Privacy of Personal Data
For existing, previous, and future individual clients, and others from whom personal data is collected (hereinafter referred to as “You”), we would like to present our commitment to protecting your personal data and respecting your privacy in full compliance with Law No. 06/l-082 of the Republic of Kosovo on the Protection of Personal Data.
Cash Plus Sh.A., hereinafter referred to as “Cash Plus,” through this Privacy Notice, offers you detailed information regarding the processing and protection of your personal data. The purpose of this Privacy Notice is to inform you about what personal data Cash Plus collects about you, the reasons for using/collecting that personal data, how we share that personal data, how long we retain that data, what your rights are, and how you can exercise those rights regarding your personal data.
For the implementation of your rights and obtaining information regarding personal data, you can obtain this information at any time and whenever necessary for you, when you apply for credit, another application, or use a specific product or service:
1. Your Personal Data that Cash Plus Collects and Uses
1.1 In the course of our activities and to achieve a high standard of products and services, Cash Plus may collect and use various types of your personal data to the extent necessary, including:
a) Identification information such as: name and surname, personal identification number, country and date of birth, gender, photograph;
b) Contact information such as: postal address and email address, phone number;
c) Family status such as: marital status, number of children;
d) Information about education and employment such as: profession/school attended, employment, employer’s name;
e) Banking and financial data such as: bank account details, account statement, and credit history.
f) Customer relations;
g) Information related to your digital activities, including electronic signatures.
h) Data related to your expressions and preferences.
i) Data related to your use of our products and services.
j) Data from your interactions with Cash Plus: in our branches, our websites, our mobile app applications, our social media pages, meetings, calls, chats, emails, interviews, phone conversations.
k) Data related to your leisure activities and interests.
l) By joinig our community on Viber/WhatsApp or other social media platform, you consent to the collection, use, and sharing of your personal information as described in this privacy policy, under article 1.
1.2 Your personal data collected and used by Cash Plus may be obtained directly from you or from the following sources to verify or enrich our databases:
- Publications/databases made available by official authorities (e.g., the official gazette, the Credit Registry of Kosovo, the Tax Administration of Kosovo).
- Clients or service providers.
- Websites/social media pages containing publicly made information by you (e.g., your website or social media).
- Publicly available databases from third parties;
Cash Plus may retain and store pictures of customers during the onboarding process in our mobile app for identity verification and account setup purposes.
2. Specific Cases of Personal Data Collection, Including Indirect Collection
In certain circumstances, Cash Plus may collect and use personal data of individuals with whom we have, may have, or have had direct relationships, or potential clients. For some reasons, Cash Plus may also collect information about you while you have no direct relationship with Cash Plus. This may happen when your employer provides information about you, or your contact details are provided by one of our clients, in the case of: a) family members; b) Legal representatives (with authorization); c) Shareholders of the company; d) Representatives of a legal entity (which may be a client or seller); e) Employees of service providers and business partners; f) Personal contacts.
3. Purpose and Legal Basis of Collecting and Processing Your Personal Data
3.1 Cash Plus collects and uses your personal data in accordance with various legal and regulatory obligations, but not limited to:
3.1.1 Compliance with laws and regulations applicable to Non-Bank Financial Institutions, including:
- a) Establishing security measures to prevent abuse, fraud, or other prohibited activities;
- b) Detecting transactions deviating from normal patterns;
- c) Recording, when necessary, phone calls, chats, emails during communication with you, etc.;
- d) Preventing money laundering and terrorist financing;
- e) Responding to an official request from a public authority, court, or other competent body;
- f) Defining the credit risk assessment and your debt repayment capacity;
- g) Identifying you for security purposes;
- h) Enforcing laws and sub-laws in force.
3.1.2 Execution of a contract with you or taking steps at your request before entering into a contract, these personal data are used to:
- a) Provide information about our products and services;
- b) Assist and respond to your requests/complaints and to establish communication with you;
- c) Assess whether we can offer you a product or service and under what conditions;
- d) Provide products or services to our clients (in the context of managing ready cash);
- e) Manage and execute any payment (including loan repayment) related to the services and products requested by you.
