INTRODUCTION
At Fininity we value your privacy and are committed to protecting and processing your personal data responsibly.
This Privacy notice defines our basic principles and terms for personal data processing, as well as the measures we have taken to ensure the security of personal data.
This Privacy notice extends to our website https://crezu.my/, as well as our marketing communications related to the promotion of our services.
CONTROLLER`S CONTACT DETAILS
Fininity OÜ (hereinafter referred to as the “Fininity” or “We”) is the controller for the personal data we process, unless otherwise stated.
There are many ways you can contact us, including by email, post.
Our postal address:
3 Paadi tee, Haabneeme, 74001, Estonia
E-mail: compliance@crezu.my
WHAT DATA, FOR WHAT PURPOSES, ON WHAT GROUNDS AND FOR HOW LONG DO WE PROCESS?
We operate in the capacity of the Controller of your personal data. This implies that we autonomously define the processing purposes and select relevant processing services and tools.
DATA SUBJECT | PURPOSE | PERSONAL DATA UTILIZED | SOURCES OF OBTAINING PERSONAL DATA | LEGAL BASIS |
|---|---|---|---|---|
Customer | To confirm of the subject's age of majority (Service of preliminary application for a loan to credit institutions) | Date and year of birth; | Directly from You | Contract |
Customer | To provide services for preparing a loan application and submitting it to partner lending institutions for decision-making on approval or denial of the loan (Service of preliminary application for a loan to credit institutions) | Personal Identification Details: • Name, Surname; • Date and Year of Birth; • ID Number; • ID Number Issue Date; • ID Number Due Date; Contact Information: • Email; • Phone Number; • Zip Code; • State; • City; • Street; • House; • Apartment Number; Financial Information: • Information about the amount and purpose of the loan; • Income Amount; • Source of Income; • Monthly Expenses; • Housing Monthly Payment; • Household Income; • Household Spendings; • Bank Account Number; Employment Information: • Employment Position; • Employer Name; • Employer Industry; • Work Start Date; Personal and Family Details: • Gender; • Marital Status; • Dependents; • Living Status; • Housing Start Date; Education: • Education Details; Other Financial Obligations: • Information about other loans; • Other Loans Amount; | Directly from You or from third party: partners- affiliate companies (when you use third party loan application services) | Contract |
Information about the rejection or preliminary approval of a loan | From third party: partners-credit institutions, credit brokers | |||
Customer | To compare and present to the Customer of the credit offers obtained for them (Service of preliminary application for a loan to credit institutions) | Information about the rejection or preliminary approval of a loan | From third party: partners-credit institutions, credit brokers | Contract |
Customer | To redirect the Customer to the credit institution for further processing of their selected loan (Service of preliminary application for a loan to credit institutions) | Information about the partner's website to which the Customer/User is redirected; | Generated when You interact with our website | Contract |
Information about the rejection or preliminary approval of a loan | From third party: partners-credit institutions | |||
Customer User | Promotion of partner credit offers through the offer showcase (Service of showcase of preliminary credit offers) | Click ID; Information about the partner's website to which the Customer/User is redirected | Generated when You interact with our website | The legitimate interest for maintaining or developing partnerships that provide business stability and additional value for users |
Customer | To notify about the progress of the provided service via email, SMS (Service of preliminary application for a loan to credit institutions) | Email; Phone number; | Directly from You | Legitimate interest in improving the quality of services provided and in more promptly conclusion and execution a contract with the customer |
Customer | To process Customer support request | Name, Surname; Email; Phone number; Other details that you specify at your discretion or that the support team requests at its discretion | Directly from You | Contract |
Customer | To provide feedback from Customer | Name, Surname; Email; Phone number; Customer’s feedback | Directly from You | Legitimate interest in receiving feedback and improving our service based on that feedback |
Customer User | To handle and boost client experience by enhancing our understanding of our clients | Customer ID; AB test keys | Generated when You interact with our website | Legitimate interest to enhance the quality of our products and solutions |
Events information; IP address; Device ID, device type and model, mobile operating system | Received from your browser; | |||
Information about the partner's website to which the Customer/User is redirected; | Generated when you interact with our website | |||
Information about the partner’s website from which the Client/User was redirected; Information about credit offers received through the Service | Received from third parties: partners-credit institutions, credit brokers, partners- affiliate companies | |||
Customer User | To promote of goods and services through marketing activities via email, push notifications, sms | Email; Phone number | Directly from the you | Consent |
Push token | Received from your browser; | |||
Customer User | To ensure security and prevent fraudulent activities. | IP address; Device ID, device type and model, mobile operating system | Received from your browser; | Legitimate interest in ensuring the security of our systems |
Customer User | To protect our legitimate rights and the rights of third parties, to resolve disputes and legal claims | Data provided by you as part of the legal claim | Directly from the you | Legitimate interest in protecting our rights, resolving disputes |
If you do not provide personal data, the basis for the processing of which is a contract, we will not be able to provide you with the service (service of preliminary application for a loan to credit institutions) in accordance with the Terms of Use.
