Last update December 11th, 2023.
Data protection policy of WiZink Bank,S.A.U.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The person responsible for the processing of your personal data is WiZink Bank, S.A.U. (WiZink), with CIF A-81831067, registered office at C/ Ulises 16-18; 28043 Madrid, and with the Customer Service telephone number published on the website www.wizink.es.
We have a Data Protection Officer who will ensure that your personal data is treated appropriately and will resolve any questions, queries or suggestions you may have. You can contact him, sending a letter to his attention, to the WiZink address that we have indicated in the previous paragraph or by sending an email to mb.esp.protecciondedatos@wizink.es.
If you are already a customer, you can also contact our Data Protection Officer through the Mailbox located on the website: WiZink.es within the Customer Area. To facilitate your consultation, as well as to assist you in the exercise of your data protection rights, WiZink provides you with a "Quick Guide for the exercise of ARCO rights", which includes consultation with the DPO, which you can find at https://www.wizink.es/proteccion-datos].
The WiZink website may contain links to other third-party websites, whose privacy policies are unrelated to WiZink, and WiZink is therefore not responsible for the privacy and processing of personal data of the aforementioned third-party websites. In any case, WiZink will inform you before leaving the WiZink environment. By accessing these web pages, you will decide whether you accept their privacy policies.
2. FOR WHAT PURPOSE DO WE PROCESS YOUR DATA AND WHAT IS ITS LEGAL BASIS?
Below, we detail why and why we process your personal data.
- a) WiZink will process your data based on the management and execution of the contract and/or pre-contractual measures for the following purposes:
a.1) Process product requests that you initiate in WiZink, evaluating your payment capacity and credit risk by consulting internal and external files, as detailed below.
In order to correctly execute the pre-contractual measures related to your request, WiZink has established an automated system for creating credit risk profiles or “scoring” that allows you to evaluate your solvency when you request a card, a loan or another product or service. asset. We also use this automated system when we offer you an additional asset service or propose an increase in your card's credit line. In these cases, the probability that you will meet your payment obligations will be automatically calculated to assess whether or not we can grant you the Product or Service, as well as define the credit limit of your credit card or the amount of the loan. This “scoring” is the result of a mathematical-statistical procedure and is necessary to comply with the obligations established in our credit product contracts in accordance with data protection regulations and its results support our decision-making in these situations.
In particular, through this system we carry out an evaluation of your ability to meet the payment of the amounts that you will be required to pay by contract, as well as your level of risk, comparing it with the previously indicated credit risk profiles that we have designed in WiZink. We will carry out this evaluation based on the following information we have about you:
- The information that you provide us directly either at the time of your request, or throughout the different contractual relationships you have had with WiZink. (For example: your salary, your expenses, obligations, work or seniority)
- The information derived from the contractual relationship that we have in force with you, or that derived from previous contractual relationships that you have had with WiZink. (For example: your behavior, consumption and preferences in the amortization of current and previous credits).
- We may also consult external sources, complying with the procedures and guarantees established by current legislation at all times, based on the legitimate interest of WiZink, such as:
- Credit information systems to which WiZink has access:
- ASNEF – National Association of Financing Entities, responsible for processing the “ASNEF” file. You can access more information about this file on its website (www.asnef.com)
- EXPERIAN BUREAU DE CRÉDITO, S.A., responsible for processing the “Badexcug” file, you can access more information about said file on its website (www. experian.es)
- Risk Information Center of the Bank of Spain (“CIRBE”).
- Whenever you authorize us to do so, WiZink will use the information from your accounts in other entities, available through your electronic banking.
This analysis of your solvency, through which we will assess your ability to face possible debts, will be carried out by making automated individual decisions in accordance with the credit risk profiles indicated above. Based on the risk that we detect and the credit rating that results from the analysis of such information, we may approve, modify or deny the contracting of the product that you request from us or be eligible to offer you additional asset services or modifications to your current conditions. In the event that we deny a credit application based on an automated individual decision, you can make the allegations you deem appropriate, opposing them by requesting human intervention in the decision, expressing your point of view and challenging them.
Keep in mind that at WiZink we subject this system to periodic reviews to avoid any possible mismatch, error or inaccuracy in the evaluation and, if necessary, make adjustments and error corrections.
If you do not complete the contracting process for a product, WiZink may contact you to help you finalize your request, according to the information that we will provide you in section b) of this section.
a.2) If your request is accepted, WiZink will process your personal data to be able to register you in the private area as a client and carry out all the activities necessary for the development, management and maintenance of the contract(s) you have with us, manage your personal data, register and collect transactions, thus managing your contract or other procedures that are available at any time, as well as sending you all the information that you request from us, for example, processing your data so that you can carry out transactions, receive statements, consult your information in online banking, but also carrying out all the activities to monitor that all these processes are working correctly, as well as to send you any communication related to their operation (management and solution of possible technical incidents, notifications in case modification of the contracting conditions, or for the management of any claim you need to make) about the products you have contracted.
a.3) Record and recover operations. In the event of non-payment, WiZink will carry out all necessary steps to recover debts, including the use of the contact information provided.
a.4) If you participate in any draw or promotion organized by this entity, WiZink will process your personal data to manage all phases of the same, as well as the delivery of prizes and the sending of information (by electronic or other means) related to the themselves, in accordance with the legal bases of each one.
a.5) If you have a loyalty program in force, WiZink may carry out all the necessary treatments for its management and correct functioning. If said program is carried out with WiZink Partners, your data may be exchanged with them when necessary for the indicated purposes.
