If you have any questions regarding this policy, or if you wish to receive additional information on how to exercise the rights specified herein, you can contact LendSecured team by writing an email to firstname.lastname@example.org. Additional contact information is available in the Portal.
This policy is applicable to every User who uses, has used, has expressed interested in using, or is in any other way related to services provided by LendSecured, including clients that have registered before this policy has come into force.
- Processing of data – any type of activity or a set of activities performed with personal data automatically or manually. For example, collection, registration, organization, structuring, storage, adaptation or modification, recovering, viewing, using, disclosing, transmitting, distributing or otherwise making them available, matching or combining, limiting, erasing or destroying.
- LendSecured – “Secured Finance MGMT”, registration number 50103266451, address: Bukultu Street 11, Riga, LV-1005, under domain www.lendsecured.eu, e-mail address – email@example.com.
- User – any natural person, that has used or has expressed the intent of using any of the services provided by LendSecured or in any other way connected to LendSecured.
- Personal data – any information relating to an identified or identifiable natural person (data subject); identifiable natural person is one which can be directly or indirectly identified in particular by referring to an identifier, such as the name, surname, identification number, location data, online identifier or one or more physical, physiological, genetic, mental, economic, cultural or social identity.
- Lemon Way - Lemon Way, legal entity code: 500486915, address: 8, rue du Sentier - 75002 Paris, France, approved as a payment institution by the French Prudential Supervisory and Resolution Authority (ACPR) on December 24 2012.
Who will process my personal data?
The processor of your personal data is LendSecured.
General principles of data processing
LendSecured will ensure the confidentiality of personal data within the framework of applicable laws and enforce appropriate measures to protect your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, alteration or destruction.
You expressly authorize LendSecured to collect, transfer, use and process your information in Latvia and any other country in which LendSecured or its vendors operate. With giving this consent, you understand that the laws on storing, processing, using and transferring personal information in Latvia may be less protective of your privacy than the laws of your state or country.
Why do you collect my personal data?
LendSecured uses the information about the User for the following purposes:
- Providing Services to the User
Upon registration with the Portal, personal data of the User is used to create the Account to be used as a means to receive the Services. In order to provide Services, the User’s Data, Contact Information and Transaction Data is used. This data is necessary to verify the User’s identity, to ensure cash deposits and withdraws, send daily summaries and notices about deposits etc.
- Verifying the identification of the User
In order to identify the User, the User’s data, contact information, transaction data and communication data is used. Additionally, such data as the date of conclusion is processed as well. This data is necessary to verify the User’s identity, communicate with the User regarding the fulfilment of the Terms and conditions, as well as of the loan agreements concluded by the User.
- Creating and maintaining the User’s Account
In order to create and maintain the User’s Account, the User’s Data, Contact Information, Transaction Data and Communication data is used. Additionally, such data as the User’s password is processed as well, however, LendSecured, nor our cooperation partners have access to the User’s password.
This data is necessary to provide log in options in the Portal, to communicate with the User in case of any inquiries, to conduct surveys and to ensure a means by which the User can receive the Services. The personal data processing is based on the conclusion and fulfilment of the Agreement and compliance with such legitimate interests of LendSecured as maintenance of the Account, improvement of the Service quality, informing the User about the activity in the Account and protection of its rights and interests in case of a dispute.
- Sending registration reminders
In order to provide Services, LendSecured can send registration reminders to Users, who have not completed the registration process via e-mail.
- Enforcement of statutory obligations
In order to fulfil the statutory obligations in the fields of accountancy and anti-money laundering and terrorist financing prevention, LendSecured processes the User’s Data, Due diligence data, Communication Data, Contact Information and information specified by the User in the User’s questionnaire in accordance with the provisions of the laws and regulations of the Latvia.
- Due diligence
As per the applicable laws and regulations LendSecured performs the due diligence of the User, which includes, but is not limited to, to identifying the User and verification of the User’s identity document and processing the Due diligence data.
