SCOPE
Lowell Receivables Financing 5 DAC ("we" or "us") has prepared this Privacy Policy ("Policy") to describe how your personal data may be processed for the purposes of fulfilling our reporting obligations to the Finnish Positive Credit Register ("PCR"). In respect of such processing, Lowell Receivables Financing 5 DAC will act as a controller of your personal data and Lowell Suomi Oy ("Lowell") will process your personal data as a processor. Such processing is governed by the requirements of the General Data Protection Regulation (No. 2016/679) ("GDPR") and supplementing national data protection legislation.
PURPOSES OF PROCESSING
To comply with legal obligations: Your personal data will be processed by Lowell on our behalf to report information on certain credit arrangements to the PCR as required by Finnish law.
CATEGORIES OF PERSONAL DATA
The following categories of personal data are processed by Lowell on our behalf for the purpose of PCR reporting:
- Identification information: This includes your name and personal identity code.
- Information on your credit arrangements: This includes information about your loan, payments on your loan, the interest, collateral, amortisation, later payments, information about your possible debt restructuring or corporate restructuring.
LEGAL BASIS
The legal basis for processing your personal data for the purpose of PCR reporting is the legal obligation of Lowell Receivables Financing 5 DAC (Article 6(1)(c) of the GDPR) under the Finnish Act on the Positive Credit Register 739/2022.
We set out the corresponding purpose, type of data and lawful basis for processing your personal data in the table below:
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| Your personal data will be processed by Lowell on our behalf to report information on certain credit arrangements to the PCR as required by Finnish law. |
|
The legal basis for processing your personal data for the purpose of PCR reporting is the legal obligation of Lowell Receivables Financing 5 DAC (Article 6(1)(c) of the GDPR) under the Finnish Act on the Positive Credit Register 739/2022. |
SOURCE OF PERSONAL DATA
We obtain your personal data from the following sources:
- Lowell as seller of your debt;
- From you as debtor when you make payments to Lowell which are then reported to the PCR;
- Lowell as processor of your personal data on our behalf for PCR;
- Legal Register Centre or the courts in relation to data on debt and corporate restructuring; and
- Regulatory authorities in relation to payments reported to the PCR.
DISCLOSURE OF PERSONAL DATA
Personal data are disclosed to the following third parties:
- Lowell, which processes personal data on our behalf;
- Incomes Register Unit of the Finnish Tax Administration as controller of the PCR;
- CSC Capital Markets (Ireland) Limited; and
- Relevant regulatory authorities to enable us to comply with our legal obligations.
Your personal data is stored and processed only within the European Union (EU) and European Economic Area (EEA). We do not transfer your personal data to any third country outside the EU/EEA. In the event this changes, we will update this Policy and ensure that all appropriate safeguards are in place.
DATA RETENTION
Personal data will be retained only as long as necessary for fulfilment of the purposes for which it was collected or as otherwise required by legislation. In general, and unless otherwise required by law or supervisory authority guidance, your personal data will be retained until the end of the relevant loan relationship (i.e. when the parties to the loan no longer have any obligations to each other) plus 13 months.
SECURITY
Appropriate security measures have been put in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
YOUR RIGHTS
In relation to personal data processed by Lowell on our behalf for PCR reporting, you have the right to request and receive:
- access to your personal data, including to receive a copy of it;
- information on how your personal data is processed; and
- to have inaccurate data rectified.
In certain situations, you may request deletion of your personal data, object against and/or request restriction of certain processing. You may also have the right to receive your personal data in a structured, commonly used and machine-readable format and transmit it to another controller (data portability). You also have a right to lodge a complaint about the processing of your personal data to the Data Protection Commission (Ireland), the Office of the Data Protection Ombudsman (Finland), or your local data protection authority.
CONTACT US
Personal information requests, issues or complaints about our compliance with this Policy regarding the handling of personal data, and questions or comments about this Policy may be addressed, on behalf of us, to:
Lowell Suomi Oy
Postal address: PL 20, 20101 Turku
Web service: https://oma.lowell.fi/