Data Protection Regulations – Any applicable laws and regulations regulating the processing of Personal Data, including but not limited to the GDPR;
Sortter – Sortter Oy, company registration no. 2954352-7, registered address Bulevardi 21, 00180 Helsinki, Finland, phone: +358-9-8566 5550, e-mail email@example.com;
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
Personal Data – Any information relating to an identified or identifiable natural person (Data Subject);
Processing – Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, storing, alteration, granting access to, responding to enquiries, transfer, viewing, etc.
User – A natural person who is acting on behalf him- or herself, on behalf of his/her co-applicant, or on behalf of a corporate client that uses, has used or has expressed an intention to use the services offered by Sortter.
Sortter is responsible for the Processing of your Personal Data and, as such, should be considered a data controller under the GDPR in relation to your application and other the Personal Data provided by you.
The Processing of your Personal Data shall be governed by the laws of Finland.
We collect your Personal Data in the following ways:
- If you’re the User who intends to use our loan intermediation service, you provide us your Personal Data directly when you fulfil the application form to find the best loan for yourself.
- If you are co-applicant of the User you should give your consent to the User to entitle him/her to provide us with your Personal Data.
- In order to provide loan intermediation service, we may also collect your Personal Data from credit bureaus and address registries in order to supply accurate offers from financial service providers. We may use these databases in order to verify your identity data and perform credit and risk assessments. The Personal Data required depends on the services requested by you.
The Personal Data collected is necessary for the purposes explained here below.
The provision of Personal data is voluntary, however, if you do not provide Personal data we might be unable to fulfil these Processing purposes.
We are Processing your Personal Data
- to provide and offer you the loan intermediation service through our platform from different financial entities. This includes the verification of your data given in the application form and performing credit and risk checks and assessments on you in order to supply the best offer concerning the loan you applied;
- to obtain statistics and analysis of our services and market trends, anonymously;
- to respond to your inquiries;
- to send you commercial communications (direct marketing) related to our service and products and services from the financial sector that may be of interest to you, through any means, including e-mail or other equivalent electronic means;
- to protect our rights and legitimate interests;
- to comply with legal obligations attributable to us.
For the foregoing we may process the following Personal Data:
- identification data (e.g. name, surname, date of birth, personal ID number, nationality, politically exposure status);
- contact data (e.g. phone number, e-mail address);
- professional data (e.g. current and former employer and position, highest education);
- financial data (e.g. salary, income, assets, liabilities, properties, residence type, bank account information (IBAN), marital status, household type);
- communications data (e.g. e-mails, phone call recordings);
- Sortter`s website account log-in data;
- data related to the services by Sortter (e.g. performance of the application or the failure thereof, submitted applications, requests and complaints).
- co-applicant data (e.g. name, surname, date of birth, personal ID number, nationality).
The legal basis for Processing your data to provide access to your Sortter account and carry out the verification of your data given in the application from and performing credit and risk checks and assessments on you is the entering into and performance of the Contract with you, as well as Sortter`s legitimate interest to ensure you are trust- and creditworthy and if you represent a corporate client. This Processing makes us able to provide you with our loan intermediation service.
Your explicit freely given consent is required to carry out Processing of your Personal Data in order to use our loan intermediation service and to use your activity information in our platform, with the purpose of carrying out analysis and statistical studies anonymously.
Our legitimate interest, in dealing with your Personal Data for the purpose of protecting our legal rights and interests, including fraud prevention.
Your consent, when you submit your inquiry about our services.
Co-applicants’ information is processed on the basis of their consent.
Your consent is needed for us to be able to send you promotions and marketing materials about the financial services, products which are available via us.
When Processing is based on your consent, you can withdraw consent at any time by contacting us on the contact details below. Please note that withdrawing consent does not affect the lawfulness of Processing based on consent before its withdrawal.
We can contact you with direct marketing based on our legitimate interest to offer you our product and services if you are our existing customer or used recently our services. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Remember, you can opt out of direct marketing at any time by clicking the unsubscribe link at the end of each email.
The compliance with legal obligations, for example, in the area of prevention of money laundering and financing of terrorism.
The financial entities acting as credit providers for the purpose of providing the requested loan for you.
