Privacy policy evaluated candidate

Version October 2024

Introduction

When we need your agreement to process data concerning you, we ask you to confirm this by means of the various tools present on the website and by referring to this privacy policy, available and consultable at any time on https://www.mytrusty.eu/.

Changes compared to the previous version (June 2024):

• Clarifications regarding the processing of your data for direct marketing purposes;
• Modification of the entry into force: immediately after publication;
• Other minor corrections.

For the purposes of this policy, we understand by:

• Fintensy or the Provider: Fintensy SA/NV as the provider of the MyTrusty Service.
• MyTrusty Service: assessment tool used by Fintensy.
• Assessment: assessment of the payment behaviour of one or more persons, carried out by Fintensy at the User’s request.
• User: the natural or legal person wishing to use the MyTrusty Service for itself or for other persons (Candidates). When two Users act jointly, they are considered together as one User for the purposes of this policy.
• Candidate: the natural or legal person whose payment behaviour is assessed by Fintensy at the User’s request. When two persons are being assessed jointly, they are considered together as one Candidate for the purposes of this policy.
• Score: numerical result of the Assessment, accompanied by various indicators.

By using the services of Fintensy, you acknowledge you have taken cognisance of this privacy policy. This is not an agreement but rather an undertaking on behalf of Fintensy with regards to the processing of your data and the exercise of your rights.

Data Controller

Your personal data is processed by and under the responsibility of Fintensy SA/NV, as the Data Controller, whose registered office is located at 1 Chemin du Stocquoy, 1300 Wavre, Belgium, under BCE number 0651.648.473, in compliance with this privacy policy and respecting the legislation applicable in Belgium, in particular, the General Data Protection Regulation (GDPR) 2016/679. You can also contact us by letter at the address hereunder, or by email to privacy@mytrusty.eu or by phone to number +32 (0)2 765 09 69.

On which basis do we collect and process your data?

We process your personal data in accordance with the legal basis for processing as set out in the GDPR.

Why do we collect and process your data?

In the context of our activities, we are called upon to collect and process your personal data. The different processing purposes are described hereunder.

Use of the platform:

We use your personal data primarily to allow you to use the various functionalities of the MyTrusty platform, to provide you with the requested services and to follow up on your questions or requests.

In particular, we collect your personal data so that you can create an account (User or Candidate) on our platform and to allow you to use its functionalities.

Introduction and processing of Assessment requests:

When you have created your account on the platform, we can use some of your data to allow you to make an Assessment request (for yourself or for one or more Candidate(s)).

When you have made an Assessment request and it has been accepted, some of your personal data is processed with the aim of concluding the service agreement.

Some of your personal data is also used by Fintensy to execute the service agreement concluded and to process your Assessment request.

Carrying out the Assessment:

When you are subject to the Assessment, we process some of your data in order to carry out the Assessment requested by the User or by yourself to Fintensy. To do this, we ask your specific authorisation to establish a connection between Fintensy and your bank account to allow us to collect the data that is necessary to carry out the Evaluation.

We draw your attention to the fact that to carry out this Assessment, Fintensy collaborates with various providers and that these providers will collect and process your data in accordance with their own privacy policy. We highly recommend that you consult these policies.

The aforesaid Assessment consists of analysing the risk of payment default that your profile may represent over a year. This is achieved by comparing the data we collect by connecting to your bank account with your consent, with a series of statistical rules drawn up by us.

Functioning and development of the platform and improvement of our services:

We process some of your data, either in an automated or manual way, with the aim of ensuring the smooth functioning of our platform and its ongoing improvement.

With regards to the use of data collected automatically during your visits on our website, we refer you to our Cookie Policy accessible on https://www.mytrusty.eu/.

We also regularly carry out internal audits with the aim of improving our platform and our services.

Finally, we may need to process your data in order to carry out research on our behalf with the aim of improving existing products and services or to develop others.

Direct marketing:

We can use some of your data to get back in touch with you, for example if you created an account on the platform but have not used it afterward. These reminders are done via e-mail. They are however time-limited, and you can object to them at any time by contacting us.

Furthermore, with your prior consent, we can use your data, in particular your email address and mobile phone number, to send you marketing communications on behalf of Fintensy and of our partners.

With your prior consent, we can also use some of your data to track your browsing across websites and display more targeted, interesting and relevant advertisements for you. You can obtain more information on this matter by consulting our cookie policy accessible on https://www.mytrusty.eu/en/cookie-policy/.

