Bondora Terms of Use

2.1. The Terms of Use shall determine the main terms and conditions of: 1) the communication between the Lender and the User; and 2) the services provided by the Lender to the User.

2.2 These Terms of Use shall form an integral part of all User Agreements and other agreements concluded between the User and the Lender when using the Portal. The Terms of Use shall become applicable when the User Agreement is deemed to have been concluded in accordance with Section 3.4.

2.3 In addition to the Terms of Use, the relationship between the Lender and the User shall be regulated by the applicable law and the Loan Agreement(s) concluded between the Lender and the User. If the Terms of Use are in conflict with the Loan Agreement, the Loan Agreement shall have a priority.

2.4 Terms of Use, General Terms of the Loan Agreement, Price List and other relevant information and documents shall be made available to the User at any time free of charge on the Lender’s webpage and/or in the Portal.

3.1. Only by becoming a User, a person shall obtain a right to use the User’s functionalities of the Portal, including:

• 3.1.1. a right to submit Loan Applications;
• 3.1.2. a right to conclude Loan Agreements;
• 3.1.3. a right to apply for using other services offered by the Lender and to conclude respective agreements;
• 3.1.4. an opportunity to communicate with the Lender.

3.2. In order to become a User of the Portal, a person must:

• 3.2.1. register his/her e-mail address on the webpage of the Lender;
• 3.2.2. confirm that he/she accepts the terms and conditions of the Terms of Use;
• 3.2.3. confirm that he/she accepts that his/her personal data shall be processed by the Lender in accordance with Section 10; and
• 3.2.4. verify his/her e-mail address by logging in the Portal by using temporary password created by the Portal.

3.3. By confirming acceptance with the terms and conditions of the Terms of Use, the User represents and warrants:

• 3.3.1. he/she is a natural person;
• 3.3.2. he/she is at least 18 years of age;
• 3.3.3. he/she has full passive and active legal capacity;
• 3.3.4. he/she is a citizen of the European Union or Switzerland;
• 3.3.5. he/she is a permanent resident of the European Union or Switzerland;
• 3.3.6. he/she is not a Politically Exposed Person;
• 3.3.7. he/she is not a subject to an International Financial Sanction;
• 3.3.8. he/she is not under the influence of a relevant mistake, an unlawful threat or violence or other condition which may have unpropitiously influenced his/her judgement.

3.4. A User Agreement shall be deemed to have been concluded between the Lender and the User on the terms and conditions set forth herein immediately after fulfilment of all conditions provided in Section 3.2 and shall be valid for an unlimited period or until terminated in accordance with Section 12.

3.5. The User shall not receive a notification confirming that the User Agreement has been concluded between the parties, but instead, shall gain an access to the User functionalities of the Portal. The User Agreement, including the Terms of Use, shall be sent to User’s e-mail address without delay and shall be made available to the User at any time free of charge in the Portal.

4.1. For logging in the Portal, the User has to enter his/her Portal user name and password.

4.2. Before conclusion of the first Loan Agreement, the User shall identify himself/herself by:

• 4.2.1. making a bank transfer from a bank account opened on his/her name in a credit institution which has its place of business in a contracting state of the European Economic Area either directly from such bank account or by using any of the alternatives accepted by the Lender;
• 4.2.2. submitting any and all documents requested by the Lender for the purposes of identifying the User and for complying with applicable money laundering and terrorist financing prevention regulations.

4.3. If identification in accordance with Section 4.2 is not required by the applicable law, the User shall be identified before any action or transaction which has legal consequences (e.g. before conclusion of a Loan Agreement or submitting withdrawal application) by using one of the following identification methods chosen by the User:

• 4.3.1. unique user name and password of the Portal chosen by the User;
• 4.3.2. mobile approval by using unique PIN-code sent to the User’s mobile number; or
• 4.3.3. approval by any other means which are compliant with the applicable legislation and considered sufficient by the Lender.

4.4. Upon identifying a User, the Lender shall not be limited by Sections 4.1 to 4.3 and shall have the right at any time to unilaterally alter the identification process, including use other legally permitted methods for identification.

4.5. Information, received through the identification process, such as name, personal ID code, bank account number, residential address etc. will be collected at the end of the registration process and stored as personal data.

