Information on the processing of personal data

Protecting personal data is very important to us and we do our utmost to ensure that you are protected and always informed and in control of the data you submit to us and that we process in our interactions and contractual relationships.

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About the new legislation on personal data protection

&If the EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data entered into force on 25 May 2018. The new legislation aims to increase the level of protection of personal data and to ensure a transparent framework through which we can all have better control over personal data.

&In this regard, we provide below details of how Patria Credit manages your personal data and also the types of information we hold, &for what purposes, how we collect, store, use and disclose it.

Who we are

PATRIA CREDIT INSTITUTIE FINANCIARĂ NEBANCARĂ SA (hereinafter referred to as “Patria Credit IFN SA”) with registered office în șoseaua Pipera, nr. 42, Globalworth Plaza building, et. 8, Bucharest, Romania, postal code 020112, Commercial Register number: J40/19452/2017, Fiscal Registration Code: RO 16129932, Share capital (subscribed and paid up): 13.539,230 lei, e-mail: office@patriacredit.ro, website: www.patriacredit.ro, înregistrée înregistrée ANSPDCP register of personal data processing under no. 5655, collects and processes personal data, în accordance with the legal provisions în matters of personal data processing and the free movement of such data.

Before providing personal data to PATRIA CREDIT IFN SA, please read below and understand how în which your personal data are used and the purpose în which they are used. If you are unclear about the information below regarding the processing of your personal data or would like further information, please contact the Data Protection Officer at the following contact address: office@patriacredit.ro or telephone 0800.872.874.

What is this information for?

Protecting personal data is very important to us and we make every effort so that înc;t you SA are protected and always informed and îin control of the data you submit to us and that we process înc;in our interactions and îin contractual relationships.

Transparency is also very important to us and in our work we ensure the protection of fundamental rights and freedoms, respect the law and conduct ourselves in a professional, responsible and customer-friendly manner. To this end, in order to protect your personal data and to provide accurate and complete information to all customers and potential customers, we have set out in this document our policy on the management of your personal data and the types of information we hold, for what purposes and how we collect, store, use and disclose it.

How do we use your personal data?

We use your personal data to deliver the services or products you have requested from us (or a third party designated by you who has requested them îon your behalf). The provision of personal data for this purpose is not mandatory, but refusal to provide it leads to the impossibility to provide you with our services, and the processing of such personal data may be carried out without your consent to the processing.

We are subject to our legal obligations arising from national and EU regulations (e.g. regulations on: Know Your Customer and prevention of money laundering and terrorist financing, fraud prevention, distribution of financial investment services, tax certifications and taxes, etc), as well as from legal regulations and instructions issued by supervisory and control authorities (e.g. National Bank of Romania, National Office for the Prevention and Fight against Money Laundering, Financial Supervisory Authority, Ministry of Finance, Fraud Investigation Services, etc). The provision of personal data for these purposes is mandatory and no consent is required for the processing of data for these purposes.

We carry out functional activities for the promotion and marketing of our products or those of the Patria Group companies or third party partners, as well as activities ancillary thereto - the provision of personal data for these purposes is optional, and we require your consent to process such data.

The Patria Group includes: Patria Bank SA, Patria Credit IFN SA, Patria Investments SA – Subsidiary, SAI Patria Asset Management SA (together with the managed investment funds: FDI Patria Stock, FDI Patria Global, FDI Patria Obligațiuni), SC Imobiliar Invest SRL, SSIF Patria Invest SA.

What data do we collect from you?

We collect data from you &in the process of purchasing a product or service or when you enter into any kind of contractual collaboration with Patria Credit IFN SA .

We have detailed below all the situations în which we collect data, as follows:

In order to benefit from our products and services, you must also become a customer of Patria Credit IFN SA. In order for you to legally become a client of Patria Credit IFN SA or to legally represent a client of Patria Credit IFN SA, the Institution is obliged to collect and process personal data about you as follows: the data contained în your identity card, including a copy thereof; your pseudonym; date and place of birth; domicile and, if applicable, residence; telephone number, fax, e-mail address; nationality; occupation and, if applicable, the name of your employer or the nature of your activity; important public position held, if applicable; identification data of the beneficial owner of your funds. If you do not wish to provide us with these data, you cannot become a client of Patria Credit IFN SA and thus a business relationship cannot be initiated with you.

