Effective from 17 December 2024
Our website address is: https://www.laina.fi/.
Laina.fi markets the services of Sortter Oy and the site is maintained by Sortter Oy.
This privacy policy explains the processing of personal data by the data controller Sortter Oy.
Sortter values your privacy. The following statements relate to data collection, data security and data protection, and they apply to all users, including applicants and other registered persons using this site (hereinafter “you”). Our privacy policies may vary in different countries in which we operate, due to local practices and statutory requirements. Please read this privacy policy carefully. If you have questions, contact the Data Protection Officer at dpo@sortter.com.
Sortter is a broker that mediates products and services of other financial service providers (banks, credit institutions, insurance companies) to private persons and corporate customers. In its capacity as broker, we routinely collect and store personal data of those customers who use our services when seeking the best possible financial product or service.
Definitions
Agreement – The agreement between Sortter and the user, by which the terms of use of our platform and this privacy policy are accepted.
Data Protection Regulations – Applicable laws and regulations, such as the EU General Data Protection Regulation, which govern the processing of personal data.
Sortter – Sortter Oy, Business ID 2954352-7, registered address Bulevardi 21, 00180 Helsinki, telephone number: 09 8566 5550, email address: asiakaspalvelu@sortter.fi.
General Data Protection Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.4.2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
Personal Data – All information relating to an identified or identifiable natural person (Data Subject).
Processing – An operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means or manually, such as collection, storage, alteration, granting of access rights, queries, transfer, viewing, etc.
User – A natural person, who is an applicant acting on their own behalf and on behalf of their co-applicant, or on behalf of a corporate customer, and who uses, has used, or has expressed the intention to use the services offered by Sortter.
Data Controller
Sortter (Sortter Oy, Business ID 2954352-7, Bulevardi 21, 00180 Helsinki, 09 8566 5550, asiakaspalvelu@sortter.fi) is responsible for the processing of your personal data, and with regard to your application must be regarded as the controller within the meaning of the General Data Protection Regulation.
The processing of your personal data is governed by Finnish law.
Collection of Personal Data
We collect your personal data in the following ways:
- If you are a user intending to use our services, you give us your personal data directly when you fill in an application form when seeking a suitable financial service or product.
- If you are the co-applicant of a user, you should authorise the user to provide us with your personal data.
- We also collect personal data automatically when you use our site. Such collection is described in more detail in our Cookie Policy, which can be found here.
- We also collect your personal data from credit information services (Asiakastieto and/or Bisnode) and from address registers (Population Register Centre), in order to provide targeted offers from financial service providers. With the help of these databases we verify your identity and carry out credit and risk assessments. The necessary personal data depends on the services you request.
The collected personal data is needed for the purposes described below.
Purpose of Processing
We process your personal data in order to:
- Provide you with a financial sector comparison service on our platform (“Service”), which represents various financial institutions. This includes checking the data you provide in the application form as well as carrying out credit and risk checks and assessments in order to provide the best possible offer for the desired service.
- Monitor that the user complies with our platform’s terms of use in the use of the Service.
- Obtain anonymous statistical data and analyses of market trends.
- Send you commercial messages (direct marketing) about our service and products, as well as financial services that may interest you, using various channels such as email and other similar electronic means.
For the above purposes we process the following personal and business data:
- Identification data (e.g. name, date of birth, personal identity code, nationality, basic company data, politically exposed person).
- Contact details (e.g. telephone number, email address).
- Employment details (e.g. current and previous employer and position, academic degree).
- Financial data (e.g. salary, income, assets, debts, real estate, housing type, bank account (IBAN), marital status, household type).
- Communication data (e.g. email messages, call recordings).
- Login details for Sortter’s website.
- Data related to Sortter’s services (e.g. processing or expiration of application, submitted applications, requests and complaints).
- Co-applicant’s data (e.g. name, date of birth, personal identity code, nationality).
Legal Basis for Processing
he legal basis for processing, i.e. checking the data you provide in the application and carrying out credit and risk checks and assessments, is the contractual relationship with you as well as Sortter’s legitimate interest to ensure that you are reliable and creditworthy. Thanks to the processing of data, we can provide you with our Service.
Your explicit consent, which you give voluntarily, is required for us to process the personal data required by the Service and to use your activity data on our platform, as well as to carry out anonymous analyses and statistical research. Your consent is required for us to send you offers and marketing material about our services and products. When the processing of data is based on consent, you may withdraw your consent at any time by contacting us using the contact details mentioned below. Please note that withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.
Our legitimate interest related to our Service is to process your personal data in a way that enables fraud prevention and direct marketing.
We may direct direct marketing to you based on our legitimate interest to offer you products and services, if you are our customer or have recently used our services. When we process your personal data in accordance with our legitimate interests, we take into account the situation and weigh the possible impact of the processing on you as well as the rights given to you by the Data Protection Act and other relevant laws. Remember that you can at any time refuse direct marketing by clicking the unsubscribe link at the end of each email or by contacting our customer service (contact details below).