4.6. Any person logging in the Portal with User’s tools (e.g. user name and password) are deemed to be the User, unless the User has informed the Lender that a third person has gained access to the tools.

5.1. The User shall:

• 5.1.1. not use the Portal for illegal transactions or operations, including for fraud, money laundering, terrorist financing etc.;
• 5.1.2. submit to the Lender true, accurate and not misleading information and shall not withhold from the Lender any information which might be relevant to the Lender;
• 5.1.3. inform the Lender immediately but not later than within five (5) Banking Days about any and all changes in the information and/or documents he/she has submitted to the Lender;
• 5.1.4. inform the Lender immediately but not later than within five (5) Banking Days about any circumstances which affect or may affect User’s ability to fulfil his/her obligations arising from any agreements concluded between the Lender and the User, above all, from the Loan Agreements;
• 5.1.5. keep the data and tools required for logging in the Portal, including ID-card, passwords and usernames in such a manner that third parties do not gain possession of such data or tools;
• 5.1.6. inform the Lender immediately, but not later than within five (5) days if third party has gained possession of the data or tools specified in Section 5.1.5;
• 5.1.7. act politely and respectfully when communicating with the Lender.

5.2. If the User fails to fulfil its obligations under Section 5.1.3, the Lender shall have a right to assume that the information and documents previously submitted by the User are correct until otherwise notified by the User.

6.1. Communication between the User and the Lender shall be in the language of the Terms of Use and shall be sent to the receiving party through the Portal, unless otherwise agreed herein and/or required by the law.

6.2. If a communication between the User and the Lender shall be sent to the receiving party by an e-mail or mail, then it shall be sent by using contact data notified by the receiving party to the other party through the Portal, by e-mail or mail. The party shall bear the risk of not notifying the other party about the change in his contact data.

6.3. Communication sent to the other party by using correct contact data shall be deemed to have been received by the receiving party: 1) if delivered personally, when delivered against the signature; 2) if sent through the Portal or by e-mail, three (3) days after being sent; 3) if sent by mail to a destination within the country of dispatch, five (5) days after being deposited by registered mail; and 4) if sent by mail to a destination outside the country of dispatch, seven (7) days after being deposited by registered mail.

6.4. If the User has not received a communication the receipt of which he/she can anticipate or the receipt of which has been agreed between the parties, the User shall notify the Lender immediately, but not later than within three (3) Banking Days after the deadline during which one could expect receipt of the notification has passed.

6.5. The User shall be obliged to immediately verify the correctness of the information included in the communication received from the Lender and lodge his/her complaints immediately after receipt of the communication.

7.1. It is only possible to apply for Loans by submitting a Loan Application through the Portal.

7.2. The User shall disclose and determine in the Loan Application:

• 7.2.1. contact data, including his/her name, personal ID-code, address, phone number;
• 7.2.2. general information, including information about his/her home ownership, education, relationship status, dependants, employment status;
• 7.2.3. information about his/her income;
• 7.2.4. information about his/her liabilities;
• 7.2.5. information about his/her payment defaults;
• 7.2.6. preferred Loan Amount;
• 7.2.7. purpose of the Loan;
• 7.2.8. due date of Monthly Repayments; and
• 7.2.9. other information that may be requested by the Lender (including but not limited to documents to verify the income and liabilities of the User).

7.3. By submitting a Loan Application, the User confirms that:

• 7.3.1. the data and documents submitted by him/her to the Lender are true, accurate and not misleading and he/she has not withhold from the Lender any information which is or might be relevant to it;
• 7.3.2. the data and documents submitted by him/her to the Lender may be handed over to the Lender and the Lender may use them in accordance with the data protection rules set forth in Section 10;
• 7.3.3. he/she has thoroughly examined the terms and conditions of the Terms of Use and the Loan Agreement, fully understands their contents and confirms that they are fully coherent with his/her will; and
• 7.3.4. representations and warranties made pursuant to the Terms of Use and the Loan Agreement, are correct.

7.4. Before submitting a Loan Application, the User must identify himself/herself in accordance with Section 4.

7.5. The Loan Application is not binding to the User, i.e. he/she may withdraw the Loan Application without declaring the reason at any time before conclusion of the respective Loan Agreement.

