Privacy Policy

The controller responsible for processing personal data through the SOSCredit mobile application is:

SIA SCHAEFER

Registration number: LV50103412751

Legal address: Lielā 2B, Saldus, LV-3801, Latvia

General and privacy enquiries:

[email protected]

Application support and account deletion:

[email protected]

SIA SCHAEFER operates as a credit intermediary under Credit Intermediary Licence No. KS-25.

In this Privacy Policy, “SOSCredit”, “we”, “us”, and “our” refer to SIA SCHAEFER.

This Privacy Policy applies to:

• the SOSCredit mobile application;
• accounts created through the application;
• financing requests submitted through the application;
• communication with our support team;
• technical and diagnostic information generated when the application is used;
• related services that refer or link to this Privacy Policy.

The availability of the application in a particular country does not necessarily mean that every financing product, lender, cooperation partner, or application function is available in that country.

Products, partners, eligibility criteria, application processes, and legal requirements may differ by country.

More detailed information about local processing activities, partners, legal requirements, contact details, and user rights is available in the applicable country-specific privacy policies:

• Spain: https://www.soscredit.es/es/politica-de-privacidad
• Poland: https://www.soscredit.pl/pl/polityka-prywatnosci
• Romania: https://www.soscredit.ro/ro/politica-de-confidentialitate
• Kazakhstan: https://www.soscredit.kz/ru/zashchita-dannih
• Mexico: https://www.soscredit.mx/es/aviso-de-privacidad
• Lithuania: https://www.soscredit.lt/lt/privatumo-politika
• Latvia: https://www.soscredit.lv/lv/privatums
• Colombia: https://www.soscredit.co/es/politica-de-privacidad

The country-specific policy applicable to your local service forms part of this Privacy Policy.

If there is a difference between this global application Privacy Policy and a country-specific policy, the country-specific policy applies to the extent required by local law or in relation to the relevant local service.

SOSCredit provides or facilitates credit comparison, financing search, and credit intermediary services.

Depending on the country and available cooperation partners, our services may include:

• receiving a financing request;
• assessing the general parameters of the request;
• identifying potentially relevant lenders or cooperation partners;
• forwarding the request to selected partners;
• displaying or communicating available financing offers;
• assisting with communication during the application process;
• providing technical and customer support.

SOSCredit is not a lender and does not provide loans directly.

We do not guarantee that:

• your application will be approved;
• you will receive a financing offer;
• a particular loan amount will be available;
• a particular interest rate, repayment term, fee, or other condition will be offered.

The final decision regarding approval, rejection, financing amount, interest rate, fees, repayment schedule, security requirements, and other conditions is made by the relevant lender or cooperation partner according to its own criteria and applicable law.

The information we process depends on the country, the service requested, the information you provide, the functions you use, and applicable legal requirements.

5.1 Identification information

We may process:

• name and surname;
• date of birth;
• personal identification number or another national identifier;
• nationality or citizenship;
• gender, where relevant;
• identification-document information;
• information required to verify your identity;
• information concerning politically exposed person status, sanctions, fraud prevention, or other compliance requirements.

5.2 Contact information

We may process:

• email address;
• telephone number;
• residential or correspondence address;
• preferred language;
• communication preferences.

5.3 Financial and credit-related information

We may process:

• requested financing amount;
• preferred repayment period;
• income and employment information;
• occupation or professional information;
• existing loans and other financial obligations;
• credit history or repayment information;
• bank account details, including IBAN, where required;
• bank statements or account information;
• information concerning assets or proposed security;
• marital status, dependants, or household circumstances, where relevant to the assessment;
• other information necessary to process or evaluate a financing request.

5.4 Business and representative information

Where a service is requested on behalf of a company or another legal entity, we may process:

• company name and registration number;
• registered or operating address;
• business activity and industry;
• turnover and other financial indicators;
• information about directors, representatives, shareholders, and beneficial owners;
• information confirming a person’s authority to represent the company;
• the intended purpose of the financing.

Information relating to a company is treated as personal data where it identifies or relates to an identifiable individual.

