Information and instructions regarding the personal data processing
The company Raiffeisen – Leasing, s.r.o. with registered office at Hvězdova 1716/2b, 140 00 Prague, ID No. 61467863, registered in the Commercial Register administrated by the Municipal Court in Prague, section C, insert 29553 (hereinafter as “Company”) as the data controller, hereby informs you about the manner and extent of the personal data processing and advises you on the rights which you have as data subjects relating to the processing of your personal data by the Company.
Data Subjects
Subjects whose personal data the Company processes may primarily be clients and potential clients of the Company, in particular the recipients of financing and their representatives, website visitors and users of other communication and business channels, other parties to the contractual relationships and their representatives (e.g. collateral providers), or other subjects whose personal data processing is processed on the Company´s legal basis (e.g. the beneficial owners of legal entities).
The Purpose for Personal Data Processing
The Company will process your personal data in compliance with valid and effective legal regulations to fulfil the following purposes:
1. Realization of a contractual relationship
The data processing is necessary in concluding a contract and in fulfilling the contractual relationship with the Company. To fulfil this purpose, your identification data, contact data and information related to the subject of the contract (ex. identification services, subject of financing, payment details, etc.) will be processed to the necessary extent.
A contractual relationship can also be concluded remotely by using electronic signing. In such a case your identification data, contact details and information related to the signing of the contract are included in the application for signing documents provided by a third party, in SMS, email, on the signed electronic document and in the audit trail capturing information about the signing process.
2. Protection of rights and the right of protecting the Company's interests (legitimate interest)
The data processing is necessary for the protection of the Company's interests, especially within enforcing financial claims, the resolution of any litigation agenda, development of provided services, internal statistical research, analysis or evaluation or for internal administrative purposes within terms of the Raiffeisen group (see below). For this purpose, the Company is even entitled to process data serving towards ensuring the safe use of the offered services, risk management, prevention and evaluation of possible fraud behaviour, etc. Based on an authorized interest, the Company also processes information regarding creditworthiness, or one’s ability to repay their obligation, payment behaviour and the trustworthiness of natural persons who are not the consumers and all so being with the use of registries.
For this purpose, the Company also keeps recordings of incoming and outgoing calls made via the client center.
To a limited extent based on legitimate interest, the Company is entitled to process your personal data for the purpose of direct marketing (i.e. offering other similar products and services to clients).
In cases where your personal data is processed for the purpose of protecting the legitimate interests of the Company, you shall have the right to object processing of your personal data. If you enter the objection, the Company shall no longer process the personal data unless the Company demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
3. Compliance with legal obligation
The Company must collect and evaluate some information and retain it for an specified period of time as it is the requirement put forth by the legal regulations. For example, the personal data processing for the purpose of preventing the misuse of the financial system to legalize orders made from criminal acts and to finance terrorism and the creation of conditions for detecting such actions under the Act No. 253/2008 Coll., on selected measures against legitimisation of proceeds of crime and financing terrorism, as amended, where it concerns e.g. information about the sources and origin of income, capital entanglement, nationality, residence, political exposure. The obligation to process information on the creditworthiness, payment behaviour and the trustworthiness of consumers follows from Act No. 257/2016 Coll., Consumer Credit Act, as amended, as this information is necessary for assessing the creditworthiness of the consumer. Furthermore, it may also include legal regulations in the field of accounting, taxation and control activities.
4. Processing subject to consent
In order to process your personal data beyond the above the Company needs your consent. Based on your consent, the Company and selected cooperating companies process your personal data for marketing purposes, consisting primarily in the offer of products and services of the Company and selected cooperating companies, activities related to the preparation of the offer in which automated processing and profiling may occur with the aim of adapting the offer to your needs (the above mentioned may include mainly the evaluation of data related to the creation of the offer, the processing of information from your requests and opinions and form the monitoring of your activities within the communication channels and platforms used), and in the development of product or services and enhancing the client´s experience.
