This POLICY contains information on the collection, processing and storage of personal data by COIN FINANCE, as well as on the rights of natural persons in connection with the protection of their personal data. COIN FINANCE carries out its activity in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) and the other European and Bulgarian regulatory acts in the field of personal data protection. Upon processing Your personal data the Company observes the following principles:
· legality, good faith, and transparency;
· restriction of the purposes of processing;
· relevance to the purposes of processing and minimizing the data subject to collection;
· accuracy and topicality of the data;
· limitation of storage with a view to achieving the objectives;
· integrity and confidentiality of processing and ensuring an appropriate level of security of personal data.
Collection, processing and storage of personal data
Personal data means any information related to You, which can be used by us to identify You, such as Your name, Personal ID No. (PIN), email address, contact telephone number and information about Your access to our website. You can browse our website without entering any personal data. In cases when You want to send an inquiry to us, it is necessary to receive Your personal data (name, telephone number and email address) in order for us to be able to respond to Your inquiry and to provide You with the requested information. In such case, it is necessary to have Your consent to process Your personal data. COIN FINANCE also collects, processes and stores personal data in connection with the conclusion and execution of contracts with its clients, as well as for the purposes of credit intermediation and advising clients on financing by banking and non-banking financial institutions. COIN FINANCE is a Data Controller and in its capacity as such it collects, processes and stores personal data on the following grounds:
· fulfillment of obligations under a concluded agreement;
· Your consent explicitly obtained;
· observation of obligations resulting from a regulatory act;
· for the performance of a task of public interest;
· for the purposes of the legitimate interest of the Company.
Purposes, for which Your personal data is collected, processed and stored
COIN FINANCE collects, processes and stores personal data provided by You for the following purposes:
· individualization of a party under the agreement and the contact persons in connection with its implementation;
· accounting purposes;
· credit intermediation and advice in financing by banking and non-banking financial institutions;
Types of personal data subject to collection, processing and storage
COIN FINANCE collects, processes and stores the following types of personal data:
· names, Personal ID No. (PIN), address, email address (e-mail), telephone number - for clients-natural persons, or of natural persons that manage and represent clients-legal entities. Such data is required for the purpose of conclusion and implementation of the agreements entered into with the Company’s clients, for credit intermediation and consulting for financing by banking and non-bank financial institutions, as well as for having contact with the client and sending information to it/him/her, including under conditions of explicitly given consent - and for sending promotional and advertising messages. No sensitive data is subject to collection;
· information on Your use of our website - IP address, operating system, browser, search queries and viewed content. This information is collected in order to improve and personalize consumer searches;
The Company neither collects, processes and stores any special categories of personal data (sensitive data), nor performs any automated decision-making using such data.
Term of storing Your personal data
COIN FINANCE will not store Your personal data for a period longer than the period necessary to achieve the purposes, for which we process such data. Upon determining the appropriate term of storage, we take into consideration the amount and nature of the personal data, the purposes we process such data for, as well as whether we can achieve these purposes by using other means. Furthermore, the Company complies with the applicable legal requirements for storage of certain categories of data in order to fulfill our obligations resulting from a regulatory act or a contract, as well as to protect our legal rights in case of lodging a claim.
When the storage of such data is no longer necessary, COIN FINANCE will securely delete or destroy Your personal data without undue delay.
Transfer of Your personal data for processing
COIN FINANCE independently collects and processes the personal data provided by You. Such personal data will be provided to third parties only in the cases stipulated by the law. All personal data will be stored on the territory of the Republic of Bulgaria. COIN FINANCE does not transfer Your personal data to any third countries.
Your rights to protection of Your personal data
In certain circumstances, You have the statutory right:
· to request information on whether the Company stores Your personal data, and in case we have such - what this data is, on what grounds and for what purpose we process and store it;
· to request access to Your personal data (the so-called “data access request”). This will allow You to receive a copy of Your personal data held by the Company and to verify whether we process such data by virtue of the law;
· to request correction of Your personal data held by the Company. This will provide You with the opportunity to correct any incomplete or inaccurate information we have about You.
