Data processing policy

The Controller

1. The controller is Traffic Control is Traffic Control OÜ (“Traffic Control”), the company established in Estonia and registered in the Estonian Commercial Register under no. 11501857.
2. To contact Traffic Control click here. Otherwise, please send your correspondence to the following address:
Traffic Control OÜ
Laeva 2, 10111,
Tallinn
Estonia
3. To contact Traffic Control's Data Protection Officer, please send your e-mail to: [email protected] or to:
Data Protection Officer
Traffic Control OÜ
Laeva 2, 10111,
Tallinn
Estonia

Processing of personal data

4. Traffic Control processes personal data for the following purposes:
4.1. the fulfillment of its contractual obligations, including the sending of personal data to the loan providers, in accordance with the Terms and Conditions
The basis for the processing of personal data is provided for in Article 6 (1) (b) of the General Data Protection Regulation. The contract concluded between Traffic Control and a data subject is concluded precisely the stipulation that Traffic Control may forward the personal data provided by the data subject to a service provider. Please note that not all personal data provided by the data subject will be forwarded to each loan provider. Different loan providers request different data. However, since Traffic Control does not know in advance to which loan provider a data subject's data will be sent, it collects sufficient data to ensure that each loan provider with which Traffic Control maintains professional relationships performs the initial evaluation by approving or declining to grant the loan; (in order to obtain the final decision, a loan provider may request additional data, in light of the principle of data size minimization, Traffic Control does not collect such data).

4.2. settlement of accounts with transaction partners,

The basis for the processing of personal data is provided for in Article 6 (1) (f) of the General Data Protection Regulation. Loan providers pay Traffic Control to send them data and information about data subjects who wish to receive loans, in order to lend money to those data requesters. The amounts Traffic Control pays to its own vendors (e.g., websites that post advertisements on this website or websites that collect personal data and send it to Traffic Control to forward to the loan providers) depend on the number of people who access this website through those vendors.
4.3. taking the necessary actions for the prevention of fraud
The basis for processing personal data is provided for in Article 6 (1) (f) of the General Data Protection Regulation (and in some cases Article 6 (1) (c) of the General Data Protection Regulation). Traffic Control is interested in not being defrauded and may be subject to legal obligations to the loan providers to ensure that it does not send to the loan providers any data or information, interested in fraud or misinformation. Even if there is no such direct legal obligation, sending information about scammers or sending incorrect information to a loan provider will likely cause the loan provider to consider terminating its relationship with Traffic Control or taking legal action against Traffic Control.

4.4. compilation of analysis on the use of this website and the services provided by Traffic Control
The basis for the processing of personal data is provided for in Article 6 (1) (f) of the General Data Protection Regulation. The performance of the analyses is necessary for Traffic Control to have sufficient information about its business to develop and execute its business plans (e.g. information about successful marketing channels, information about which features of this website are used by users, etc.). This is necessary, among other things, to provide the interested parties with a better service.
4.5 direct marketing.
The basis for the processing of personal data is Article 6 (1) (f) of the General Data Protection Regulation. Traffic Control does not accept money from data subjects for the services available to them through this website. Considering the expense of marketing within the general line this would not be possible without direct marketing.
5. Traffic Control will not be able to perform its tasks as stipulated in the Terms and Conditions, unless the interested parties complete all fields of the application form.
6. In addition to the personal data entered by the data subject himself, Traffic Control collects personal data belonging to the following categories:
6.1. Location (including IP address) from which and when the data subject accesses this website,
6.2 how the user has come to this website (e.g., through a Traffic Control partner that submitted an advertisement for this website or a partner that collects the user's personal data and then sends it to Traffic Control, etc.),
These data are obtained from the website through which the user accessed this website.

