Partners Finances Personal Information Charter (22/05/2018)

Identification :

PARTNERS FINANCES, PARTNERS FINANCES SPRL Registered Office: 10 Rue du Follet - Espace Wallonie Picarde - 7540 KAIN, BELGIUM - BE0628.480.717. A credit broker registered with the Belgian Financial Services and Markets Authority (FSMA - www.fsma.be) - insurance broker N° FSMA 115462 A. Tel: +352 284 809 371

The object of this declaration is to explain how PARTNERS FINANCES collects, uses and stores personal data (hereafter « the data ») relative to their customers, natural persons, and all potential customers (hereafter « prospects »).

1. Who is responsible for processing your data?

PARTNERS FINANCES is responsible for processing your data. Which means that they determine the purpose, or purposes for which they collect such data.

Therefore, PARTNERS FINANCES processes and protects your data in conformance with, and in respect for the law, and in a fair and transparent manner.

2. What does the processing of personal data involve?

Personal data means any information relating to an identified or identifiable person, or who can be identified, directly or indirectly, in particular by reference to an identification of an element, or elements, that are specific to that person.

Personal data processing consists of any operation or series of operations carried out on such data, regardless of the procedure used, such as collection, recording, organisation and storage.

By virtue of their different services, and particularly to respond to their obligations as a consumer credit broker and insurance broker, PARTNERS FINANCES collects and processes facts, data and information of any nature, supplied by you or by third parties, to the extent necessary or useful to carry out their activity.

Although you have no legal obligation to provide your personal data, please understand that if your refuse to do so, PARTNERS FINANCES may be impossible to develop a commercial relationship with you, and it may be detrimental to the analysis of your project requests.

3. What personal data is processed?

PARTNERS FINANCES may be required to process facts, data and information of any nature, supplied by you or by third parties, to the extent necessary or useful to carry out their activity as a consumer credit broker and insurance broker.

The personal data processed includes:

• Identification data, such as your name and first name, address, date and place of birth, e-mail address etc...
• Socio-demographic data such as your family situation, civil status, job, etc...
• Data relative to your financial resources and assets
• Financial and transactional data such as your bank statements, loan repayments, etc...
• Data concerning your knowledge and experience in terms of credit, loans and insurance
• Data relative to your habits and behaviour when navigating on our website in our Customer Area: getting information, consulting simulations, credit requests, reactions to our commercial propositions, etc...
• Data concerning our satisfaction surveys
• Data obtained from third parties, for example, your broker, your legal advisor, etc...
• Data obtained via cookies (cookies are essential for our website to function properly)
• Data collected via trackers (trackers help compile browsing history and preferences, collecting statistical data, adapting website content and/or publicity to meet your needs).

PARTNERS FINANCES does not process sensitive data such as health data, nor racial or ethnic data, nor political, philosophical or religious data, nor data relating to trade union membership or sexuality.

4. When do we collect your data?

We collect your data when you contact PARTNERS FINANCES and at each stage of the process of putting your project file together, for example when:

• You complete our form to request an online simulation (on our website or an affiliated website)
• You contact one of our agencies directly by telephone
• You respond positively to our simulation and you want to put together and present a project file to one of our partner banks.

5. Why does PARTNERS FINANCES process your data?

First of all, PARTNERS FINANCES processes your data because we are subject to numerous legal and regulatory obligations linked to our status as a consumer credit broker and insurance broker.
For example:
Analysing the customer's financial situation, and the consequences entering into a new loan agreement will have on their financial situation’
The obligation to counter and fight against money laundering and the financing of terrorism.
The obligation to respond to official demands from the competent public authorities, etc...).

