Data protection policy - Benefit Agreement
The Benefit Agreement is a subscription service that aims to continuously help you with your personal finances by providing a higher level of personal service, information and personalized marketing that has been tailored just for you. ITo be able to offer you this, we use a type of analysis (profiling) which means that we create tools to try to predict your future need for Zmarta Group's services. This is done on the basis of historical data (your previous engagements with Zmarta), the engagement of other Zmarta customers, statistically aggregated data and other external third-party data concerning you.
About the Benefit Agreement
If you want to read more about the Benefit Agreement and the services and benefits it contains, you can read here: link. The Benefit Agreement is a subscription service that aims to continuously help you with your household finances by providing you with a higher level of personal service, information and personalized marketing that has been adapted just for you. The solutions and products that you may be informed about and offered within the scope of the Benefit Agreement are services offered by companies within Zmarta. At present, this applies to, for example, private, car, home and business loans, insurance, credit cards, savings and electricity. The service means that Zmarta, based on information about which services you have previously used within Zmarta (e.g. previously applied for loans and insurances) as well as information that you enter yourself in your application and/or on your personal page on My pages/My account (e.g. marital status, family situation, form of residence, vehicle ownership and personal interests), and other external information that have been collected by Zmarta in accordance with this policy, gathers and presents information and services that we think are relevant and of interest for you.
What personal data is collected and what is it used for?
The Benefit agreement can currently only be entered into in connection with you using one of Zmarta's mediation services, for example mediation of loans and/or insurance or changing electricity contracts. In order to provide the Benefit Agreement, we need to collect, process and save your personal data. The processing of your personal data also includes so-called profiling.
This data protection policy aims to describe how we process your personal data. You provide certain information to us yourself in connection with your application for one of our services and/or the Benefit Agreement. This data can be personal and contact information, e.g. name, address, e-mail address, telephone number and social security number or application information, e.g. information about your income, employment information and requested credit amount. We collect certain information about you in connection with and/or after you submit your application to us. Such data can be updating your personal data or supplementing data via external registers such as UC and Bisnode. The update is made in order to maintain good customer and register care. We also store information about how you use our services, for example which application channel you used, when the application was made, at what times we have been in contact with you and what the contact was about. ITo be able to provide the Benefit Agreement, Zmarta uses statistical information in the form of aggregated data (i.e. data in aggregated form that does not enable the identification of an individual person) to a large extent, both with regard to other users of our services and other aggregated data. Furthermore, Zmarta uses other relevant information about you that has been collected from third parties. Zmarta compares the information with the data you enter yourself in your application and/or on My pages/My account to provide you with the most personalized service possible. In this way, we try to predict what you are interested in receiving information about. The service means that Zmarta, through so-called profiling, compare your conditions with your previous engagements with us as well as with information about what others in a similar situation as you (e.g. similar life phase, finances, form of living and residential area, etc.) have been interested in. In this way, the service aims to only offer you relevant offers and you avoid receiving information about services that do not interest you. Read more in the section "How is the service personalized to me?".
This information describes the processing of personal data that is specific to the Benefit Agreement. The information in this part must be read together with the general part for a complete picture of Zmarta's processing of personal data for the Benefit Agreement. The personal data controllers for the financial service are the companies within Zmarta (Zmarta AB, Zmarta Försäkring AB and Elskling AB) jointly.
More detailed information about which categories of personal data we collect specifically for the Benefit Agreement and which processing we carry out, for which purpose and based on which legal basis:
(e.g. name, social security number, address, telephone number and e-mail address)
Purpose of the processing: We need the information to be able to fulfill our obligations according to the Benefit Agreement, i.e. to be able to deliver the service to you. We also need the information to communicate with you, to develop and ensure the functionality of our services, for information security, for customer service and to prevent abuse of our services and to fulfill legal obligations. Your personal data will also be de-identified to be used on an aggregated level, i.e. without any connection to you as an individual, within the framework of the service in relation to other customers. For more detailed information on the basis on which the respective treatment is based, see the heading "More detailed information on how your personal data is used".
Legal basis: Fulfillment of our agreement with you and fulfillment of legal obligation and/or legitimate interest. For more detailed information on the basis on which the respective treatment is based, see the heading "More detailed information on how your personal data is used".
Automated decision-making and profiling: No automated decision-making is done. The information is analyzed to be able to offer you a personalized service. Read more in the section "How is the service personalized to me?".