6.3. response from the loan providers.
This information is obtained from the loan providers.
7. Traffic Control transfers the personal data collected by it to recipients belonging to the following categories:
7.1. loan providers,
7.2. email providers,
7.3. SMS service providers,
7.4. analysis providers,
7.5. providers of servers and network access (such as the Internet).
8. In addition, Traffic Control's IT and marketing subcontractors that process personal data on the same servers where Traffic Control stores personal data may have access to this personal data.
9. Traffic Control does not transfer personal data outside the European Union.
10. Without prejudice to the interested party's right to withdraw, Traffic Control stores personal data for a longer period of time during the following periods:
10.1. a period of ten years from the moment the data subject used or accessed the data. I visited this website for the last time. The storage of the data allows the data subject easier and simplified use of this website and the services provided by Traffic Control (for example, it is not necessary to re-enter all data again to send information). ;n to loan providers). Also, it makes it easier for Traffic Control to provide better services to its clients, as well as how to determine if payment is already due to the partner (for example, a partner should not be paid for referring to Traffic Control of a client that that partner has already referred to Traffic Control);
10.2. the period in which the contractual claims of the following contracts are prescribed: contracts between (i) Traffic Control and the interested party, (ii) Traffic Control and loan providers to whom the contract was referred. information about the data subject (iii) ) between Traffic Control and contractual partner from whose website the data subject arrived. to this website;
10.3. the period for which the lender is required to maintain information about the borrower under applicable laws (including applicable anti-money laundering and terrorist financing laws) when Traffic Control is in effect. outside of his duty, whether contractual or not, to the relevant lender to assist the lender with the collection of data about the borrower, information which the lender must retain.
11. The interested borrower may at any time withdraw any consent to the processing of personal data that he has provided to Traffic Control.
12. Traffic Control makes decisions based on the automated processing of personal data, including profiles. Such processing of personal data is necessary for the performance of the contract with the data subject or is based on the consent of the data subject. If a data subject does not agree to such processing, Traffic Control will not be able to do so. provide the services referred to in the Terms and Conditions. On the one hand, such processing is necessary to determine the order in which information is sent to loan providers. Without it, Traffic Control would not be able to perform its tasks under the Terms and Conditions. On the other hand, such processing is necessary to provide interested parties with commercial communications with consumer loan offers. It is also necessary to exclude the presentation of certain marketing materials to certain data subjects. Without it, Traffic Control should not collect money from interested parties for the use of this website.

Rights of the Borrower with personal data

13. The interested party has the following rights:
13.1. obtain confirmation from Traffic Control if personal data concerning you are processed,
13.2. Where personal data concerning you is processed, obtain from Traffic Control the information referred to in Article 15 (1) of the General Data Protection Regulation,
13.3. to request that Traffic Control rectify incorrect personal data belonging to the data subject,
13.4. provide Traffic Control with additional data to complete incomplete personal data relating to the data subject.
13.5. request that Traffic Control delete, in accordance with the conditions established in article 17 of the General Data Protection Regulation, the personal data belonging to the interested party;
13.6. request that Traffic Control restrict the processing of personal data belonging to the interested party in the situations explained in article 18 (1) of the General Data Protection Regulation,
13.7. receive from Traffic Control, in .csv format, the personal data that you have provided to Traffic Control,
13.8. deny the processing of your data for direct marketing purposes,
13.9. object to the processing of your personal data when Traffic Control processes personal data for purposes contrary to other legitimate interests pursued by Traffic Control. Traffic Control will cease processing unless there are legitimate grounds for the processing that override the interests, rights and freedoms of the data subject or the processing is necessary for the establishment, exercise or defense of legal claims
13.10. file a complaint with a supervisory authority.
14. To exercise any of the rights mentioned in clause 13 (except the right to lodge a complaint with a supervisory authority) the interested party must write to Traffic Control using this form. Traffic Control will respond to the request without undue delay and, in any case, within one month of receipt of the request (this period may, taking into account the circumstances, be extended by two months). Response time will depend on on the number of requests Traffic Control receives and the content of a particular request.