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Privacy policy FLOA
Version : 08.02.2024
Donwload the PDF file SummaryThe terms used in this privacy policy (the "Privacy Policy"),
when capitalized, shall have the meaning given to them in
article 1.
FLOA Bank places the respect of Your Personal Data at the
center of its concerns.
Our Privacy Policy is intended to inform You in a clear,
simple and transparent way about the Processing
performed on the Personal Data You entrust to Us.
Specifically, We inform You about:
- The Personal Data that We collect and process
(article 2) ;
- The way We collect Your Personal Data (article 3) ;
- The purposes and legal basis of the Processing of
Your Personal Data (article 4) ;
- The possible transfers of Your Personal Data to a
third country (article 5) ;
- How long We keep Your Personal Data (article 6) ;
- The recipients of Your Personal Data (article 7) ;
- The modalities of the profiling made from Your
Personal Data (article 8) ;
- The security measures that We put in place to
protect Your Personal Data (article 9) ;
- The right You have regarding Your Personal Data
(article 10) and;
- Modalities regarding the installation of cookies and
trackers on Your device and Processing of the
Personal Data collected through them (article 11).
Our Privacy Policy may be modified, supplemented or
updated at any time, in particular to comply with legal,
regulatory, jurisprudential or technical developments. If
applicable, Your Personal Data will be treated in
accordance with the Privacy Policy in effect at the time of
collection.
Additional information concerning the Processing of Your
Personal Data by FLOA Bank may be communicated to You
particular when You request a specific product and/or
service.
1. Definitions:
In our Privacy Policy, the following capitalized terms
will have the meanings as described below:
« FLOA Bank », « We », « Our/Ours », or «Us » means FLOA,
called under its trade name «FLOA Bank », limited
company with the capital of 72 297 200 euros, registered
at RCS of Bordeaux under the registration number
434 130 423, whose head office is located 71, rue Lucien
Faure – Bâtiment G7 – 33000 Bordeaux (France). FLOA
Bank is under the ACPR authority control (Autorité de
Contrôle Prudentiel et de Résolution), located 4 Place de
Budapest, CS 92459 - 75436 Paris and registered at ORIAS
(www.orias.fr) under the number 07 028 160.
« Personal Data » refers to any information related to an
identified or identifiable natural person within the
meaning of Data Protection Laws (hereafter « data
subjects »). Some fields are marked with an asterisk when
they relate to Personal Data necessary to achieve a
specific purpose.
« Data Protection Laws » means together the German
Data Protection Laws (in particular the German
Federal Data Protection Act [« BDSG »]) and
Regulation (EU) (EU) 2016/679 of the European
parliament and of the council of 27th of April 2016 on
the protection of natural persons with regard to the
processing of personal data and on the free
movement of such data («GDPR »), as well as any
regulation relating to the Processing and/or
protection of Personal Data in force or may come into
force.
« Controller » refers to FLOA Bank, unless otherwise
specified.
« Processing » (or « To Process ») refers to, in accordance
with the article 4.2 of the GDPR, means any operation or
set of operations performed upon personal data or sets of
personal data, whether or not by automated means, such
as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation,
use, disclosure by transmission, dissemination or any other ways of making the data available, the alignment or
combination, the restriction, the erasure or destruction.
« You», « Your » or « Yours » refer to the natural person
concerned by the collect and the Processing made by
FLOA Bank, person called “Data subject” within the
meaning of Data Protection Laws. Data subjects are
customers and prospects of FLOA Bank, and visitors of
websites and applications edited by FLOA Bank.
2. What Personal Data Do We Collect and Process?
We undertake to collect and Process only the Personal
Data necessary to achieve the purposes listed in article 4
These Personal Data include, but are not limited to:
- The data related to Your identity. Examples:
civility, surname, first names, address, telephone
number (fixed and/or mobile), e-mail addresses,
date of birth, identity document, photograph.
- Your financial and banking information.
Examples: bank account number, bank card
number, expiry date of the bank card, banking
establishment.