· to request the erasure of Your personal data (the so-called “right to be forgotten"). This will allow You to ask us to delete or remove without undue delay all or a part of Your personal data if there are no grounds for us to continue to process and store such data. COIN FINANCE does not delete any data it is legally obliged to store, including for protection on the occasion of court claims lodged against it or for proving its rights;
· to object against the processing of Your personal data in case we refer to a legitimate interest (or the interests of a third party) and for this reason something in Your specific situation makes You object to the processing. Furthermore, You have the right to object if we process Your personal data for direct marketing purposes;
· to request the restriction of the processing of Your personal data. This will allow You to ask us to stop processing Your personal information if, for example, You wish to establish its accuracy or the reason for its processing;
· to request the transfer of Your personal data to You or to another person in an electronic and structured form (the so-called “right to data portability”). This will allow You to take Your data from us in such electronic format that is suitable for use and transfer it to another person in an electronic format that is suitable for use;
· to withdraw Your given consent. You may withdraw Your consent as regards all Your personal data or just a part of it, as well as for a specific purpose or for all purposes of processing. If You have given Your consent to the collection, processing and storage of Your personal data for a specific purpose, You have the right to withdraw Your consent at any time as regards that specific type of processing. Once You notify us of the withdrawal of Your consent, we will no longer process such data for the purpose or purposes You have initially given Your consent for, unless there are other grounds for us to continue such processing;
· to be notified in case of violation of the security of Your personal data, thus eventually posing a high risk to Your rights and freedoms. COIN FINANCE will inform You without undue delay and in a proper manner upon establishing such violation, as well as about the respective measures already undertaken or to be undertaken.
In order for You to exercise any of Your rights listed above, please send a free text request or notification to the following email address: firstname.lastname@example.org, or contact us at: 1303, Sofia, Vazrazhdane district, 15 “Pozotano” Str., fl. 6, office 16. Please, keep in mind that it is possible we may request specific information from You to help us verify Your identity and respect Your right of access to information or any of Your other rights. This additional security measure aims at ensuring that Your personal data will not be disclosed to any persons not entitled to receive it. The exercise of the above mentioned rights does not require the payment of any fee on Your part. However, we may charge an administrative fee to a reasonable amount if Your request for access is clearly unfounded, or in case of repeated or excessive requests. In such circumstances, it is also possible that we refuse to comply with the request. If in Your opinion Your privacy rights have been violated, You have the right to lodge a complaint with the Data Protection Commission.
Measures for ensuring Your personal data protection
COIN FINANCE complies with strict security procedures upon storing Your personal data, as well as in order to protect such data against unauthorized access, accidental loss, destruction or damage. The security of Your personal data is our uncompromised priority. COIN FINANCE applies organizational, physical, information technology and other measures necessary in order to ensure the security and protection of Your personal data and the personal data processing monitoring. The following activities are included in some of the security measures undertaken by the Company:
· the rules for the collection, processing and storage of personal data are established in internal procedures, the compliance of which is subject to continuous monitoring;
· all Company’s employees have been imposed obligations to keep confidential;
COIN FINANCE aspires to continuously improve the security measures we have introduced and we have been applying in our activity, and to keep those in compliance with the latest technologies.
In order for us to facilitate the use of our website, COIN FINANCE requires a technology for memorization and storage of information. This is done with the help of the so-called “Cookies”. Cookies are small text files containing insignificant amounts of information and are stored on Your computer or in the memory of Your web browser. Then, every time You visit and open our website Your web browser sends these cookies back to our website, thus helping the website to recognize You and to store information about Your user preferences (visits, clicks, activity history). The use of the collected cookies is very limited and is related to technical purposes for the purpose of improving and customizing the functionality of our website. The information collected by using cookies cannot be linked to a given person. The term for storing cookies is 5 years according to the international NAI standards, which can be found at https://www.networkadvertising.org
. More detailed information about cookies and their functionality can be found at http://www.aboutcookies.org
COIN FINANCE may at its discretion change and add to the present Policy at any time upon observation of the requirements of the applicable legislation in the field of personal data protection.
Information about the Data Controller: Name:
“COIN FINANCE” LTD, UIC: 203018272
Head office and registered office address: 1303, Sofia, Vazrazhdane district, 15 “Pozotano” Str., fl. 6, office 16, e-mail: email@example.com, Contact telephone: +359 2 987 77 97