INFORMATION CONCERNING THE PROCESSING OF PERSONAL DATA
MIKRO KAPITAL IFN S.A., located in Iasi Mun., Str. Pacurari, no. 111-113, Jud. Iaşi, no. Banking Registry: RG-PJR-24-110315 / 23.09.2016, no. in the Register of Commerce of Iasi Tribunal J22 / 378/2016, Unique Registration Code 35643645, subscribed capital and paid 14,100,000 Lei, enlisted in the Register of personal data recorders at no. 37741 (“MIKRO KAPITAL IFN SA” or “the institution”), as a data controller, we communicate this Information to explain how we process and protect your personal data.
1. Personal data and processing thereof
We process the following categories of data relating to a natural person that can be identified, directly or indirectly:
– information on identification data: name, surname, CNP, serial number and identity card number, passport and other information contained therein (eg date and place of birth, nationality), home address, correspondence address, e-mail, telephone (fixed, mobile, fax), online identifier;
– the occupation, the name of the employer, the nature of his / her own activity, the public office held, the political exposition (if any);
– financial information (eg, income, transaction data);
– information about fraudulent / potentially fraudulent activity, consisting of data related to investigations and convictions related to crimes such as fraud, money laundering and terrorist financing;
– information resulting from the video if you visit one of the locations of Mikro Kapital IFN SA;
– any other information that results from the processing (such as customer segmentation by different criteria, the unique institution-level identifier for each individual customer, specific information about the products and services contracted from Mikro Kapital IFN SA and how the Customer has used it)
– any other information that is required to conduct our activities for the purposes below.
Individuals whose personal data are processed are named “Persons targeted”.
2. What is the processing of personal data?
Processing means operations such as: collecting, recording, organizing, storing, modifying, retrieving, consulting, using, transmitting, combining, blocking, restricting, deleting, destroying, archiving personal data, etc.
3. Who owns the personal data that Mikro Kapital IFN SA handles?
(a) The processing of personal data refers to the Client, the Client’s legal or conventional agents, as well as to the persons whose data is provided to us by the Customer for the purpose of obtaining a product, performing a service (for example : spouse, wife, child, parents, beneficiary of a payment transaction, guarantor of a credit, beneficiary of insurance, persons subject to the attachment procedure, natural persons whose data are provided in the documents provided by clients or other persons using the services our, etc.). (b) If the Customer is the one who provides us with information about other persons, he / she has the obligation to inform those concerned about the content of this document regarding the processing of personal data.
4. Where do we collect personal data from?
The data are obtained directly from the Client and / or from a Customer’s representative (when completing forms or documents of Mikro Kapital IFN SA, the website is accessed, or by any other means of communication). In addition, Mikro Kapital IFN SA can obtain the above data by consulting external sources. By external sources, we understand public institutions and authorities, public registers, electronic databases, information available in social media and on the Internet, or third parties who possess such information, such as but not limited to: Personnel Evidence and Database Administration, National Trade Register Office, Credit Bureau SA, the portal of courts in Romania administered by the Ministry of Justice, third parties authorized to hold databases of persons accused of terrorism or politically exposed, etc.