  • In order to benefit from Patria Credit IFN SA loan products, as a partner / shareholder / beneficial owner / legal representative / empowered / guarantor / natural person guarantor of a PATRIA CREDIT IFN S.A client, it is necessary for you to înclude with PATRIA CREDIT IFN SA a credit agreement / guarantee agreement as well as any other necessary agreement îndepending on your request.

    In order to comply with the legal provisions necessary to create categories of default risk PATRIA CREDIT IFN SA collects and processes the following information: information on your sources of income, their amount, currency îin which you are remunerated; information on the number of persons îin your family dependants; payment commitments you have îin progress (credit contracts, leasing contracts, credit card, overdraft, CAR etc..); any litigation and/or seizures that you have pending and that may significantly affect your ability to repay any loan product obtained from PATRIA CREDIT IFN SA; information about your marital status and, if applicable, identification data of your spouse (name, surname, CNP); information about your education and related qualifications; information about your profession and length of service; information about your current employer, type of employment contract and position held, if you are an employee; summary information about the properties you own, including those with which you wish to guarantee the loan product.

    For the analysis of the collateral required to contract credit products, PATRIA CREDIT IFN SA collects and processes the following information: detailed information on the properties/assets you wish to pledge as collateral when contracting a credit product.
    In order to be able to send you information necessary for the credit contract, PATRIA CREDIT IFN SA collects and processes the following information: address, landline/mobile phone and/or email address where you choose to receive correspondence or be contacted by PATRIA CREDIT IFN SA.

    If you do not wish to provide us with these data, PATRIA CREDIT IFN SA cannot înclude a credit agreement with you with îndepliance with the legal provisions and thus you cannot benefit from the credit products offered by PATRIA CREDIT IFN SA.

    &In the legitimate interest, &in order to carry out a responsible lending activity, &in the conditions of protection of data subjects, compliance with the legal framework on creditworthiness assessment and credit risk reduction, as well as to prevent the use of the financial-banking system to carry out illegal activities, PATRIA CREDIT IFN SA interrogates: Credit Bureau for obtaining the Credit Report (collecting and processing the following categories of personal data on the data subject: identification data: name, surname, CNP, home/residence and correspondence address, landline/mobile phone number, date of birth; employer data: name and address of the employer; data relating to the credit products requested/granted: type and name of the entity granting the credit facility, type of product, status of product/account, date granted, term granted, amounts granted, amounts due, due date, currency, frequency of payments, amount paid, monthly instalment, amounts outstanding, number of instalments outstanding, number of days past due, category of credit;date of the product closure, number of queries; data related to events occurring during the life of the credit product, such as those related to restructuring/refinancing, giving & paying, assignment of the credit agreement, assignment of the claim, etc.; data related to relationships with other accounts: information relating to credit products where the data subject is a co-debtor and/or guarantor; Insolvency data: information relating to data subjects against whom insolvency proceedings have been opened), the Credit Risk Centre for obtaining the overall risk situation, the outstanding credit situation and the card fraud situation, as well as independent public sources of information as required by law.
  • In order to be able to înclude a collaboration contract for the intermediation and/or promotion of credit products, PATRIA CREDIT IFN SA is obliged to  collect and  process personal data about you as follows: data contained în your identity card including a copy thereof; your pseudonym; date and place of birth; domicile and, if applicable, residence; telephone number, fax, e-mail address; nationality; occupation and, if applicable, the name of your employer or the nature of your activity; important public position held, if applicable; identification data of the beneficial owner of your funds; source of your funds/income; status of person affiliated to the institution, data on tax residence.

    If you do not wish to provide us with these data, we cannot legally enter into a cooperation agreement with you for the intermediation and/or promotion of our institution's loan products.
  • For the purpose of concluding and carrying out a cooperation agreement for the intermediation and/or promotion of credit products, as well as for assessing your professional qualifications and ability to meet the sales targets, in addition to the personal data mentioned above, PATRIA CREDIT IFN SA collects and processes the following personal data: information on your professional qualifications and CV; your signature, which is necessary for the authentication of documents concluded with PATRIA CREDIT IFN SA; the address, landline/mobile phone and/or email address at which you choose to receive correspondence or to be contacted by PATRIA CREDIT IFN SA in order to inform you about changes in the terms and conditions of business or other information necessary for the performance of the contract.