8.1. The Lender shall assess the creditworthiness of the User and shall make a credit decision based on the data and documents submitted by the User and made available to the Lender in the public databases or otherwise.

8.2. The Lender shall have a right to make one of the following credit decisions:

• 8.2.1. accept the Loan Application;
• 8.2.2. reject the Loan Application; or
• 8.2.3. make a counteroffer and accept the amended Loan Application.

8.3. The Lender shall make the credit decision and inform the User about it immediately, but not later than within two (2) Banking Day as of receiving all required data and documents from the User. The Lender shall not be obliged to substantiate the credit decision, unless it rejects the Loan Application based on information it has received from the public databases, in which case it shall inform the User about the results of such inquiries.

9.1. The Loan Agreement shall be considered legally binding and concluded between the Lender and the Borrower as of the date it has been electronically or digitally signed or approved by both parties.

9.2. The Loan Agreement and other required information and documents shall be made available to the User through the Portal immediately after the Loan Agreement shall be deemed to have been concluded between the parties and shall be made available at any time during the term of the Loan Agreement free of charge in the Portal.

10.1. User’s consent and general principles

• 10.1.1. Upon entry into the User Agreement, submitting the Loan Applications and entry into Loan Agreement, the User gives his/her consent to the Lender to process his/her personal data in accordance with the provisions of the Terms of Use and especially according to this Section 10.
• 10.1.2. User shall present only correct, accurate and up to date data to the Lender. Deliberate submission of false and incomplete information is forbidden and is deemed to be a breach of the User Agreement.
• 10.1.3. The Lender shall process User’s data as long this is reasonably required for the business purposes of the Lender and performance of any obligation under User Agreement, Loan Agreements or legislation applicable, unless otherwise provided in the Terms of Use.
• 10.1.4. User has, at all times, the right to:
  • a) ask from the Lender which data it has collected with respect to the User;
  • b) ask from the Lender to which third persons the personal data of the User has been transferred;
  • c) review the data about the authorised processors at the Lender’s website (www.bondora.ee);
  • d) notify the Operator that he/she does not wish: 1) to receive personal offers or advertisements; 2) that his/her data is processed for the purposes of researching consumer habits and/or direct marketing; and/or 3) that his/her data is communicated to third person for the same purposeswithdraw his/her consent to process his/her personal data, and
  • e) demand that: 1) processing of his/her personal data shall be terminated; 2) personal data collected with respect to him/her is deleted or sealed; 3) his/her User account is closed; provided that the User has no valid agreements with the Lender, the Lender has no obligation arising from legislation to preserve or process the data and the Lender has no other legal basis for processing User’s data.
• 10.1.5. The Lender shall inform the Borrower if the Loan Application is rejected due to the data gathered from third parties and shall disclose such data to the Borrower.

10.2. Purpose of data processing

The Lender shall use the User’s personal data for:

• 10.2.1. concluding, amending and performing User Agreement and other agreements, including but not limited to performing Lender’s obligations, assessing credit-worthiness of the User, determining the maximum credit limit of the User, ensuring and managing the performance, and enforcement of Loan Agreements;
• 10.2.2. enforcement and protection of the Lender’s rights under the User Agreement and other agreements, including but not limited to forwarding data to debt collection companies and legal councillors;
• 10.2.3. communicating with User;
• 10.2.4. advertising services to the User, inter alia the Lender may forward offers of the Lender’s cooperation partners;
• 10.2.5. developing and maintaining the Lender’s IT-systems and services, products and services;
• 10.2.6. performing statistical and financial analysis;
• 10.2.7. forwarding information to the (potential) investors, creditors and cooperation partners; and
• 10.2.8. performing other legal obligations.