We also have statutory obligations, for example with regard to the prevention of money laundering and financing of terrorism.
To whom can personal data be disclosed?
Financial institutions (banks, credit institutions, insurance companies) that provide you with the financial service or product you requested.
In accordance with Article 6(1)(b) of the General Data Protection Regulation, you are informed that in order to provide the service it is necessary that Sortter delivers your personal data (in practice, transmits the application form you submitted) to a financial institution, bank or equivalent partner, which uses your personal data solely for the contractual processing of the requested financial product, including your identification and verification of your data, as well as processing your personal data for assessing your creditworthiness (“scoring”) before concluding an agreement concerning a loan or other financial product.
Service providers, which act as processors of personal data and process your data on behalf of Sortter in accordance with the requirements of the General Data Protection Regulation.
Sortter uses the following categories of processors: legal and other advisers, data storage service providers, customer service, marketing and survey providers, email and SMS gateway providers, invoicing service providers, call service providers.
We also have an obligation to notify the relevant authority of any events or measures for which there are indications or certainty that they are connected with money laundering.
Third parties
We disclose your personal data to third parties only if this agreement so provides, applicable law so requires (for example, when Sortter must disclose personal data to authorities), or you give your consent for it.
We disclose your personal data to our auditors and to a possible statutory supervisory authority. In such a case, the legal basis for disclosure is Sortter’s statutory obligation.
Transfer of personal data
Sortter and its processors of personal data mainly process personal data in Finland and in the EEA area. If the controller transfers or discloses personal data outside the EEA, it ensures the protection of personal data with appropriate safeguards such as standard contractual clauses approved by the EU Commission and other additional protective measures.
Automated decision-making and profiling
Sortter uses profiling to determine whether the selected financial service provider can accept or reject the customer’s application either in whole or in part.
The decision is based on the data you provide in the application form and on data obtained from external sources, such as public and private registers and other third parties. No special categories of personal data (e.g. health data or genetic data) are processed, unless such data is required for a specific product, such as insurance.
Profiling and automated decision-making are necessary for the fulfilment of our service agreement.
Automated decision-making helps us to verify your identity and select potential providers of banking, financing or insurance services, whose products or services correspond to the needs described in your application. Automated decision-making also helps us reduce the possibility of human errors, discrimination and misuse of power, as well as to speed up decision-making, considering the number of applications received by Sortter.
Automated decision-making may prevent you from receiving a loan or other product. If, however, you want to appeal the decision, you can contact us using the contact details below.
When you use Sortter’s services, Sortter receives information about your solvency, which it uses for profiling and on the basis of which it offers you services proactively (using direct marketing, if you allow it). In this case the legal basis for processing is Sortter’s legitimate interest to market its Service. As a result of profiling, some users may not receive such offers. However, profiling does not produce any legal effects for you or otherwise significantly affect you.
Data Retention
The personal data you provide remains in the possession of Sortter as long as you are a registered user of our platform. If you exercise your right of withdrawal, we block the use of your personal data during the statutory limitation period. When the statutory limitation period has expired, we destroy the user’s personal data.
Sortter retains your personal data in accordance with general industry guidelines for as long as they are needed for the purposes for which they were collected, or as long as they are needed to safeguard Sortter’s rights, or as long as applicable legislation so requires. Note that if the same personal data is processed for different purposes, the longest applicable retention period applies. The longest retention period means the limitation period for claims related to business transactions, which is at most 5 years from the closing of your user account.
Your Rights
With regard to applicable Data Protection Regulations, you have all rights of the Data Subject concerning your personal data. These include the right to:
- request access to your personal data,
- obtain a copy of your personal data,
- rectify inaccurate or incomplete personal data concerning you,
- erase your personal data,
- restrict the processing of your personal data,
- have your personal data transferred,
- object to the processing of your personal data on the basis of legitimate interest, when the purpose of the processing is direct marketing.
If you believe that your rights have been violated, you have the right to lodge a complaint with:
- our customer service (asiakaspalvelu@sortter.fi), or
- our Data Protection Officer, or
- the website of the Office of the Data Protection Ombudsman: http://www.tietosuoja.fi/en/, or
- a court, if you believe that your rights have been violated.
You can exercise your rights by contacting Sortter using the contact details given below.
Amendment of the Privacy Policy
If Sortter’s practices of processing personal data change or these principles must be changed due to applicable legislation or instructions issued by competent authorities, we have the right to change these principles unilaterally at any time. The most recent privacy policy is always available on our website, and we recommend that you read it at least once a month.
Contacts
If you have questions about how Sortter processes your personal data, or if you want to exercise your rights as a data subject, contact us.
Sortter has appointed a Data Protection Officer, whom you may also contact in the same matters, at dpo@sortter.com.