Addendum for favoritlån.se

This data protection policy describes how Axo Finans AB processes personal data. Personal data refers to information that can be directly or indirectly linked to you, such as name, address, telephone number, IP address and e-mail address.

Below we explain, among other things, which personal data we collect, why we do it and what we use it for. Contact us if you want to know more about how we process your personal data. Contact details for us can be found at the bottom of this document.

  1. What personal data is stored and how it is used

    Personal data that you provide yourself when you fill in the loan application form:

    Loan amount, repayment period, refinancing purpose, mobile phone number, e-mail address, position, employment (from month/year, empty month/year), monthly income, employer, telephone number, marital status, number of children under 18, type of accommodation, address since month /year, housing rent, purpose of the loan and social security number.

    Some of the personal data we request is collected from our dynamic application form. As a result, you do not always have to provide all the personal data above yourself.

    Personal data that Axo Finans AB collects on its own:

    IP address (obtained from the browser session).

    Personal data we collect from other sources:

    First and last name, address, payment notes, debts to the bailiff, postcode, city.

    By completing a loan application, you also agree that we obtain credit approval, credit rejection and additional information about the status of your loan application from our cooperating lenders.

    This information is also collected for any co-applicants.

    Our sources of personal data:

    Credit information company UC AB. UC AB guarantees that only one (1) credit report is registered on you and any co-applicants when we send out inquiries to our cooperating lenders. By law, UC will send you inquiry copies to inform you of what information has been disclosed and to whom. Note that you may receive several inquiry copies sent home, but that this does not mean that several credit details are registered on you.

    The personal data that we receive from you, or that we collect, is stored in our database.

  2. The purpose of the processing of the personal data and the legal basis for it

    We use your personal data for the following purposes based on the following legal grounds:

    Provision of our services
    We use your personal data to process your loan application and to check your creditworthiness. We will contact you during the application process by phone, e-mail or SMS. We collect information about credit approval, credit rejection and additional information about the status of your loan application from our cooperating lenders in order to fulfill the mission as a loan intermediary.

    Legal basis: Fulfillment of our agreement with you and fulfillment of legal obligation.

    Marketing:
    We may use your personal data to market the same, similar and other services from Axo Finans AB to you. Such marketing can be conveyed through, for example, letters, text messages, e-mails or directly addressed letters. We may also analyze and segment your personal data in order to provide you with relevant marketing, and in connection with this share your data with certain marketing partners (such as Facebook, Microsoft and Google).

    Legal basis: Legitimate interest in marketing our services.

    Development of our services:
    In order to develop and improve our services, your personal data may be used to analyze the use of our services. For this purpose, we may also compile your personal data for statistical analysis, in which case your personal data will be anonymised.

    Legal basis: To the extent that non-anonymized personal data is processed for this purpose, Axo Finans AB relies on its legitimate interest in developing its services and its website.

    Fulfill our obligations according to law and regulation
    We need to process and save personal data according to certain legislation such as e.g. the accounting act, the loan brokerage legislation and the money laundering legislation. For example, we will process your personal data for the purpose of checking and investigating whether you are a politically exposed person (PEP).

    Legal basis: Fulfillment of legal obligation.

    Information security and countering fraud
    We may process your personal data in order to maintain customer security for our services and to counter fraud. Such processing is carried out, among other things, by analyzing your personal data against other data in order to investigate, prevent or take measures for your customer security and to counter fraud.

    Legal basis: Legitimate interest to provide customer security and prevent fraud and performance of our contract with you.

    Recording of calls
    When talking to our customer service, the call is recorded. The purpose of recording the conversations is to document the application process, investigate customer knowledge and to be able to fulfill our agreement with you.

    Legal basis: Fulfillment of our agreement with you and fulfillment of legal obligation.

    When you have registered your loan application at axofinans.se, Axo Finans AB forwards the application to its cooperating lenders. The lenders evaluate the application and produce loan offers.

  3. Who gets access to the personal data

    Axo Finans AB only discloses your personal data to other businesses to the extent required to fulfill the purposes of the processing in accordance with point 2 above.

    The businesses that get access to the personal data can mainly be divided into three groups:

    Lender

    Axo Finans AB discloses all personal data that you provide, or that we ourselves collect, to our cooperating lenders. The lenders can only use your personal data to assess whether to make a loan offer and to determine the loan terms in more detail. The lender is the personal data controller for the processing of personal data when assessing the loan application, and the lender’s processing of your personal data will then follow the lender’s own data protection policies. https://www.axofinans.se/om/bank

    Other collaboration partners

    Within the framework of your loan application, we may disclose your personal data to selected partners. These can be seen in the overview below.

    Centeo Group ApS may access your contact details, e-mail address and mobile phone number. Centeo Group informs customers who have been rejected by the banks and lenders we cooperate with about other financing options.

    Technical system suppliers

    We disclose your contact details to our technical system suppliers who act as so-called personal data assistants in relation to Axo Finans AB when processing your personal data. These can be seen in the overview below.