10.3. Data processed

The Lender is entitled to process all data disclosed by the User to the Lender. The Lender is also entitled to search for, collect and process data about the User from publicly accessible sources or sources with limited access in the course of providing services to the User under the User Agreement or Loan Agreement or for processing Loan Application. The Lender shall process mainly (but not only) the following User’s data:

• 10.3.1. User’s personal data, e.g. name, date of birth, personal identification code, language of communication, family status and data of identification documents;
• 10.3.2. User’s contact data, e.g. postal address, residential address, e-mail address and telephone number;
• 10.3.3. data about User’s employment and educational status and relations, e.g. education, educational institution, employer, position and profession;
• 10.3.4. data about User’s economical and financial situation and relations, e.g. income, assets, liabilities, origin of assets, and transactions on the bank account;
• 10.3.5. data about User’s transactions and legal relationships related to these, e.g. contractual partners, business activities, transactions conducted via the Portal, and performance of obligations;
• 10.3.6. data about User’s habits, preferences and satisfaction when using services of the Portal;
• 10.3.7. data about participation in consumer games and campaigns organised by the Lender, e.g. data about points granted and prizes won;
• 10.3.8. data about the trust- and creditworthiness of the User, e.g. data about User’s payment behaviour and default of obligations; and
• 10.3.9. data obtained when performing an obligation required by the law.

10.4. Disclosure of User’s data to third parties

The Lender is entitled to disclose User’s data (to the extent reasonably necessary considering the objectives listed in Section 10.2) to:

• 10.4.1. any legal entity within the same group with the Lender;
• 10.4.2. any person related to the conclusion and/or amendment of User Agreement and/or any other agreements concluded between the Lender and the User and performance of the Lender’s obligations therefrom (e.g. providers of communications and printing services, payment intermediaries, credit institutions and IT service providers);
• 10.4.3. any service provider to whom the Lender has outsourced its activities necessary for or related with the provision of services under the User Agreement or Loan Agreement (either in part or in full) on terms and conditions provided by the applicable law;
• 10.4.4. any person maintaining databases about data necessary for the assessment of the creditworthiness (e.g. Suomen Asiakastieto Oy) and registers of defaulted payments (e.g. Creditreform, group of companies);
• 10.4.5. any service provider used by the Lender for performing activities described above under Section 10.2 – for the data about authorised processors please see Lender’s website (www.bondora.ee);
• 10.4.6. authorised processors, i.e. persons who process data on behalf of the Lender based on an agreement;
• 10.4.7. actual or potential buyer of Claims;
• 10.4.8. any person acquiring a Claim;
• 10.4.9. actual or potential holder of pledge over a Claim;
• 10.4.10. actual and potential investors and/or creditors of the Lender;
• 10.4.11. other third persons if necessary in the course of enforcement of Claims against the User (e.g. debt collectors, lawyers, courts, bailiffs and bankruptcy administrators);
• 10.4.12. any person providing the Lender with legal services, accounting or auditing services, provided that the provider of the respective service has undertaken an obligation concerning the Lender to not disclose the respective personal data to third parties; and
• 10.4.13. any other person (not mentioned above) as far the obligation derives from applicable legislation.

10.5. Giving notice of any changes in the data

• 10.5.1. the User shall immediately notify the Lender about any changes in their personal data in accordance with the Section 5.1.3 and Section 6;
• 10.5.2. failure to provide notification of any changes in the data shall constitute a fundamental breach of the User Agreement.

11.1. The Lender has the right to restrict or cancel User’s right to use the Portal, reject Loan Applications and as far as permitted by the applicable law, refuse to perform its obligations under the User Agreement and/or any Loan Agreement and/or any other agreement concluded between the Lender and the User if the User is in a breach of the User Agreement and/or, the Loan Agreement any other agreement concluded with the Lender.

11.2. The Lender shall have a right to contact the User regarding any arrears using all contact details disclosed by the Borrower to the Lender.

11.3. If the User has entered into more than one Loan Agreement and the funds transferred to the Lender are insufficient for satisfying all Claims due and payable, the funds shall be divided by the Lender proportionally.

12.1. The User shall have a right to withdraw from the User Agreement without providing a reason within fourteen (14) days as of the date of entry into the User Agreement by submitting a withdrawal application which can be reproduced in writing through the Portal or via e-mail. To exercise the right to withdraw from the User Agreement, an application for withdrawal must be submitted to the Lender before the expiry of the term specified herein. In order to validly withdraw from the User Agreement, the User must fulfil immediately, but not later than within thirty (30) days after submitting an application for withdrawal, fulfil all his/her outstanding financial obligations towards the Lender under any agreement. Should the User fail to fulfil his/her obligations within the term set forth herein, the User shall be deemed to not have validly withdrawn from the User Agreement.

