This Privacy Policy explains how Sc Innovative Professional Services Srl (Finovo), with registered office in Romania, Cluj County, Cluj-Napoca, Calea Floresti no. 4, CUI RO40506547 ("Finovo", "we"), processes your personal data when you use the website and services available within the Finovo Platform ("Platform"). We comply with applicable data protection legislation, including Regulation (EU) 2016/679 (GDPR).

Finovo is registered in the register of personal data processing operations managed by ANSPDCP under General Register number 2771 dated 06.02.2019.

Please read this policy carefully to understand what information we collect, how we use it, to whom we may disclose it, and what rights you have. Use of the Finovo Platform implies acceptance of this Privacy Policy.

We collect personal data directly from you, automatically through use of the Platform, or from external sources, as applicable.

• Identification data: surname, first name, date of birth, address, ID card series and number, CNP, photo image.
• Contact data: phone number, e-mail address.
• Data required to create the account: username, password.
• Any information voluntarily provided in communications with us (e-mail, phone, chat, forms).

• Technical data about the device used: device type, operating system, version, IP address, technical identifiers, browser type.
• Data about Platform usage: pages accessed, actions performed, session duration, interactions.
• Data collected through cookies and similar technologies.

• Data obtained from Biroul de Credit, exclusively based on the Mandate and Consent granted by you.
• Data obtained from third-party service providers, as applicable.

Within this Platform module, we process your personal data for the following purposes:

• Creating and administering your account in the Platform.
• Processing requests and applications initiated by you.
• Verifying identity where necessary.
• Providing information and results generated through the Finovo Platform services.
• Facilitating the right of access to data and displaying credit offers.

• Resolving technical or general assistance requests.
• Communications regarding Platform functionalities and account administration.

• Complying with obligations imposed by fiscal and accounting legislation, fraud prevention rules, or requirements imposed by competent authorities.

• Maintaining, securing, and improving the Finovo Platform.
• Preventing and identifying potential abuse or fraud attempts.
• Analyzing Platform operation for optimization.

• Sending information about relevant services, offers, or updates.
• Communications by e-mail, SMS, or notifications, only if you have consented.

We process your data only where there is a legal basis, as applicable:

• Performance of the contract or requests initiated by you.
• Legal obligation.
• Legitimate interest, proportionate to your rights.
• Your explicit consent for certain operations.

We may disclose your personal data only within the limits permitted by law, to:

• Partners or third-party providers involved in providing Finovo services (IT, hosting, identity verification, payment processing, support).
• Biroul de Credit, exclusively based on the mandate expressed by you.
• Public authorities, when we are legally required to do so.
• Mandataries or processors, within the limits of legitimate interest (for example, law firms).
• We do not sell your personal data.

Data processing may, in certain situations, involve transfers to countries within the EU or EEA. For transfers outside the EU/EEA, we will use safeguards provided by the GDPR, such as standard contractual clauses or adequacy decisions.

Data retention periods vary depending on the processing purpose:

• Your account data is kept until the account is deactivated or deleted at your request, subject to legal exceptions.
• Data obtained from authorized inquiries (Biroul de Credit) is kept for 36 months in order to display the evolution of your data over time, such as FICO score from Biroul de Credit and number of loans. At any time, by e-mailing contact@finovo.ro, retained data may be deleted, with confirmation after the procedure is completed.
• Data used for legal obligations is kept for the period required by fiscal and accounting legislation.
• In general, data is not kept for more than 2 years after the end of the contractual relationship, except where the law (fiscal, accounting) requires retention for a longer period.

Finovo applies appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration, or destruction. In the event of a security breach, we will notify the authorities and, if necessary, affected users, in accordance with legal requirements.

The Finovo Platform may use cookies for:

• proper operation of the Platform;
• usage analysis;
• preferences and functionalities;
• marketing, only with your consent.
• You can manage cookies from your browser settings or through the dedicated banners displayed in the Platform.

Under the GDPR, you have the following rights:

• the right of access to data;
• the right to rectification;
• the right to erasure ("right to be forgotten");
• the right to restriction of processing;
• the right to object;
• the right to data portability;
• the right not to be subject to automated decision-making, including profiling;
• the right to withdraw consent (without affecting the lawfulness of prior processing);
• the right to lodge a complaint with ANSPDCP;
• the right to address the courts.
• To exercise your rights, you can contact us at: Sc Innovative Professional Services Srl (Finovo) / Calea Floresti no. 4, Cluj-Napoca, Cluj County, Romania / E-mail: contact@Finovo.ro

The Finovo Platform is not intended for minors. We do not knowingly collect data from persons under the legal age.

We may update this Policy periodically. Any change will be published in the Platform. We recommend that you periodically check the current version.