This processing is qualified to your consent, which is given voluntarily and in the event that you give your consent, you are entitled to withdraw it at any time. Withdrawing of consent means that the Company will not be entitled to process your personal data for the purpose specified in the consent. The withdrawing has no consequences for your contractual relationship with the Company. The Company may continue to process your personal data if the Company disposes of another legal basis for processing of your personal data. Withdrawing your consent does not aggrieve the legitimacy of any processing as a result of your consent which had been given before it was withdrawn.
Extent and source of personal data processing
The Company processes your personal data to the necessary extent for fulfilling the above-stated purposes, and the Company especially processes your identification and contact data (e.g. first name, last name, date and place of birth, birth certificate number, permanent address, contact address, citizenship, telephone number, email address, type, number and expiration date of your ID, registration number, VAT), data received in accordance with the evaluated risk of the legalize of orders made from criminal acts and financing of terrorism, data regarding creditworthiness, trustworthiness and payment behaviour, including sociodemographic data and data regarding property situation (e.g. age, gender, civil status, education achieved, mode of living, number of persons in the household, income and expenses of the household, data regarding the method of ensuring regular income, data regarding property ownership rights, data regarding membership in business corporations and associations) and data received in connection with the provided financial products (ex. contract type, expiration date of the contract, method of collateral security of the contract, due date, amount of the provided financing, financing purpose, state of the claims and debts towards the Company), correspondence and other communication with the data subject, information of a business and marketing nature.
The Company obtains personal data (a) directly from you, (b) from publicly available sources, (c) from its own activities or (d) from third parties, for example from company Dun & Bradstreet Czech Republic, a.s. (more information about the company and its processing of personal data can be found at www.dnb.com/cs-cz//privacy) or from the registers, as described below.
Duration of the personal data processing
Personal data will be processed by the Company for the duration of the processing purpose.. In case of the termination of the contractual relationship with the Company, another legal basis for the processing of your personal data may persist (e.g. the Company´s obligation to comply with legal requirements, protection of the rights and legally protected interests of the Company, the data subject or third parties). Your data may e.g. be retained after a period specified by law for the purpose of archiving or for the purpose of fulfilling obligations established by specific legal regulations (e.g. Act No. 253/2008, Coll., on selected measures against legitimisation of proceeds of crime and financing terrorism, as amended or Act No. 257/2016 Coll., Consumer Credit Act, as amended).
In the case of personal data processing under your consent, the period of personal data processing is explicitly stated in the text of the consent. In the case of consent granted for marketing purposes, the consent is valid for one year from the date of its granting; if the contract between you and the Company is concluded, the consent is valid for the duration of the contract and for the further period of another one year from the termination of the last contractual relationship concluded between you and the Company.
Recipients of personal data
Your personal data is made available in particular to the Company´s employees in connection with the performance of their work duties, during which it is necessary to deal with personal data of clients but only to the extent that is necessary in each case and in compliance with all security measures. In addition, your personal data may be transferred to third parties who participate in client´s personal data processing or the personal data may be made available to them for another reason in accordance with legal regulations.
In particular, the Company is entitled to make your data disclosed within the fulfilment of obligations established by specific legal regulations, where the authorized persons may be public authorities, especially prosecuting authorities, courts, executors / bailiffs, supervisory authorities etc. In addition, the Company may disclose your data to entities that the Company uses in fulfilling its contractual obligations arising from the contract concluded with you, or to entities use by the Company to protect its rights and legally protected interests.
The Company may entrust a third parties (data processors) with the processing of your personal data. Particularly the recipients of your personal data are mainly insurance companies, intermediaries / business representatives of the Company, companies via which the Company collects its claims, law offices, advertising agencies, forwarding agencies, printing companies, providers of the Company's information systems and companies from the Raiffeisen Group (see below).
Based on your consent, the Company is entitled to transfer your personal data to selected cooperating companies for marketing purposes.
In the basis of legitimate interest and fulfilment of legal obligation the Company also transfers data relating your creditworthiness to CNCB – Czech Non-Banking Credit Bureau, z.s.p.o., which operates the Non-Banking Register of Client Information NRKI (details are contained in the Information Memorandum).