12.2. The User may terminate the User Agreement by submitting to the Lender a relevant application which can be reproduced in writing through the Portal or by e-mail only if all his/her financial obligations towards the Lender under any agreement have been completely fulfilled.

12.3. The Lender may terminate the User Agreement and disable or restrict access to the Portal[, in each case subject to Sections 3.3 and 13.3, as applicable, of the General Conditions, including the grace periods set out therein,] if:

• 12.3.1. the User violates the terms and conditions of the User Agreement;
• 12.3.2. the User has used or is using without the Lender’s written consent any automated means (which access means are not provided by the Lender) to access the Portal and collect any data from the Portal through automated means (included harvesting bots, robots, spiders, scrapers or any other automatic devices or programs) or if the User is using framing techniques to enclose any of the data or content to the Portal or otherwise affect the Portal.

13.1. The Lender shall have a right to receive and the User shall be obliged to pay a Fee for the rendered services pursuant to the Price List, Loan Agreement and/or other agreements he/she has concluded with the Lender.

13.2. In addition to the Fees specified in the Price List and in the agreements concluded between the Lender and the User, the User shall cover all Lenders cost which arise from the operations performed in the interest of the User and the costs relating to the collection of claims which have become collective (including legal expenses, debt collection expenses, court expenses etc.) up to the maximum amount permitted by applicable law.

13.3. All Fees and costs shall be paid by the User to the Lender in accordance with the relevant notification made available to the User in the Portal by the end of the reasonable payment term indicated on the notification.

13.4. The User shall pay all Fees and costs without any deductions and/or set-off.

14.1. The User shall be liable for the damage and loss caused to the Lender due to the fact that the User failed to duly fulfil any of his/her notification obligations deriving from the Terms of Use or other agreements concluded between the User and the Lender, including (but not only), unless the User has duly fulfilled his/her notification obligation under Section 5.1.6, the User shall be liable for the damage and loss caused to the Lender due to the fact that a third party has gained possession of the data and tools specified in Section 5.1.5.

14.2. The User shall enter into transactions through the Portal directly and at his/her own liability, being a party to the transactions themselves; the agreement forms suggested in the Portal can be used by Users at their own liability and risk. The Lender is not liable for possible obligations that may arise for the User according to the law as a result of concluding or executing a Loan Agreement using the Portal.

14.3. Nothing in this Agreement limits the liability in case of wilful breach of obligations.

15.1. The Lender shall have a right to unilaterally amend the Terms of Use if the applicable legislation or standards regulating the relations arising from the Terms of Use change and amendment of the Terms of Use is required to comply with the new legislation and/or standards. The User shall be notified of such amendments through the Portal. The amendments shall enter into force as of the disclosure of the relevant notification in the Portal.

15.2. The Lender shall have a right to unilaterally amend the Terms of Use provided that such amendments are not unfair with regard to the User, the User shall be given a minimum of thirty (30)-day advance notice and the User shall be given a right to immediately terminate the User Agreement and all other agreements concluded between the Lender and the User. The User shall be notified of such amendments through the Portal without delay. For the avoidance of doubt, should the User choose to terminate the User Agreement and all other agreements concluded between the Lender and the User, then he/she shall submit a relevant application to the Lender through the Portal or by e-mail address within thirty (30) days as of receipt of relevant advance notification and must fulfil all his/her financial liabilities arising from the any of the agreements concluded with the Lender within the same term. For the avoidance of doubt, if the User fails to fulfil all his/her financial liabilities within such term, the User shall be deemed to not have validly terminated the User Agreement or any other agreement concluded with the Lender. The amended Terms of Use shall enter into force within thirty (30) days as of the disclosure of the notification or when the User accepts the amended Terms of Use by clicking the respective field (e.g. box, button or similar) when logging in the Portal, whichever occurs earlier.

15.3. The Lender shall have a right to unilaterally amend the Price List, in which case the User shall be given an advance notice of at least thirty (30) days and the right to immediately terminate the User Agreement and all other agreements concluded between the Lender and the User. The amended Price List shall enter into force as of the disclosure of the notification, provided that the User has not chosen to terminate the User Agreement in accordance with this Section.