5. The purposes of processing personal data
(a) The purposes for which Mikro Kapital IFN SA processes personal data are:
– identifying the targeted persons both in the physical locations of the institution and through the means of communication (eg telephone, e-mail, mail, internet);
– providing credit products;
– Performing preliminary analyzes (eg analyzing the exposure to the risk involved in providing a product / service of Mikro Kapital IFN SA), which aims to assess the Client / other person concerned in order to decide on the conclusion of certain financial transactions or contracting of certain products;
– checking the Client / other person concerned for identifying, preventing and combating fraud, financing terrorism and money laundering;
– carrying out economic, financial and / or administrative management activities within the institution;
– the centralization of operations and the maintenance of an internal database in which the information about the data subjects is stored so that they can be used by the departments and structures of the institution in their activity (eg the use of such data involves processing them by applications internal documents of Mikro Kapital IFN SA which are used by the relevant departments in the conduct of business);
– contacting the Client / other person by means of the means of communication with the purpose of informing / notifying information about Mikro Kapital IFN SA products contracted (eg: expiration, failure to fulfill obligations, modification / completion of features / costs / functionalities / benefits )
– provision of support services for the Client / person’s requests (eg additional information about Mikro Kapital IFN SA products, updating some of the identification data, conducting investigations on the malfunctions of the products and services offered, solving the claims, complaints and petitions formulated) both in the physical locations of Mikro Kapital IFN SA and through the means of communication (eg telephone, e-mail, mail);
– evaluation of your financial and commercial behavior during the relationship with Mikro Kapital IFN SA;
– creating or analyzing profiles for the improvement of the products / services of the institution, for personalized / general promotion by Mikro Kapital IFN SA and / or other entities within the Mikro Kapital Group and / or by Mikro Kapital IFN SA partners, for any other types of promotion of the products / services of the institution, or direct marketing activities by any means of communication (eg communication by mail, telephone, fax, e-mail, SMS of advertisements addressed directly and specifically to a particular person ) if the Customer has accepted this via the Online Application or by any other form / form of Mikro Kapital IFN SA;
– Carry out general marketing or advertising activities, loyalty activities and surveys;
– performing internal analyzes (including statistical analyzes) on both products / services and customer portfolio, improving and developing products / services, and conducting market studies and analysis of products / services Mikro Kapital IFN SA for the improvement and development of the institution’s products / services;
– Developing models to streamline the way in which the entire Mikro Kapital IFN SA network operates and all credit processes, as well as financial analyzes on the costs, budget and profitability of the institution’s network;
– generating reports on the financial activity of the institution in order to facilitate the operational management of all processes, as well as to analyze the performance of the institution;
– Analyzing the counterparty risk in relation to other Banks and financial institutions in the market, analyzing the profit and losses recorded on the financial markets;
– the creation of charging schemes for sales force representatives, as well as the calculation of commissions to which sales force representatives are entitled as a result of their business activity;
– performing debit collection and / or debt collection or management of such activities;
– archiving in both physical and electronic formats of documents, making of mail correspondence services sent to and sent by the institution, as well as carrying out courier activities;
– settling disputes, investigations or any other petitions / complaints / requests to which Mikro Kapital IFN SA is a party;
– carrying out risk controls on the procedures and processes of the institution, as well as carrying out audits or investigations of the institution;
– reporting to the competent institutions according to the legal regulations applicable to the institution;
– to monitor customer activity to detect unusual transactions and suspicious transactions;
– for the video recording of the presence of persons in the physical locations of Mikro Kapital IFN SA, in order to maintain a high level of security.
(b) Please note that personal data are sometimes used by Mikro Kapital IFN SA for a number of secondary purposes (eg for archiving, internal audit, external, etc.), which are always consistent with the main purposes, for which the data were originally collected by the institution.
6. Subjects of personal data processing by Mikro Kapital IFN SA
We process your personal data for the purposes mentioned above, based on the following:
– based on the Customer’s consent, if it has been granted to us (eg in the case of direct marketing or automated decisions that produce significant legal effects or significant similar effects and which are not necessary for the performance of a contract or the fulfillment of a legal obligation);
– for the performance of a contract to which the Customer / the person concerned is a party (eg: providing financial services providing support services for your requests, sending notifications / information about the product held) or for pre-contractual steps at Client’s request concluding a contract (eg conducting preliminary client evaluation and acceptance analyzes) or providing Customer with information on the products held or support for their use;
– based on a legal obligation under the responsibility of Mikro Kapital IFN SA (eg identification and knowledge of customers, identification and prevention of fraud, reporting of financial activity parameters);
– based on the legitimate interest of the institution (eg centralizing operations and maintenance of internal databases, analyzing ideas to streamline the way they operate the whole network of Mikro Kapital IFN SA and all processes, performing statistical analysis on portfolio of customers, fulfilling current operations for the activities of the institution by making relationship management Mikro Kapital IFN SA, analyzing and minimizing financial risk, reputational they expose the institution in connection with the provision of services and financial products, accumulation of high levels of knowledge of the financial market, planning a strategic development of the institution, development and improvement of Mikro Kapital IFN SA products and services, ensuring a high level of security at the level of the IT systems (eg applications, network, infrastructure, pag ina web) and physical locations (e.g., back office, front office, headquarters); maintaining the stability of the financial system, in particular as regards the discovery and minimization of fraud risks that may affect the institution);
– for reasons of public interest, namely, reducing the risk associated with contracting with a politically exposed person, as stated in Law 656/2002 on preventing and sanctioning money laundering as well as on measures to prevent and combat terrorist financing .
