Privacy policy (until 11 July 2023)

1. General

  • 1.1. This privacy policy (the Policy) applies when You have submitted Your personal data to any of the group companies of Montonio Finance (Montonio, We or Our):
    • (a)  Montonio Finance OÜ, registry code 14557628 (Estonia).
    • (b)  Montonio Finance Europe OÜ, registry code 14588818 (Estonia).
    • (c)  Montonio Finance UAB, registry code 305205122 (Lithuania).
  • 1.2.  The Policy shall be available on Our website at all times.
  • 1.3.  We have the unilateral right to amend the Policy or to cease providing the services.

2. Categories of data processed and reason for processing

  • 2.1. We process the personal data You submit to us prior to during using or while using services, such as the payment initiation or the credit intermediation services.
  • 2.2. We may receive Your personal data additionally from third parties, such as public and private registers (population registries, credit registries, partner creditors). We use that data mainly for the purposes of verifying and updating the personal data we have on You.
  • 2.3. We process Your personal data for compliance with legal obligations stemming from legal acts (national laws, supervisory guidelines, regulations and EU legal acts), performance of contracts and preparing for entering into contracts, e.g., for processing applications submitted by You, on the basis of Your consent and for protection of Our legitimate interests.
  • 2.4. Our legitimate interest is expressed in the enhancement of the services that we provide to our customers, while ensuring data and information security and performance of the legal obligations set forth in legal acts.
  • 2.5. We process Your contact details in the marketing purposes only on the basis of your explicit consent. You can withdraw from such consent at any time.
  • 2.6. We may use cookies on Our website. Cookies are used in the purposes of a better user experience. You can configure your web browser not to allow cookies, however, we cannot guarantee that Our services will function properly if You decide to do so.
  • 2.7. The following is a list of categories of the personal data We may use with the legal grounds for such processing:

Category

Purpose

Grounds for processing
Identification data (e.g., name, personal identification code, data of the identification document)
Identification
Obligations deriving from the applicable anti-money laundering legislation
Contact details (e.g., phone number, e-mail, address)
Performance of a contract, direct marketing
Performance of a contract, consent
Data about marital status, area of employment
Assessment of creditworthiness
Legal obligations deriving from consumer credit legislation
Financial data (income, obligations)
Assessment of creditworthiness
Legal obligations deriving from consumer credit legislation
Payment data (name, payment amount, name of payee, list of payer’s IBANs, email, address, IP address)
Provision of payment services
Performance of a contract
Data on the website sections visited
Risk management, fraud prevention
Legitimate interest for risk management
Mobile device data (type of device, device identifier, other metadata)
Fraud prevention
Legitimate interest for fraud prevention
Technical data on the use of the website and Our software (IP address, type and version of the browser)
Fraud prevention
Legitimate interest for fraud prevention

3. Third parties, transfer of data and data security

  • 3.1. We may transfer Your personal data to:
    • (a) Our partner creditors when you apply for credit. Legal acts require Our partner creditors and Montonio to obtain, verify, and record identifying information about all their customers. For this purpose, Montonio or the partner creditors may consult other sources to obtain information about You. The list of partner creditors and their privacy policies are available HERE.
    • (b) Our partner merchants whose products You are paying or applying financing for. (c) Third-party service providers. On such occasions, Montonio will be responsible for the processing of Your data. The list of such third-party service providers is available here.
  • 3.2. We will generally process Your personal data only within the European Economic Area. Where it might be necessary to transfer Your personal data to third countries, we shall ensure that appropriate protection measures are applied.
  • 3.3. We have implemented security measures to ensure that Your personal data is protected from unauthorized or unlawful access, modification and deletion.

4. Retention periods

  • 4.1. We will not process Your personal data for longer than necessary for the objectives of the processing. In general, We will retain Your personal data until the end of the statute of limitations, unless there is a requirement in the applicable laws to retain Your personal data for a longer term.

5. Your rights and contacts for questions and complaints

  • 5.1. If permitted by the applicable law, You have the right to request:
    • (a) Access to and rectification of or erasure of Your personal data.
    • (b) To restrict the processing of Your personal data.
    • (c) To receive Your personal data in a machine-readable format.
    • (d) To object to automated decision-making.
  • 5.2. Do not hesitate to contact us if you have any questions, requests or complaints on the processing of Your personal data at dpo@montonio.com.
  • 5.3. Regardless of whether You submit the complaint submitted or the outcome of the complaint procedure, You may contact the competent supervisory authorities for the protection of Your rights.
  • 5.4. Contact details of the supervisory authorities:
  • For Estonian customers: Andmekaitse Inspektsioon, www.aki.ee, info@aki.ee, Tatari 39, Tallinn Estonia
  • For Lithuanian customers: Valstybinė duomenų apsaugos inspekcija, www.ada.lt, ada@ada.lt, L. Sapiegos 17, Vilnius Lithuania