16.1. The Terms of Use and the User Agreement shall be governed by the laws of the Republic of Estonia.

16.2. Any disputes between the Lender and the User arising out of or in connection with the Terms of Use or User Agreement shall be resolved by way of negotiations, taking into account the Procedure for Processing Consumer Complaints in force at the time and made available on the webpage of the Lender. The User shall additionally have a right to address competent pre-trial bodies, e.g. the Finnish Consumer Disputes Board (in Finnish: kuluttajariitalautakunta), the Estonian Consumer Protection Board, the Estonian Financial Supervision Authority and/or the Estonian Data Protection Inspectorate. A dispute which the parties fail to resolve within reasonable time through amicable negotiations shall be settled (i) in the appropriate courts of the Republic of Estonia, also (but not only) if the User takes up residence abroad following the entry into force of the User Agreement or if the place of residence of the User at the time of filing an action is unknown and (ii) in respect of Users having domicile in Finland, in the competent district court of Finland as first instance.

17.1. In the event of the Lender’s insolvency, entry into new Loan Agreements shall be terminated immediately. The insolvency of the Lender shall not affect the validity of the Loan Agreements.

17.2. The Portal, the website of the Lender and the copyright of the contents thereof belong to the Lender. The User does not have the right to save, copy, change, transfer, forward and/or disclose the pages of the Portal for a purpose other than for personal use.

17.3. The Lender is supervised by the Estonian Financial Supervision Authority (address: Rahukohtu 2, 10130 Tallinn, Estonia; email: [email protected]; webpage: www.fi.ee).

These Terms of Use shall be applicable to all User Agreements and Loan Agreements concluded after 23.03.2017 and before the entry into force of the next redaction of the Terms of Use.

This privacy policy gives you an overview of the data and information we collect from you when you use our services, how we use this collected information, who we share it with and what are your rights in relation to it.

We follow very strict guidelines on handling your information, based on the European Union and the Estonian Personal Data Protection laws. This privacy policy is applicable to the Users who are natural persons and does not cover those Users who are legal persons.

Terms used in this Privacy Policy have the respective meaning as described in the Terms of Use of Bondora.

1. Information collected

Information we collect from you can be divided to the following categories:

• Personal information (e.g name, personal identification code, date of birth, address, gender, identification document information, bank name, bank account number);
• Contact information (e.g email address, mobile phone);
• Financial information (e.g income, obligations);
• Transaction information and browsing data – (e.g services used on our website, IP address, browser type, preferences, investment goals, incoming payments, communication).

This abovementioned information we might get from following sources:

• You (e.g data inserted and shared by you, the way you use our Platform, what digital devices you use, communication, cookies);
• Third parties (e.g publicly available resources, credit reference agencies, cooperation and affiliated partners);
• State and commercial Institutions.

2. Information used

In order for us to provide you the services available via Platform you might need to submit us or to our partners data necessary for providing our services. If you fail to provide us the data, we are not able to provide you the services.

We might use the information collected about you for the following reasons:

• Manage your User account with us;
• To provide you our services;
• Assess your credit worthiness;
• To take action against you if you fail to pay your loan with us;
• Verify your identity and any other information you have provided to us;
• Prevent or detect fraud, money laundering or other crime;
• To improve the quality of our Platform and services;
• To establish, exercise and defend legal claims;
• Analyze and improve our services for you;
• Develop and offer you new services;
• Conduct statistical reports from information collected to evaluate our business, activities and quality of our services;
• To offer you any other services and products provided by us or our group companies;
• Contact you;
• To promote our services via Platform or via your contact information;
• Sending you servicing and marketing messages;
• Regulatory reporting;
• Any other legal manner.

3. Information shared

We may share your information with the following third parties for the purposes described above:

• Group companies;
• Co-operation partners (e.g third-party data processors, marketing service providers, accounting companies etc.);
• State and commercial institutions (e.g police, courts, credit reference agencies etc.);
• Collection agencies and lawyers;
• To anyone whom we may transfer part of our activities or assets.

We guarantee that access to User information is limited to the company's employees, whose duties require access to such data. All Bondora employees are required to keep information confidential and are forbidden to share it with the third parties unless reasons stated above.