PARTNERS FINANCES also processes your data for the needs of contractual relationships with you as a Customer (non-exhaustive list) :

• Responding to your requests for a simulation, and, where appropriate, notifying you of the impossibility of a successful offer from our banking partners
• You login to our website and access our services as part of our contractual relationship: for example you login in to your Personal Customer Area.
• Managing your project file: helping you put together your project file evaluating the opportunities and risks linked to entering into a loan agreement determining the conditions and guarantees of your project responding to requests for further information from the bank we have presented your file to.
• Participating in our satisfaction surveys
• Improving our services
• Direct marketing, sending you information, publicity and propositions concerning the products and services which are pertinent to you.

6. To whom can your data be transferred?

Your data is treated in a confidential manner. All of the employees at PARTNERS FINANCES are subject to confidentiality clauses specifically provided as a condition of their employment contract.

• Your data is transferred to those of our banking and insurance partners who may be interested in your project:
  ALPHA CREDIT, rue ravenstein 60/15, 1000 Brussels, Belgium
  CKV Bank, Mannebeekstraat 33, 8790 Waregem, Belgium
  COFIDIS, Chaussée de Lille 422A, 7501 Tournai, Belgium
  CREAFIN NV, Duwijckstraat 17, 2500 Lier, Belgium
  CREDIMO NV, Weversstraat 6-10 1730 Asse, Belgium
  EB-LEASE, Place Paul Emile Janson 1A ,7500 Tournai, Belgium
  ELANTIS, Rue des Clarisses 38, 4000 Liege, Belgium
  KREFIMA SA, rue du marquis1, 1000 Brussels, Belgium
  RECORD BANK, avenue H. Matisse 16, 1140 EVERE, Belgium.
• PARTNERS FINANCES belongs to the MENTOR Group, so certain other companies in the group, and their employees, may have access to your personal data, for operational reasons and to manage your requests, but also to be able to offer products and services to you which are pertinent to your situation.
• In order to comply with our legal obligations, PARTNERS FINANCES may have to share certain of your personal data with the judicial authorities, the Data Protection Authority etc.

PARTNERS FINANCES keeps your personal data exclusively within the European Economic Area.

7. How long do we keep your personal data for?

The length of time we keep your personal data does not exceed the time necessary to process the data for the reason it was collected, except if the law or the regulations stipulate a specific period.

The data collected is kept for a period between 2 and 5 years, depending on the type of financing involved. Over and above this period, your data is archived in order to comply with legal obligations and judicial requirements for data retention, to prove such compliance and to be able to respond to requests for such information from competent authorities.

8. What are your rights and how do you exercise them?

8.1. The general right to object to direct marketing

At any time you may oppose the use of the data we collect, store and process for marketing purposes, by sending an e-mail to : dpo@partners-finances.lu, or in writing addressed to: PARTNERS FINANCES – DPO – 10 Rue du Follet - Espace Wallonie Picarde - 7540 KAIN, Belgium.

8.2. The right of access, correction, deletion and portability of your personal data

You have a permanent right of access to your personal data and in this context, you can request the following information:

• the categories of personal data in our possession
• the purpose of the processing
• the recipients or the categories of recipients

If your personal data is not correct, not pertinent or incomplete, we can modify and complete it, and in certain specific cases allowed by law, delete it. You can also request that certain data is sent directly to you or to a third party.

Please send your specific request directly to us by e-mail on: dpo@partners-finances.lu, or in writing addressed to: PARTNERS FINANCES – DPO – 10 Rue du Follet - Espace Wallonie Picarde - 7540 KAIN, Belgium.

8.3. The automatic processing of your personal data and the feasibility of your project

In principle, the PARTNERS FINANCES account managers examine all simulation requests. However, your request may be refused based on an automatic processing of your personal data. If that is the case, your will be notified.

8.4. The Data Protection Authority

If we have not been able to satisfy your request, you can contact the Data Protection Authority, Rue de la Presse 35, 1000 Brussels, Belgium
– Tel: 00 32 (0)26 667 48 00
- Fax: 35 32 (0)26 667 48 00
- Email: commission@privacycommission.be
- Website: https://www.privacycommission.be/fr