Pursuant to the provisions of Article 6.1 b) of the GDPR, you are informed that in order to provide the service, it is necessary for Sortter to communicate your Personal Data (forward your submitted application form in the practice) to the financing entity, who will use your Personal Data only and exclusively to manage the effective contracting of the requested loan including your personal identification and verification, as well as to process your Personal Data in order to assess your creditworthiness or credit (“scoring”), prior to contracting the loan.
The service providers, who act as data processors, processing your Personal Data on behalf of Sortter and having been contracted respecting the requirements of the GDPR.
Sortter uses the following categories of data processors: legal and other advisors, data storage providers, customer care, marketing and surveys service providers, e-mail and SMS gateway service providers, invoicing service providers, voice call dialler service providers.
We are also obliged to inform the designated authority of any event or operation with respect to which there is an indication or certainty that it is related to money laundering.
We only share your Personal Data with third parties if stipulated herein, if required under the applicable law (e.g. when Sortter is obligated to share Personal Data with the authorities) or with your consent.
We share your Personal Data with our auditors and with the regulator if this is applicable by the law. The legal basis for such sharing is the legal obligation of Sortter.
In some cases, we may also transfer personal data to our partners in so-called third countries (countries outside of the EEA). Such transfers can be made if any of the following conditions apply:
- the EU Commission has decided that there is an adequate level of protection in the country in question, or
- other appropriate safeguards have been taken, for example the use of the standard contractual clauses (EU model-clauses) approved by the EU Commission or the data processor has valid Binding Corporate Rules in place, or
- that there are exceptions in special situations, such as to fulfill a contract with you or your consent to the specific transfer.
Sortter uses profiling in loan intermediation service in order to decide whether the User’s application could be accepted fully or partially or rejected by the selected financial entity acting as credit provider.
The decision is made based on information received from you in the application form, information received from external sources, such as public and private registers and other third parties. No special categories of Personal Data (eg. data concerning health, genetic data) are processed, unless needed when you are applying specific products, such as insurances where such data is processed.
Profiling and automated decision-making are necessary to fulfil our Contract with regard our loan intermediation service.
Automated decision-making helps us to verify your identification data and to select potential bank and other financial services providers which loans are matching with your needs according to your application. Automated decision-making also helps us to reduce the potential for human error, discrimination and abuse of power, as well as enables to deliver decision-making within a shorter period, taking into account the volume of applications received by Sortter.
Because of the fact that the decision-making is automated, you might not be eligible for the applied loan.
Sortter also uses profiling in order to decide based on your financial soundness in using our services whether to offer services on its own initiative (by direct marketing). The legal basis of such Processing is the legitimate interest of Sortter to market its loan intermediation service. As a result, thereof, some Users may not receive such offers. However, such profiling does not produce any legal effects on you or otherwise significantly affect you.
The Personal Data provided by you will remain in the files of Sortter while you remain as a registered User of our platform. In the event that you exercise your right of withdrawal, we will block your Personal Data during the corresponding legal limitation period. Once the legal limitation periods have elapsed, we will destroy the User’s Personal Data.
Sortter retains your Personal Data in accordance with industry guidelines for as long as necessary for the purposes for which the data was collected, or for as long as necessary to safeguard our rights, or for as long as required by applicable legal acts. Please note that if the same Personal Data is Processed for several purposes, the Personal Data will be retained for the longest retention period applicable. The maximum period applicable is the limitation period for claims, which is up to 5 years from of the date of the closure of you user account.
To the extent required by applicable Data Protection Regulations, you have all the rights of a Data Subject as regards your Personal Data. This includes the right to:
- request access to your Personal Data;
- obtain a copy of your Personal Data;
- rectify inaccurate or incomplete Personal Data relating to you;
- erase your Personal Data;
- restrict the Processing of your Personal Data;
- portability of your Personal Data;
- object to Processing of your Personal Data which is based on your overriding legitimate interest and which is Processed for direct marketing purposes;
- obtain human intervention, to express the point of view and contest decision in the event of automated individual decision-making;
- should you believe that your rights have been violated, you have the right to lodge a complaint with:
- our data protection officer or;
- the Office of the Data Protection Ombudsman or;
- the courts should you believe that your rights have been violated.
In order to exercise your rights, please contact Sortter on the contact details below.
In case you have any question regarding the Processing of your Personal Data by Sortter or you would like to exercise your rights as a Data Subject, please contact us.
Sortter has appointed a data protection officer whom you also may contact regarding the same on the following contact details: firstname.lastname@example.org.