PRIVACY NOTICE FOR ICT SMART SOLUSNS DOOEL Skopje

Information about the controller and processor of personal data:

Company name: ICT SMART SOLUTIONS DOOEL Skopje
EMBS: 7699603
Location: 18/2-2 ASNOM Blvd. – Reon 42, Aerodrom – Skopje
E-mail: info@credy.mk

Information about the personal data processor – in connection with the provision of a service for hosting and storing the data of users of the website Credy.mk, owned by the Controller:

Name: VORTEX MEDIA DOO
EMBS: 6836208
Address: 21, 29th November Street, 2460 Valandovo, Republic of Macedonia
E-mail: info@zemi.mk

Information about the competent supervisory authority:

Name of the organ: Agency for Personal Data Protection
Address: 18 Goce Delchev Boulevard, 1000 Skopje
Telephone: 02 3230 635
E-mail: info@privacy.mk
Website: https://azlp.mk/

Basis for collecting, processing and storing your personal data:

ICT SMART SOLUTIONS DOOEL Skopje collects, processes and stores your personal data on the following basis:

Explicit consent obtained from you as a customer with a specific purpose of processing indicated therein;
Fulfilment of the pre-contractual and/or contractual obligations of ICT SMART SOLUTIONS DOOEL Skopje under a contract with you or a third party;
Compliance with legal obligations relating to ICT SMART SOLUTIONS DOOEL Skopje in accordance with an agreement with you or a third party;
Compliance with legal obligations relating to ICT SMART SOLUTIONS DOOEL Skopje, such as fulfilling obligations to provide information to regulators, courts, prosecutors, etc.;
The legitimate interest of ICT SMART SOLUTIONS DOOEL Skopje – for example, to analyse your data, improve the quality of the services provided, etc.;

ICT SMART SOLUTIONS DOOEL Skopje is the controller of personal data in relation to your data as users of our services. In certain cases, ICT SMART SOLUTIONS DOOEL Skopje may also process personal data in its capacity as a personal data processor, such as when acting as an intermediary for a bank or other financial institution.

Objectives and principles for the collection, processing and storage of your personal data:

ICT SMART SOLUTIONS DOOEL Skopje collects and processes your personal data for the following purposes:

Establishing contact between users of the website Credy.mk or Credy.mk's Facebook page and explicitly designated third parties – licensed financial institutions involved in the processing of credit applications submitted by users. The credit institutions to which we transfer your data are always explicitly listed on the relevant page of the website where you enter your data, and you must explicitly indicate your consent for your data to be transferred to them. All institutions to which your data is transferred when applying for a loan have the necessary licence for their activities from the Ministry of Finance or the Personal Data Protection Agency and are bound by a contract for the processing and storage of the personal data of the user who provided it. The establishment of contact between the user and third parties listed on the website – licensed financial institutions – is also related to the provision of pre-contractual information to the user, the calculation of the credit rate and/or the risk rate of the insurance, obtaining an offer and/or concluding a credit and/or insurance agreement with the relevant financial institution;
Conclusion and performance of contracts of any nature;
Sending out informational and promotional newsletters – the purpose of this operation is to manage the process of sending newsletters to customers who have indicated that they wish to receive them; and
Statistical studies.

Types of personal data that ICT SMART SOLUTIONS DOOEL Skopje collects and processes:

Identification details: Your identification details (first and last name, city of residence, e-mail and telephone number).

Goals for which the funds are collected:

Maintaining contact with users of financial institutions to which they have applied for credit and sending information, including whether they wish to receive newsletters and promotional messages;
Establishing contact between the user and explicitly designated third parties – licensed financial institutions involved in the processing of this data for the purpose of obtaining pre-contractual information, credit assessment, obtaining an offer and/or concluding a credit agreement with the relevant financial institution;
Conclusion and performance of contracts (employment, civil, etc.).

Basis for processing your personal data: By submitting a credit application, you expressly consent to the processing and transfer of the personal data you have provided to the financial institutions listed in the consent form, which is also our basis for processing your personal data – Article 4(1)(11) of the Personal Data Protection Act.

Basic data: Data necessary for establishing contact with financial institutions licensed by the Ministry of Finance and the Personal Data Protection Agency and obtaining pre-contractual information, credit assessment, obtaining offers or concluding a credit agreement with the relevant financial institution: first and last name, city of residence, e-mail and contact telephone number.

Purpose for which the data is collected: 1) Maintaining contact with users of financial information, including sending newsletters and promotional messages; 2) Establishing contact between the user and explicitly designated third parties – licensed financial institutions involved in the processing of this data for the purpose of obtaining pre-contractual information, credit rating, obtaining an offer and/or concluding a credit agreement with a relevant financial institution.