If the contractual relationship between you and the Company is related to your participation in the subsidy program (or you represent a client participating in the subsidy program or provide collateral to such a client) the Company for the purpose of concluding and fulfilling the contract and for its legitimate interest transfers your personal data to the entity that provides subsidy (e.g. Národní rozvojová banka, a.s., Podpůrný a garanční rolnický a lesnický fond, a.s.).
In case that it is necessary to transfer or process your personal data in the context of cooperation with third parties and unless the authorization for processing is authorised by applicable law, the Company shall conclude a personal data processing agreement with the data processors. These data processors are obliged to meet the Company´s requirements for compliance with the purpose of processing and technical and organizational security of personal data protection while the Company continuously monitors the fulfilment of their obligations. In the event of personal data processing by data processors you are guaranteed the same rights as if the processing was carried out by the Company itself. The Company does not release itself from responsibility for the processing of personal data by transferring personal data to other data processors. If you are not satisfied with the way your data is processed, you are entitled to contact the Company with your objections.
Cooperation with the Non-Banking Client Information Register and SOLUS Registers
To ensure the effective fulfilment of responsibilities, particularly resulting from the legal regulations related to consumer protection during providing of consumer loans, and for the purpose of protecting the interests of the Company in providing credit products only to trustworthy and creditworthy clients, the Company collects and processes personal data necessary to assess the creditworthiness, and for this purpose the Company is the user of the Non-Banking Client Information Register (here in after as “Non-Banking Client Information Register “NRKI” or rather “NRKI”) that is operated by the CNCB - Czech Non-Banking Credit Bureau, z.s.p.o.
In NRKI is being processed the information that non-banking crediting subjects particularly provide to each other regarding contractual (credit) relationships between these subjects and their clients and that either individually or in their summary give information about the solvency and trustworthiness, respectively, the creditworthiness of the non-banking crediting subjects’ clients.
In connection with the participation of the Creditor in NRKI, the Creditor processes, provides or obtains these personal data of the Issuer:
(a) personal identification data,
(b) data about the conclusion or non-conclusion of a contract between the Issuer and the Creditor,
(c) data indicating the Issuer´s financial obligations and the fulfilment of these obligations by the Issuer,
(d) data about security measures,
(e) data about assignment of claims in relation to the Issuer,
(f) data indicating the Issuer´s solvency, credibility (or payment discipline), creditworthiness, communicated to the Creditor or obtained by the Creditor in connection with the performance or non-performance of the relevant contractual relationship.
This data can also be provided to the users of the Client Information Bank Register (“BRKI”), which is operated by the company CBCB - Czech Banking Credit Bureau a.s., within mutual informing of the users of NRKI and BRKI regarding solvency, trustworthiness, payment behaviour, respectively the creditworthiness of clients, and the allowance (being repeated) of assessing the creditworthiness, trustworthiness and payment behaviour, respectively the creditworthiness in connection with the contractual relations between you and the users of NRKI and/or BRKI.
The legal basis for the processing of personal data of clients in NRKI is (a) fulfilling of legal obligations in cases of providing consumer loans, (b) the legitimate interests of the creditor operators, especially interest in providing credit products only to creditworthy and trustworthy clients, (c) consent to processing of personal data in the case of persons representing clients or the proprietors of clients. The legal basis for the processing of information (personal data) pertaining to the provision of mutual information between NRKI and BRKI users about solvency, credibility, creditworthiness and payment discipline of clients is (a) fulfilling of legal obligations of banks and creditor operators in cases of providing consumer loans to individuals, (b) the legitimate interests of banks and loan providers, and (c) consent to the processing of personal data in cases of persons representing clients (legal persons) or the proprietors of clients (legal persons).
All the information regarding NRKI, the participation of creditors in NRKI, the processing of NRKI's creditors’ clients’ personal data, the mutual informing of the users of NRKI and BRKI as well as the information regarding all the rights of the creditors’ clients in connection with NRKI or the mutual informing of the users of NRKI and BRKI, are stated in the Information Memorandum of the Non-Banking Client Information Register (including basic information on the mutual exchange of information with the BRKI).