- Sending of informational materials
Upon applying for receipt of informational materials the User agrees that User’s Data, Contact Information, and certain Transaction Data (funds invested and incoming payments) is used to prepare an appropriate commercial communication for the User.
- Service quality control
On the basis of the legitimate interest of LendSecured to improve the quality of the Services, LendSecured within the aim to evaluate and control the quality of the Services, processes at least the Communication Data when communicating with the User.
- Compilation of statistical data
On the basis of the legitimate interest of LendSecured to compile statistical data regarding the Services used by the Users, to improve the Service quality and to develop Services, LendSecured, with the aim to analyse information related to the provision of the Services, processes summarised information regarding the User’s Data, Contact Information and Transaction Data.
What kind of data LendSecured collects?
LendSecured processes the following categories of User’s personal data:
- User’s Data, including, but not limited to, the User’s full name, gender, date of birth, personal identity number, investor’s ID number, copy of an identity document, User’s bank account number, position grade, area of work, preferred language;
- Due diligence data, including, but not limited to, origin of funds, information on the purpose and intended nature of the business relationship, information gained from risk assessment-based activities, information on User’s income, experience on financial investing;
- Contact Information, including the User’s address, country of residence, e-mail address and phone number;
- Transaction Data, including, but not limited to, the User’s invested funds, investments, transactions, incoming payments, information regarding the concluded loan agreements, selected currency, available funds;
- Communication Data, including the User’s communication with LendSecured through the Portal via chat, via email and/or by phone.
Amongst other, LendSecured may collect information and record details of your visits and interactions and the way you use LendSecured, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise, and the resources that you access. On a non-obligatory basis LendSecured may collect other information which from time to time may be relevant to the effective provision of our services.
LendSecured may collect information about any device you may use to access the services, including, where available, the device's or computer's unique device identifiers, operating system, browser type and mobile network information as well as the device's telephone number, for system administration and to report aggregate information to our advertisers. LendSecured may associate Device information with Registration Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
When you use the services or view the content on LendSecured, LendSecured may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, internet service provider (ISP), clickstream data, language, viewed and exit pages and date or time stamps and cookie information.
Where does LendSecured store my personal data?
The data that LendSecured collects from you will be transferred to and stored at a destination inside the EEA. All information you provide to LendSecued is stored securely on our servers or servers of our partners. The information is encrypted.
You are responsible for keeping your chosen password confidential. LendSecured asks you not to share a password with anyone.
The transmission of information via the internet is not completely secure. Although LendSecured will do its best to protect your personal data, LendSecured cannot guarantee the security of your data transmitted. Once receiving your information, LendSecured will use strict procedures and security features to try to prevent unauthorized access.
The access to your personal information within LendSecured is limited to those employees who have a good business reason to access or know this information.
Will LendSecured disclose my information to third parties?
LendSecured will never disclose your personal information to any third parties without your consent. Companies belonging to LendSecured (parent, subsidiaries, affiliates) are not considered to be third parties.
However, please note that LendSecured may disclose your personal information without your consent to third parties in the following specific cases:
· to any person related to the fulfilment of commitments arising to LendSecured from the Terms and conditions (including to communications service providers, payment intermediaries, credit institutions, IT service providers, etc.);
· to outsourced service providers that LendSecured has engaged in the provision of services arising from the Terms and conditions, insofar as such information is necessary for the performance of functions delegated to them;
· to personal data processors, the supervisor whereof is LendSecured, insofar as such information is necessary for the performance of functions delegated to them;
· upon handing over (transferring) a Claim to third parties;
· to a third party, who is taking debt collection steps to recover debt from the User (such as debt collectors, lawyers, court bailiffs, insolvency administrators, etc.);
· to LendSecured legal, accounting, or auditing service providers, ensuring that the said persons have undertaken not to divulge such information.
In the cases specified by law, LendSecured is obligated to disclose the User’s personal data to state authorities. LendSecured does not disclose any personal data to state authorities or third parties without a legal basis.
What are cookies and does LendSecured use them?
