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DATA PROTECTION

General Information on the Protection of Personal Data


Further to the provisions of EU Regulation 2016/679 of the European Parliament from 27 April 2016 concerning protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR) and repealing Directive 95/46 / EC,


MARFIN LEASING IFN (ROMANIA) S.A., with headquarters in Bucharest, Emanoil Porumbaru 90-92 street, floors 1-2, District 1, with unique registration code 15991165, the fiscal attribute RO, registered with the Trade Register Office near the Bucharest Court under no. J40 / 17042 / 12.12.2003,

as an operator, we detail hereon the situations in which we process your personal data, the way we use it, the way we can use it, the conditions we can divulge to others, and how we store them safely.


If you have any questions regarding the way we process your personal data, you can contact us by post to the registered address indicated above, by email at: dpo@marfinleasing.ro or by phone: +40 21 405 0500.

  1. What personal data are processed?


We process the following types of data:

•           Identification details such as your name, identification number, date of birth, KYC documentation (including a copy of your national identity card or passport) and contact details;
•           financial information, including payment and transaction records and information about your assets, and tax information;
•           details of our interactions with you and the products and services you are using;
•           when you access our Site, the data transmitted by your browser and automatically recorded by our server including the date and time of the access, the name of the file you access, as well as the data volume and access performance, your web browser, the language you browser is using, domain and IP address (additional data will only be logged through our site if the disclosure is voluntary, for example, during a registration or request);

and

•           In some cases, depending on the product or service we provide you, sensitive personal data such as political opinions or affiliations, information on health, race or ethnic origin, religious or philosophical beliefs and, as far as possible legally, the offenses committed or allegedly committed.
•           if it is relevant to the products and services we offer, we can also collect information about business partners (including other stakeholders or actual beneficiaries), representatives and agents

Before making this information available to MARFIN LEASING IFN (Romania) S.A., please inform the respective persons about the manner and purposes in which we process their data.

We will interact with you under the consideration that that you are authorized to disclose all data you provide to us.

        2.    Why do we need this information?

We need the personal data you provide for:

•           registering with our customer data base and providing you with products and services;
•           managing our relationship with you and providing information about the products and services you receive from us and our business partners;
•           helping us learn more about you as a customer, about the products and services you receive, and about other products and services that you might be interested in receiving;
•           contacting you for direct marketing purposes about the products and services we consider to be of interest to you, including those offered by us and other business partners, as well as facilitating promotional contests and promotions, if we have your agreement in this scope;
•           fulfilling legal obligations which we are tasked;
•           ensuring the safety of our customers and employees, as well as other parties;
•           performing transactional analysis;
•           ensuring operational management (including risk management, insurance, audit, training on similar systems and products and administrative purposes);
•           for other purposes which will be made periodically known to you.

In addition, processing of personal data can take place in order to fulfil our legitimate interests, such as:

•           preventing, detecting and investigating offenses, including fraud, money laundering and terrorist financing, and analysing and managing commercial risks;
•           In connection with any claims, demands or actions in court (including but not limited to writing and reviewing documents, drafting agreements, obtaining consultancy and dispute resolution) and / or protecting and enforcing our contractual rights and obligations;
•           addressing responses to authorities (including, but not limited to, research and regulatory authorities) and responses to regulatory and auditing authorities;
•           Inner reporting, feedback request and survey participation, and research and statistical analysis or to establish and improve our services and products to understand customer behaviour, market preferences and trends.