    If you do not wish to provide us with these data, we cannot enter into a cooperation agreement for the intermediation and/or promotion of our institution's credit products.
  • To access the information provided online at www.patriacredit.ro. Our online viewable page uses cookies. Cookies are small text files that a website transfers to your hard drive (computer, tablet or mobile phone). This technology allows us to tailor the site to your needs. Basically, cookies allow the website to remember a range of information from your visit and how you used it (e.g. language settings, keeping a user logged in to your webmail account, online banking security, etc.). If your browser is configured not to accept them, some pages may not work (partially or fully). For more information on how we use cookies in our relationship with you, please read our Cookie Policy by accessing the following link: https://www.patriacredit.ro/politica-de-cookies.

    If you wish to obtain further information on our products and/or services, PATRIA CREDIT IFN SA will ask for your consent to process minimal personal data in order to contact you and guide you according to your needs. PATRIA CREDIT IFN SA also processes the IP address identified as belonging to your connection with us in order to try to inform you about the nearest Patria Credit IFN SA location.

IMPORTANT!

&In the course of the business relationship with PATRIA CREDIT IFN SA, îin order to comply with the legal regulations îin force and/or the legitimate interest of PATRIA CREDIT IFN SA to protect itself îin case of misunderstandings arising îin the course of the business relationship: automatically captures images that may contain the actions întreprense by you în the premises of PATRIA CREDIT IFN SA units, as well as în their immediate vicinity, (the images thus captured by PATRIA CREDIT IFN SA are not processed for the compilation of individual profiles and will be processed only în the purpose for which they were processed) and may în automatically record the telephone calls that you have with us, with your prior information.

Where else do we use your data?

We use your data for profiling and automated decisions.

&In accordance with the provisions of the legislation în matters of customer knowledge and the prevention and combating of money laundering and terrorist financing, as well as the implementation în international sanctions, PATRIA CREDIT IFN SA is obliged to classify you in terms of potential money laundering risk. We are obliged to carry out your risk classification based on criteria established by EU and national legislation. The processing of the risk rating based on these criteria is carried out by an automated process which aims to make the calculation process more efficient. Manual processing based on these criteria has the same result as automated processing and the same effects on your classification in terms of potential money laundering risk.

&If you are a partner / shareholder / beneficial owner / legal representative / authorised representative / guarantor / natural person guarantor of a client PATRIA CREDIT IFN S.A, in order to comply with the legal provisions for classifying the target clientele by default risk categories, based on the general risk profile of PATRIA CREDIT IFN SA, the client is classified by default risk criteria according to socio-demographic, professional or qualitative variables based on the information provided in the credit application. The default risk rating is processed on the basis of the criteria and scores set out in the procedure.

How will we communicate?

How will personal data be communicated to you?

&In the course of the business relationship, in order to comply with legal and contractual regulations, and depending on the available communication channel chosen by you (over-the-counter support, email) you will receive from PATRIA CREDIT IFN SA information containing personal data.

Please note that your choice to use email to receive information may not ensure a satisfactory degree of protection of the confidentiality of your personal data for reasons beyond the control of PATRIA CREDIT IFN SA.

If you consider that the use of email for the transmission of your personal data is not satisfactory from the point of view of maintaining confidentiality, please choose another channel for communicating your personal data to you.

Communication of information about PATRIA CREDIT IFN SA

products and services

&If we obtain your freely given consent, PATRIA CREDIT IFN SA may use your contact details (mailing address, telephone and email) îfor the purpose of informing you about its products and services or those of the companies in the Patria Group mentioned above. You have the right to withdraw this consent at any time, without affecting the lawfulness of the processing carried out on the basis of your consent given before its withdrawal.