A cookie is a small piece of data sent from a website and stored on the client's computer by the client's web browser while the client is browsing.
Our services use cookie technology to distinguish you from other clients. This helps us to provide you with a good experience when you use our website and also allows us to improve.
LendSecured may use different types of cookies to better understand how you interact with our services, to monitor aggregate usage by our clients and web traffic routing on our services, and to customize and improve our services.
In case you would like to change your browser’s cookie preferences, you can change the browser’s settings. However, some services may not function properly if you disable cookies.
User’s rights related to personal information
Below is a summary of User’s specific rights.
· Right of access
The User is entitled to receive information on whether or not LendSecured processes the User’s personal data, and, if LendSecured processes said personal data, request a copy of the User’s personal data undergoing processing.
The User has the right to obtain the following information:
- purposes of the processing;
- categories of personal data being processed;
- personal data recipients or categories of such recipients;
- length of time the data will be stored (or criteria for determining the period);
- User’s rights in connection to the data processing;
- available information on the data source (if the personal data was not obtained from the User);
- Existence of automated decision-making.
· Right to rectification, to the extent possible
The User is entitled to request LendSecured to rectify the User’s inaccurate or incorrect personal data.
· Right to erasure, to the extent possible
The User is entitled to request LendSecured to erase the User’s data. This right can be exercised if at least one of the following grounds applies:
- purposes of the processing have been reached;
- personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- User withdraws the given consent;
- User objects to the processing;
- personal data has been unlawfully processed;
- Personal data has to be erased for compliance with a legal obligation.
LendSecured reserves the right to reject the request to erase the User’s personal data if there is a legitimate legal ground for doing so, for example, to comply with a legal obligation which requires processing, to establish, exercise or defend legal claims, or for statistical purposes, providing appropriate technical and organisational security measures.
· Right to the restriction of processing
The User is entitled to request LendSecured to restrict processing if one of the following grounds applies:
- User contests the accuracy of the personal data, for a period that enables LendSecured to verify the accuracy of the personal data;
- processing is unlawful, and the User requests restriction opposed to the erasure of the personal data;
- LendSecured no longer needs the User’s personal data, but the personal data is necessary for the User to establish, exercise or defend legal claims;
- User has objected to processing pending the verification whether the legitimate grounds for processing of LendSecured override those of the User.
Upon restricting the processing of the User’s personal data, LendSecured will only process the User’s personal data after receiving consent from the User, or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. This does not apply to storing personal data.
· Right to object to the processing of personal data
The User is entitled to object to the personal data processing activities concerning direct marketing or which are based on LendSecured legitimate interests but given the basis of the User’s particular situation they want to object to processing on this ground.
· Right to data portability, to the extent possible
The User is entitled to request LendSecured to receive and transfer the User’s personal data to the User or another data controller. The User can exercise this right insofar as the data has been provided by the User based on consent or a contract and the processing is carried out by automated means.
· Right to withdraw consent
The User is entitled to withdraw previously given consent at any time via the Account. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. This right applies to receiving commercial notices from LendSecured.
· Right to submit a complaint to the national personal data protection authority
In case of any uncertainty related to your personal data, you are welcome to contact LendSecured and we will seek to provide you with an answer or find a solution to your issue. However, if you believe we cannot find the solution, the User is entitled to submit a complaint to the national personal data protection authority regarding data processing activities conducted by LendSecured.
The contact information of the national personal data protection authority of the Republic of Latvia:
Data State Inspectorate of Latvia
Blaumana Street 11/13-11, Riga, LV-1011, Latvia
telephone: +371 67 22 31 31
Changes to this policy
Should the User wish to exercise any of the information listed above, the User can do so by submitting a request in one of the following ways:
· by sending an electronic request to – firstname.lastname@example.org;
· by sending a signed request to - Bukultu Street 11, Riga, LV-1005.
The User has the right to access the personal data free of charge. However, if the User’s requests are manifestly unfounded or excessive, LendSecured retains the right to charge a reasonable fee or to refuse to act on the request.
Effective as of 01.07.2020.