We may also reuse data from your account, but solely under an aggregated form that does not allow direct identification, for the purposes of customer segmentation. This use of data is enshrined in technical and organisational measures designed to impede any illegal use of your data. You can obtain more information regarding these measures by contacting us.

The MyTrusty platform may finally contain links to other websites. These, like the MyTrusty pages and Fintensy on another platform or on social media, may also collect data that concerns you, in accordance with their own rules and conditions. We recommend that you read these attentively. This privacy policy is applied solely to the information collected on the MyTrusty platform.

Publication of statistical data:

Finally, some of your data may also be used for statistical purposes. Statistic results may also be used for various purposes, including commercial purposes (e.g. sale of statistical data to third parties, provision of services based on statistical results, etc.).

In this context, your data is processed in an anonymous and aggregated form, which does not allow your identification.

Data collected

You will find hereunder information with regards to the various categories of data that we may need to collect and process depending on the processing purpose.

Use of the platform:

To allow you to use our platform, we primarily collect data you provide us by means of the account creation form. This consists of elementary identification data, such as your surname and first name(s), place and date of birth, email, postal addresses and phone number.

If you wish, and by means of your specific consent during the registration application process, you can facilitate the creation of your account by means of a connection via the Itsme platform or by any other accepted mean. In this case, we collect data to which you give us specific access.

Introduction and processing of Assessment requests:

In order to allow you to communicate your Assessment requests to us and therefore allow us follow up on these, and also to allow us to conclude and execute an agreement with you, we may need to process your elementary identification data, such as your surname and first name(s), email and postal addresses, etc.

Carrying out the Assessment:

In order to proceed with the processing of an Assessment request, we first process your identification data, such as surname and first name(s), etc.

In this context, by means of the bank connection established with your specific consent, we may collect and process some of your personal data, such as the list of your bank accounts, possibly filtered by you or by your bank, as well as recent transactions (limited to the last 12 months). Nevertheless, we do not collect your authentication data, such as your password or PIN number, for example.

If your Assessment has been requested by a User, once the Assessment has been executed, your consent will once again be requested so that your Score may be shared with this User. If you do not consent to the communication of your Score, it will not be shared with the User. When two persons are assessed jointly (e.g. spouses, cohabitants, etc.), the consent of one of them will be sufficient provided that they mandated each other to accept the sharing of the Score with the User.

We also draw your attention to the fact that data we collect via the bank connection will never be sent to the User who has requested your Assessment. The User will only receive from Fintensy, with your specific consent, the Score, i.e. the result of the Assessment carried out by us based on various criteria, accompanied by various indicators (e.g. activity level on your account, income stability, etc.). In any case, the Score will not disclose the amounts of the transactions registered on your accounts, their provenance or their beneficiary. Going forward, you can maintain full confidentiality of your financial data, irrespective of the Assessment outcome.

Functioning and development of the platform and improvement of our services:

We also collect certain data in the context of using a tool that allows us visualise your actions (click, browsing, etc.) on: https://www.mytrusty.eu/. This tool allows us optimise the use of our website. To do so, Fintensy uses the services of a sub-contractor, Smartlook, with which a personal data processing agreement has been concluded, Smartlook, in compliance with Article 28 of the European Regulation on Data Protection. Nevertheless. sensitive information such as your password is not collected. You can find further information regarding this by consulting our cookie policy available on: https://www.mytrusty.eu/.

Direct marketing:

In the absence of any objection from you, we may also use your data, including your personal identification information and contact details (mobile phone number and email address), to get back in touch with you if you have created an account on the MyTrusty platform without using this account afterward.

With your prior agreement, we may also use your data, in particular your identification data, email address and mobile phone number, to send you marketing communications on behalf of Fintensy and on behalf of our partners.

In the same conditions, we may use your electronic identification data to track your browsing across websites and display more targeted advertisements.

Publication of statistical data:

We may also re-use certain data relating to your bank transactions (e.g. type of expenditure, amount) in an anonymous and aggregate form for statistical purposes.

Automated decisions

The Assessment carried out by Fintensy based on information that you have provided and on information that it has collected via the connection established with your bank account is based exclusively on a scoring method developed by Fintensy.

In other words, the data that you provide us and data concerning you that we collect from your bank are subject to automated analysis according to our scoring model. The result of this automated analysis may have an impact, both positive and negative, on your opportunities for entering into a relationship with the User or a third party, or for obtaining what you have requested from them. Nevertheless, you always have the possibility of asking Fintensy for a human intervention in regards to your file. You can contact us if you would like further information on this.