7. Communication of data by the client. Consequences in case of refusal.
Processing of personal data required by Mikro Kapital IFN SA in application online / other forms / channels is mandatory, unless the processing is based on the approval of the Client (eg in case of direct marketing or making automated decisions which produce significant legal effects or similar effects and which are not necessary for the performance of a contract or the fulfillment of a legal obligation), in which case the Customer will be informed that the provision of the data or the agreement is optional. In other cases, Customer’s refusal will cause Mikro Kapital IFN SA to be unable to provide services or products.
If you voluntarily provide us with personal data by interacting with our Website or by contacting us by phone, e-mail or in any other way, by our own will and not by our request, we will delete personal data from our systems unless we consider that processing is necessary for a legitimate purpose of Mikro Kapital, unless you have made this data public, in which case we will delete this data from our Website only if the law imposes it or if we do not want to preserve it.
8. Transmission of personal data
(a) Recipients of data may be:
– Service providers: IT services (maintenance, software development), physical and / or electronic archiving; courier; utilities; audit; support services; market research service providers, marketing communications, personalization services for various types of marketing, marketing services through social media resources, content marketing services; debt recovery and / or debt collection services, valuers, real estate agencies;
– Court judges and notary offices, the Credit Bureau, external consultants who give us advice or assist us in exercising and defending court rights;
– Financial-banking / non-banking institutions in Romania and abroad;
– Judicial bodies in Romania and other countries, such as members of the courts, arbitration courts, prosecutor’s offices;
– Public institutions for the supervision of the financial and financial market management (eg: the National Bank of Romania, the Competition Council);
– Central and local public authorities (eg National Authority for Fiscal Administration, National Office for Preventing and Combating Money Laundering) in Romania and other countries, police bodies;
– Investigation and support for cyber security incidents;
– Entities to which the institution has outsourced the provision of financial services;
– The institution’s office network or other financial product intermediaries;
– The parent company (Mikro Kapital SARL) and other companies in the group of companies, including brokerage companies, etc.
9. Period for which Mikro Kapital IFN SA processes personal data
In order to achieve the aforementioned purposes, the personal data will be processed by the institution throughout the contractual relationship and after its completion in order to comply with the applicable legal obligations in the field, including but not limited to the archiving provisions.
10. Rights of the data subject and exercise of those rights
(1) The person concerned has the following rights:
– Right to information – the right to receive detailed information about the processing activities performed by Mikro Kapital IFN SA, as provided in this document;
– The right of access – may request and obtain confirmation that his or her personal data is or is not processed by Mikro Kapital IFN SA and, if so, may request access to such data as well as certain information. Upon request, Mikro Kapital IFN SA will also issue a copy of the processed personal data, with additional copies being priced according to the actual costs of the institution;
– Right to rectification – the right to obtain inaccurate personal data rectification and completion of incomplete data;
– The right to delete data (“the right to be forgotten”) – in situations expressly governed by law (especially in the case of withdrawal of consent or in the case where personal data processing is found not to be lawful), may obtain the deletion those data. Following such a request, Mikro Kapital IFN SA can anonymize the data, depriving it of its personal character and further processing it for statistical purposes;
– The right to restrict processing – in situations specifically governed by law (especially when the accuracy of such data is challenged for the time necessary to determine this inaccuracy or if the processing is illegal and the deletion of the data is not desired, but only the restriction )
– Opposition Right – may at any time object, for reasons related to its particular circumstances, to processing based on the legitimate interest of Mikro Kapital IFN SA (including the creation of profiles) or to the pursuit of a public interest or authorization with which the institution is invested;
– The right to data portability – can receive personal data in a structured format that can be read automatically or request that the data be passed to another operator. This right applies only to: (i) for personal data provided by the Customer to the institution, (ii) whether the processing of personal data is by automatic means, and (iii) whether the processing is legally based on either the execution of a contract, or the consent of the person concerned;
– The right to lodge a complaint – may lodge a complaint with the personal data processing of Mikro Kapital IFN SA with the National Supervisory Authority for Personal Data Processing;
– Right of withdrawal of consent – in cases where processing is based on consent, it can be withdrawn at any time. Withdrawal of consent will only have effect for the future, and processing prior to the withdrawal will remain valid;
– Additional rights related to automated decisions used in the process of providing services and products Mikro Kapital IFN SA – If the institution makes automated decisions about personal data, the person concerned may (i) request and obtain human intervention that processing, (ii) can express its views on that processing, and (iii) contest the automatic decision.