Method of Personal Data Processing
The Company mainly uses personal data obtained directly from you. In some cases, e.g. when assessing credithworthiness, these personal data are not sufficient, therefore the Company also uses information from external sources. There include mainly publicly available registers – the Commercial Register, the Register of Economic Entities, the Insolvency Register, professional registers etc. The Company is also entitled to obtain personal data from cooperating with third parties (e.g. from the insurance company, entities providing subsidies, CNCB – Czech Non-Banking Credit Bureau, z.s.p.o.). However, in all circumstances the Company shall carefully protect your personal data, while the Company has internally set the rules for the handling of personal data regularly checked by the Company. All persons who process the personal data in connection with performance of their duties (whether already employees, data processors or other data controller) are bound by confidentiality and they are regularly trained in the field of personal data protection. The Company regularly checks and consistently enforces compliance with the standards of personal data protection.
For the above stated purposes, the Company process personal data manually and automatically.
Automated Individual Decision-Making, including Profiling
The Company is entitled to use profiling within the provision of services, which means 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. Your application for vehicle financing can be approved on the basis of automated decision-making in case of this is necessary for entering into the contract. After you have provided the information necessary to assess the financing application, your creditworthiness will be automatically checked based on the data you entered, data from the Company´s databases and data obtained from the registers, which will allow fair and responsible decision to be made on your application. The application will only be approved if the Company does not detect problems with the repayment of your existing debts or other negative information. If your application is not approved based on automated checks, a representative of the Company will review it (i.e. there is no automated rejection of your application for financing without human intervention). The application approval methods used are regularly reviewed to ensure they remain fair, efficient and objective.
You always have the right to express your point of view and contest the given decision on the results of automated individual decision-making incl. profiling through the Company´s contact details listed below.
Subject’s data rights
Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation, you are entitled to request information about the purpose of personal data processing, information regarding the extent of personal data being processed and its categories, including information regarding the source from which the personal data was obtained, the intended duration of the processing, the information about the existence of automated decision-making, including profiling and information regarding relevant recipients or categories of personal data recipients. Furthermore, you are also entitled to request rectification or erasure of your personal data, should it be inaccurate, or if the purpose of their processing has passed.
Should your personal data be transferred to a third country or to an international organization, you have the right to be informed of the appropriate security safeguards that apply to the transfer.
You have the right to obtain from the Company personal data concerning you and the data that you have provided to the Company on the basis of your consent or for the purpose of concluding a contract. Based on your request, the Company will provide you with this data, without any undue delay, in a structured, commonly-used and machine-readable format. This right does not apply to the personal data where the processing is not carried out by automated means.
Should you believe that the personal data processing contradicts with the protection of your private and personal life or it contradicts with legal regulations, you are entitled to object, request an explanation and the removal of the resulted situation, and you are especially entitled to request restriction of personal data processing, blocking, rectification, completion in or erasure. Should you believe that your personal data has been processed unlawfully, you may lodge a complaint with the supervisory authority which, in the Czech Republic, is the Office for Personal Data Protection (www.uoou.cz).
Company contact information
Address: Hvězdova 1716/2b, 140 00 Prague
Telephone number: +420 221 511 611
Email address: rl@rl.cz
Website: https://www.rl.cz
You can also contact the Data Protection Officer with your suggestions, claimed rights and other requests at the following address: Raiffeisenbank a.s., Hvězdova 1716/2b, PSČ 140 78, Prague 4, poverenec@rb.cz.
Raiffeisen Group
For the purposes of this document Raiffeisen Group means the Company and in particular these other companies:
- Raiffeisenbank a.s., ID No. 49240901, with registered office at Hvězdova 1716/2b, 140 78 Prague 4
- Raiffeisen Broker, s.r.o., ID No. 09968237, with registered office at Hvězdova 1716/2b, 140 00 Prague 4
- Raiffeisen stavební spořitelna a.s., ID No. 49241257, with registered office at Hvězdova 1716/2b, 140 00 Prague 4
- Raiffeisen investiční společnost a.s., ID No. 29146739, with registered office at Hvězdova 1716/2b, 140 78 Prague 4
- Raiffeisen-Leasing International Gesellschaft m.b.H., with registered office at Am Stadtpark 3, 1030 Vienna, Austria
- Raiffeisen Bank International AG, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
- Raiffeisen-Leasing GmbH, with registered office at Mooslackengasse 12, 1190 Vienna, Austria
- Raiffeisen CEE Region Holding GmbH, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
- Raiffeisen RS Beteiligungs GmbH, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
Data Subjects
Subjects whose personal data the Company processes may primarily be clients and potential clients of the Company, in particular the recipients of financing and their representatives, website visitors and users of other communication and business channels, other parties to the contractual relationships and their representatives (e.g. collateral providers), or other subjects whose personal data processing is processed on the Company´s legal basis (e.g. the beneficial owners of legal entities).