4. Information stored

Information is stored and archived on a secure server with access limited to a number of people. Security is enforced through rigorous privacy protection standards performed by dedicated third party partners.

5. Information security

A number of Internet security measures have been added to ensure that information is processed, transmitted and archived securely.

Servers are located at a data center in Frankfurt, Germany and operated by Telehouse, a global 200 company. Server management is separately contracted to Virtion GmbH. These companies allow us to provide improved availability, better scalability and increased flexibility of our IT resources.

All their activities are carried out in accordance with a number of standards including ISO 27001:2005 (Information Security Management), BS25999-2:2007 (Business Continuity Management), PCI-DSS (Payment Card Industry), ISO 9001:2008 quality standards and ISO 14001:2004 (Environmental Management System Standard).

The companies have enforced physical and virtual security 24/7. All internal movements within the data center are monitored by proximity card readers and infra-red intruder sensors.

At Bondora security breaches are identified, monitored and warded off by software and hardware firewalls.

6. Your rights

We need to inform you about what information is collected, from where information is collected, how information is used, to whom this information is shared, how long this information is kept and what your rights in relation to it are. This information is provided to you on our Website (if applicable) and in this Privacy Policy.

You have a right to access your information. We must submit you the overview of the information we have on you unless there is a legal reasons not to comply with this request. We aim to provide you the information as soon as possible with free of charge. Please note when you request the personal information more than twice a year we have a right to charge a fee to cover our costs for providing you that information. Please e-mail our customer support [email protected].

You have a right to ask for correction of your inaccurate or incomplete date. Please e-mail our customer support [email protected].

You have a right to ask us to erase your information. We have a right to refuse the request if the continuation of the information is necessary for the fulfilment of the contractual obligations or if such obligation arises from applicable legislation. Please e-mail our customer support [email protected].

You have a right to ask us to restrict processing information and revoke your prior consent for such information processing. We have a right to refuse the request if processing is for the establishing or exercise of defense of legal claims. Please e-mail our customer support [email protected].

You have a right to receive your personal information submitted to us by yourself for purpose of transferring this information to another service provider. Please e-mail our customer support [email protected].

7. Retaining information

We will keep your information until we are legally required to do so. When information processing and storing is no longer required under applicable legislation it is removed from the registry.

8. Automated decisions

We use automated process to decide whether to approve your loan application or reject the application. Our automated process assesses all the information we have collected about you and calculates your credit score. Based on this you either will be offered the loan on the conditions you applied for or offered a lower amount, different duration or the application will be rejected.

In addition to the automated credit scoring we may automatically decide you pose a fraud or money laundering risk based of our information processing results.

Our automated processes are regularly tested, assessed and reviewed to make sure they remain accurate.

You can e-mail to ask us to reconsider decisions at [email protected].

9. Cookies

We use “cookies” which are small text files placed on your hard drive by a web page server. This allows us to collect certain information from your web browser. Please see Cookie Policy for additional information.

10. Links to Third Party Websites

Links to third party websites from/ to Bondora website are provided solely as an access point to obtain useful information on services or topics that may be needed to the users of our platform.

Please note that third party websites may have different privacy policies and/or security standards governing their sites.

11. About Bondora

Bondora AS is incorporated in Estonia under company registration number 11483929, having its registered office at A.H.Tammsaare Business Building, Tallinn, Estonia. Bondora AS is authorized and regulated by Financial Supervision Authority.

This Policy was updated on 5th of June 2018.

What is a cookie?

A cookie is a small morsel of text that a website asks your browser to store. All cookies have expiration dates in them that determine how long they stay in your browser. Cookies can be removed in two ways: automatically, when they expire, or when you manually delete them. We've included more details below to help you understand what kinds of cookies we use.

Please remember that by deleting existing cookies or disabling future cookies you may not be able to access certain areas or features of our website.

What cookies does Bondora use?

