"We", "our" or "us" means Qred Bank AB (org. no. 559008-9800) and all other companies within the Qred Group - Qred Holding AB (publ) (org. no. 559031-0685) and Qred Factoring AB (org. no. 559221-0180) registered with the Swedish companies register and with our main office located at Drottninggatan 98, 111 60 Stockholm. For the purposes of EU data regulation, we are the data controller in respect of the personal data we receive from you, or otherwise collect about you, and we are responsible for ensuring that we use your personal data in compliance with applicable data privacy regulation (EU Regulation 2016/679).
By visiting our website you approve the processing of personal data described in this policy.
1 What kind of personal data do we process?
Information you provide to us. This includes personal data you provide us with as part of the credit application. It also includes personal data such as name, address, email, phone numbers and national ID-numbers. Also, information about your business, such as business plans, bank account information and payment history might be asked of you.
Information we collect about you. As part of the credit assessment process, we need to collect certain information about you and your business. We do this in order to provide you with the best possible credit offer and to comply with our legal obligations under KYC, anti-money laundering and anti-terrorist financing regulations. We also collect information from third parties such as credit rating agencies and other publicly available information sources. This information may include the following:
- Identification- and contact information: name, date of birth, ID number, address, phone number, nationality etc.
- Financial information: information collected from a third party, such as income and other credit information.
- Credit history: information collected from a third party, such as financial history, negative payment remarks and previous payment- and credit acceptances.
- Information on how you use our services and communicate with us: how you use the Services, including information on outstanding and historical debts and your repayment history with Qred; technical data such as page response times, download errors, personal preferences; your interactions with the Qred customer team, etc.
- Device information: information such as IP address, language settings, browser settings, operating system and platform and screen resolution.
- Geographic information: information regarding your geographical position.
- Information from external sanction lists and PEP lists: we may screen your information against lists of persons subject to sanctions, and lists of persons who are so called Politically Exposed Persons.
- Special categories of personal data: you can, completely voluntary, choose to give us information that can be classified as “special categories” of information according to EU regulation 2016/679, which includes information that reveals your religion, political- or philosophical convictions, union membership, or information regarding health, sex life or sexual orientation. We will never ask for that information in order to provide our services. If you were to provide us with such information, it shall be considered completely voluntary and based on your expressive consent. If you wish to know more about consent and how to revoke it, see the consent section further down below.
- Service specific information: in order to provide you with some of our Services we may collect and process additional personal data that is not covered by the above categories.
2 What do we do with the data?
Offer and improve our services. We process personal data to provide our services and offer business loans to small and medium-sized businesses. As part of this process, we also collect personal data to improve our service. Below is an overview of how we process personal data and the legal basis for processing:
3 Qred’s credit services
The following services involve Qred giving you a credit :
- Qred business loans
- Qred Factoring - factoring business (purchase of invoices)
Your personal data is shared with companies that perform a credit assessment and other suppliers in order to make a credit worthiness check when you’re applying for a business loan (Qred loan) the Qred Factoring service.
To be able to offer our Services, we do a credit assessment of you (credit worthiness check). The credit assessment is based on contact- and identification information, information on how you interact with Qred and other financial information. Financial information includes information that is provided externally by companies that perform credit assessments, based on, for example, income and payment defaults.
The credit assessment is based on contact- and identification information and information on how you interact with Qred. This includes how you interact and communicate with us but also financial information that you provide us, for instance transactional records, bank account statements and external information from credit assessment companies.
4 Marketing and communication
We can come to use your contact information in order to communicate with you. We can do this either by performing customer surveys or to send out offers regarding our products/services based on our relationship with you. If you choose to not receive such communication/information, you can at any time contact us at email@example.com.
To be able to give you customized offers and discounts etc, we look at information on how you interact with Qred, your contact- and identification information, information about products/services and your usage of these services. This processing may constitute profiling (see excerpt 6 for more information). The information is the foundation regarding Qred’s marketing- and customer analysis and the development of statistical information. We customize offers where we use contact- and identification information, information on payment patterns, and your interaction with Qred in order to improve our services and better our offers. We can utilize information in order to present personal offers via mail, email, text message, or other digital channels.
You can unsubscribe from customized personal offers either by clicking on the link in the digital communication or by contacting us directly (see contact information below).
In those cases where Qred processes your personal information based on your consent or expressive consent (for instance when you give us a power of attorney for a third party to get access to your information, or give us additional information that constitutes sensitive data). You can at any time revoke this consent by contacting us. To revoke your consent will not lead to any lesser version of our service since we don’t need this information to offer our services.