The Purpose for Personal Data Processing
The Company will process your personal data in compliance with valid and effective legal regulations to fulfil the following purposes:
1. Realization of a contractual relationship
The data processing is necessary in concluding a contract and in fulfilling the contractual relationship with the Company. To fulfil this purpose, your identification data, contact data and information related to the subject of the contract (ex. identification services, subject of financing, payment details, etc.) will be processed to the necessary extent.
A contractual relationship can also be concluded remotely by using electronic signing. In such a case your identification data, contact details and information related to the signing of the contract are included in the application for signing documents provided by a third party, in SMS, email, on the signed electronic document and in the audit trail capturing information about the signing process.
2. Protection of rights and the right of protecting the Company's interests (legitimate interest)
The data processing is necessary for the protection of the Company's interests, especially within enforcing financial claims, the resolution of any litigation agenda, development of provided services, internal statistical research, analysis or evaluation or for internal administrative purposes within terms of the Raiffeisen group (see below). For this purpose, the Company is even entitled to process data serving towards ensuring the safe use of the offered services, risk management, prevention and evaluation of possible fraud behaviour, etc. Based on an authorized interest, the Company also processes information regarding creditworthiness, or one’s ability to repay their obligation, payment behaviour and the trustworthiness of natural persons who are not the consumers and all so being with the use of registries.
For this purpose, the Company also keeps recordings of incoming and outgoing calls made via the client center.
To a limited extent based on legitimate interest, the Company is entitled to process your personal data for the purpose of direct marketing (i.e. offering other similar products and services to clients).
In cases where your personal data is processed for the purpose of protecting the legitimate interests of the Company, you shall have the right to object processing of your personal data. If you enter the objection, the Company shall no longer process the personal data unless the Company demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
3. Compliance with legal obligation
The Company must collect and evaluate some information and retain it for an specified period of time as it is the requirement put forth by the legal regulations. For example, the personal data processing for the purpose of preventing the misuse of the financial system to legalize orders made from criminal acts and to finance terrorism and the creation of conditions for detecting such actions under the Act No. 253/2008 Coll., on selected measures against legitimisation of proceeds of crime and financing terrorism, as amended, where it concerns e.g. information about the sources and origin of income, capital entanglement, nationality, residence, political exposure. The obligation to process information on the creditworthiness, payment behaviour and the trustworthiness of consumers follows from Act No. 257/2016 Coll., Consumer Credit Act, as amended, as this information is necessary for assessing the creditworthiness of the consumer. Furthermore, it may also include legal regulations in the field of accounting, taxation and control activities.
4. Processing subject to consent
In order to process your personal data beyond the above the Company needs your consent. Based on your consent, the Company and selected cooperating companies process your personal data for marketing purposes, consisting primarily in the offer of products and services of the Company and selected cooperating companies, activities related to the preparation of the offer in which automated processing and profiling may occur with the aim of adapting the offer to your needs (the above mentioned may include mainly the evaluation of data related to the creation of the offer, the processing of information from your requests and opinions and form the monitoring of your activities within the communication channels and platforms used), and in the development of product or services and enhancing the client´s experience.
This processing is qualified to your consent, which is given voluntarily and in the event that you give your consent, you are entitled to withdraw it at any time. Withdrawing of consent means that the Company will not be entitled to process your personal data for the purpose specified in the consent. The withdrawing has no consequences for your contractual relationship with the Company. The Company may continue to process your personal data if the Company disposes of another legal basis for processing of your personal data. Withdrawing your consent does not aggrieve the legitimacy of any processing as a result of your consent which had been given before it was withdrawn.
