Privacy policy

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

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?

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 carefully 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
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 optimise Our service and to improve Our Website, services, direct marketing, User relationships, behaviour profiling and experiences Necessary for Our legitimate interests

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 analyse 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 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:

Domain Cookie name Cookie lifetime Description of the Cookie purpose
https://creditron.org XSRF-TOKEN Session XSS attack protection
https://creditron.org cookie 2 years Used to check if the user agree with cookie policy
https://creditron.org laravel_session Session Used to identify user
https://creditron.org remember_web 2 hours Used to remember authenticated user
https://creditron.org unique_record_id 1 year Statistics

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 analyse, 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 the compliance with the requirements of the GDPR Regulation and protect the rights of data subjects. 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

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 on 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.

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 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, analyse application and profile data, comply with the terms and conditions of our agreement and send your Personal Data to private lenders

Upon termination of our contractual relationship, we can store your information as long as possible to fulfil 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.

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.

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 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:

- 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.

- 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.

- 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.

- 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, you have the following rights:

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

  • 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.

  • 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.

  • 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.

  • 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

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

  • 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.

  • 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.

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

  • 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 Data Protection Act and GDPR.

Complaints to the Latvian Data Protection Inspectorate should be made by using the appropriate forms provided in the Latvian Data Protection Inspectorate Website.

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 19th August 2020.