 

  1. What do we do with your personal data?

We may provide your information to third parties, including:

•           third parties acting on your behalf or otherwise involved in a transaction with you, including: a party acquiring a benefit or taking a risk in relation to or in connection with the transaction; payment recipients, intermediaries, correspondent banks and agencies; specialized companies or payment institutions; other financial institutions, any third-party fund manager who provides you with asset management services; and any broker acting as a sales or customer service representative, to whom we offer presentations or recommendations;
•           third parties providing services, and other suppliers, namely IT and hosting services, marketing providers, communication services and print service providers, debt collection, tracking, debt recovery, fraud prevention, and when doing so, we take steps to make sure that it complies with our data security standards so your personal data remains safe);
•           third parties, including prospective buyers who receive information in the context of the proposed sale or proposed sale of our business or a reorganization (and when we do so, we take steps to ensure that such potential buyers keep the data secured);
•           from time to time, public authorities, regulatory authorities or governmental bodies, including where this is required by law or regulation, or when such authorities or bodies so request;
•           our affiliates or third parties to whom the disclosure of personal data is necessary for the fulfilment of our contractual obligations or for the fulfilment of our legitimate interests.

 

  1. What is the legal basis for processing your personal data?

MARFIN LEASING IFN (Romania) SA processes your personal data only with your consent unless it is necessary to fulfill our contractual obligation to provide you with the services you have purchased or intend to purchase or if we have a legal obligation or legitimate interest.

 

  1. Automated decision process (including profiling)

MARFIN LEASING IFN (Romania) S.A uses automated processing, including profile creation, to determine your eligibility and solvency.

MARFIN LEASING IFN (Romania) S.A will process your personal data as received from you or obtained from other sources to assess your solvency and eligibility through automatic processing. Before we offer our services and products, we need to make sure you can benefit from these financial services, so that automatic processing helps us make a legal and fair decision.

Any automatic processing, including the creation of profiles, carried out by us, will be done in compliance with the applicable legal provisions. Such processing of your personal data will only occur if:

•           It is required for the conclusion and execution of the financing agreement concluded with you;
•           It is applicable according to the specific law under which we operate;
•           It is based on your consent.

You have the right to receive information about the algorithm of automatic processing, as well as its consequences and legal effects. At your express request, the assessment of your eligibility and solvency will be done with human intervention, in addition to the automated process.

6.    How long do we keep your personal data?

MARFIN LEASING IFN (Romania) SA processes the personal data for the entire period necessary to achieve the purposes for which it was collected, unless there is a legal requirement to keep them in the longer term or there is a justification of a legitimate interest.

7.    Are your data safe at MARFIN LEASING IFN (Romania) S.A?

We have adequate technical and organizational measures to prevent unauthorized or unlawful access to personal data that you have provided us with. Because full data security for emails, instant messaging and similar media cannot be guaranteed, we recommend that you send any particularly confidential information by a secure means.

8.    What are your rights?


As a person you are interested in, you can contact our Data Protection Officer (DPO) at any time, through a written request, using the contact details listed below to exercise your rights under the HG PR. These rights are:

•           The right to receive information regarding the data processed and to receive a copy of the processed data (right of access, Article 15 GDPR).
•           The right to request rectification of inaccurate or incomplete data (Right to rectification, Article 16 GDPR).

•           The right to request the deletion of personal data and, if the personal data has been made public, information on the removal request (Right to erasure ‘right to be forgotten’, Article 17 GDPR).
•           Right to request restriction of data processing (Right to restriction of processing, Article 18 GDPR).
•           The right to receive personal data about the data subject in a structured, commonly used, computer-readable format, and request the transmission of this data to another operator (Right to data portability, Article 20 GDPR).
•           The right to oppose data processing (Right to object and automated individual decision-making, Article 21 GDPR),
•           The right to withdraw at any time a given consent in order to stop processing of personal data based on your consent. Withdrawal of consent will not affect the lawfulness of processing under consent prior to its withdrawal (Right of withdrawal, Article 7 (3) GDPR).
•           The right to lodge a complaint with a supervisor if you believe that data processing is a violation of the GDPR (right to file a complaint with a supervisory authority, Article 77 GDPR).

If you wish to exercise your rights in relation to your personal data, please contact our Data Protection Officer (DPO) at dpo@marfinleasing.ro, +40 21 405 0500 or in writing to MARFIN LEASING IFN (Romania) SA:  Emanoil Porumbaru 90-92, 1st and 2nd floor, 1st District , Bucharest, Romania to the attention of the Data Protection Officer who will examine your request to respond in a timely manner.