Sharing of information: Information is shared with Bisnode AB, or similar partners, for updating name and address information. If you log in to My pages/My account with BankID, your personal data is shared with BankID to ensure your identity. To be able to monitor any debt balance and provide you with relevant service within the scope of the service, information is shared with Creditsafe i Sverige AB, or similar partners. Information about your street address or residential area may also be shared with our suppliers for, for example, services of retrieving statistical information and analyzing the information. Read more in the section "How is the service personalized to me?". If you choose to take part in a campaign or an offer as part of the Benefit Agreement, for example free insurance, name and address information is shared with the partners who provide these services. ITo offer you services for your entire household finances, as well as for marketing purposes, the information may be shared with other companies within Zmarta.
2. IP address, certain cookies and technical data
(e.g. how you navigate the service, which pages you visited, hardware type, operating system and browser version)
Purpose: We use the IP address for identification and to recognize your settings in order to offer a better user experience. We also collect the IP address for administrative reasons, e.g. to be able to see which channel you used to get to our website. In addition, we save the IP address to prevent fraud. We collect technical data about the device you as a customer use to reduce the risk of misuse of our services and your data, as well as to make technical improvements and troubleshoot. More information about our use of cookies can be found in our cookie policy .
Legal basis: We use a balancing of interests for all purposes regarding IP addresses and your consent in relation to cookies in ways specified in our cookie policy.
Automated decision-making and profiling: No automated decision-making. Information about how you act on our web pages and when you use our services is used as part of the Benefit Agreement to provide you with personalized information and offers. For example, we can see which category of services on our pages you show interest in and which information you receive.
Sharing of information: for administrative reasons, the IP address may be shared with our marketing partners, for example to see how and where you made your application, in connection with legal action, suspicion of crime (e.g. fraud or money laundering) or potential threats to Zmarta or rights of others, and the IP address can be disclosed to connected loan and insurance providers as well as to the police and other authorities. In the service, you may sometimes be offered to share information from the service on social media, such as Facebook or Twitter, via an implemented social plug-in (such as a like button). We do not have full influence over the information social media collects using these plug-ins if you choose to use them. We therefore urge you to keep yourself informed about the purpose of, and the scope of, the collection of data that is made via social plug-ins.
Purpose of the processing: Information about payment notices and any debt balance with the Enforcement Agency (Sw. Kronofogden) is processed to be able to provide you with relevant service within the scope of the service.
Legal basis for the processing: o be able to fulfill our contractual obligations to you.
Automated decision-making and profiling: No.
Sharing of information: To be able to offer the service regarding monitoring of debt balance information at the Swedish Enforcement Agency, social security numbers are shared with Creditsafe.
(e.g. information on income, marital status, interests, form of residence, vehicle ownership, employer, requested loan amount/insurance, purpose of loan or basis for insurance, etc.)
Purpose of processing: The information is used by us to be able to provide the service according to the Benefit Agreement, e.g. to be able to provide you with relevant and personalized offers, as well as to establish statistics and carry out analyzes on an aggregated level using de-identified data, without any connection to you as an individual.
Legal basis for the processing: Fulfillment of our agreement with you and fulfillment of legal obligation and/or legitimate interest. For more detailed information on the basis on which the respective treatment is based, see the heading "More detailed information on how your personal data is used"
Automated decision-making and profiling: No automated decision-making. The information is analyzed to be able to offer you a personalized service. Read more in the section "How is the service personalized to me?"
Sharing of information: For marketing purposes, the information may be shared with other companies within Zmarta.
Fulfillment of our obligations under the agreement
We need the information to provide our service to you and confirm your identity. We need this information to enter into and fulfill our agreement with you. If you do not provide this information, unfortunately we cannot provide you with the service according to the Benefit Agreement. As mentioned above, Zmarta primarily uses statistical information to be able to provide the Benefit Agreement. This means your personal data (especially information about gender, zip code, age and application information) will also be de-identified to be used on an aggregated level within the service framework in relation to other customers.
Legal basis: Fulfillment of our contract with you
Communicate with you
Via post, telephone, electronic communication (such as text messages, e-mails, e-mail forms, social media accounts or via our chat function) or in other ways, e.g. when we send information about and are in contact with you about questions regarding our services.
Legal basis: Fulfillment of our contract with you
For direct marketing
Your personal data may also be used to offer you other services from Zmarta/ or from our other companies within the Zmarta Group.
Legal basis: Fulfillment of our contract with you and/or legitimate interest.
