For existing, former, and future individual clients, as well as other individuals whose personal data is collected (hereinafter referred to as “You”).
With this notice, we aim to demonstrate our commitment to protecting your personal data and respecting your privacy. KEP Trust (hereinafter referred to as “We”) provides you with detailed information regarding the protection of your personal data through this Notice. The purpose of this Personal Data Privacy Notice is to inform you about the personal data we collect about you, the reasons we use/collect such personal data, with whom we share this personal data, how long we retain it, your rights, and how you can exercise these rights regarding your personal data.
To exercise your rights and obtain information regarding your personal data, you can access this information at any time and whenever it is necessary for you, such as when you apply for a loan, submit another application, or use a specific product or service:
1. What Personal Data Do We Collect and Use?
1.1 Within the scope of our activities and to achieve high standards of products and services, we may collect and use various types of your personal data as necessary, including:
a) Identification information: such as name and surname, ID/passport number, place and date of birth, gender, photograph;
b) Contact information: such as postal address, email address, phone number;
c) Family status: such as marital status, number of children;
d) Education and employment information: such as profession/education completed, employment, name of employer;
e) Banking and financial data: such as bank account details, account statements;
f) Client relationship information;
g) Digital activity information;
h) Data related to your habits and preferences;
i) Data concerning your use of our products and services;
j) Data from your interactions with us: such as in our branches (contact reports), our websites, applications, social media pages, meetings, calls, conversations, emails, interviews, and phone conversations;
k) Data related to your hobbies and interests.
1.2 Your personal data that is collected and used by Us may be obtained directly from you or from the following sources to verify or enrich our databases:
- Publications/databases made available by official authorities (e.g., official gazettes);
- Clients or service providers;
c) Websites/social media pages containing information made public by you (e.g., your website or social media); and
d) Databases made public by third parties.
2.Specific Cases of Personal Data Collection, Including Indirect Collection
In certain circumstances, we may collect and use the personal data of individuals with whom we have, may have, or have had a direct relationship, as well as potential clients.
For certain reasons, we may also collect information about you even if you do not have a direct relationship with us. This may occur in cases where your employer provides us with information about you, or your contact details are provided by one of our clients, such as in the case of:
a) A family member;
b) A legal representative (with authorization);
c) A shareholder of a company;
d) A representative of a legal entity (which may be a client or vendor);
e) An employee of service providers or business partners;
f) Personal contacts.
3.The Purpose and Legal Basis for Collecting and Processing Your Personal Data?
3.1 We collect and use your personal data in compliance with and to fulfill various legal and regulatory obligations, including but not limited to:
3.1.1 Compliance with CBK laws and regulations applicable to Microfinance and Financial Institutions, under which we:
a) Establish security measures to prevent abuse, fraud, or other prohibited activities;
b) Detect transactions that deviate from normal patterns;
c) Record, when necessary, phone calls, conversations, emails during communication with you, etc.;
d) Prevent money laundering and terrorism financing;
e) Respond to an official request from an authorized public or judicial authority;
f) Define credit risk assessment and your debt repayment capacity;
g) Identify you and address security matters;
h) Ensure compliance with applicable laws and regulations.
3.1.2. Making a contract with you or to take steps at your request prior to entering into a contract, this personal data is used to:
a) Provide you with information about our products and services;
b) Assist and respond to your requests/complaints and establish communication with you;
c) Assess whether we can offer you a product or service and under what conditions;
d) Offer products or services to our clients (in the context of cash management); and
e) Manage and execute any payments (including loan repayment) related to the services and products you have requested.
3.1.3 Fulfilling our legitimate interest we use your personal data to distribute and develop our products or services, improve risk management, and protect our legal rights, including:
a) Evidence of transactions;
b) Fraud prevention;
c) Training our staff;
d) IT management, including infrastructure management (e.g., shared platforms);
e) Business continuity and IT security;
f) Creation of statistics, testing, and models collected for research and development purposes, to improve risk management, enhance existing products and services, or develop new ones.
3.1.4 Personalization of our offer through: a) Improving the quality of our financial products or services;
b) Advertising products or services that align with your situation and profile, by:
Segmenting our clients and potential clients; and
Managing a contest, promotional lottery, giveaway, competition, or other similar marketing campaign or event management;
c) Communicating about our products, services, offers, and news;
d) Customer service, including responding to your inquiries;
e) Improving and personalizing your experience on our websites and applications;
f) Maintaining credit accounts, including managing any loyalty or customer reward programs;
g) Processing and awarding prizes won through your participation in our promotional games;
h) Your data may be aggregated into anonymous statistics that may be provided to professional clients to assist them in developing their business. In such cases, your personal data will never be disclosed, and recipients of these anonymous statistics will not be able to determine your identity.
3.1.5 Respecting your choice if we have requested your consent for specific processing of your personal data, in certain cases, such as:
a) When the aforementioned purposes lead to automated decision-making that produces legal effects or significantly impacts you. In such cases, we will separately inform you about the logic involved as well as the significance and anticipated consequences of such processing;
b) If we need to carry out further processing for purposes other than those mentioned above, we will inform you and, where necessary, obtain your consent;
c) For interactions on social networks for the purpose of organizing competitions.
4. With Whom Do We Share Your Personal Data?
4.1 To fulfill the aforementioned purposes, we disclose your personal data to: a) Service providers who perform services on our behalf;
b) Financial or judicial authorities, state agencies, or public bodies, as requested and to the extent permitted by law;
c) Certain regulatory professionals such as lawyers, notaries, external auditors, enforcement officers, and our debt collection companies.
5.How Can You Be Informed About Changes to This Personal Data Privacy Notice?
Based on continuous legal and business changes, we may need to regularly update this Data Protection Notice. We invite you to review the latest version of this notice online, and we will inform you of any significant changes through our website or other usual communication channels.
6.How Long Do We Retain Your Personal Data?
We will retain your personal data for a period longer than required to ensure compliance with applicable laws and regulations or any other period related to our operational needs, such as facilitating client relationship management and responding to legal or regulatory requests.
7.What Are Your Legal Rights and How Can You Exercise Them?
7.1 Based on applicable laws and regulations, you have the right to be informed as well as to:
- To have access to your personal data: receive information regarding the processing of your personal data and obtain a copy of the processed personal data;
- Correct your personal data: when you believe your personal data is inaccurate or incomplete, you can request that such personal data be corrected by providing us with the accurate information;
Delete your personal data: to request the deletion of your personal data, to the extent permitted by applicable laws and regulations.
- To restrict the processing of your personal data: by requesting the restriction of the processing of your personal data.
- Object to the processing of your personal data: object to the processing of your personal data for reasons related to your particular situation. You have an absolute right to object to the processing of your personal data for direct marketing purposes, including profiling related to such direct marketing.
- To withdraw your consent to the processing of personal data: withdraw your consent for the collection and processing of your personal data at any time after it has been given.
- To transfer your personal data: where legally applicable, have the right to have your personal data that you have provided to us returned to you or, when technically feasible, transferred to a third party.
7.2 In accordance with applicable laws and regulations, in addition to the above rights, you also have the right to file a complaint with: State Agency for Personal Data Protection/Agency for Information and Privacy.
8.How Can You Contact Us?
If you have any questions or comments regarding this Notice, please send your email to the following address: data_protection@keptrust.org