- Your transaction data. Examples: file number,
product(s) and/or service(s)
requested/subscribed, amount and duration of
funding.
- Data related to the management of the business
relationship. Examples: history of purchases
and/or subscriptions, correspondence,
exchanges, recordings of telephone calls.
- Data relating to the repayment of Your financing.
Examples: schedule, repayment incident.
- Data necessary to carry out sales promotion
activities.
- Your opinions and comments. Examples: opinions
concerning a product(s) and/or service(s)
distributed by FLOA Bank
- Data related to Your behavior, habits, and
preferences.
- Data related to Your requests to exercise Your
rights, in accordance with article 10 of the Privacy
Policy.
We do not collect any Personal Data related to Your racial
or ethnic origins, political, religious or philosophical
opinions, trade union membership, sexual orientation or
sex life, or genetic data, unless required by law.
We inform You, if necessary, of the consequences of a
refusal to disclose Your Personal Data. We inform You, for
example, that refusing to provide Us with the Personal
Data necessary about Your financial situation prevents Us
from studying Your credit application.
3. How Do We Collect Your Personal Information?
The Personal Data that We process may have been
provided directly by You (3.1) or collected indirectly from
third parties (3.2), in accordance with Data Protection
Laws.
3.1 Personal Data collected directly from You:
Within the framework and during the commercial,
contractual and pre-contractual relations with You, We
directly collect Your Personal Data in particular when:
- You are visiting one of the websites or using one
of the applications published by FLOA Bank or
one of its partners ;
- You create an account on one of the websites or
applications published by FLOA Bank or one of its
partners ;
- You subscribe to one of the products and/or
services distributed by FLOA Bank ;
- You agree to receive Our commercial communications ;
- You communicate them to Us voluntarily, in
particular via collection forms, requests for
information or surveys.
3.2 Personal Data collected indirectly, from third
parties :
We indirectly collect Your Personal Data, in particular
from:
- From Our partners, in compliance with the Data
Protection Laws and in accordance with the
agreements made with these partners;
- Third parties with whom You have subscribed to
a product or service and/or whom You have
authorized to communicate Your Personal Data
to Us;
- Entities making available to Us the files necessary
for the provision of certain products or services,
in accordance with applicable regulations;
- Administrative or judicial authorities, when they
publish Personal Data, in accordance with the
applicable legislation.
4. What are the purposes of the Processing that We carry out and their legal bases?
Your Personal Data is processed by FLOA Bank for the
following purposes:
4.1 Compliance with the legal and regulatory obligations of FLOA Bank :
We Process Your Personal Data to comply with our legal
and regulatory obligations in the following cases (Art. 6 (1) c) GDPR)::
- Making declarations to authorized third
parties, in particular to the State,
administrative or judicial authorities,
German Bundesbank or the national
financial authorities ;
- Evaluation of credit risk and the fight against over-indebtedness. To this end, when You make a credit
request to FLOA Bank :
- We check Your creditworthiness ;
- We detect people in situations of financial fragility. Thus, depending on the type of credit taken out with FLOA Bank, We may process Your Personal Data in order to detect any financial difficulties that You may encounter. If necessary, We will offer You a solution adapted to Your situation. - Fight against money laundering and terrorist
financing. These processes aim at setting up
appropriate surveillance and the detection of
operations that could constitute money
laundering or terrorist financing;
- Physical, logical and IT security of the FLOA Bank
network and information system. This Processing
allows Us to protect Your personal Data
(examples: identification data, password, etc.) as
well as Ours and Our entire information system.
It allows Us, for example, to detect suspicious
behaviors on the websites and applications that
We publish, a massive connection, an extraction
from Our databases, an attempt of fraud, etc.
- Management of administrative and judicial
procedures. Examples: responses to the
Portuguese Data Protection Authority (Comissão
Nacional de Proteção de Dados (CNPD));
- Management of the rights arising from the Data
Protection Laws. This Processing allows Us to
respond to the requests that You address to Us
concerning the rights listed in article 10 of the
Privacy Policy.