Extent and source of personal data processing
The Company processes your personal data to the necessary extent for fulfilling the above-stated purposes, and the Company especially processes your identification and contact data (e.g. first name, last name, date and place of birth, birth certificate number, permanent address, contact address, citizenship, telephone number, email address, type, number and expiration date of your ID, registration number, VAT), data received in accordance with the evaluated risk of the legalize of orders made from criminal acts and financing of terrorism, data regarding creditworthiness, trustworthiness and payment behaviour, including sociodemographic data and data regarding property situation (e.g. age, gender, civil status, education achieved, mode of living, number of persons in the household, income and expenses of the household, data regarding the method of ensuring regular income, data regarding property ownership rights, data regarding membership in business corporations and associations) and data received in connection with the provided financial products (ex. contract type, expiration date of the contract, method of collateral security of the contract, due date, amount of the provided financing, financing purpose, state of the claims and debts towards the Company), correspondence and other communication with the data subject, information of a business and marketing nature.
The Company obtains personal data (a) directly from you, (b) from publicly available sources, (c) from its own activities or (d) from third parties, for example from company Dun & Bradstreet Czech Republic, a.s. (more information about the company and its processing of personal data can be found at www.dnb.com/cs-cz//privacy) or from the registers, as described below.
Duration of the personal data processing
Personal data will be processed by the Company for the duration of the processing purpose.. In case of the termination of the contractual relationship with the Company, another legal basis for the processing of your personal data may persist (e.g. the Company´s obligation to comply with legal requirements, protection of the rights and legally protected interests of the Company, the data subject or third parties). Your data may e.g. be retained after a period specified by law for the purpose of archiving or for the purpose of fulfilling obligations established by specific legal regulations (e.g. Act No. 253/2008, Coll., on selected measures against legitimisation of proceeds of crime and financing terrorism, as amended or Act No. 257/2016 Coll., Consumer Credit Act, as amended).
In the case of personal data processing under your consent, the period of personal data processing is explicitly stated in the text of the consent. In the case of consent granted for marketing purposes, the consent is valid for one year from the date of its granting; if the contract between you and the Company is concluded, the consent is valid for the duration of the contract and for the further period of another one year from the termination of the last contractual relationship concluded between you and the Company.
Recipients of personal data
Your personal data is made available in particular to the Company´s employees in connection with the performance of their work duties, during which it is necessary to deal with personal data of clients but only to the extent that is necessary in each case and in compliance with all security measures. In addition, your personal data may be transferred to third parties who participate in client´s personal data processing or the personal data may be made available to them for another reason in accordance with legal regulations.
In particular, the Company is entitled to make your data disclosed within the fulfilment of obligations established by specific legal regulations, where the authorized persons may be public authorities, especially prosecuting authorities, courts, executors / bailiffs, supervisory authorities etc. In addition, the Company may disclose your data to entities that the Company uses in fulfilling its contractual obligations arising from the contract concluded with you, or to entities use by the Company to protect its rights and legally protected interests.
The Company may entrust a third parties (data processors) with the processing of your personal data. Particularly the recipients of your personal data are mainly insurance companies, intermediaries / business representatives of the Company, companies via which the Company collects its claims, law offices, advertising agencies, forwarding agencies, printing companies, providers of the Company's information systems and companies from the Raiffeisen Group (see below).
Based on your consent, the Company is entitled to transfer your personal data to selected cooperating companies for marketing purposes.
In the basis of legitimate interest and fulfilment of legal obligation the Company also transfers data relating your creditworthiness to CNCB – Czech Non-Banking Credit Bureau, z.s.p.o., which operates the Non-Banking Register of Client Information NRKI (details are contained in the Information Memorandum).
If the contractual relationship between you and the Company is related to your participation in the subsidy program (or you represent a client participating in the subsidy program or provide collateral to such a client) the Company for the purpose of concluding and fulfilling the contract and for its legitimate interest transfers your personal data to the entity that provides subsidy (e.g. Národní rozvojová banka, a.s., Podpůrný a garanční rolnický a lesnický fond, a.s.).
