Privacy Policy

BASIC INFORMATION ON DATA PROTECTION

RESPONSIBLE FOR THE TREATMENT :

Classic Garden Loans, SL (hereinafter, "LOAN").

NIF: A34562399

West Street, 52, 1a. 08010, Burr Ridge

info@classicgardensinc.com

Data Protection Officer: dpo@classicgardensinc.com

PURPOSE : Provision of loan intermediation service, management of the relationship with our users, marketing activities of our services, the forwarding of the loan application to the lenders, as well as the management of the resolution of doubts and queries that may be generated on our service and manage the personnel selection processes.

The data will be kept as long as the commercial relationship is maintained or its deletion is not requested by the interested party, they should not be eliminated because they are necessary for the fulfillment of a legal obligation or for the formulation, exercise and defense of claims.

ORIGIN: Provided by the user himself, directly or indirectly.

BASES OF LEGITIMATION:

- The execution of the contract with the user.

- Classic Loans's legal obligations.

- The legitimate interest of Classic Loans in relation to commercial communications related to its products or services.

- The consent of the user, to send commercial communications from third parties, always through Classic Loans, or the installation of monitoring systems according to the Cookies Policy.

RECIPIENTS OF ASSIGNMENTS : All are necessary for the fulfillment of the aforementioned purposes, or they are carried out in compliance with a legal obligation. Public Administrations, providers for the provision of the requested services, companies and collaborating entities.

RIGHTS : Access, rectify and delete the data, as well as oppose the treatment, limitation of the treatment, portability, and where appropriate, not to be the subject of automated individual decisions, including profiling.

Who is the data controller?

This is the relevant information of the Person Responsible for the Treatment of the personal data that is processed and provided by users:

RESPONSIBLE FOR THE TREATMENT OF THE DATA

Identity : Classic Garden Loans, SL (hereinafter LOAN)

Address : West Street 52, 1a, 08010, Burr Ridge

Telephone : 93 271 01 86

Email : info@classicgardensinc.com

At Classic Loans we are committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you about your rights under the General Data Protection Regulation (“RGPD”).

We inform you that Classic Loans has a Data Protection Delegate in accordance with the RGPD, who is at your disposal for any questions or queries you want to make in relation to this matter, and who you can contact from here .

What information do we process?

The information that we receive from users, which will be treated with the utmost confidentiality, is collected as explained below.

a) Information that users provide us directly : Classic Loans collects and stores certain information that the user enters voluntarily on the Classic Loans website or that is provided in any other way either through a phone call or email.

Request for loan, information, consultations or services:

The information that the user provides us when they send us an email or contact us by telephone. Likewise, the user also provides us with their information when making a loan application on the Classic Loans website (section ¨Loan application¨). That is, name and surname, e-mail, ID, telephone. Additionally, the following data may be processed, among others: date of birth, IP address, employer data (company name, telephone number and address), profession, current loans, voice (calls may be recorded exclusively for quality reasons , and it may be communicated to the collaborating entities as long as there is a firm proposal from the latter to the interested user), as well as any other information that you provide us in the loan application. Likewise, we may process other types of data that the user voluntarily provides us.

Data quality :

The user must guarantee, both against Classic Loans and against third parties, the quality of the information and personal data provided through the Classic Loans website, email or phone call. This implies that all personal data and information provided must be real, truthful, updated and belong to the user and not to third parties. In the event that they belong to third parties, we understand that it is through their consent and we request that said third party be invited to know our legal texts as soon as possible.

All the fields that appear marked with an asterisk (*) in the forms provided in the channels must be completed, in such a way that the omission of any of them could make it impossible for the requested services to be provided.

The user may not, when providing any information that may be requested on the channels, choose abusive expressions, coinciding with brands, commercial names, names or pseudonyms of publicly relevant or famous people for whose use they are not authorized.

Data modification :

The user must notify Classic Loans of any modification that occurs in the personal data provided, responding in any case to the veracity and accuracy of the data provided at all times.

b) Information that users provide us indirectly :

Data derived from the use of the Web:

Classic Loans collects the data derived from the use of the Web by the user each time he interacts with the Web.

Data derived from "cookies":

Classic Loans uses cookies to facilitate navigation for its users.

Data provided by third parties:

Classic Loans may receive data from third-party collaborating companies, to which the user has provided them, consenting to their communication to PRESTALO.

What is the origin of the data?

We consider that all the data of the users that are treated by Classic Loans have been freely provided.