4.2 Execution of pre-contractual measures or a contract to
which You are or wish to be a party:
We Process Your Personal Data for the purpose to carry
out pre-contractual measures or a contract to which You
are or wish to be a party in the following situations (Art. 6 (1) b) GDPR):
- Credit granting and management. The purpose of
this Processing is to collect, at the time of Your
request, the Personal Data necessary for the
study of Your file and, if necessary, for credit
management (payment, reimbursement, etc.).
- Evaluation of credit risk. To this end, when You
make a credit request to FLOA Bank, We use
automated Decision Support Processes based on
information available to Us, particularly related
to Your financial situation and/or based on
scoring models. When You make a credit
application, this Processing allows Us to study it
and evaluate the statistical risk of default
attached to You. If Your application is refused,
You may ask Us to re-examine Your file and
present Your observations, in particular on Your
financial situation.
- Establishment of proof of transactions. This
Processing may consist of the recording of
postal, electronic, chat and SMS correspondence
between You and Us and the retention of all
elements necessary to establish proof of
transactions between You and Us.
- Customer relationship management. This
Processing allows, in particular, to provide
information and assistance relating to the
management operations of your account (e.g.:
changes of contact details, status, retractions,
etc.), to process postal, electronic, chat, SMS and
telephone correspondence between You and Us,
to manage disputes, litigation and complaints.
- Management of payment incidents, unpaid bills
and amicable or judicial recovery of any credit
granted. This Processing allows Us to identify the
sums that You owe, to manage Your possible
unpaid debts and to approach You to recover
them in an amicable or legal manner. If
necessary, We may request the registration of
information concerning You in the relevant files
in the event of a payment incident occurring in
the context of the reimbursement of credits.
4.3 Pursuit of the legitimate interests of FLOA Bank:
We Process Your Personal Data for the purpose of
pursuing our legitimate interests in the following cases (Art. 6 (1) f) GDPR):
- Prevention and fight against external fraud. This
Processing ensures :
- The detection of acts carried out within the framework of activities presenting an anomaly, an inconsistency or having been reported as potentially fraudulent (e.g. communication of false proof of income or contradictory information);
- Management of external fraud alerts leading to checks, requests for explanations or additional supporting documents;
- Taking appropriate measures in the event of external fraud or attempted external fraud, after verification, including the creation of lists of persons duly identified as perpetrators of acts qualified as fraud. - Building of statistics and score models. In order to
evaluate the credit risk and to optimize risk
management, We build score models based on
statistics, notably from data related to previously
granted credit, Your Personal Data, and
information related to payment incidents that
may have occurred on Your account.
- Anonymization and aggregation of data in
order to establish scoring models or
statistics.
4.4 Other purposes pursued with Your consent:
On the basis of Your consent, We Process Your Personal
Data for the following purposes:
- Prospection and sales promotion,
including through social networks. This
Processing allows You to be informed of
Our news (example: subscription to Our
newsletter or to Our Facebook or
Instagram page) as well as to receive Our
offers by email, SMS, postal mail (according to Your choices). We draw Your
attention to the fact that You may
withdraw Your consent to this Processing
at any time in accordance with article 10.
- Personalization / optimization of the path
and offers that are proposed to You on the
websites and applications that We publish.
This Processing allows Us to analyze Your
browsing path, to know the searches that
You have made, the products or services
that We distribute and that are likely to
interest You, in order to improve Your
experience and Your satisfaction ;
- Realization of statistics, surveys,
satisfaction surveys and study of the
results based of anonymized data, to
increase Our knowledge about Our
customers, about their use of the
websites and applications published
by FLOA, about the products and
services that We distribute, and the
relevance and performance of our
promotional campaigns, with
objective to improve Our customers
experience and their satisfaction;
- Collection of customer opinions. The
purpose of this Processing is to collect
Your opinions concerning the products
and services distributed by FLOA Bank and
thus to improve Your experience and Our
offer. Your opinions may be posted on Our
websites and applications as well as on
the websites and applications of our
partners.
