, strikes. All and any of these circumstances shall be regarded as force majeure circumstances. Within 24 (twenty-four) hours upon receipt of information about commencement of any force majeure circumstances which delay or interfere otherwise with the performance of the Regulations, the Parties shall notify each other in writing.

11.2. The Parties shall not be held liable for any damages, losses, claims or other expenses that may be incurred as a result of force majeure circumstances.

11.3. If force majeure circumstances interrupt or make impossible the performance of obligations of the Parties for a period longer than 30 days either Party may terminate this Agreement serving a prior written notice of termination on the other Party.

11.4. In the event that the Operator determines in its reasonable opinion that a Force Majeure Event exists, the Operator shall be entitled without notice and at any time take one or more of the following steps:

(a) suspend or modify application of any or all of these Provisions of the present Agreement to the extent that the Force Majeure Event makes it impossible or impractical for the Operator to comply with these clauses; or

(b) take any other actions as the Operator may consider to be reasonable under the circumstances in relation to the position of the Operator, the User and the Operator’s other Users.

12. Dispute settlement procedure

12.1. All disputes and disagreements that arise or may arise out of this Agreement at the User’s initiative shall be settled on an out-of-court basis.

12.2. In case of a dispute and/or disagreement that may arise out of this Agreement the Parties within 10 (ten) working days shall send each other written complaints at the following addresses:

12.2.1. If the written complaint is addressed to the Operator - the legal address of the Operator

12.2.2. If the written complaint is addressed to the User - the email stipulated by the User in his/her Personal Data and/or User Form.

12.3. If the parties have not been able to resolve the dispute within ten working days of receipt of the written complaint, the parties shall refer the dispute to the relevant judicial authority.

13. Governing Law

13.1. This Agreement will be construed in accordance with and governed by the laws of Latvia.

13.2. For all matters not covered in this Agreement, Parties shall be governed by the laws of Latvia.

14. Miscellaneous

14.1. Electronic Communications. The Operator shall send information relating to the User’s account (e.g. payment authorizations, invoices, changes in password or Payment Method, confirmation messages, notices) in electronic form, for example via emails to your email address provided during registration in User’s Form/Authorization Data.

14.2. Survival. If any provision or provisions of this Agreement shall be held to be invalid, illegal, or unenforceable, the validity, legality and enforceability of the remaining provisions shall remain in full force and effect.