Privacy Policy

Fellow Finance is fully committed to protecting your individual rights and keeping your personal data safe. In this Privacy Policy we describe the collection, usage, storage and sharing practices of personal data. Within the Fellow Finance-group, the data controller will be Fellow Finance Plc and/or the Fellow Finance company(ies) you have your relationship with. Details of the controllers can be found on our webpages. We process individuals’ personal data for several reasons. When we write «you», we mean you as a customer, a potential customer, our customer’s employee or other relevant parties, such as beneficial owners, authorised representatives and associated parties.

This privacy policy includes the following sections:

1. What personal data we collect

Personal data is in most cases collected directly from you or generated as part of the use of our services and products. Sometimes additional information is required to keep information up to date or to verify information we collect. The personal data we collect can be grouped into the following categories:

Identification information:

National identification number and name. We are obliged to collect documentation of such information, for instance in the form of copies of your passport, driver’s license, or the like or by identifying the customer electronically.

Contact information:

Phone numbers and addresses, including postal address – in the case of a foreign address, also the home country.

Financial information:

Type of agreement, transactional data, credit history, insurance history.

Information related to legal requirements:

Country of taxation or foreign tax payer reference, customer due diligence and anti- money laundering requirements.

Special categories of data:

For example information concerning health is needed for Fellow Finance insurance product.

Personal data we may collect from you:

We collect information you provide directly to us. For example, when becoming a new customer, we collect personal data, such as name, national identification number, e-mail address and phone number, income and debt information to be able to provide you with the product or service in question. Fellow Finance also collects information which you provide us with such as messages you have sent us, e.g. feedback or a request in our digital channels. Calls and chat conversations with you may also be recorded and logged for verification of orders, documentation, and for quality and improvement purposes. For security purposes, we may have cameras in our offices.

Personal data we may collect from third parties:

Publicly available and other external sources; register held by governmental agencies (such as population registers and registers held by tax authorities, company registration offices, enforcement authorities, etc.), sanction lists (held by international organisations such as the EU and UN as well as national organisations such as Office of Foreign Assets Control (OFAC)), registers held by credit-rating agencies and other commercial information providers providing information on e.g. beneficial owners and politically exposed persons.

In connection with payments, we collect information from remitters, banks, payment service providers and others. From other entities in the Fellow Finance Group or other entities which we collaborate with.

2. How we may use your personal data and the lawful basis for doing so

We use your personal data to comply with legal and contractual obligations as well as to provide you with offers and services. Entering into and administration of service and product agreements (performance of a contract). The main purpose of our processing of personal data is to collect, verify, and process personal data prior to giving an offer and entering into a contract with you as well as documenting, administering and completing tasks for the performance of contracts. Examples of the performance of a contract:

Fulfilment of requirements and obligations for us stated in laws, regulations or decisions from authorities and supervisors (legal obligation) In addition to the performance of contract, processing of personal data also takes place for us to fulfil our obligations under law, other regulations or authority decisions.

In addition to the performance of contract, processing of personal data also takes place for us to fulfil our obligations under law, other regulations or authority decisions. Examples of processing due to legal obligations:

Marketing, product- and customer analysis (legitimate interest)

Personal data is also processed in the context of marketing, product- and customer analyses. This processing forms the basis for marketing, process-, business- and system- development, including testing. This is to improve our product range and optimize our customer offerings. This may also involve profiling (see below). We have a legitimate interest to use profiling for example when conducting customer analysis for marketing purposes or monitoring transactions in order to detect frauds.

Consent

There are situations when we will ask for your consent to process your personal data. Examples of such situations are processing of payment transaction data for marketing purposes, or for some processing of special categories of data. The consent will contain information on that specific processing activity. If you have given consent to a processing of your personal data you can always withdraw the consent.

3. Automated decision-making

We may in some cases use automated decision-making, if it is authorized by legislation, if you have provided an explicit consent or if it is necessary for the performance of a contract, for example automated credit intermediation and approval process in the online channels. You can always request a manual decision-making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you.

4. Who we may disclose your personal data to

We may share your personal data with others such as authorities, Fellow Finance companies, suppliers, payment service providers and business partners. Before sharing we will always ensure that we respect relevant secrecy obligations.

To fulfill services and agreements we have to disclose information about you. If, for example you have asked us to transfer funds, we need to disclose certain information to fulfill that transfer.

Third parties and Fellow Finance Group companies

To provide our services, for example credit transfer, we disclose data about you that is necessary to identify you and perform an assignment or agreement with companies that we cooperate with in order to perform our services. These services include, but not limited to, secure identification solutions in the relevant country and between parties in the financial system such as transaction receivers.

We also disclose personal data to authorities to the extent we are under statutory obligation to do so. Such authorities include tax authorities, police authorities, enforcements authorities and supervisory authorities in relevant countries.

In addition, data are disclosed, with your consent or if this is permitted pursuant to legislation, internally in Fellow Finance and to external business partners (including correspondent banks, vendor partners of finance object and insurers).

5. How we protect your personal data

Keeping your personal data safe and secure is at the centre of how we do business. We use appropriate technical, organizational and administrative security measures to protect any information we hold from loss, misuse, and unauthorized access, disclosure, alteration and destruction.

6. Your privacy rights

You as a data subject have rights in respect of personal data we hold on you. You have the following rights;

Your request to exercise your rights as listed above will be assessed given the circumstances in the individual case. Please note that we may also retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

7. Cookies

We collect, process and analyse data regarding the use of our webpages. Traffic data is data connected to visitors on the webpage and data handled in communication fields for sending, distributing or making messages available. We use cookies and similar technologies to deliver products and services to you, provide a secure online environment, to manage our marketing and provide a better online experience, track our website performance and to make our website content more relevant to you. The data will not be used to identify individual visitors except for Fellow Finance online service customers. You can set or amend your web browser controls to accept or reject cookies. If you choose to reject cookies, you may still use our websites and some services, however your access to some functionality and areas of our website or services may be restricted substantially. For more information, see cookies at the footer of fellowfinance.com.

8. How long we process your personal data

We will keep your data for as long as they are needed for the purposes for which your data was collected and processed or required by laws and regulations. This means that we keep your data for as long as necessary for the performance of a contract and as required by retention requirements in laws and regulations. Where we keep your data for other purposes than those of the performance of a contract, such as for anti-money laundering, bookkeeping and regulatory capital adequacy requirements, we keep the data only if necessary and/or mandated by laws and regulations for the respective purpose.

The data retention obligations will differ within Fellow Finance subject to local law. Specific examples are:

The above is only for explanatory purposes and the retention times may differ country to country.

9. How changes to this Privacy Policy and the Cookies policy will be made

We are constantly working on improving and developing our services, products and websites, so we may change this privacy policy from time to time. We will not diminish your rights under this privacy policy or under applicable data protection laws in the jurisdictions we operate. If the changes are significant, we will provide a more prominent notice, when we are required to do so by applicable law. Please review this Privacy Policy from time to time to stay updated on any changes.

10. Contacting us or the data protection authority

If you have any questions or concerns regarding our privacy policy, you can always contact Fellow Finance’s customer service. Also, Fellow Finance has appointed a Data Protection Officer that you can contact by sending a message to: customerservice@fellowfinance.fi or by sending a letter to: Fellow Finance, Group Data Protection Office, Pursimiehenkatu 4 A, 00150 Helsinki, Finland You can also lodge a complaint or contact the data protection authority in any of the countries where we provide services or products to you.

In case of any different interpretation of the texts of this Agreement in Finnish and English, the Finnish wording shall be decisive.