5. Are your Personal Data transferred outside the European Union?
In principle, Your Personal Data is processed within the European Union.
However, some of FLOA Bank 's service providers and
banking agents, who assist Us in particular in the
management and execution of Your request and, where
applicable, Your contract, may be located outside the
European Union. If this is the case, FLOA Bank ensures
that this transfer is carried out in compliance with Data
Protection Laws and guarantees an adequate level of
protection of Your privacy and Your fundamental rights.
6. What are the retention periods We apply to Your Personal Data?
The retention periods for Your Personal Data are as
follows:
- If You are a client of FLOA Bank (a current
contract binds You to FLOA Bank), Your Personal
Data will be kept for a period of 5 years from the
date of termination of Your contract and the
closing of Your client account. Your contract is
kept for 10 years, in accordance with our legal
obligations ;
- If You are a prospective client of FLOA Bank (no
contract binds You to FLOA Bank), Your Personal
Data will be kept for 3 years from the date of
collection or from the last contact made by You.
- If Your request for financing from Floa Bank is
unsuccessful, Your Personal Data is kept for 6
months from the date of refusal of Your request
by FLOA Bank.
- Special case of fraud alerts and characterized
frauds:
- In the event of a fraud alert: any external fraud alert that is not qualified within 12 months of its issuance shall be deleted without delay;
- In the event of serious fraud: data relating to serious fraud is kept for a maximum period of 5 years from the closing of the fraud file. Data relating to persons registered on a list of proven fraudsters are deleted after the 5-year period from the date of inclusion on the list. - Cookies and tracers: The methods for depositing
cookies and other tracers are detailed in article
11.
When an administrative or judicial procedure is in
progress, we keep the data until the end of the procedure.
They are then archived in accordance with the applicable
statutory limitation periods.
You will be informed of any Processing of Personal Data with a retention period other than those listed above.
7. Who are the recipients of Your Personal Data?
In order to achieve the purposes detailed in article 4, Your
Personal Data may be transmitted:
- to Our service providers, who perform services
on Our behalf, including lawyers, bailiffs, auditing
firms, etc. ;
- to Our financial and commercial partners ;
- to credit institutions s bound by professional banking secrecy in accordance with Article L.511-33 of the
French Monetary and Financial Code and belonging to the FLOA Bank’s Group (the list of companies can
be sent to You on request), i.e. controlled by FLOA Bank, or which controls FLOA Bank, directly or
indirectly, within the meaning of Article L.233-3 of the French Commercial Code, within the framework
of preventive risk management and collection;
- subject to the conditions for the lifting of
professional secrecy, to judicial, administrative,
financial or other governmental authorities, in
particular :
- the tax and customs authorities;
- the German Bundesbank or the national financial authorities;
- social security organizations;
- The Data Protection Authorities. - to financial institutions.
The communication of Your Personal Data to the
recipients listed above is carried out in compliance with
the Data Protection Laws and the agreements that We
have concluded with the recipients, if any.
8. What categories of profiling do We do ?
Profiling is defined by the RGPD as follows: "any form of
automated processing of personal data consisting of the
use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or
predict aspects s concerning that natural person's
performance at work, economic situation, health, personal
preferences, interests, reliability, behavior, location or
movements" (Article 4).
We carry out several categories of profiling:
- Profiling for credit risk assessment and granting
purposes, notably through Our Score Model.
This type of profiling may have legal effects on
you and may result in a decision such as a credit
refusal. These decisions are, however, necessary
for the conclusion or performance of the
contract between You and FLOA Bank.
- Profiling for "marketing" purposes, in order to
send You personalized offers, to suggest
services, products or complementary offers
likely to correspond to Your preferences and
this, on the basis of segmentation or selections
or based on algorithms. This type of profiling
may have legal effects on You, such as marketing
segmentation leading to the non-reception of
some of Our commercial offers. However, these
decisions are necessary in order to improve the
targeting of Our marketing campaigns and
therefore, to Your satisfaction.
