Personal Data Privacy

For existing, former and future individual clients, and other individuals whose personal data are collected (hereinafter: “You”)

Hereby, we would like to present to you our commitment in protecting your personal data and respecting your privacy. KEP Trust (hereinafter “WE”), through this Notice, provides you with detailed data/information about the protection of your personal data. The purpose of the Personal Data Privacy Notice is to inform you about what personal data WE collect from YOU, the reasons why we use/collect such personal data, with whom we share such personal data, how long do we keep such data, what are your rights and how can you realize these rights in relation to your personal data.

 

You can get information in relation to implementation of your rights about your personal data at any time and whenever necessary; when you apply for a loan, other product or when you use a certain product or service.

  1. Your personal data that we collect and use?

1.1 In the framework of our activities, and to achieve a high standard of products and services, we may collect and use different types of personal data to the extent necessary, including: a) identification information, such as: name and surname, number of identity card/identification, place and date of birth, sex, photography; b) contact information such as: postal address and email address, telephone number); c) family status, such as: marital status, number of children; d) information on education and employment, such as: profession/school completed, employment, employer’s name; e) banking and financial data, such as: bank account details, statement of account; f) relationship with the client; g) information concerning your digital activities, such as; h) data related to your habits and preferences; h) data related to your use of our products and services;) data for your interactions with us: in our branches (contact reports), our websites, our applications, our social media, meetings, calls, conversations and e-mails, interviews, telephone conversations; j) data regarding your free activities and interests.

 

1.2 Your personal data to be collected and used by us, can be obtained directly from you or from the sources below, to verify or enrich our database:

  1. Specific cases of personal data collection, including indirect ones

Under certain circumstances, we can collect and use personal data of individuals with whom we have or may have or have had direct relations, or potential clients.

 

For several reasons, we can also collect information about you, while you do not have direct relationship with us. This may happen in cases when your employer gives us information about you or your contact details are provided by one of our clients if you are: a) family member; b) legal representative (with authorization); c) shareholder of the company; d) representative of a legal entity (which may be client or seller); e) employee of service providers and trade partner; f) personal contacts.

  1. Reasons and legal basis for collection and processing of your personal data?

3.1 We collect and use your personal data in accordance with different legal and regulatory obligations not limited to:

3.1.1 Compliance with laws and regulations of CBK  applicable for microfinance and financial institutions in accordance with which we: a) Establish security measures in order to prevent abuse and fraud or other prohibited activities; b) discover transactions that deviate from normal models; c) Register, when necessary, phone calls, conversations and e-mails during communication with you, etc; d) prevent money laundering and financing of terrorism; e) respond to an official request from a public authority or judicial authority; f) define your credit risk assessment and creditworthiness; g) identify you and for security issues; h) Compliance with laws and regulations in force;

3.1.2. Entering into a contract with you or to take steps according to your request prior to entering into a contract. These personal data are used in order to: a) provide you with information about our products and services; b) help you and respond to your requests/complains and to create communication with you; c) assess whether we can offer a product or service and under what conditions; d) offer products or services to our clients (in the context of cash management); e) manage and perform any payment (including loan repayment) with respect to the products and services requested by you.

 

3.1.3 Fulfillment of our legitimate interest – we use your personal data to distribute and develop our products or services, to improve risk management and to protect our legal rights, including: a) evidence of transactions; b) fraud prevention; c) training of our staff; d) management of IT, including management of infrastructure (e.g. common platforms), e) business continuity and IT security; f) Generation of statistics, tests and models collected for research and development in order to improve risk management or improvement of existing products and services or development of new ones;

 

3.1.4 Customizing our offer through: a) improving the quality of our financial products or services; b) advertising products or services that comply with your situation and profile, by making: a) segmentation of our clients and potential clients; and b) administration of a competition, promotional lottery, gifts, competition or other similar marketing campaign and event management; c) communication for our products, services, offers, news; Customer service, including answers to your questions; d) improvement and personalizing your experience in our websites and applications; e) Credit account maintenance including administration of any program related to loyalty or client rewards; f) processing and granting the price won through your participation in our promotional games; g) your data can be grouped in anonymous statistics that can be provided to professional clients to help them develop their businesses. In this case, your personal data shall never be disclosed and those who accept these anonymous statistics will not be able to ascertain your identity.

 

3.1.5 Respecting your choice – if we have requested your consent processing of your specific personal data, in certain cases such as: a) when the above mentioned purposes lead to automated decision making, which produces legal effects or affects you significantly. At that moment, we will inform you separately about the logics involved as well as the importance and projected consequences of such processing; a) if we need to perform further processing for purposes other than those above, we will inform you and, where necessary, take your consent; b) for interaction in social networks for purposes of organizing competitions.


  1.  With whom do we share your personal data?

4.1 To fulfill the purposes mentioned above, we disclose your personal data to: a) service providers that perform services on our behalf; b) financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law; c) Some regulatory professionals such as lawyers, notaries, external auditors, enforcement agents, our debt collection companies.

  1. How can you be informed about changes to this Personal Data Privacy Notice?

Based on continuous legal and business changes, we may need to update regularly this Data Protection Notice. We invite you to review the latest version of this Notice online, and we will inform you of any material change through our website or through other common communication channels.

  1. How long do we keep your personal data?

We will keep your personal data for a longer period than required in order to be compliant with the applicable laws and regulations, or our operational requirements, in relation to facilitating customer relationship management and response to legal or regulatory requirements.

  1. What are your legal rights and how can you realize such rights?

7.1 Based on the applicable laws and regulations, you have the right to be informed and to:

  1. have access to your personal data: to get information regarding the processing of your personal data and a copy of such processed personal data;
  2. correct your personal data: when you think that your personal data are incorrect or incomplete, you can request that such personal data be changed by informing us with the correct data;

delete your personal data: request to delete your personal data, to the extent permitted by law and regulations in force.

  1.  restrict the processing of your personal data: by request the restriction of processing your personal data.
  2. object the processing of your personal data: by objecting the processing of your personal data, for reasons related to your particular situation. You have the right to object the processing of your personal data for purposes of direct marketing, which includes profiling in relation to such direct marketing.
  3. withdraw your consent given for the processing of personal data: at any time after giving such consent for collection and processing of your personal data,
  4. transfer your personal data: when implemented legally, you have the right to have your personal data that you have provided to us; to have such data return to you or, when this is technically possible, be transferred to a third party.

7.2 In accordance with the applicable laws and regulations, in addition to the above rights, you also have the right to file a complaint with the National Agency for Protection of Personal Data/Information and Privacy Agency.

  1. How can you contact us?

If you have any question or comment about this Notice, please email use to the email address data_protection@keptrust.org

Withdrawing consent

Please provide your reasons for withdrawing your personal data processing consent by clicking here.