Privacy Policy

1 Purpose & Scope

This privacy policy (the “Privacy Policy”) explains how we will collect and use Your Personal Data. The Privacy Policy applies to our Business (as defined below), our website https://www.finloup.com and our web application https://app.finloup.com (collectively the “Website”) and to all Services offered by Finloup to You.

FINLOUP P.C. (“Finloup”, "we", "us", "our" or “Company”) is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

References to “You” or “Your” is to the user who wishes to avail of any service or product of the Company and/or any service or product of its clients (the “Services”) and from whom the Company and/or its clients shall collect and process the Personal Data required to provide the Services to You, as well as to previous and current customers of the Company.

2 Who we are

We are FINLOUP P.C. a private company registered in Greece with Tax No. 801397730, headquartered in 190 Leoforos Andrea Singrou, 2nd Floor, Athens, Greece, 17671 and trading as finloup.

We are the Controller of your personal data for the purposes of the applicable data protection legislation.

3 The basis on which we process your data

We process personal data in accordance with this policy on one of the following bases:

  • Where necessary for the performance of a contract with you or to take steps to enter into a contract, such as the administration of your account and/or to provide services to you.
  • For other purposes not covered above:
    • Where we have sought your consent and you have provided consent, on the basis of that consent; or
    • Where we have not sought your consent, on the basis of our legitimate interests and we have assessed that these are not overridden by your interests. These legitimate interests are:
      • Associated activities with the administration of our business such as finance and accounting, compliance with legal obligations of the company;

4 Why we collect information about you

We collect data about you for the following purposes (which are explained in more detail later in this policy):

  • To consume, analyse and aggregate your data based on your personal information and, where you have agreed, share such information with a particular client;
  • To provide you with a data analytics report on and monitoring your financial standing;
  • To better understand our customers and to provide our customers with better and personalised experiences with our company; and
  • To aggregate your personal information from other sources such as banks and financial institutions.

5 Information we may collect and process about you

We may collect and process the following data about you:

  • Information you give us.
    • you may give us information about you by filling in forms on our Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product (for example, loan amounts, currency, loan duration), apply for a product such as a loan on our Website, your activity levels on boards or other social media functions on the applicable social media sites, the applications you use on social media sites, and when you report a problem with our site.
    • the information you give us may include your name, address, e-mail address and phone number, login information for social networking sites, financial and credit card information, purchase transaction history and personal description
  • Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login Information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
    • anonymised repayment data.
  • Information we receive from other sources. We may receive information about the following information about you:
    • if you use any of the other websites we operate, the other services we provide and/or the social media sites which you login to via our site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, social media sites, advertising networks, analytics providers, search information providers, credit reference agencies, and financial services and credit providers) and may receive information about you from them;
    • you consent to your banks, financial institutions and other relevant parties to share personal data with us as part of our open banking solution. We rely on your consent as a lawful basis for processing. We use an application programming interface tool which comprises a set of definitions, communications protocols and tools, which allows us to use the information from third party sources for the purposes of analysing, aggregating and consuming data. To access the relevant information for the purpose of open banking we will be able to access your accounts using the same credentials as you usually use to access your accounts held with third parties. Once we obtain your personal information, we will handle it in accordance with this policy, however you should check each privacy policy of each provider to ensure that you are satisfied with the ways your personal information is handled by them before it is transferred to us as part of open banking. Your data will only be shared with the third parties that you consent to share it with, which means that you have more control over which websites and apps have access to your personal data. We will be able to access your personal information if you consent to it with your relevant banks and other financial institutions. At any time, you can opt-out of open banking and withdraw your consent with the relevant provider.

6 Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e- billing services.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our website. Except for essential cookies, all cookies will expire after a period appropriate to their use and no longer than six months after their use.

7 Uses made of the information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • to aggregate and analyse data based on your information and provide that rating to third parties selected by you or where you have agreed that we may share your analytics data with;
    • to establish a "Know Your Client" relationship;
    • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
    • to notify you about changes to our service;
    • to ensure that content from our site is presented in the most effective manner for you and for your computer;
  • Information we collect about you. We will use this information:
    • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our site to ensure that content is presented in the most effective manner for you and for your computer; or to allow you to participate in interactive features of our service, when you choose to do so;
    • as part of our efforts to keep our site safe and secure.
  • Information we receive from other sources (including social media sites).
    • We collect this information to provide data analytics services based on your information and provide the results to third parties selected by you or where you have agreed that we may share your data with;
    • We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
  • Restrictions on how we use your data We do not:
    • store your contacts;
    • store your SMS log data;
    • store your calendars, events and reminders data;
    • access any photographs on your device other than those taken in our mobile application or via third party mobile interfaces and we remove pictures from servers and store only the description of the photos.

8 Disclosure of your information

We may share your information with the following third parties:

  • our clients selected by you or where you have agreed that we may share your aggregated analytics data with a particular client. Sub-contractors we use for the performance of any contract we enter into with them or you for the services and activities described in this policy (and we ensure that appropriate safeguards are in place when selecting such subcontractors who may process your personal data).
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • We may disclose your personal information to third parties:
    • If FINLOUP P.C. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    • We use an agent to help us to provide open banking services; our agent is acting on our instructions and carries out the account information services on our behalf (as processor only). This means that the Agent does not control how it processes your account information held with third parties, accordingly. Where we share your personal data with our agent, we will ensure that they do not process your personal data for any other purpose, unless specifically stated otherwise elsewhere in this policy.
    • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of FINLOUP P.C., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

9 Where we store your personal data

The data that we collect from you is stored within the European Economic Area. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

10 The Period We Store Your Personal Data

We store your personal data for the following periods:

  • Category of Personal Data - Storage Period
    • Contact details and details contained on your registration form - For the period you are using the site
    • Information received from other third-party sources - For the period you are using the site
    • Technical information about your visit to our website - For the period you are using the site
    • Cookies - Persistent

11 Your right

You have the following rights:

  • The right to object to your data being used for marketing purposes;
  • The right to request access to the personal data that we hold about you;
  • The right to request rectification of the personal data that we hold about you;
  • The right to request erasure of the personal data that we hold about you;
  • The right to request restriction of processing about you;
  • The right to object to processing; and
  • The right to data portability.

If you wish to invoke any of the above rights, please notify us using the contact details set out in Section 15below. Where our processing of personal data is based on your having given consent, you have the right to withdraw that consent at any time. If you wish to invoke this right, please notify us using the contact details set out in Section 15 below. You have the right to lodge a complaint with a supervisory authority. In Greece, the supervisory authority is the Hellenic Data Protection Authority, full contact details for which can be found at https://www.dpa.gr/portal/page?_pageid=33,15510&_dad=portal&_schema=PORTAL

12 Your Preferences

You have the following choices available to you with respect to how we process your personal data:

  • You can opt out of receiving any marketing communications by clicking the unsubscribe link in our emails to you, by changing the privacy settings in your profile via the email address below.

13 Third party websites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link from or to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

14 Changes to this policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

15 Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to 190 Leoforos Andrea Singrou, 2nd Floor, Athens, Greece, 17671 and email dpo@finloup.com.

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