The profiling tools We use are based on different
variables, including:
- Your contact information;
- If applicable, the type of product or service being
considered for financing;
- Where applicable, a check with the relevant official
records;
- A score based on the Processing of Your Personal
Data, including those collected from our partners
(examples: customer account data and/or loyalty
card(s), associated with Your purchase history).
With regard to automated decisions and profiling, We
assure You the right to obtain human intervention, to
present Your observations and to contest the automated
decision that will have been opposed to You, if necessary.
9. What security measures do we put in place to protect Your Personal Data?
FLOA Bank undertakes to implement the appropriate
technical and organizational measures in order to
guarantee the protection, confidentiality, non-alteration,
availability, absence of access by an unauthorized third
party, and therefore, in general, the security of Your
Personal Data.
These measures are defined and implemented following
the best market standards in terms of security and in
particular the recommendations of the supervisory
authorities regarding the protection of Personal Data.
10. What are Your rights regarding the Personal Data We collect?
In accordance with the Data Protection Laws, You have
the following rights regarding Your Personal Data:
- the right of access: You may obtain a copy of all
of Your Personal Data processed by FLOA Bank;
- the right of rectification: You may ask FLOA Bank
to correct and/or complete Your Personal Data if
it is inaccurate or incomplete;
- the right of deletion: You can obtain the deletion
of your Personal Data. Your Personal Data may
however be retained by FLOA Bank when their
Processing is necessary to comply with a legal
obligation or to exercise a right before an
administrative or judicial authority;
- the right of object: you may ask FLOA Bank,
for reasons concerning Your particular
situation, to cease the Processing that are
being made on Your Personal Data, unless
FLOA Bank justifies that its legitimate and
compelling interests prevail over Your rights
and freedoms. With respect to commercial
prospection, You have the right to object,
without charge or reason, to the use of Your
Personal Data for commercial prospection
purposes.
- the right to the limitation of the Processing:
You may request a limitation on the
Processing of Your Personal Data, for
example when You dispute their accuracy, in
order to allow FLOA Bank to carry out the
appropriate verifications, or when You
exercise Your right of opposition, during the
time that FLOA Bank is studying Your
request. Where applicable, Your Personal
Data may only be processed with Your
consent or for the defense of a right before
an administrative or judicial authority;
- the right to portability: You may obtain the
Personal Data that you have provided to FLOA
Bank in a structured, commonly used, machinereadable format, and if possible in open format,
as well as their transmission to another service
provider, where technically possible;
- the right to withdraw consent: when the
legal basis for the processing is your consent,
you can withdraw it at any time without
affecting the processing already performed
based on your consent;
- the right not to be subject to a decision
based solely on automated processing,
including profiling, which produces legal
effects concerning you or similarly
significantly affects you, except if: (a) is
necessary for entering into, or performance
of, a contract between the Data Subject and
a data controller; (b) is authorised by Union
or Member State law to which the controller
is subject and which also lays down suitable
measures to safeguard the Data Subject's
rights and freedoms and legitimate interests; or (c) is based on the Data Subject's explicit
consent.
Visit the German Data Protection Authority
(Bundesbeauftragter für den Datenschutz und die
Informationsfreiheit) website for more information
about Your rights.
If You have any questions regarding the Processing and
collection of Your Personal Data or in order to exercise
the above rights, You may contact FLOA Bank :
- by e-mail at: contact@floa.com ;
- or by post at: SERVICE CONSOMMATEUR – FLOA
Bank – 36 rue de Messines – 59 686 Lille Cedex
9, France.
- Or contact Our Data Protection Officer (DPO) by e-mail
at: dpofloa@floa.fr.
You may, at any time, address a complaint to a
supervisory authority. The competent supervisory
authority for Us is the French data protection
authority: www.cnil.fr.