In case that it is necessary to transfer or process your personal data in the context of cooperation with third parties and unless the authorization for processing is authorised by applicable law, the Company shall conclude a personal data processing agreement with the data processors. These data processors are obliged to meet the Company´s requirements for compliance with the purpose of processing and technical and organizational security of personal data protection while the Company continuously monitors the fulfilment of their obligations. In the event of personal data processing by data processors you are guaranteed the same rights as if the processing was carried out by the Company itself. The Company does not release itself from responsibility for the processing of personal data by transferring personal data to other data processors. If you are not satisfied with the way your data is processed, you are entitled to contact the Company with your objections.
Cooperation with the Non-Banking Client Information Register and SOLUS Registers
To ensure the effective fulfilment of responsibilities, particularly resulting from the legal regulations related to consumer protection during providing of consumer loans, and for the purpose of protecting the interests of the Company in providing credit products only to trustworthy and creditworthy clients, the Company collects and processes personal data necessary to assess the creditworthiness, and for this purpose the Company is the user of the Non-Banking Client Information Register (here in after as “Non-Banking Client Information Register “NRKI” or rather “NRKI”) that is operated by the CNCB - Czech Non-Banking Credit Bureau, z.s.p.o.
In NRKI is being processed the information that non-banking crediting subjects particularly provide to each other regarding contractual (credit) relationships between these subjects and their clients and that either individually or in their summary give information about the solvency and trustworthiness, respectively, the creditworthiness of the non-banking crediting subjects’ clients.
In connection with the participation of the Creditor in NRKI, the Creditor processes, provides or obtains these personal data of the Issuer:
(a) personal identification data,
(b) data about the conclusion or non-conclusion of a contract between the Issuer and the Creditor,
(c) data indicating the Issuer´s financial obligations and the fulfilment of these obligations by the Issuer,
(d) data about security measures,
(e) data about assignment of claims in relation to the Issuer,
(f) data indicating the Issuer´s solvency, credibility (or payment discipline), creditworthiness, communicated to the Creditor or obtained by the Creditor in connection with the performance or non-performance of the relevant contractual relationship.
This data can also be provided to the users of the Client Information Bank Register (“BRKI”), which is operated by the company CBCB - Czech Banking Credit Bureau a.s., within mutual informing of the users of NRKI and BRKI regarding solvency, trustworthiness, payment behaviour, respectively the creditworthiness of clients, and the allowance (being repeated) of assessing the creditworthiness, trustworthiness and payment behaviour, respectively the creditworthiness in connection with the contractual relations between you and the users of NRKI and/or BRKI.
The legal basis for the processing of personal data of clients in NRKI is (a) fulfilling of legal obligations in cases of providing consumer loans, (b) the legitimate interests of the creditor operators, especially interest in providing credit products only to creditworthy and trustworthy clients, (c) consent to processing of personal data in the case of persons representing clients or the proprietors of clients. The legal basis for the processing of information (personal data) pertaining to the provision of mutual information between NRKI and BRKI users about solvency, credibility, creditworthiness and payment discipline of clients is (a) fulfilling of legal obligations of banks and creditor operators in cases of providing consumer loans to individuals, (b) the legitimate interests of banks and loan providers, and (c) consent to the processing of personal data in cases of persons representing clients (legal persons) or the proprietors of clients (legal persons).
All the information regarding NRKI, the participation of creditors in NRKI, the processing of NRKI's creditors’ clients’ personal data, the mutual informing of the users of NRKI and BRKI as well as the information regarding all the rights of the creditors’ clients in connection with NRKI or the mutual informing of the users of NRKI and BRKI, are stated in the Information Memorandum of the Non-Banking Client Information Register (including basic information on the mutual exchange of information with the BRKI).
Method of Personal Data Processing
The Company mainly uses personal data obtained directly from you. In some cases, e.g. when assessing credithworthiness, these personal data are not sufficient, therefore the Company also uses information from external sources. There include mainly publicly available registers – the Commercial Register, the Register of Economic Entities, the Insolvency Register, professional registers etc. The Company is also entitled to obtain personal data from cooperating with third parties (e.g. from the insurance company, entities providing subsidies, CNCB – Czech Non-Banking Credit Bureau, z.s.p.o.). However, in all circumstances the Company shall carefully protect your personal data, while the Company has internally set the rules for the handling of personal data regularly checked by the Company. All persons who process the personal data in connection with performance of their duties (whether already employees, data processors or other data controller) are bound by confidentiality and they are regularly trained in the field of personal data protection. The Company regularly checks and consistently enforces compliance with the standards of personal data protection.