5.5 Application and service information

We may process:

• information entered in application forms;
• documents and attachments submitted through the application;
• selected financing products;
• application status;
• offers presented to you;
• lenders or cooperation partners connected with your request;
• account settings and preferences;
• communication with us or our support team;
• complaints, feedback, and other correspondence.

5.6 Technical and application usage information

When you use SOSCredit, we may automatically collect:

• account or user identifier;
• IP address;
• device type and model;
• operating system and version;
• application version;
• language and regional settings;
• app instance ID, device ID, or similar technical identifiers;
• login dates and activity records;
• application screens or functions used;
• crash reports and error logs;
• diagnostic and performance information;
• security and fraud-prevention information;
• notification preferences.

We may obtain personal data:

• directly from you when you create an account, complete a form, upload a document, submit a request, or contact us;
• automatically when you use the application;
• from lenders and cooperation partners involved in your request;
• from identity-verification providers;
• from open-banking or account-information providers, where such functionality is used;
• from payment, communication, hosting, analytics, or technical service providers;
• from public registers and publicly available sources;
• from credit-information databases or other lawful financial-information sources, where permitted;
• from an authorised representative acting on your behalf.

You should provide information about another person only where you are authorised to do so and have informed that person about the processing of their information.

7.1 Creating and administering your account

We use personal data to:

• create your SOSCredit account;
• authenticate you;
• maintain your account;
• remember your settings;
• provide access to application functions.

Where applicable, the legal basis is the performance of a contract or taking steps at your request before entering into a contract.

7.2 Processing your financing request

We use personal data to:

• receive and review your request;
• understand your financing requirements;
• determine which partners may be relevant;
• forward your request to selected partners;
• receive and display information about offers;
• communicate with you about the status of your request.

The legal basis may be the performance of a contract, taking steps at your request before entering into a contract, consent, or another basis permitted by applicable law.

7.3 Identity verification and legal compliance

We may process personal data to:

• verify your identity;
• confirm your authority to act for a company;
• prevent fraud and misuse;
• comply with anti-money-laundering, sanctions, accounting, tax, financial, consumer-protection, and regulatory requirements;
• respond to lawful requests from courts, regulators, law-enforcement authorities, or other public institutions.

The legal basis is compliance with legal obligations or, where applicable, our legitimate interest in protecting our services and users.

7.4 Customer support and communication

We use personal data to:

• respond to questions;
• provide technical assistance;
• resolve complaints;
• investigate application errors;
• communicate important service information.

7.5 Security and service improvement

We may process technical and application usage data to:

• maintain application functionality;
• identify and correct errors;
• prevent unauthorised access;
• detect suspicious or fraudulent activity;
• improve performance and usability;
• analyse how application functions are used;
• protect our systems, users, and legal interests.

Where applicable, the legal basis is our legitimate interest in operating a secure and effective service.

7.6 Marketing

Where required by law, we will obtain your consent before sending:

• promotional emails;
• SMS messages;
• push notifications;
• information about financing offers;
• information about products or services offered by us or selected partners.

You may withdraw your consent at any time by:

• using the unsubscribe option in the relevant message;
• changing your available communication settings;
• disabling push notifications in your device settings;
• contacting us at [email protected].

Withdrawal of consent does not affect processing carried out before consent was withdrawn.

7.7 Legal claims and dispute resolution

We may retain and process information where necessary to:

• manage complaints and disputes;
• establish, exercise, or defend legal claims;
• demonstrate compliance with legal or contractual obligations;
• protect our rights and legitimate interests.

SOSCredit may use automated or partly automated processes to identify lenders or cooperation partners whose general criteria may correspond to your request.

Matching may take into account information such as:

• requested financing amount;
• preferred repayment period;
• age and place of residence;
• income or turnover;
• employment or business information;
• existing financial obligations;
• product type;
• other eligibility parameters provided by cooperation partners.

The matching process may determine:

• which partners may receive your request;
• which products or offers are displayed;
• whether your application corresponds to a partner’s general criteria.

SOSCredit does not make the final decision to grant or refuse financing.

The relevant lender or cooperation partner performs its own assessment and makes the final decision according to its own policies and legal obligations.