We use cookies across our website to improve the performance and enhance the user experience. Please be advised that when you visit our website you agree that we use the following cookies:

• Essential cookies that are only set or retrieved by the website while you are visiting which allow us to identify you as a subscriber and ensure that you can access the subscription only pages. We can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf.
• Functionality cookies are used to allow us to remember your preferences on the website, such as language or username to customize your user experience.
• Performance cookies allow us to collect information how you use the website. All of the information collected is anonymous and is only used to help us improve the way our website works and measure the effectiveness of our advertising campaigns.
• Third party cookies are behaviorally targeted advertising cookies (e.g. Google Analytics) that allow us to record pages that are visited and the links that are followed. The information collected in non-identified.
• Secure cookies are used to ensure that any data in the cookie will be encrypted as it passes between the website and the browser. It helps us to protect the security of your account.

How to change cookies settings?

In case you want to change your preferences about the cookies that we use, please change your browser settings. For more information you may wish to visit http://www.aboutcookies.org/

We would like to avoid seeing you dissatisfied with our services, but if this happens, we ask to hear from you! Here is how you can do it:

• Email your complaint to our customer support [email protected]
• Once we receive your complaint, you will be emailed an automatic notification (normally within 1 business day)
• From that moment we will start looking into your complaint and will send you an answer within 5 business days.

If you are dissatisfied with our answer, you can appeal the decision by emailing the previously received response to our customer support. Here is what will happen then:

• Our Customer Service Manager will acknowledge the receipt and offer you initial feedback within 5 business days
• Within 4 weeks from receiving your appellation, we will send you a final response or an indication when we will contact you again. Should the final response be negative, we will clearly explain why we are not in the position to satisfy your request.
• Should you still remain dissatisfied with the answer, you can exercise the right to turn to your Financial Ombudsman Service. Please note that you also have the right to turn to the Financial Ombudsman Service right away.

Introduction

Any conflicts of interest, which may arise in relation to Bondora, shall be identified and managed by the company. We will maintain and manage all arrangements necessary to prevent a conflict from escalating to causing material damage to the interests of our clients. The given document states our conflicts of interest policy (here and further “Conflicts Policy”) inasmuch as it applies to the operation of our activities.

We are fully committed to complying with our regulatory and legal obligations and maintaining the ethical standards. We require that all of our employees are contractually bound to comply with our Conflicts Policy and any breach of such may lead to disciplinary proceedings, not excluding discharge of services.

Potential or Actual Conflicts Indication

A conflict of interest may take place if any of Bondora directors, employees, outsource partners or otherwise “relevant persons” linked to the company by control is providing a service to Bondora clients or engaging in activities on their own account, which may cause a material risk or damage to Bondora clients’ interests, for example where any of the mentioned above persons:

• could either make a financial gain or avoid a financial loss, on the account of a Bondora client;
• has an interest in the outcome of a rendered service, which is different from the interest of a Bondora client;
• is incentivized to offer privilege to one of Bondora clients on the account of another Bondora client;
• receives an incentive in any form (financial / goods / services) other than the standard commission fee, from a person other than the Bondora client for a service rendered to a Bondora client.

Potential or Actual conflicts of interest we have identified

Borrowers are subject to a borrowing fee for receiving access to our platform, as stated in their Loan Agreement and any other contracts. This fee includes the amount, which we estimate to reflect the possibility of their default, viewed against their Credit Rating and in relation to their Loan Agreement.

We may as well make payments to the third parties for referring clients to us; however an appropriate disclosure shall be made for such instances.

Employees

A conflict of interest may occur if a Bondora employee (or the employee’s family) is somehow associated to the other party of any given transaction, especially if such party is a Bondora client. This association may include being a director, significant shareholder or a consultant to any Bondora client. Bondora employees are required to disclose any connection, which could compromise their judgment, or involve any material interests.

Managing Conflicts of Interest and Disclosure

Bondora will make all possible and reasonable efforts to mediate any conflict of interest.

Should there be a considerable risk of damage to any Bondora client, we will issue an appropriate disclosure.

We will carry out all necessary procedures, including employee training, to ensure that circumstances at which conflict of interest may arise are identified and properly managed.

All conflicts, which may arise, shall be closely monitored.

Further Information

The given document shall be reviewed and updated as necessary. In case of any questions in regards to this policy, please send an email to [email protected].

Capitalized terms bear the meaning outlined in Bondora Terms and Conditions, unless defined otherwise.