In the event that they belong to third parties, the user guarantees that they have been informed of this Privacy Policy and their authorization has been obtained to provide the data to Classic Loans for the purposes indicated above. Likewise, the user guarantees that the data provided is accurate and up-to-date, becoming responsible for any direct or indirect damage or loss that may be caused as a result of breach of such obligation.

For what purpose and on what legitimating basis do we process the data?

PURPOSE OF THE TREATMENT:

Provision of services:

Based on the management of the contractual or pre-contractual relationship, we carry out the following treatments:

- Provide the corresponding services (a.- Loan application registration, identity verification, b.- Data analysis in the loan application and information in credit reports, c.- Forwarding of the loan application to the lenders with those who collaborate in accordance with the basic requirements of the lender on the borrowers, d.- Contact by email, sms, telephone and ordinary mail if applicable, e.- Customer service management, f.- Present loan offers, decisions rejection, etc.).

- Manage your registration as a registered user on our website, as well as allow your access to the reserved area.

- To provide you with the services that you have requested and to attend to your requests for information, as well as to facilitate the exercise of your rights.

- Assess the CVs received and manage the selection processes.

Based on the existence of a legitimate interest on the part of Classic Loans:

- Keep you informed about the products and services of Classic Loans, as well as send you news by conventional means and / or electronic means (emails, SMS, ...), related to the products or services that we commercialize and that may be of interest to you. In any case, you can avoid sending new commercial e-mails by requesting it at the email address info@classicgardensinc.com or through the link that appears in the body of each of the e-mails we send and consequently, PREST IT will immediately cease sending the aforementioned information. Likewise, personal data may also be used to send service messages by SMS.

- Segmentation, emails, marketing analysis, creation of "lookalike" audiences and personalized audiences on Facebook, creation of "Similar audience" and personalized audiences in the Google Adwords advertising network and to provide information that the user requests through of the "loan application" form and / or via email or phone call, contact details that appear in the "contact" section on the Classic Loans website.

Based on the consent given by the user:

- Keep me informed about third-party products and services, always sent through Classic Loans, and provided that you have given us your express consent to do so, by conventional means and / or emails (emails, SMS, ...), related to the sectors leisure, travel, culture, art, music, insurance, gastronomy, environment, sports and technology.

Automated decision making:

Automated decision making refers to a decision that is made solely on the basis of the automated processing of your personal data. Classic Loans uses automated decision making when you use our service. This means that the information you have provided and the information we receive through a loan application is automatically matched with the basic requirements of the borrowers with whom we collaborate to make a loan, for example: income, form of employment, loan amount requested. These automated decisions are necessary to enter into or execute a contract with the user and are intended to provide a fair and accurate loan service and it is necessary that we comply with the agreement that we have entered into with the user. If the user has an objection to an automated decision made by Classic Loans, they should contact us info@classicgardensinc.com .

How long will we keep the data?

The personal data of the users of Classic Loans will be kept exclusively for the time necessary to provide the agreed and / or requested products or services, and to fulfill any of the objectives mentioned in this Privacy Policy. All this, as long as the user has not requested the withdrawal or cancellation of these.

Likewise, Classic Loans will block and keep personal data for the time necessary to comply with the different legal obligations that correspond to it and in case the data were requested at any time by a judge, court or administrative authority. Law 10/2010, of April 28, on the prevention of money laundering and terrorist financing establishes that they will be kept for a period of 10 years. During this conservation time, the data will not be used for any other purpose apart from those mentioned. Once the legal retention periods and the limitation periods for actions applicable in each case have ended, we will permanently delete your personal data.

To which recipients is the data communicated?

As indicated in the previous sections, the personal data that Classic Loans collects will be exclusively used to achieve the objects defined in this Privacy Policy. We take all reasonable contractual, legal, technical and organizational measures to ensure that your personal information is processed securely and with an adequate level of protection when transferred or shared with selected third parties as detailed below.

To achieve these objectives and the correct provision of services, Classic Loans could share certain personal data of users:

- Prior legal requirement, PRÉSTALO may share information with executive authority bodies and / or third parties regarding requests for information related to criminal investigations and alleged illegal activities. Therefore, you can provide the necessary information to authorities such as the Police, Bank of Spain or other authorities if required by law. An example of a legal obligation to provide information is for measures against money laundering and terrorist financing.

- It is reported that, for a loan comparison, we will send your request to the lenders with whom we collaborate , whose basic requirements are in accordance with your request. The lenders who receive your application are personally responsible for their own processing of personal data. This data communication may be carried out both before and after having requested and / or received a loan.