Basis for processing your personal data: By submitting your personal data, you expressly consent to the processing and transfer of the personal data you have provided to the financial institutions listed in the consent form, which is also our basis for processing your personal data – Article 4, paragraph 1, point 11 of the Personal Data Protection Act. Personal data is collected by ICT SMART SOLUTIONS DOOEL Skopje from the persons to whom it relates. The company does not make automated decisions about data.

Period of storage of your personal data:

Once you have completed the online credit application form, ICT SMART SOLUTIONS DOOEL Skopje stores your personal data for a period not exceeding the technical time required to send the data to the employees listed below (no more than 48 hours). After this period, ICT SMART SOLUTIONS DOOEL Skopje takes the necessary care to delete or anonymise your data without undue delay. ICT SMART SOLUTIONS DOOEL Skopje will store your e-mail address if you have registered to receive e-newsletters or promotional messages for a certain period of time until you decide to unsubscribe from receiving messages. „Privacy Policy“ on the website, or by clicking on the unsubscribe link at the end of each promotional message, by submitting a request to unsubscribe from receiving promotional messages. ICT SMART SOLUTIONS DOOEL Skopje will take the necessary care to delete all your data without undue delay. For the avoidance of doubt: Through the page Credy.mk and the generated registration company, ICT SMART SOLUTIONS DOOEL Skopje, only assists users who have completed the loan application to contact the listed financial institutions. If you have not given your consent for marketing messages to be sent to you, ICT SMART SOLUTIONS DOOEL Skopje does not store the personal data you have provided, as it will submit your loan application to ICT SMART SOLUTIONS DOOEL Skopje will transfer them in the form in which you have filled them in to the financial institutions for review and assistance with the submitted request.

ICT SMART SOLUTIONS DOOEL Skopje will notify you if it is necessary to extend the data storage period in order to fulfil the purposes, perform the contract, legitimate interests of ICT SMART SOLUTIONS DOOEL Skopje or otherwise.

ICT SMART SOLUTIONS DOOEL Skopje stores personal data, which it is required to keep on the basis of a contract or applicable legislation, for the period specified in the regulatory act.

Submission of your personal data for processing:

ICT SMART SOLUTIONS DOOEL Skopje may transfer some or all of your personal data to personal data processors for the purposes of processing in accordance with the requirements of the Personal Data Protection Act. The persons to whom ICT SMART SOLUTIONS DOOEL Skopje will deliver the personal data you have provided in the credit application (name and surname, e-mail address, city of residence and telephone number and/or other personal data expressly provided by you for the purposes of establishing contact in accordance with the provisions of the applicable legislation – the Personal Data Protection Act).

ICT SMART SOLUTIONS DOOEL Skopje will notify you in the event of a decision to transfer some or all of your personal data to third countries or international organisations.

Your rights regarding the collection, processing and storage of your personal data:

Whenever ICT SMART SOLUTIONS DOOEL Skopje stores or processes your personal data, you have the following rights:

Consent to the processing of your personal data:

If you do not want all or part of your personal data to continue to be processed by ICT SMART SOLUTIONS DOOEL Skopje for specific or all processing purposes, you may withdraw your consent for processing at any time by completing the form in „Personal Data Protection“ or by submitting a request.

ICT SMART SOLUTIONS DOOEL Skopje may ask you to confirm your identity with the data subject.

Right of access:

You have the right to request and obtain from ICT SMART SOLUTIONS DOOEL Skopje confirmation as to whether personal data relating to you is being processed, as well as the right to access the data relating to you and/or information regarding the collection, processing and storage of your personal data.

ICT SMART SOLUTIONS DOOEL Skopje provides you with a copy of the processed personal data related to you in electronic or other appropriate form of confirmation.

Access to the data is free of charge, but ICT SMART SOLUTIONS DOOEL Skopje reserves the right to charge an administrative fee in the event of repeated or excessive requests.

Right to correction or deletion:

You may correct or complete any inaccurate or incomplete personal data relating to you by submitting a request to ICT SMART SOLUTIONS DOOEL Skopje.

Right to erasure („right to be forgotten“):

You have the right to request ICT SMART SOLUTIONS DOOEL Skopje to delete your personal data, and ICT SMART SOLUTIONS DOOEL Skopje is obliged to delete it without undue delay, when one of the following grounds exists:

Personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
The subject of personal data has given his or her consent on which the processing of data is based in accordance with the legal basis for data processing;
The subject of personal data has consented to the processing of the data;
Personal data is processed unlawfully.

ICT SMART SOLUTIONS DOOEL Skopje is not obliged to delete personal data as long as it stores and processes it:

To uphold the right to freedom of expression and information;
To comply with a legal obligation that requires processing under the law applicable to the controller, or to perform tasks in the public interest or in the exercise of official authority;
Reasons of public interest;
For archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
For the purpose of establishing, enforcing or defending legal claims.