(2) The Customer may exercise these rights, either individually or by aggregation by submitting a written, dated and signed application, at the headquarters of Mikro Kapital IFN SA mentioned in the Preamble of the Information or by fax 0374 824 092 or by e-mail: protectidatele @ mikrokapital ro .
(3) In addition, a Data Protection Officer (DPO) was appointed at the level of the institution, which can be contacted if there are any concerns about any aspect related to the protection of personal data by submitting a written, dated and signed at the following contact details: Mun. Iasi, Str. Pacurari, no. 111-113, Jud. Iasi, or by fax 0374 824 092 or by e-mail: firstname.lastname@example.org.
11. Automated individual decision-making processes
(1) In order to provide services and products, as well as to identify and combat fraud, Mikro Kapital IFN SA uses automated individual decision-making processes, including the creation of profiles exclusively by automated individual means, resulting in decision-making regarding the Client. These processes only occur when they are necessary for the conclusion or performance of a contract, have been accepted by the Customer or are authorized by law.
(2) Mikro Kapital IFN SA has the legal obligation to apply customer awareness measures to prevent and combat money laundering and terrorist financing. In the process of acceptance of any Client, Mikro Kapital IFN SA has established client categories with which it wishes to enter into contractual relations and customer categories which it will refuse because it presents a high risk of performing money laundering activities and / or the financing of terrorism. To determine which of the two categories you will be included at the time of the request to open the relationship, Mikro Kapital IFN SA adopts automated decisions through an automated, automated decision-making process. Through this process, the institution automatically consults a database to determine whether the prospective Client has been convicted for economic / fraud offenses or has fraudulently behaved in relation to Mikro Kapital IFN SA which has led to the closure of the relationship. The consequences of such a decision are the refusal to open the relationship in cases where Mikro Kapital IFN SA discovers that he has committed or participated in acts of fraud.
(3) Mikro Kapital IFN SA also uses automated individual processes for the pre-bidding and granting of credit products as well as for the measures the institution will follow in the event that a Client of Mikro Kapital IFN SA becomes unable to return the loan. Extensive information on how the automated processes used to make decisions in the cases mentioned above and details of the consequences of such decisions and the rights of Clients related to them will be found in the information on credit products.
(4) In order to transmit personalized offers as close as possible to the Client’s interests, Mikro Kapital IFN SA, members of the Mikro Kapital Group and the Partners of the Institution (depending on Customer’s options) process all or part of the data that the Customer provides directly in the context the contractual relationship with Mikro Kapital IFN SA, the data provided by the Client Credit Bureau (to the extent permitted to process these data), as well as data resulting from the contractual relations relating to the products and services previously acquired by
Client. The computer techniques / algorithms used in this process, which allow identification of client preferences and / or behaviors, do not involve the presence of a human factor (including profiling) and may have legal effects on the Client or may affect it to a significant extent.
In order to provide services and products, Mikro Kapital IFN SA develops various profiles regarding its Customers. These profiles do not imply automated decision making, such as those mentioned above. Such profiles are used:
– for the detection of persons accused of terrorist acts, offenses that may affect the security and integrity of the financial system, as well as to analyze the degree of political exposure of Clients. These profiles are based on consulting public databases containing such information, processing information directly from Customer, and verifying the client’s transaction history. The consequences of these profiles may consist of restricting access to Mikro Kapital IFN SA’s products and services if the Customer is found in the above mentioned databases;
– in order to segment the Client portfolio of Mikro Kapital IFN SA for the development of the products and services of the institution, as well as to ensure the personalized promotion of Mikro Kapital IFN SA and the members of the Mikro Kapital Group and the Partners of the institution, as well as to ensure direct marketing activities taking into account the products owned by Clients, the transaction history and their preferences resulting from the way of using the products and services.
12. Video monitoring
(2) To ensure a high level of security for the financial activity, all physical locations of Mikro Kapital IFN SA are monitored video. In these locations there are corresponding markings with video-specific symbols, followed by the “Video Surveillance Area” message.
This update may support updates that will be notified by posting the new version on our website: www.mikrokapital.ro or in any location of the institution.
Please refer to this Information periodically for any changes.