- Likewise, and if required, they may be provided with the recording of the call so that they can verify the information provided and the correct provision of the service.

- With the consent of the user: apart from what is established above, the user will be informed in the event that any information about the same is made known to the commercial partners of the web, or to third parties, with a character other than those purposes set out in this Privacy Policy (eg: for commercial purposes), so that you have the opportunity to decide not to share your information. None of the above data communications will include selling, renting, sharing or otherwise disclosing personal information of clients for commercial purposes in a manner contrary to the commitments made in this Privacy Policy.

- We also inform you that some companies subcontracted by Classic Loans may have access to your personal data and personal information, always under the exclusive control of Classic Loans, such as companies that provide computer services, tools or computer infrastructure on which the services of Classic Loans (hosting providers, CRMs, emailing service companies, etc.), in its capacity as Treatment Manager.

In the same way, Classic Loans guarantees that if there are suppliers that are located in countries outside the European Union or others not considered adequate in accordance with data protection regulations, the necessary precautions are taken to guarantee that the data can be transferred. securely, either because the provider offers adequate guarantees, through, among others, its participation with the Privacy Shield or Privacy Shield EU-US and Swiss-US, the signing of Standard Contractual Clauses of the European Commission, or either one of the exceptions included in the regulations is met.

What rights does the user have against the data provided?

The user may exercise the following rights before Classic Loans:

- Right to request access to the personal data related to the interested party, to know which are being processed and the processing operations carried out with them.

- Right to request rectification (inaccurate data) or deletion (when the data is no longer necessary for the purposes for which it was collected).

- Right to request the limitation of its treatment when the accuracy, legality or need for the treatment of the data is doubtful, in which case, in which case we will only keep them for the exercise or defense of claims.

- Right to object to automated decision making , including profiling.

- Right to object to the treatment when the legal basis that enables us to process it is the ultimate interest. Classic Loans will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.

- Right to data portability , when the legal basis that enables us to process it is the existence of a contractual relationship or the consent of the user.

- Right to revoke the consent granted to PRESTALO.

To exercise the aforementioned rights provided for in the legislation, the user can contact Classic Loans through the email info@classicgardensinc.com or by writing to the address that appears in section 1 of this Policy. The communication will contain the following data and documents:

-Name and surname of the interested party, attaching a photocopy of the DNI or providing any other information that unequivocally identifies him and, where appropriate, of the person who represents him; the use of electronic signature will exempt from the presentation of these documents.

-Indication of the address of the interested party and request in which the request is specified (the right that is intended to be exercised).

The user will also have the right to file a claim with the corresponding Spanish Agency for Data Protection / Control Authority ( www.aepd.es ), when deemed appropriate.

In addition, we inform the user that they can sign up for the Robinson List at www.listarobinson.es : the advertising exclusion system managed by the Spanish Association of Digital Economy (ADIGITAL), in which they can register in order to show their opposition to that your data be used in order to send you commercial communications.

How do we protect the data of our users?

Classic Loans informs the user that it has adopted the necessary technical and organizational measures required by current regulations on Data Protection to guarantee the security of their data, in order to avoid the alteration, loss, access or unauthorized treatment of the data. themselves.

As mentioned, the personal data provided by users through the Classic Loans website will not be transferred to other entities or companies to be used for their own purposes. However, some companies subcontracted by Classic Loans may have access to personal data and personal information, always under the exclusive control of Classic Loans, with the sole purpose of providing a service necessary for the proper functioning of the Classic Loans website.

Retention periods and Cookies

We will only keep your data for as long as necessary to offer you these services. Any of the data that you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available in the event that there is a legal obligation (derived from a request from the Security Forces of the State or Courts and Tribunals) as well as when you exercise your rights.

In relation to your personal data obtained through the channels, Classic Loans uses Cookies according to the Cookies Policy that you can consult here .

Modifications

Classic Loans reserves the right to modify this Privacy Policy in accordance with the applicable legislation at all times. Therefore, it is recommended that the user periodically review this Privacy Policy in order to be informed of the treatment and protection of personal data, as well as the rights that assist them.

Applicable legislation

This Policy will be governed and interpreted in accordance with Spanish legislation, as well as the resolution of any controversy or divergence related to this website. The use of the services of this website implies the express acceptance of the Spanish jurisdiction.

Privacy policy update

We do our best to keep our privacy policy fully updated on a monthly basis. If we make changes, these will be clearly identifiable in a clear and specific way, as allowed in the relationship we have established with the user (for example: we can communicate the changes by email).

This privacy policy has been reviewed and published on February 7, 2020.

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