The following definitions are used in this document:
AISP: the licensed Account Information Service Provider employed by Finloup to retrieve and collect your banking data, subject to your prior consent.
Instalment Plan: the instalment plan agreement entered into between the Merchant and you that has been facilitated by our Platform.
Instalment(s): all subsequent individual instalments repaid to the Merchant by you as part of the Instalment Plan.
Merchant: any legal person selling goods or services to you through its e-shop using our Platform as a payment option.
Platform or Finloup’s Platform: means app.finloup.com.
Suggested Instalment Plan: the personalized instalment plan suggestion that has been derived by our Platform’s analysis and proposed to you.
Transaction: each individual sale of goods and services conducted through the Platform and with an Instalment Plan between the Merchant and you.
1. A few words about Finloup’s Platform
Finloup develops and distributes the Platform, allowing Merchants and its customers the possibility of deferring payments, via Ιnstalments, by proceeding on behalf of the Merchant to the assessment of the eligibility of its customers and by facilitating the conclusion of an Instalment Plan entered into between the Merchant and its customer.
2. What is Personal Data?
‘Personal Data’ means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. What is processing of Personal Data?
‘Processing of Personal Data’ means 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. Is it mandatory to provide your Personal Data?
5. What Personal Data do we collect from you?
We collect only the absolutely necessary Personal Data, which are appropriate and clear for the intended purpose. This Personal Data includes the following:
-Full name (first name, last name, father’s name)
-Mobile phone number
-Date of birth
-Delivery method (carrier used)
-Banking data, specifically information related to your bank products (accounts and cards), such as IBAN, masked card number (i.e. only the last 4 digits), type of account, product holder name, balances, transaction history, ID number of holder.
-Content of your shopping cart
-Your purchase history with the Merchant
-User traffic source (e.g. referrals, organic search), where our user come from
-Page locations in company’s properties (e.g. app.finloup.com/bank_review)
-Visiting device information (mobile, desktop, operating system, device type/brand, device screen size, browser type and version)
6. How we collect and process your Personal Data?
a) Merchant provides us with certain information regarding your personal details (i.e. name, surname, full address for billing and shipping the product, mobile phone number, e-mail address, information on whether you are a registered user with the Merchant or a guest buyer) and purchase-specific data (i.e. products in basket, value per product, shipping costs).
b) We employ an AISP in order to retrieve and collect the information arising from your banking data (see clause 5 above). The banking data we will be able to retrieve via our AISP partner is subject to your prior authorization during our Platform’s procedure for the assessment of your eligibility to conduct a Transaction with an Instalment Plan. If you do not authorize access to your banking data we will not be able to conclude the eligibility assessment and we will not be able to offer you a Suggested Instalment Plan.
c) During our Platform’s procedure for the assessment of your eligibility, you may be asked to complete a short questionnaire.
d) During form submission by you on our contact forms.
e) Through web traffic analytics mechanisms.
7. Why we collect and process your Personal Data?
a) To proceed with the assessment of your eligibility to conduct a Transaction with an Instalment Plan.
b) For our Platform to analyze your Personal Data provided and conclude an outcome on whether you are eligible for a Transaction with an Instalment Plan and, in a positive answer, under what terms.
c) To display to you the Suggested Instalment Plan.
d) To facilitate the Instalment Plan entered into between you and the Merchant and the payment of the first (1st) Instalment at the day of your purchase via debit or credit card, using the services of our partner payments servicer.
e) To allow our partner payments servicer store your payment card so as to automatically retrieve the upcoming Instalments or to offer you the ability to pay the Instalments via direct debit, using the services of our partner payments servicer.
f) To send you notifications via – among others - email, SMS, mail or call your mobile phone on behalf of the Merchant.
g) To provide Merchants with information regarding the status of your Instalment Plan;
h) To comply with our contractual or legal obligations to exchange Personal Data with law enforcement.
j) For research purposes, promotional purposes, sending of newsletters.
k) Sending newsletters/offers: With your consent, we will use your Personal Data, preferences and transaction details to inform you via e-mail, internet, telephone and /or social media about related products and services, including personalized offers, discounts, etc. Of course, you have the option to revoke this consent at any time.
l) To respond to your inquires or contact you regarding new partnership opportunities that you have shown interest.
8. Who are the recipients of your Data - How is your Data communicated?
Only the absolutely necessary staff of the Finloup and the staff of the Merchant has access to your Personal Data.