    • Amazon Web Services EMEA SARL (“AWS Europe”) is a technical hosting partner and stores the personal data on its servers in Sweden.
    • Webhuset AS is a technical hosting partner and stores the personal data on its servers in Norway.
    • UC AB processes personal data to make credit reports.
    • Make AS uses the personal data to send you e-mail on our behalf.
    • Google, Inc. stores the personal data in connection with email processing and to target advertising to you on our behalf.
    • Kundo AB stores the personal data in connection with e-mail handling.
    • Link Mobility ASA uses the personal data to send you SMS on our behalf.
    • Eurobate AS uses the personal data to send you SMS on our behalf.
    • Mailchimp, Inc. uses the personal information to send you email on our behalf.
    • Trustpilot.com uses the personal data to send you emails on our behalf.
    • Twilio Inc. uses the personal data to send you e-mail on our behalf.
    • > Facebook, Inc. uses the personal data to offer chat facilities and direct advertising to you on our behalf.
    • > Microsoft Ads, uses the personal data to target advertising to you on our behalf.

    The personal data processors listed above are bound by personal data processor agreements and cannot use your personal data for their own purposes, or purposes that conflict with the purposes stated in this data protection policy.

    We also disclose your personal data to third parties in the event of investigation into suspected crime or if we are otherwise obliged to do so according to law or authority decision. Your personal data may, for example, be shared with third parties for the purpose of checking and investigating whether you are a politically exposed person (PEP), more information on this can be found under point 8 below.

    Axo Finans AB or a significant part of Axo Finans AB may be sold to a third party. In such case, your personal data may be shared with such third parties in connection with such sale. Such sharing then takes place with the support of Axo Finans AB’s legitimate interest in being able to carry out a sale of its business.

    In addition to what is mentioned above, we do not disclose any personal data unless you have expressly consented to it.

  4. Transfer to third countries

    As a starting point, your personal data will be processed within the EU/EEA. In exceptional cases, your personal data may be processed outside the EU/EEA. When processing outside the EU/EEA, Axo Finans AB ensures that transferred data is processed in accordance with applicable law by taking appropriate protective measures. Such suitable protective measures can be, for example, the signing of agreements that contain standard clauses approved by the European Commission.

  5. Procedures for archiving and deletion

    Axo Finans AB has routines for archiving and deleting personal data.

    The personal data is not stored longer than necessary to fulfill the purposes stated in point 2 above and to comply with mandatory regulations in applicable legislation. As a starting point, the personal data is not stored longer than 15 months from the time you completed the loan application. According to law or regulation, however, there may be an obligation to store certain personal data for longer than 15 months.

  6. How we store and secure personal data

    Axo Finans AB assures that its customers’ privacy is protected in accordance with the requirements of current legislation.

    In addition, Axo Finans AB assures that the personal data is stored securely in accordance with current law and that it is not processed by unauthorized persons. Furthermore, Axo Finans AB assures that the personal data is stored in systems that have the information security required to meet the requirements for confidentiality, integrity and accessibility.

    Axo Finans AB requires its employees and contractual parties to follow the laws, regulations and internal guidelines that apply to the processing of personal data. Axo Finans AB has introduced organizational and technical procedures to ensure that your personal data does not go astray, is not accidentally changed and that it is available on request.

  7. Your rights as a registered customer/client

    Right to access
    As a registered user, you have the right to request access to the personal data that we store about you and to request insight into how we use them. To request access and transparency, you can contact our customer service, which provides register extracts.

    Right to correction
    If you believe that the personal data we store about you is incorrect or incomplete, you have the right to request that the data be corrected or supplemented.

    Right to object
    You have the right to object to the processing of personal data that is processed on the basis of a balancing of interests. In the event of such an objection, you must specify which treatment you object to.

    Right to restriction of processing
    In some cases, you can demand that the processing of your personal data be restricted. Such right applies, for example, if you have objected to certain processing in accordance with above.

    Right to deletion
    Axo Finans AB will, as a rule, delete your personal data if you request it, provided that continued storage is not necessary to document services provided or continued storage for another reason is required by law.

    Right to data portability
    Provided that processing takes place with the support of your consent or if processing is necessary to fulfill an agreement with you, in certain cases you have the right to obtain and use your personal data elsewhere. The right to data portability only applies to the personal data you have provided yourself.

    Right to file a complaint
    Furthermore, you have the right to make a report to the Data Protection Authority if you believe that your personal data has been processed in violation of current legislation.

  8. PEP – person in a politically vulnerable position

    The term PEP mainly covers politicians at national level, other senior officials who have or have had an important public function in a state or who have or have had a function in the management of an international organization, as well as their family members. If you are a politically exposed person, you must notify us of this before submitting your application, as this is a requirement according to the Act (2009:62) on measures against money laundering and the financing of terrorism and the Financial Supervisory Authority’s regulations (FFFS 2009: 1) and general advice on measures against money laundering and terrorist financing. By approving your loan application, you confirm that you are not a politically exposed person and also that the purpose of your loan application is not to commit serious crimes such as terrorism or money laundering.

  9. Changes to this data protection policy

    Axo Finans AB reserves the right to update and make changes to this data protection policy at any time. In case of major changes, you will receive information about the changes via e-mail. The latest version of this data protection policy is also always available on our website.

  10. Contact details

    Axo Finans AB, with organization number 556907-5673, is the personal data controller for the personal data collected in accordance with this data protection policy.

    You can at any time ask us questions about how we process your user data and invoke the above-mentioned rights by contacting our customer service below.

    Telephone: 0771-323 400
    E-mail: [email protected]
    Contact form: https://www.axofinans.se/om/kontakta-oss
    Address: Axo Finans AB, Box 3040, 136 03 Haninge

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Firstborn Group Ltd
Squire Patton Boggs Llp
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148 Edmund Street
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