LoanClear respects your privacy. You can be confident that we handle your personal data with due care. We believe it is important that we provide you with a service in a way that is transparent and reliable. We are therefore constantly looking for ways to improve our services and tailor them to your wishes and needs.
We use your personal data in order to be able to provide the services correctly and completely. We process this data carefully and securely. We would like to be open and clear about the way in which we process your personal data. In this privacy statement, we therefore answer the most important questions about the processing of your personal data by LoanClear.
Who is responsible?
LoanClear B.V. (“LoanClear”) is responsible for the processing of your personal data for all provided services. LoanClear is a subsidiary of Dynamic Credit Group B.V.
Within the Dynamic Credit group, the policy on privacy and data protection and the fulfilment of the role of Data Protection Officer (DPO) are arranged at group level.
What is personal data?
Personal data is any information that relates to an identified or identifiable living individual. You share personal data with us if you are a customer with us, if you have opted-in for a seminar or similar, mail or contact us. Consider, for example, your name, address, phone number or email address.
What is processing?
Processing personal data is all that can be done with this data. For example, collecting, but also storing, using, consulting and removing your data from our administration.
Which personal data do we process about you?
In order to be able to offer LoanClear related services, LoanClear processes the following categories of personal data:
- Contact details (such as: name, address, city, e-mail address, telephone number).
- Professional and / or business data that are important (such as: profession or company).
Applied lawfulness of processing
As prescribed in the General Data Protection Regulation (Algemene Verordening Gegevensbescherming), LoanClear only processes your personal data if there is a legal basis for this. The data processing by LoanClear can be based on the following legal bases:
- The processing is necessary for the performance of a consultancy, brokerage or agreement.
- The processing is necessary to comply with a legal obligation, where applicable.
- The processing is for the purpose of a legitimate interest of LoanClear, except when your interests prevail over our interests.
- With your consent, where you have given it, which you can withdraw.
For what purposes do we use your personal data?
LoanClear uses your personal data, as the case may be:
- To be able to enter into and execute a consultancy agreement, brokerage agreement or loan agreement with you. In other words, to be able to provide you with services or a product.
- To develop and improve our services and products, for which we perform, for example, statistical analysis.
- For promotional and marketing purposes, for example to inform you about services or products that may be of interest to you.
- To keep track of how, when and what contact we have with you, so that we can improve communication with you or coach and train our employees.
- If LoanClear intends to further process personal data for a purpose other than that for which the personal data was collected, LoanClear will first provide you with information about that other purpose and how we ensure that the processing takes place carefully and transparently.
Who do we share your personal data with?
We also share your data with other parties. Your personal data will be used for transmission to, control and exchange with other companies and institutions.
We engage third parties for the execution of our services, such as our service partners, other companies within Dynamic Credit Group, IT companies and data centres. If these third parties have access to your data when performing the relevant services, we will take the necessary contractual and organizational measures to ensure that your data is only processed for the above purposes. We do not share your personal data with third parties for marketing or sales activities without your permission.
How do we protect your personal data?
Our LoanClear website, your LoanClear account and our IT systems are well secured. Furthermore, we do everything we can to protect your personal data as well as possible by taking appropriate technical and organizational measures. We have these measures checked several times a year by independent experts.
We have also instructed our employees and those of our suppliers to handle your data carefully and to keep it secret. Access to the data is controlled and limited as much as possible. In this way we try to prevent unauthorized persons from gaining access to your personal data.
To achieve this protection, we have implemented our Information Security Policy, which is periodically evaluated and improved when necessary. And what if something does go wrong? Then we follow a clear step-by-step plan. We tackle and record data leaks. We also report them to the Dutch Data Protection Authority and to you, if necessary.
How long do we keep your personal data?
We keep your data for the duration necessary for the purposes for which we process the data or as long as we must keep it by law. The retention period can differ per purpose and depending on the basis of the processing.
What do we do with your data after the retention period?
After the retention period, your personal data will be deleted or anonymised. Anonymization means that your personal data is no longer or can no longer be linked to you in any way.
Processing in other countries
With regards to processing of personal data, we always ensure to be compliant with the GDPR: We strive to process personal data only within the European Economic Area (EEA: EU countries, Norway, Iceland, Liechtenstein) and expect our partners to also have this goal. If we need to use services outside the EEA, we ensure partners have privacy shield in places or setup a “GDPR model contracts” with us, in a way to give us reasonable assurance that your privacy is protected.
What rights do you have?
Since the new privacy legislation (GDPR) came into effect, you have more control over your personal data. Existing rights have been extended and new rights have been added. You have the following rights:
- Access: You have the right to inspect your personal data and can generally gain access to all personal data that we have about you within one month of your request to us.
- Correction: You can ask us to correct inaccuracies in your personal data.
- Delete: You can ask us to delete personal data under certain circumstances. In that case, we will take reasonable steps to notify other processors who process the personal data on our behalf that you have requested the removal of links to and copies of your personal data.
- Objection to processing: If you object to certain processing of your personal data, for example e-mails with offers.
- Restriction of processing: You can request us to limit the processing of personal data under certain circumstances, for example if the accuracy of personal data is disputed by you.
- Transferability: You can request the personal data that you have provided to us and that we keep. We then deliver these in a structured, commonly used and machine-readable manner. You can send this to a third party, for example.
- Withdrawal of permission: Where you have given permission to use your personal data, you can withdraw your permission. We may then no longer process the personal data for which the consent applied.
- Submit a complaint: You can submit a complaint about the processing of your personal data by us to the Dutch Data Protection Authority.
Exceptions may apply when executing these rights, so you might not be able execute certain rights in some cases.
How can you exercise your rights?
If you want to execute a right, please state the right you wish to execute and send via an email to email@example.com or send a letter to LoanClear B.V., Frederik Roeskestraat 97 D, 1076 EC Amsterdam.
If you want to execute your rights, please also include a copy of your passport or ID card. Do not forget to make your citizen service number (BSN) and passport photo illegible. This can be done, for example, by using the Central Government's CopyID app. We will respond within four weeks of receiving your message. Please be advised when you send us an email to protect your ID by adding it to a password protected archive (for instance, 7-zip can do this) and send us the password in a separated email.
We do our best to protect your privacy and personal data as well as possible. If you are not satisfied, you can send an e-mail to firstname.lastname@example.org or send a letter to: LoanClear B.V., Frederik Roeskestraat 97 D, 1076 EC Amsterdam.
In your e-mail or letter please describe your complaint and provide us with your address, telephone number and e-mail address. We will then give you a substantive answer within 14 days. You also always have the right to file a complaint with the Dutch Data Protection Authority.
Questions about privacy and data protection
If you have any questions about the way we handle your privacy and personal data, you can contact:
Data Protection Officer - Dynamic Credit Group
+31 20 7981383
Changes to this Privacy Statement
We can adjust this Privacy Statement. A new version is always published on our website. The latest version was published on 16 October 2020