To exercise your right to be forgotten, you must submit a request via the „Privacy Protection“ section on the website or send a written request to ICT SMART SOLUTIONS DOOEL Skopje, and confirm your identity and the identity of the person for whom you are submitting the data to ICT SMART SOLUTIONS DOOEL Skopje by presenting your identity card at the location for identification purposes.

ICT SMART SOLUTIONS DOOEL Skopje does not delete data that it is legally obliged to store, including for the purpose of defending itself against legal claims brought against it or for proving its rights.

Right to restriction:

You have the right to request ICT SMART SOLUTIONS DOOEL Skopje to restrict the processing of data related to you when:

The accuracy of personal data shall be contested by the subject of the personal data for a period that allows the controller to verify the accuracy of the data;
The processing is unlawful and the data subject objects to the erasure of the personal data;
For the purposes of processing, ICT SMART SOLUTIONS DOOEL Skopje no longer needs the personal data, but the data subject requests it for the establishment, exercise or defence of legal claims;
The customer objects to the processing of personal data, pending verification whether the legitimate interests of ICT SMART SOLUTIONS DOOEL Skopje override the interests of the subject.

Right to portability:

You can access your data stored and processed for you at any time by using the services of ICT SMART SOLUTIONS DOOEL Skopje directly through the „Personal Data Protection“ section of the website page or by sending an e-mail. You may request ICT SMART SOLUTIONS DOOEL Skopje to transfer your personal data directly to a controller you specify, where technically feasible.

Right to obtain information:

You may request ICT SMART SOLUTIONS DOOEL Skopje to inform you of all recipients to whom your personal data has been disclosed and for whom a correction, deletion or restriction of processing has been requested. ICT SMART SOLUTIONS DOOEL Skopje may refuse to provide this information if it is impossible or would require a disproportionate effort.

Right to a verdict:

You may at any time object to the processing of personal data by ICT SMART SOLUTIONS DOOEL Skopje that relates to you, including if it is processed for profiling purposes to the extent that it is related to direct marketing.

Right to be informed in the event of a breach of the security of your personal data:

If ICT SMART SOLUTIONS DOOEL Skopje discovers a breach of the security of your personal data that may pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach and of the measures that have been taken or are planned to be taken.

ICT SMART SOLUTIONS DOOEL Skopje is not obliged to inform you to what extent:

Appropriate technical and organisational measures are in place to protect data subjects affected by a security breach;
Additional measures to ensure that there is no longer a high risk to the rights and freedoms of the customer;
The announcement would have caused disproportionate pressure.

Persons to whom your personal data is disclosed:

To the extent that you have agreed to the processing and transfer of your personal data when completing a credit application, your personal data will be transferred to the financial institutions specifically mentioned in the agreement licensed by the Ministry of Finance expressly mentioned in the agreement for the purpose of obtaining pre-contractual information, credit rate, risk rate of insurance, obtaining an offer and/or concluding a loan agreement with the relevant financial institution.

In accordance with legal requirements, the controller may disclose your personal data to the following persons:

Persons providing services for the organisation, storage, indexing and destruction of archives on paper and/or electronic media;
The competent authorities, which by law are authorised to request information, including personal data, such as courts, prosecutors, various regulatory bodies such as: the Consumer Protection Commission, the Ministry of Finance, the Personal Data Protection Agency;
State bodies and institutions that have public powers;
Internal and external process auditors, financial and regulatory reports and references – for the purposes of relevant audits;
Postal operators, for the purpose of sending and receiving shipments containing documents and requiring identity verification upon delivery;
Persons whose task is to maintain equipment, software and hardware used for processing personal data and necessary for building the company's network and performing various services for notification and work on products, technical support, etc.;
Persons who provide service support for terminal devices.

ICT SMART SOLUTIONS DOOEL Skopje does not transfer your data to third countries.

Other provisions:

In the event of a violation of your rights under the above or applicable data protection legislation, you have the right to submit a request for confirmation of a violation of the provisions of the Personal Data Protection Act to the Personal Data Protection Agency in the following manner:

By filling in your personal details, such as: first and last name, residential address, contact telephone number, e-mail address, details of your legal representative, if you have one;
Submit information about the legal entity/natural person who you believe has damaged your personal data, including the following information: name of the legal entity/first and last name of the natural person, registered office of the legal entity/address of residence of the natural person, telephone number, e-mail, a brief description of the damage that has occurred, as well as evidence supporting the above claim.

This request may be submitted in paper form to the Personal Data Protection Agency and in electronic form using the forms attached to this information.