For the above stated purposes, the Company process personal data manually and automatically.
Automated Individual Decision-Making, including Profiling
The Company is entitled to use profiling within the provision of services, which means 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. Your application for vehicle financing can be approved on the basis of automated decision-making in case of this is necessary for entering into the contract. After you have provided the information necessary to assess the financing application, your creditworthiness will be automatically checked based on the data you entered, data from the Company´s databases and data obtained from the registers, which will allow fair and responsible decision to be made on your application. The application will only be approved if the Company does not detect problems with the repayment of your existing debts or other negative information. If your application is not approved based on automated checks, a representative of the Company will review it (i.e. there is no automated rejection of your application for financing without human intervention). The application approval methods used are regularly reviewed to ensure they remain fair, efficient and objective.
You always have the right to express your point of view and contest the given decision on the results of automated individual decision-making incl. profiling through the Company´s contact details listed below.
Subject’s data rights
Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation, you are entitled to request information about the purpose of personal data processing, information regarding the extent of personal data being processed and its categories, including information regarding the source from which the personal data was obtained, the intended duration of the processing, the information about the existence of automated decision-making, including profiling and information regarding relevant recipients or categories of personal data recipients. Furthermore, you are also entitled to request rectification or erasure of your personal data, should it be inaccurate, or if the purpose of their processing has passed.
Should your personal data be transferred to a third country or to an international organization, you have the right to be informed of the appropriate security safeguards that apply to the transfer.
You have the right to obtain from the Company personal data concerning you and the data that you have provided to the Company on the basis of your consent or for the purpose of concluding a contract. Based on your request, the Company will provide you with this data, without any undue delay, in a structured, commonly-used and machine-readable format. This right does not apply to the personal data where the processing is not carried out by automated means.
Should you believe that the personal data processing contradicts with the protection of your private and personal life or it contradicts with legal regulations, you are entitled to object, request an explanation and the removal of the resulted situation, and you are especially entitled to request restriction of personal data processing, blocking, rectification, completion in or erasure. Should you believe that your personal data has been processed unlawfully, you may lodge a complaint with the supervisory authority which, in the Czech Republic, is the Office for Personal Data Protection (www.uoou.cz).
Company contact information
Address: Hvězdova 1716/2b, 140 00 Prague
Telephone number: +420 221 511 611
Email address: rl@rl.cz
Website: https://www.rl.cz
You can also contact the Data Protection Officer with your suggestions, claimed rights and other requests at the following address: Raiffeisenbank a.s., Hvězdova 1716/2b, PSČ 140 78, Prague 4, poverenec@rb.cz.
Raiffeisen Group
For the purposes of this document Raiffeisen Group means the Company and in particular these other companies:
- Raiffeisenbank a.s., ID No. 49240901, with registered office at Hvězdova 1716/2b, 140 78 Prague 4
- Raiffeisen Broker, s.r.o., ID No. 09968237, with registered office at Hvězdova 1716/2b, 140 00 Prague 4
- Raiffeisen stavební spořitelna a.s., ID No. 49241257, with registered office at Hvězdova 1716/2b, 140 00 Prague 4
- Raiffeisen investiční společnost a.s., ID No. 29146739, with registered office at Hvězdova 1716/2b, 140 78 Prague 4
- Raiffeisen-Leasing International Gesellschaft m.b.H., with registered office at Am Stadtpark 3, 1030 Vienna, Austria
- Raiffeisen Bank International AG, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
- Raiffeisen-Leasing GmbH, with registered office at Mooslackengasse 12, 1190 Vienna, Austria
- Raiffeisen CEE Region Holding GmbH, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
- Raiffeisen RS Beteiligungs GmbH, with registered office at Am Stadtpark 9, 1030 Vienna, Austria
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