The use of your data by PATRIA CREDIT IFN SA for the purpose of improving the products and services it offers you

Independent of the legal/contractual purpose for which they were collected, în legitimate interest, PATRIA CREDIT IFN SA may use the data provided by you în statistical purposes for the development of new products and services. The processing of your personal data & in legitimate interest for the development of the business of PATRIA CREDIT IFN SA cannot and will not prejudice your fundamental rights and freedoms.

To whom do we transfer your personal data?

PATRIA CREDIT IFN SA will keep confidential the personal data collected about which it has informed you above and will not disclose or transmit it to any third party without a legal/contractual basis or without your knowledge or consent, where required.

For the purpose of fulfilling legal or contractual requirements agreed with you, as well as în legitimate interest, PATRIA CREDIT IFN SA transfers part or all of your personal data to recipients such as: The National Bank of Romania, the Central Credit Union, the National Authority for Consumer Protection, the National Authority for the Supervision of Personal Data Processing, the National Office for the Prevention and Combating of Money Laundering, the Criminal Investigation and Investigation Bodies at their request according to the law, as well as any other entities that may request personal data about you or about the operations carried out by you, în entitled by legal provisions; to the entities of the Patria Group, for suspicious transactions/suspected money laundering, în case în case you are also the client of that entity; any other natural or legal persons with whom PATRIA CREDIT IFN SA will înclude agreements for înde fulfilment of contractual obligations (National Tax Administration Agency, appraisers, notaries public, operators of the Electronic Collateral Archive, IT service developers, insurers etc..); natural or legal persons with whom PATRIA CREDIT IFN SA has contractual relations and with whom it offers services related to credit products; in the legitimate interest, PATRIA CREDIT IFN SA will process your personal data and transfer your information to legally authorized institutions for the recovery of any claims that may arise from the execution of contracts; to any entities other than those listed above for which we request and have your consent; & for the purpose of carrying out contractual relations and fulfilling legal obligations, your data may be transmitted in Romania and in countries in the European Union and outside the European Union, including the United States of America.

The period we need to keep your personal data

PATRIA CREDIT IFN SA is legally obliged to keep identity data and secondary or operational records and records of all financial transactions arising from the conduct of the business relationship with you or an occasional transaction for a period of at least 5 years from the end of the business relationship or from the completion of the occasional transaction, in an appropriate form, including for use as evidence in legal proceedings.

If you decide SA în terminate business relations with PATRIA CREDIT IFN SA, în the sense în that you are no longer a partner / shareholder / beneficial owner / legal representative / empowered / guarantor / guarantor natural person of a client PATRIA CREDIT IFN SA , personal data concerning your identity collected îfor the purpose of entering into a business relationship with PATRIA CREDIT IFN SA will be deleted from the operational records of PATRIA CREDIT IFN SA after the legal retention periods mentioned above. The rest of the data that you provide to us becomes anonymous data (it cannot be identified as belonging to you) and may be used by PATRIA CREDIT IFN SA in legitimate interests, including for the development of PATRIA CREDIT IFN SA products and services, in accordance with the law, without prejudice to your rights and freedoms.

If, îon the basis of the application of a PATRIA CREDIT IFN SA client, for which you hold the status of associate / shareholder / beneficial owner / legal representative / empowered / guarantor / guarantor natural person, and îfollowing the assessments carried out by PATRIA CREDIT IFN SA, you and/or the applicant cannot become our client and/or cannot obtain a product or service presented în PATRIA CREDIT IFN SA offer, personal data concerning your identity collected for the purpose of entering into a business relationship with PATRIA CREDIT IFN SA will be deleted from PATRIA CREDIT IFN SA operational records. The rest of the data you provide us with becomes anonymous data (it cannot be identified as belonging to you) and may be used by PATRIA CREDIT IFN SA for legitimate interests, including for the development of products and services, in accordance with the law, without prejudice to your rights and freedoms.

PATRIA CREDIT IFN SA also keeps, in accordance with the specifications of the regulation on the protection of personal data, all documents collected for the purpose of contractual or pre-contractual relations with you as well as related transactions in electronic format and which are necessary for the establishment, exercise or defence of a right in court. To this end, a minimum set of data concerning your identity will be processed by PATRIA CREDIT IFN SA for the sole purpose of complying with the legislation in force with regard to the recording, inventory, selection, storage and use of the documents it holds.