A lender may carry out its own automated decision-making or profiling. Information about such processing should be provided in the lender’s privacy notice.

We do not sell personal data.

We may share personal data only where necessary and where an appropriate legal basis exists.

9.1 Lenders and cooperation partners

Your application information may be shared with selected lenders or financial cooperation partners for:

• eligibility assessment;
• creditworthiness or affordability assessment;
• identity and compliance checks;
• preparation of financing offers;
• processing and administration of your request.

Lenders and cooperation partners may act as independent data controllers. They process information according to their own privacy policies and legal obligations.

Where required, the relevant partner will be identified during the application process or before your information is transferred.

9.2 Service providers

We may use service providers for:

• application and website hosting;
• cloud infrastructure;
• information security;
• technical maintenance;
• identity verification;
• account-information or open-banking services;
• email, SMS, and push-notification delivery;
• customer support;
• analytics and diagnostics;
• crash reporting;
• document storage and processing;
• fraud prevention;
• legal, accounting, audit, and compliance services.

Service providers acting on our behalf may process personal data only according to our instructions, contractual requirements, and applicable law.

9.3 Public authorities and professional advisers

We may disclose information to:

• courts;
• law-enforcement authorities;
• supervisory or regulatory authorities;
• tax or financial authorities;
• other competent public institutions;
• lawyers, auditors, accountants, and other professional advisers.

Such disclosure will take place where required by law or where necessary to protect lawful rights and interests.

9.4 Business transactions

If SIA SCHAEFER is involved in a merger, acquisition, restructuring, sale of assets, or similar transaction, personal data may be disclosed to relevant advisers and transaction participants, subject to appropriate confidentiality and data-protection safeguards.

Where available, you may choose to provide bank account information through an authorised open-banking or account-information service provider.

Depending on the selected service, information may include:

• account-holder details;
• bank account number;
• account balance;
• transaction history;
• income and expenditure information.

The open-banking provider may act as an independent data controller and will provide its own privacy information.

Relevant account information may be shared with the lender or cooperation partner assessing your financing request.

Certain application features may request access to device functions, including:

• notifications;
• camera access for capturing documents;
• photo, media, or file access for uploading documents;
• biometric authentication, where supported and enabled.

Permission will be requested when a relevant feature requires it.

You may manage or withdraw permissions through your device settings. Disabling a permission may prevent certain application functions from operating correctly.

Where biometric authentication is used, the application normally receives confirmation that authentication was successful and does not receive or store your fingerprint or facial template.

Websites connected with SOSCredit may use cookies and similar technologies for:

• essential website functions;
• saving user preferences;
• analytics;
• security;
• marketing, where consent is required.

The mobile application may use local storage, software development kits, application identifiers, and similar technologies to provide functions, analyse performance, detect errors, and protect the service.

Additional information about website cookies is available in the relevant local website’s cookie policy.

Personal data may be processed in countries other than the country where you reside or use the application.

For transfers within the European Union or European Economic Area, personal data is processed according to applicable EU data-protection requirements.

Where personal data is transferred outside the European Union or European Economic Area, we use safeguards required by applicable law, which may include:

• an adequacy decision;
• standard contractual clauses;
• contractual, technical, and organisational safeguards;
• another legally recognised transfer mechanism.

You may contact us for further information about safeguards applicable to a particular transfer.

We retain personal data only for as long as necessary for the purposes for which it was collected.

The relevant period depends on:

• the category of information;
• the status of your account or financing request;
• legal and regulatory requirements;
• accounting and tax obligations;
• fraud-prevention and security requirements;
• applicable limitation periods;
• complaints or legal disputes;
• contractual obligations.

In general:

• account information is retained while the account remains active and for an appropriate period after closure where necessary;
• application information is retained for the time required to process and document the request;
• financial and compliance information may be retained for periods required by applicable law;
• correspondence may be retained for customer support, complaints, evidence, or legal claims;
• technical and security logs are retained for the time necessary for troubleshooting, security, and fraud prevention;
• marketing information is processed until consent is withdrawn or the information is no longer necessary.

