Policy for collection and processing of personal data for assessment of creditworthiness

This Policy governs the collection and processing of personal data of clients or prospective clients, as well as that of users of the Platform, with respect to the assessment of creditworthiness by Leno.

Leno means all companies within the group of the same name, including but not limited to The Leno Group Ltd, a company registered in England and Wales under number 12008730, with registered address 64 New Cavendish Street, London, United Kingdom, W1G 8TB; Leno JSC, a company registered in Bulgaria under number 203217465 with registered address 2 Maria Luiza Blvd, Level 5, Sofia 1000, Bulgaria; Leno Markets JSC, a company registered in Bulgaria under number 103277217 with registered address 96 Tsarigradsko Shose Blvd., Level 7, Sofia 1784, Bulgaria; Lenno Iberia S.L., a company registered in Spain under number B88146451 with registered address Centro de Negocios, Calle Santa María Magdalena, número 10-12, planta 2 Madrid 28016, Spain; Lenno Ins., a company registered in Bulgaria with registered address 2 Maria Luiza Blvd, Level 5, Sofia 1000, Bulgaria.

The Platform means, together and separately, the internet page of www.leno.com, the "Leno" mobile application, and any other platform through which Lеno is presented, offered and / or provides services.

In the event that a client or prospective client is applying for a loan from Leno, an assessment of the client's creditworthiness should be made in order to determine whether the loan can be extended. In this connection, Leno is obliged to collect information from the applicant, as well as to make all the necessary inquiries in databases for verification and confirmation.

1.    By adopting this Policy, in compliance with the legal requirements for explicit, prior, voluntary, specific and informed consent to the processing of personal data, I declare that:

1.1.    I provide my explicit consent, in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on Personal Data Protection ("GDPR") and the provisions of the relevant local legislation, that my personal data could be collected and processed by Leno for the purpose of developing legal relationhips between the parties – entered in to / to be entered in to for the purpose of obtaining a loan, pursuing the credit activity (assessing the creditworthiness of the client or the prospective one), evaluation of the proposed collateral and other preparatory actions in the lending process, in the event of а conclusion of a loan agreement and / or a contract for the establishment of collateral, for the conclusion, management and performance of agreements, to which the data subject is a party, including for actions, preceding and stipulating the conclusion of agreements and actions undertaken under the request of the data controler, for the execution of his legitimate interests, related to the execution of the contact, the establishment, and renewal of colateral, conclusion and maintenance of property insurance,when such is required under the contract and for statistical purposes.

1.2.    I provide my explicit consent to Leno to collect and process personal data from the databases of NSSI, NRA, CCR, Real Estate and Commercial Register, GD CRAS, “Central Debt Register” at the BCPEA, Ministry of Interior, social networks, etc;

2.    I declare that I am familiar with the categories of personal data which Leno will process for me in order to assess my creditworthiness, namely:

•    Physical identity: three names, PIN, address (including email address), details from identity document (ID, passport, ohter), place of birth, telephone, IP address, other;

•    Economic identity: bank account number, payables to other banking or financial institutions, types of credit products used, financial status, other;

•    Social identity: education, work activity, work experience, type of employment, others;

•    Family identity: marital status, others;

•    Other: type of technical instrument used, purpose of credit, others.

3.    I provide my explicit consent to the processing of my personal data, as mentioned above in the Policy by Leno in accordance with the provisions of the Regulation and the local legislation for the following purposes:

•    Assessment of my creditworthiness for the purpose of granting loan/s;

•    Carrying out verifications in public registers or databases on the grounds of Art. 16, para. 1 of the Consumer Credit Act for the purpose of granting a loan/s - NSSI, NRA, CCR, Real Estate and Commercial Register, GD CRAS, “Central Debt Register” at the BCPEA, Ministry of Interior, social networks, etc.

4.    I provide my explicit consent to Leno to provide the collected personal data to third parties and credit registers kept by the Bulgarian National Bank, in their capacity as data controllers. This information will be provided only to  third parties who have been entrusted with activities such as: drafting, preparation and delivery of written correspondence with clients or information forms of the controller, third parties who have been commissioned under an agreement with the controller to assist him in the servicing and collection of his claims, third parties to whom the controller has entrusted the processing of personal data for other organizational reasons, beyond the abovementioned, third parties to whom the controller assigns a valuation of collaterals, insurers with whom the controller has a contract, for the purpose of concluding and maintaining property insurance, third parties who, by contract with the controller, mediate the provision of credit or other financial products and services or provide goods or services that are paid via credit, granted by the controller, authorities, institutions and other third parties to whom the controller is obliged to provide personal data under special legal provisions, other lending organizations which process creditworthiness assessments of a client or prospective client - Leno's counterparties, data controllers.

5.    I am aware of my rights аrising from the GDPR and the local legislation, that I may exercise with respect to the categories of personal data processed by Leno, by sending a written application signed by me to the email address: , namely:

•    My right to object to the processing of my personal data or to the disclosure of it to third parties;

•    My right to be informed before my personal information is disclosed for the first time to third parties or used on their behalf for the direct marketing of Leno's products and campaigns, and to object to such disclosure or use;

•    My right to access my personal data and my right to request the deletion, correction or blocking of (some of) my personal data, stored both on paper and electronically;

•    My right оf data portability from Leno to another controller.

By accepting this Policy, I hereby declare that all the information I provide is true, accurate and comprehensive and that I am aware that the provided information has served in order to motivate Leno to grant the requested financial service.

By accepting this Policy, I declare that the provision of my personal data is voluntary. In case of refusal of the provision, the controller will not be able to provide the requested financial product or service.

By accepting this Policy, I declare that I am aware that the provision of inaccurate and untruthful information is a ground for the loan to be declared as preliminary requested. I declare that I am aware of the criminal liability I bear under the Criminal Code for declaring untruthful information.

Last updated: April 1, 2020
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