În order to comply with the legal provisions on credit conditions, as well as în virtue of the legitimate interest to înclude credit contracts on the basis of appropriate and sufficient information and în the basis of a rigorous assessment of the capacity of the data subject to repay his/her credit în taking into account relevant factors îin accordance with the legal provisions, PATRIA CREDIT IFN SA keeps minimum and relevant personal data of former clients regarding their behaviour and capacity to repay the debts they have registered with PATRIA CREDIT IFN SA during the course of the business relationship, regardless of the product or service contracted from PATRIA CREDIT IFN SA. These data will not constitute a sole criterion for the approval or rejection of a future credit contracted by former clients of PATRIA CREDIT IFN SA, but will form part of the decision to assess the creditworthiness of the client at the time when he/she wishes to contract a new credit from PATRIA CREDIT IFN SA. Personal data processed for this purpose will be kept by PATRIA CREDIT IFN SA for an unlimited period.

Also, în the process of retention, legal reasons may arise for which we will be obliged to keep, process or disclose your personal data also after the period mentioned above.

Your rights regarding the processing of personal data by PATRIA CREDIT IFN SA

These rights are recognized by Regulation 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, as well as: „right of access”, „right to rectification”, „right to erasure (right to be forgotten)”, „right to restriction of processing”, „right to data portability”, „right to object” and „right not to be subject to automated individual decision-making”.

  • Right of access: înmeans that you have the right to obtain from PATRIA CREDIT IFN SA a confirmation as to whether or not your personal data are being processed, as well as information as to how înthis data is being processed;
  • The right to rectification: înmeans that you have the right to ask us and we to correct when your data in our possession and processed by us are incomplete, inaccurate or have changed since the date of collection;
  • Right to erasure or right to be forgotten: this means that you also have the right to ask us to erase your personal data if it is no longer necessary for us to keep or use it or if you wish to withdraw the consent you previously gave to the processing of certain data, if the data has been unlawfully processed or if you consider that the legitimate interest of processing your personal data is not justified;
  • Right to restriction of processing: this means that you have the right to ask us to restrict the processing of your data if you consider that it is inaccurate, if you consider that the processing of your data is not lawful, if you want us to keep your personal data beyond the minimum retention period required by the Bank, and during the exercise of your right to object to the processing if you consider that the legitimate interest considered by PATRIA CREDIT IFN SA is not justified;
  • The right to data portability: înmeans that you have the right to receive the data collected by us from you and processed automatically, înfollowing your consent or înfollowing contractual provisions, în a user-friendly structured format or to have your data transmitted to another personal data controller, if technically possible;
  • Right to object: this means that you have the right to object to the processing of your data on the basis of the legitimate interest of the Bank if you consider that such processing is prejudicial to your interests, rights and freedoms or if the processing of your data is for direct marketing purposes.
  • Right not to be subject to automated individual decision-making only: this means that you have the right not to be subject to a decision based solely on automated processing without human intervention, including profiling, and which SA has an effect on your interests, rights and freedoms. Automated processes that streamline the processing of data resulting from a decision based exclusively on human intervention do not constitute an exclusively automated individual decision-making process.

Complaints and contact

Claims

If you have any objections to the way în which we use your data or wish to ask us to delete or restrict the way în which we use it, please contact us.

If you believe that your rights have been violated, you have the right to lodge a complaint by sending a written, signed and dated request to the National Authority for the Supervision of Personal Data Processing (ANSPDCP, www.dataprotection.ro)

Contact

We are constantly concerned about the protection of your personal data. You can contact us with any questions or requirements regarding our privacy and personal data protection policies and procedures. Here are our details:

Head office Patria Credit IFN SA: 42, Pipera road, Globalworth Plaza building, Et. 8, sector 2, Bucharest, Romania, postal code 020112

You can also contact us by email or telephone during office hours, using:

Phone: 0800 872 874

Email: office@patriacredit.ro

Eventual changes to this information will be brought to your attention by PATRIA CREDIT IFN SA, îin accordance with the provisions of Regulation 679/2016 on the protection of individuals îregarding the processing of personal data and on the free movement of such data.