Data sent to and processed by third parties

In the context of its activities, Fintensy operates in collaboration with various third parties. To enable these collaborations, some of your data are communicated by Fintensy to its collaborators, so that they can carry out their processing.

• Some of your data may be processed by external providers who complete the Fintensy offer of products and services.
• With your prior agreement, we may use your data, such as your email address and mobile phone number, to send you marketing communications on behalf of Fintensy and also on behalf of its partners.
• With the sole aim of promoting our products and services in a relevant manner and wherever necessary, some of your data may be sent to service providers acting with the aim of marketing on the Internet.
• We may also transfer all or part of your data to third parties, when that is imposed on us by an administrative or a judicial authority, in compliance with the relevant legislation.
• Your data are intrinsically linked to the activity of our platform and may therefore be transferred to another company in the event that we must sell, divest, give or otherwise transfer all or part of our activities or merge with another company or proceed to any other form of reorganisation of our business.

Apart from these potential cases, we do not share any of your data with third parties who would be likely to use it for their own purposes.

Furthermore, your data are never stored on servers located outside the European Union.

Duration of data retention

In the context of its activities, Fintensy retains your data only for a defined period, dependant on various applicable regulations. Nevertheless, your data are never retained beyond the necessary processing period for which they have been collected.

Once these deadlines have passed, your strictly-personal data (e.g.: surname, first name(s), postal address, phone number, etc.) will be erased from our database. We always retain aggregated data for statistical reasons, that’s to say anonymised data that does not allow you to be identified (region, age, etc.).

What are your rights regarding the processing of your personal data?

In the context of the processing of your personal data, as a data subject you have a series of rights available, enumerated and described hereunder:

Right of access:

As a data subject, you have the right to ask Fintensy if your personal data have been subject to processing on its part. If affirmative, you can furthermore ask Fintensy for a list of the data concerned along with the purposes for which they have been processed.

Right to rectification:

You have the right to obtain rectification by Fintensy, without undue delay, of your inaccurate or incomplete data.

Right to erasure:

Under certain conditions, you can obtain from Fintensy that it erases personal data in its possession concerning you.

However, it is not possible to exercise this right when then retention of your data is due to a legal obligation for Fintensy or for the execution of an agreement.

Right to limitation of processing:

You have the right to ask Fintensy to limit processing of your data, for example, when you are contesting the accuracy of your data or if Fintensy no longer needs to retain your data but where these are still needed by you for the establishment, exercise or defence of legal claims.

Right to data portability:

In certain circumstances, you are entitled to obtain from Fintensy personal data being retained on you in a structured, commonly-used and machine-readable format and to transmit this data to another data controller of your choosing without hindrance. from Fintensy.

Right to object:

In some cases, you can object to the processing of your personal data by Fintensy. For example, when Fintensy processes your data on the basis of legitimate or public interest. This right is not applicable when your data is processed in accordance with a legal obligation or in the context of execution of an agreement.

Right not to be made subject of a decision based exclusively on automated processing (including profiling):

Apart from exceptions, you have the right to not be subject to a decision based solely on automated processing, including profiling, that produces legal effects or significantly affects you. This right is not applicable when the decision is necessary for the conclusion or execution of an agreement between you and Fintensy. Nevertheless, you can always ask Fintensy for human intervention, to communicate your opinion to mozzeno in regards to the decision and to object to it. To do this, you need to contact us.

Right to withdraw your consent:

You also have the right, at any time, to withdraw your consent to the uses that you have previously authorised. To do this, you can contact us. Withdrawal of your consent for a specific processing will not affect the processing already carried out prior to this but will be applied in the future.

How to exercise your rights?

To exercise your rights you simply have to contact us. We will respond within a month.

Questions, claims and objections

In the event of a question or claim, we ask you to contact us.

In the case of an objection regarding the processing of personal data, you have the possibility of instituting a claim with our main supervisory authority, the Belgian Data Protection Authority, 35 rue de la Presse, 1000 Brussels (Tel +32 (0)2 274 48 00 – email: contact@apd-gba.be) or with your local authority if you are a resident of another country of the European Union.

Entry into force and amendments

We reserve the right to make amendments to this privacy policy. These amendments will be brought to your attention by means of the platform intermediary or via an individual notification, and will immediately become effective after their publication.