This privacy notice is intended to provide comprehensive and as clear information as possible about AB NEO Finance (hereinafter referred to as – the Company) customers (hereinafter referred to as – You) about the direct marketing activities carried out by the Company, personal data processed for direct marketing purposes, and Your rights related to this.
Direct marketing involves offering the Company's services to customers (including personal offers) and providing information about new services of the Company, including sending newsletters, ongoing promotions, invitations to participate in surveys or market research, and providing opinions on the quality of services and customers’ support. These direct marketing actions may be carried out and information provided to You by sending it by email, providing it by telephone (by calls and/or SMS messages) via Your contact details, which you provided to us when registering for specific services.
DATA CONTROLLER
The controller of personal data processed for direct marketing purposes is AB NEO Finance, legal entity code 303225546, Ukmerges St. 126, Vilnius, Lithuania, operating a peer-to-peer lending platform under the name “Paskolų klubas“ and providing payment initiation and account information service, also electronic money account services under the brand name "Neopay".
PURPOSE AND BASIS OF DATA PROCESSING
Purpose and legal basis for data processing – The Company will process your personal data for direct marketing purposes based on the Company's legitimate interests – to provide You with relevant information about the Company's services and offers that may be relevant to You, also requests to provide opinions on the quality of the services we provide, thus helping us to improve the quality of the services we provide or to offer You new and relevant services. This legal ground applies and is used when you register for the Company's services and become familiar with our Privacy Policy and information on the processing of personal data for direct marketing purposes.
The Company may also process your personal data for direct marketing purposes when you consent to the processing – if you object to the processing of personal data for direct marketing purposes, You can give your consent at any time later by checking the box on the self-service portal: "I agree to my personal data being used for direct marketing purposes and I want to receive information from NEO Finance".
DATA TRANSMISSION
We may transfer your personal data to our service providers (data processors), who help organize and carry out direct marketing activities, including:
- MailerLite – Company sends monthly newsletters and news and other promotional messages to investors and borrowers through this platform;
- Omnisend – this platform is used for automated communication with customers, sending personalized and behaviorally based direct marketing offers;
- TCG Telecom – is used for sending SMS messages to customers (offers, reminders and important notifications).
DATA PROCESSING PERIOD The Company will process (store) Your personal data for direct marketing purposes based on the Company's legitimate interest for the duration of any agreement you have with the Company or until You object to the processing of Your data for direct marketing purposes. If You give consent to process Your personal data for direct marketing purposes, the Company will process personal data for the duration of any agreement You have with the Company, but no longer than 5 (five) years from the date of giving consent to direct marketing (unless You revoke consent earlier). Please note that upon expiry of this period, the Company may ask You to renew consent for direct marketing so that the Company can continue to inform You about its services and provide You with personal offers.
RIGHT TO OBJECT TO DATA PROCESSING AND WITHDRAWAL OF CONSENT TO THE PROCESSING OF PERSONAL DATA
You have the right to object at any time to the processing of your personal data for direct marketing purposes in any of the ways specified below:
- By contacting Company and notifying of Your refusal via email [email protected];
- By expressing your refusal by logging into the self-service portal and clicking "OPPOSE";
- By calling Company’s general number: +37070080075 (when calling from abroad: +37068700300) and inform Company that You do not agree (disagree/revoke) to the processing of your personal data for direct marketing purposes;
- Opting out of direct marketing messages (newsletters) sent via email by clicking on the link at the end of such email.
Please note that even if You have expressed objection to the processing of personal data for direct marketing purposes, You can later at any time express your desire to receive direct marketing messages and give Your consent to the processing of personal data for direct marketing purposes. You can also withdraw consent for direct marketing at any time in the following ways:
- By contacting Company and notifying of Your refusal via email [email protected];
- By expressing your refusal by logging into the self-service portal and clicking "OPPOSE"; By calling Company’s general number: +37070080075 (when calling from abroad: +37068700300) and inform Company that You do not agree (disagree/revoke) to the processing of your personal data for direct marketing purposes;
- Opting out of direct marketing messages (newsletters) sent via email by clicking on the link at the end of such email.
PROFILING AND PROVIDING TAILORED OFFERS
The Company may conduct profiling for marketing purposes using Your personal data and other aspects, including Your age, job, income, place of residence, whether You are an investor or a borrower, Your creditworthiness indicators, services and products You have ordered, were interested in or for which a creditworthiness assessment has been carried out, when Company seeks to assess which product or service would be relevant to You, taking into account Your needs and interests, to provide our clients (You) with personalized offers. Automated decisions are not made, but the assessment of certain personal aspects will allow us to provide You, as a customer, with suitable service offers or recommendations.
YOUR RIGHTS
In addition to the above-mentioned rights to object to data processing based on legitimate interest and to withdraw consent for direct marketing at any time, You also have these rights:
- The right to access the personal data processed;
- The right to request the correction of inaccurate personal data;
- The right to request the erasure (deletion) of personal data;
- The right to restrict the processing of personal data;
- The right to data portability (transfer) of personal data.
You can submit a request to exercise your rights orally or in writing by visiting the Company at Ukmerges St. 126, Vilnius, Lithuania, also by sending Your application by post or electronic means (e-mail). More information about Your rights as a data subject and the exercise of Your rights can be found in the Company's Privacy Policy, which is published on website https://www.paskoluklubas.lt/puslapis/24/privatumo-politika.
If You have any questions about this notice or the processing of personal data for direct marketing purposes, You can always contact Company’s Data Protection Officer by email: [email protected] (Company recommends that You indicate that the correspondence is addressed specifically to the Company's Data Protection Officer).
If You believe that Company‘s actions violate Your rights or You have any complaints, You can always contact the State Data Protection Inspectorate (address L. Sapiegos St. 17, Vilnius, Lithuania, website www.vdai.lrv.lt). However, Company recommends that You contact us first and our employees will try to resolve any issues that arise.