3.1.3 Fulfillment of our legitimate interest, Cash Plus uses your personal data to distribute and develop our products or services, improve risk management, and protect our legal rights, including:
- a) Transaction evidence;
- b) Fraud prevention;
- c) Training our staff;
- d) IT management, including infrastructure management (e.g., shared platforms);
- e) Business continuity and IT security;
- f) Creating statistics, tests, and models collected for research and development purposes, aiming to improve risk management or improve existing products and services or create new ones.
3.1.4 Personalization of our offer through:
- a) Improving the quality of our financial products or services;
- b) Advertising products or services that match your status and profile, including:
- a) Segmenting our current and potential clients;
- b) Administering a competition, promotional lottery, gift, competition, or other similar marketing and event management campaign;
- c) Communication about our products, services, offers, news; Customer service, including responding to your questions;
- d) Improving and personalizing your experience on our websites and applications;
- e) Maintaining the credit account, including managing any loyalty or customer reward program;
- f) Processing and awarding the prize won through your participation in our promotional games;
- g) Your data may be collected in anonymous statistics that may be provided to professional clients to assist them in developing their business. In this case, your personal data will never be disclosed, and those who accept these anonymous statistics will not be able to identify you.
3.1.5 Respecting your choice if we have requested your consent for specific processing of your personal data, in certain cases, such as:
- a) When the above purposes lead to automated decision-making, which produces legal effects or significantly affects you. At that time, Cash Plus will inform you separately about the logic involved, as well as the importance and anticipated consequences of such processing;
- b) If Cash Plus needs to carry out further processing for purposes other than those mentioned above, Cash Plus will inform you and, where necessary, obtain your consent;
c) For interaction on social networks for the organization of contests.
4. How Cash Plus Shares Your Personal Data?
4.1 To fulfill the above purposes, Cash Plus may disclose your personal data to:
- a) Service providers performing services on our behalf;
- b) Financial or judicial authorities, state agencies, or public bodies, upon request and to the extent permitted by law;
c) Regulatory professionals such as lawyers, notaries, external auditors, liquidators, our debt collection companies.
5. How Can You Be Informed About Changes to this Privacy Notice
Based on ongoing legal and business changes, Cash Plus may need to regularly update this Data Protection Notice. Cash Plus invites you to review the latest version of this notice online, and Cash Plus will inform you of any material changes through our website or other usual communication channels.
6. How Long Does Cash Plus Retain Your Personal Data?
Cash Plus will keep your personal data for a longer period as required to comply with current laws and regulations or any other period related to our operational requirements, ease of customer relationship management, and response to legal or regulatory requests.
7. What Are Your Legal Rights, and How Can You Exercise Them?
7.1 Based on applicable laws and regulations, you have the right to be informed and:
- Access your personal data: to obtain information about the processing of your personal data and a copy of this processed personal data;
- Correct your personal data: when you believe your personal data is inaccurate or incomplete, you can request that such personal data be corrected by providing us with accurate data;
- Delete your personal data: request the deletion of your personal data, to the extent permitted by law and regulations in force.
- Restrict the processing of your personal data: by requesting the restriction of the processing of your personal data.
- Object to the processing of your personal data: by objecting to the processing of your personal data for reasons related to your particular situation. You have an absolute right to object to the processing of your personal data for direct marketing purposes, including profiling related to such direct marketing.
- Withdraw your consent given for the processing of personal data: at any time after giving this consent for the collection and processing of your personal data.
- Port your personal data: when applicable by law, you have the right to have your personal data returned to you or, when technically possible, transferred to a third party.
7.2 In accordance with applicable laws and regulations, in addition to your rights above, you also have the right to submit a complaint to the State Agency for the Protection of Personal Data/Information and Privacy Agency.
8. How Can You Contact Us?
If you have any questions or comments about this Notice, send your email to us at data.protection@cashplus-ks.com
9. Withdrawal of Consent
Please provide reasons for withdrawing consent for the processing of personal data by sending an email at data.protection@cashplus-ks.com.