9. Personal Data Disclosure to third parties
We may transfer your personal data to third parties such as, for example, sub-contractors (including our IT support service provider), other counsel and accountants, as well as third parties involved in your matters. We ensure that sharing your Personal Data with third parties is done in accordance with applicable legislation concerning data protection, and we ensure where applicable that third parties adopt all appropriate safeguards to protect your personal data.
10. We strive to ensure your Personal Data is secure
We understand the importance of protecting your privacy and we will ensure your Personal Data is safeguarded and held securely in accordance with our obligations under the applicable legislation. Appropriate technical and organizational measures have been implemented to ensure personal information is protected and to prevent your Personal Data from being lost, used, accessed in an unauthorized way, altered or disclosed. We also limit access to your personal information to those employees, contractors and other third parties who have a business need to know. This access will be granted on a confidential basis and processing of the information will only take place subject to our instructions.
We also share your Personal Data with third party service providers, that process your Personal Data as Data Processors on our behalf and in accordance with our orders.
Finloup shares your Personal Data with third party service providers that process personal data on behalf of the Finloup, for example (indicatively mentioned) for debit card processing and payments, email distribution, research and analysis. When we use third party service providers we enter into agreements that oblige them to implement appropriate technical and organizational measures to protect your Personal Data. We may also share your Personal Data to other third parties, subject to your prior consent.
11. How do we ensure that the Data Processors respect your Personal Data?
-We provide only the information needed to perform their specific services.
-They may use your Personal Data only for the exact purposes set forth in our agreement with them.
-We work closely with them to ensure that your privacy is respected and protected at all times.
-If we stop using their services, any of the Personal Data they hold will be deleted or made anonymous.
-The Data Processors have agreed contractually with Finloup:
to ensure confidentiality,
to not send your Personal Data to third parties without the permission of Finloup,
to take appropriate security measures,
to comply with the legal framework for the protection of Personal Data and in particular Regulation 679/2016 /EU.
12. How long do we keep your Data?
13. Your rights:
a) Access your information.
You are entitled to request access to the information we hold about you (known as a ‘data subject access request’). You are entitled to receive a copy of the personal information we hold about you and to check that it is being lawfully processed.
b) Correct your information.
If the information we hold for you is incomplete or incorrect, you have the right to request a correction.
c) Request erasure.
Where there are no reasons for continuing the processing of your personal information, you are able to request the removal or deletion of the personal information.
d) Object to processing.
Where the firm relies on legitimate interest for the processing of your personal information, or for the purposes of direct marketing, you have the right to object to the processing.
e) Request the restriction of processing.
You are entitled to request for a suspension for the processing of your personal information, for example, if you are awaiting the reasons for the processing of the information or require us to establish its accuracy.
f) Right to data portability.
You are able to request the transfer of your personal information to another service provider.
If you wish to exercise any of the aforementioned rights, you can contact us at: firstname.lastname@example.org.
Finally, you can also lodge a complaint about the processing of your personal data with the Hellenic Authority for the Protection of Personal Data.
14. Cookies Policy
What is a Cookie? "Cookies" are small text files, which are stored in the browser of the user when visiting a website, app or platform. The information stored on the user's computer may contain information such as which pages the user has visited, the date and time of the visit as well as a random and unique user ID. Cookies do not contain personal information or information, which will allow anyone to communicate with the visitor of the website, app or platform, by phone, e-mail, etc. In addition, using Cookies does not access your computer documents or files.
In addition, Cookies help us test the performance and traffic of our Platform, improving its presentation and content, according to the preferences of our visitors.
Cookies can be classified as follows, depending on the purpose:
How can I manage my Cookies?
-Internet Explorer //support.microsoft.com/kb/278835
-Safari for iPad and iPhone //support.apple.com/kb/HT1677
15. What is the applicable law during the processing of your Data by us?
Applicable law is the Greek Law, as formulated according to the General Regulation for the Protection of Personal Data 2016/679/EU, and in general the current national and European legislative and regulatory framework for the protection of personal data.
The competent courts for any emerging disputes related to your Data are the Courts of Athens.
16. Which is the competent authority for submitting a complaint?
You have the right to submit a complaint to the Hellenic Authority for the Protection of Personal Data (postal address 1-3 Kifissias, PC 115 23, Athens, tel. 210. 6475600, e-mail address email@example.com), if you consider that the processing of your Personal Data violates the applicable national and regulatory framework law for the protection of personal data.
17. Questions and Comments?