Why do we need a certain set of personal data? We receive from our partners (credit institutions and credit brokers) a set of necessary categories of personal data that they need to make an appropriate decision on issuing a loan. We need such a set of personal data to send them to partners - credit institutions, credit brokers, and receive from them a decision on approving or refusing a loan.
WHAT ARE THE RETENTION PERIODS FOR PERSONAL DATA?
We process your personal data until the purpose of the processing has been achieved.
AUTOMATED DECISIONS
We neither use automated decision-making nor your personal data to automatically assess aspects of your personality (automated profiling).
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
When we transfer personal data to third parties, we make sure that they have sufficient guarantees to implement the appropriate technical and organizational measures. We transfer personal data to third parties with whom we have concluded the appropriate types of contracts with the required obligations regarding the protection of personal data at the level defined by us.
When we need to transfer personal data to a third country, we transfer the data to third country which ensures an adequate level of protection.
We monitor compliance with the principles of personal data processing and application of the appropriate security measures by third parties. We control that cross-border transfer of personal data is limited by the purposes for which the data was collected.
Information about the categories of companies to which data is transferred is provided below.
Data subjects | Purpose of Transfer | The role of the third party | The basis of interaction with a third party |
|---|---|---|---|
Customer | to send marketing mailings | Processor | Contract that includes security measures |
Data subjects | Purpose of Transfer | The role of the third party | The basis of interaction with a third party |
|---|---|---|---|
Customer, User | to operate the website | Processor | Contract that includes security measures |
Data subjects | Purpose of Transfer | The role of the third party | The basis of interaction with a third party |
|---|---|---|---|
Customer, User | Cookie analytics for the Company’s purposes | Processor | Contract that includes security measures |
Data subjects | Purpose of Transfer | The role of the third party | The basis of interaction with a third party |
|---|---|---|---|
Customer | Providing credit offers to the client | Controller | Contract that includes security measures |
YOUR RIGHTS
- Access
You have the right to obtain from us the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been disclosed;
- the envisaged period for which the personal data will be stored or the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling;
- the appropriate safeguards pursuant relating to the cross-border transfer.
- Correct (right to rectification)
You have the right to correct inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Erase (`right to be forgotten`)
You have the right to obtain from us the erasure of personal data concerning you without undue delay.
- Restrict
You have the right to restrict processing your personal data.
- Data portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided where technically feasible.
- Objection
You have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on following legal basis: legitimate interest, public interest.
The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
- Withdraw Consent
If we process your data based on your consent, you have the right to withdraw your consent at any time. If you would like to exercise your right to withdraw your consent, please contact us.
- Complaint
You have the right to file a complaint with a supervisory authority.
To exercise any of these rights or in case some questions about the protection of your personal data remain, you can contact us at compliance@crezu.my.
You can opt out of our marketing communications at any time by sending us a message at compliance@crezu.my.
HOW IS THIS DOCUMENT MODIFIED?
In the event of substantial changes to this Privacy Notice, we may use any available means (push notifications, SMS, or email) to notify you.
This would be the case, for example, if we add new categories of personal data to be processed or new purposes for which data are processed. You will be notified before such changes take effect.