When information is no longer required, it will be securely deleted, anonymised, or otherwise made unavailable for further use.

Some information may remain temporarily in protected backup systems until the relevant backup cycle has been completed.

You may request permanent deletion of your SOSCredit account directly in the application.

How to delete your account in the application

1. Sign in to your account.
2. Open Menu.
3. Select My Account.
4. Tap Delete Account.

Requesting deletion by email

If you cannot access the application, you may request account deletion by emailing:

[email protected]

Please send the request from the email address connected with your SOSCredit account.

We may request additional information where necessary to verify your identity and prevent unauthorised deletion.

What happens after a deletion request

After your request has been verified:

• your SOSCredit account will be closed;
• information that is no longer required will be deleted or anonymised;
• you may lose access to your account history and application information;
• information that must be retained under applicable law may continue to be stored for the legally required period;
• information necessary for fraud prevention, dispute resolution, regulatory compliance, or legal claims may be retained where permitted.

Deleting the SOSCredit application from your device does not automatically delete your account or personal data.

Deleting your SOSCredit account does not cancel or amend a separate financing agreement entered into with a lender or cooperation partner.

Information previously transferred to an independent lender or cooperation partner remains subject to that party’s privacy policy. A deletion request submitted to SOSCredit does not automatically delete information independently held by another controller.

Deletion requests will be processed without undue delay and within the periods required by applicable law.

Depending on your country and applicable law, you may have the right to:

• receive information about the processing of your personal data;
• access your personal data;
• request correction of inaccurate or incomplete information;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• object to direct marketing;
• withdraw consent at any time;
• receive eligible information in a structured, commonly used, machine-readable format;
• request transmission of eligible information to another controller;
• receive information about automated processing or profiling;
• lodge a complaint with a competent data-protection authority.

These rights may be subject to limitations under applicable law. For example, we may be required to retain certain information despite a deletion request.

To exercise your rights, contact:

[email protected]

Please describe your request clearly. We may request information necessary to verify your identity before responding.

You may also submit a complaint to the competent data-protection authority in your country of residence.

We apply appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental loss;
• unlawful disclosure;
• alteration;
• destruction;
• misuse.

These measures may include:

• encryption during data transmission;
• access controls and role-based permissions;
• authentication mechanisms;
• system logging and monitoring;
• security updates and maintenance;
• backup and recovery procedures;
• confidentiality obligations;
• contractual security requirements for service providers;
• internal data-protection and information-security procedures.

No electronic transmission or storage system can be guaranteed to be completely secure. We review and update our safeguards according to the nature of the information and relevant risks.

SOSCredit is intended only for persons aged 18 or older.

We do not knowingly offer the service to minors or knowingly collect personal data from persons under the age of 18.

If we become aware that personal data relating to a person under 18 has been collected without a valid legal basis, we will take appropriate steps to delete it unless retention is required by law.

SOSCredit may contain links to:

• lender websites;
• cooperation-partner platforms;
• identity-verification services;
• open-banking providers;
• payment providers;
• application stores;
• other third-party services.

Third parties may process personal data independently according to their own terms and privacy policies.

We are not responsible for the content, security, or independent data-processing practices of third-party services.

Certain personal data may be necessary to:

• create or maintain an account;
• verify your identity;
• process a financing request;
• forward a request to a lender or cooperation partner;
• present available offers;
• provide customer support;
• comply with legal obligations.

If required information is not provided, we may be unable to provide some or all of the requested services.

We may update this Privacy Policy to reflect:

• changes to the SOSCredit application;
• new functions or services;
• changes in data-processing activities;
• changes in cooperation partners;
• security developments;
• legal or regulatory requirements.

The latest version will be published on our website and, where appropriate, made available through the application.

Material changes may also be communicated through the application, by email, or through another appropriate channel.

The date displayed at the beginning of this Privacy Policy indicates when it was most recently updated.

For questions about this Privacy Policy, personal-data processing, or the exercise of your data-protection rights, contact:

SIA SCHAEFER

Lielā 2B

Saldus, LV-3801

Latvia

General and privacy enquiries:

[email protected]

SOSCredit application support and account deletion:

[email protected]