6 Profiling and automated decision making
“Profiling” means automated processing of personal data to evaluate certain personal aspects relating to you, for example in order to analyse or predict aspects of your financial situation or your preferences, such as purchase interests. We use profiling based on the personal data we have about you in order to take individual or automated decisions about you, for the following purposes:
- Predicting what marketing content would be of interest to you. You can always object to this and deregister from the marketing and this profiling, by contacting us. For further information about our processing of personal data for marketing purposes, see Section 4 above);
- Deciding what offers that might suit you;
- Deciding on the most suitable way to contact you concerning outstanding debt;
In addition, some of our Services use profiling in order to deliver the applicable Service to you, for example delivering relevant financial insights to you, or to select which offers to give you, in accordance with the terms of the relevant Service.
Decisions with legal or similarly significant effect
Automated decision making with legal effects, or automated decisions with similarly significant effect, means that some decisions in our Services are solely based on automatic means, without any interaction from any of our employees, and carry a significant impact on you as a consumer with them. By making such decisions in an automated fashion, Qred increases objectivity and transparency in the decisions when offering those Services.
We use this type of automated decision making when we:
- Decide to approve your application to use a credit Service;
- Decide not to approve your application to use a credit Service;
- Decide whether you pose a fraud- or money laundering risk, if our processing reveals that you display behaviour consistent with money laundering or fraudulent conduct, that your behaviour is inconsistent with your previous use of our Services,or that you appear to have deliberately hidden your true identity. In relevant cases, Qred also checks whether or not a specific customer is listed on a so-called sanction list.
You always have the right to challenge an automated decision which carries a legal or similarly significant effect (together with the profiling connected to it), by contacting us using the email address firstname.lastname@example.org. A Qred employee from the customer team will then look at your case.
7 Parties may we share your personal data with
Suppliers or subcontractors. We can potentially share personal data with the suppliers and subcontractors we use to be able to offer our services to you. We for instance have several software-suppliers and business-consultants. They process the personal data received from us on our behalf. We can also come to share personal data with other financial suppliers that we have a business relationship with. We take reasonable, legal, technical and organizational measures in ensuring that the personal data is shared safely.
Credit assessment companies. Your personal data will be shared with credit assessment companies and other similar suppliers to ensure that credit assessment is made before you apply for a loan.
Authorities. We have a legal obligation to prevent money laundering and financing of terrorism, and to follow other regulatory requirement. Qred can share your personal data with authorities (such as the police or the tax agency) when it is deemed necessary to fulfill a legal obligation.
Divestment. In the event that Qred sells or buys any claims, business or assets, Qred may disclose your personal data to the prospective seller or buyer of such claims, business or assets. If Qred’s or substantially all of its assets are acquired by a third party, personal data about Qred’s customers may be disclosed and shared.
8 Where do we process personal data?
We work towards processing all personal data within the EU/EES. In some cases the information may be transferred to, and be processed in, countries outside the EU/EES by another supplier. Qred ensures that reasonable legal, technical and organizational measures are taken to ensure that all data is managed in a secure way. We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line with applicable regulation.
9 How long do we process your personal data?
10 Your right to access, correction and erasure.
Right to be informed. You have the right to be informed about how we process your information. We do this through this Privacy Notice, other information on our website, and by answering questions sent to us.
Right to access your data. You may request a copy of your data if you would like to know what personal data we process about you. This copy of your personal data can also be transmitted in a machine readable format (i.e. “data portability”).
Right to correction. You have the right to correct inaccurate or incomplete information about yourself.
Right to erasure. You have the right to request deletion of your personal data, for example when it is no longer necessary for us to process the data for the purpose it was collected, or when you have withdrawn your consent. However, In some cases we are obligated to keep the data because of a legal obligation stipulated by law.
Right to restrict processing of your data or object to our processing. If you believe your information is incorrect or you believe we use your data unlawfully, you have the right to ask us to stop the processing. You may also object to our processing where you believe there are circumstances that would make such processing unlawful. Furthermore, you can always object to us using your data for direct marketing.
Right to withdraw consent. Where we process your data based on consent or explicit consent, you may withdraw this consent at any time.
Right to lodge a complaint. You have the right to lodge a complaint with your national supervisory data protection authority or by contacting us, see contact information further down.
11 Contact us
Qred is registered with the Swedish Companies Registration Office and has the registration number 559008-9800.
You’re always welcome to contact us with questions regarding privacy information protection and personal data. Also see our website for additional information about us.