Development of and ensuring the functionality and efficiency of our services
We use data to analyze and understand market trends in order to develop and improve our products and services. In this regard, we can e.g. analyze user behavior in our digital services to improve functions and their presentation in order to make them more user-friendly. For this purpose, we may also compile statistics for analysis needs, e.g. how you use and navigate our services. Application information that you provide when applying for our mediation services is also used for analysis in order to provide you with relevant offers and direct marketing.
Legal basis: Fulfill our contract with you and legitimate interest
Monitoring of debt balance
If you have a debt balance, you will not be able to use our consumer loan mediation services. Therefore, as part of the service, Zmarta monitors whether you receive, or get rid of, a registered debt balance with the Swedish Enforcement Agency. Through monitoring, we can ensure that we only contact you in case you have the opportunity to use our loan mediation service.
To whom do we disclose your personal data?
In some cases, your personal data may be shared with other companies and partners, in accordance with what is further specified in this policy.
In the event that Zmarta, or a significant part of Zmarta's assets, may be sold to a third party, your personal data may also be shared with such third party due to such sale. However, you can always rest assured that we will not sell your personal data to an external third party for marketing purposes.
How long is my data saved?
The personal data is deleted in accordance with current personal and data protection legislation, which means that the data is not saved longer than necessary with regard to the purpose of the processing or in accordance with superior legislation. Your data, incl. your IP address, will be saved as long as you subscribe to the service and the data is needed to be able to fulfill the Benefit Agreement. If you terminate the agreement, we will delete the data as soon as possible in accordance with applicable law and Zmarta's internal processes. If the agreement becomes passive (i.e. if you do not show interest in the service or its content for a period of 5 years), this will be equated to the agreement being terminated and your personal data will then be deleted in the same way as stated above.
How is the service personalized to me?
To be able to provide you with relevant offers and personal service within the framework of the Benefit Agreement, we use a type of analysis (profiling) which means that we create tools to try to predict your future need for Zmarta's services. This is done on the basis of historical data (your previous engagements with Zmarta), engagement of other Zmarta customers, statistically aggregated data and other external third-party data concerning you as described below. Data is collected from previous applications with Zmarta companies (both yours and those of other customers) and information that you provide yourself in connection with applying for a loan, insurance, an electricity contract or any of our other services (for example, if you state that you have a car). Zmarta may also collect data from providers of statistical information, such as Bisnode. These providers retrieve data from public registers and data sources and build a statistical base on probability based on special conditions, e.g. a street address or residential area. The statistical basis is based on data on an aggregated level using de-identified data, without any connection to individual individuals. In addition, we may collect data about you from external providers. We may collect information about you from, for example, Bisnode, Bilregistret Carfax and Smart Software 365. The information we collect may, for example, be information about a car or other objects you own. Zmarta may also otherwise purchase third-party data for the purpose of refining our marketing and analysis. The data is used together with the data you have provided, to send you personalized offers based on your personal preferences, your online behavior, place of residence, and your financial and family situation.
Based on your personal data that we gain access to within the scope of the Benefit Agreement, e.g. previous services you have used within Zmarta, marital status, interests, vehicle ownership, form of residence, place of residence, how you interact on our web pages as well as the aggregated and personalized information indicated above, Zmarta performs an analysis on an individual level which may result in you being sorted into a customer group or get a unique profile. Your customer group or unique profile is then compared with the above-described statistical data on decisions and behavior of a target group or customer group that is as similar to you as possible, as well as other information about you that we have collected. For example, we identify and analyze customer behaviors to understand how different types of customers within e.g. the same residential area respond to promotions or offers.
Furthermore, the information may be used to offer you a personalized analysis of how your terms and engagements compare to Zmarta's other users on an anonymous and aggregated basis.
The above analysis aims to be able to offer you information and products that are relevant to you within the scope of the Benefit Agreement, and you will not have to read information that is likely not of interest to you. Different customers can therefore receive different offers.
What happens if I do not accept the processing of my personal data as stated in this data protection policy?
In order for you to receive targeted offers and personalized marketing within the scope of the Benefit Agreement, Zmarta needs to be able to process your personal data in the manner described above. Any benefits, for example a discount on products or services from a partner to Zmarta that are not adapted specifically to you, that are offered as part of the Benefit Agreement, you can use even if you object to parts of the treatment described above (including the processing that is done in order to be able to provide you with relevant and targeted offers) but other parts of the Benefit Agreement cannot be used. Of course, you always have the right to object to your personal data being used for marketing purposes. If you no longer want offers from Zmarta, contact us on 0431-47 47 90 or info@zmarta.se.