In section “7. What rights can you exercise?” We tell you what your rights are, how to exercise them and what to do if you do not want us to carry out these treatments. For these purposes, you should know that we will not be able to respond to opposition requests to those treatments necessary for the management and execution of the contract, while it remains in force.
- b) WiZink will process your data based on its legitimate interest for the following purposes:
b.1) Offer you, through any means, including electronic, WiZink products or services, including those marketed by WiZink as an insurance mediator, that are similar to those you have contracted using only WiZink's internal sources, such as campaigns to encourage the use of said products in exchange for gift vouchers, discount vouchers or similar to be exchanged in other entities with which WiZink has agreements. In the case of insurance, it will also do so to comply with the provisions of Directive 2016/97 on the distribution of insurance.
For the personalization of the aforementioned commercial communications, and based on the legitimate interest recognized by the applicable regulations on data protection, at WiZink we will only process the information that we already have about you in our systems. In particular, we will process your identification data, your contact and professional data, as well as the information we have about your personal characteristics. In addition, and as we have already indicated, we will take into account your professional or activity data, the data related to your social circumstances that you have provided us, the information about the products and services that you have contracted and, where appropriate, or any other suggestion or query that you may have raised.
To support this legitimate interest, we have documented a “balancing test” to demonstrate that this processing activity does not harm our clients' interests in the protection of their personal data. When in this policy we refer to the documentation of a balancing test, we will be referring to the performance of an internal analysis that we have carried out to confirm that our legitimate interest does not prejudice the interests of our clients in the protection of their personal data and , that, in short, the protection of your data is not harmed.
In conclusion, we understand that our interest in carrying out this processing prevails to: (i) be able to maintain the relationship with you by contracting new products and services; (ii) know your interests in relation to the products that we make available to you; and (iii) improve the conditions of use of our platforms and websites. All of this will help us to generate a customer profile of yours that allows us to send you offers of products and services that are as tailored as possible, that respond to your tastes and preferences, and thus achieve your loyalty. In this way, as a customer, you will mainly receive commercial information about products that may interest you.
Due to the above, we understand that at WiZink we have a legitimate interest that does not affect your privacy, since to carry out this processing only data that you have already provided, or that has been generated in the contractual relationship will be used (disregarding data obtained from external sources, from third parties, other than WiZink, in accordance with the relationship incorporated in section “3. How do we obtain your data?” of this Privacy Policy).
Furthermore, it must be taken into account that this is an activity permitted and limited by current regulations on data protection and electronic communications and interpreted by the data protection authorities. This purpose is legitimized by legitimate interest based on the exception provided for in article 21.2 of the Information Society Services Law and the provisions of recital 47 of the General Data Protection Regulation. WiZink's interest is based exclusively on direct marketing in order to offer you products and services that are similar to those you have already contracted and that fit your risk profile and thus achieve your loyalty.
We will send you commercial communications while you are our client and unless you tell us otherwise, objecting at the time you provide your data and at any time thereafter in the manner indicated in section “7. What rights can you exercise?”
b.2) If you have contracted the WiZink Marketplace service, in accordance with its terms and conditions, WiZink will process your data to send you communications about products and services from third-party collaborating companies that you can consult in Annex III. WIZINK COLLABORATING COMPANIES, included in the Marketplace section with which WiZink has reached exclusive agreements, as long as you are a WiZink customer and you have not informed us of your opposition to receiving them.
We have a special interest in serving your user experience as best as possible, improving your degree of satisfaction and being able to meet your expectations when you browse our Marketplace, as well as ensuring that you know the offers that are available at all times in the Marketplace section that you have contracted.
To determine the legitimate nature of our interest, we have internally documented a balancing test that supports the legitimacy of this processing activity. In any case, you have the right to obtain additional information regarding this processing activity if you request it, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation. that justify said opposition, in the manner indicated in section “7. What rights can you exercise?”
b.3) Communicate the strictly necessary data (name, surname, date of birth and NIF/Passport or equivalent identification document) to other companies of the WiZink Group, exclusively in those cases in which you have expressed interest in contracting products from said companies, to carry out verifications of your identity, avoid fraud and expedite the contracting of the product that interests you.
WiZink's legitimate interest is to verify your identity and prevent fraud in the processing or contracting processes, as well as improve the security of the operations followed, for example, preventing incidents regarding the security of your data or identity theft.
As in the previous case, in this case we have also carried out a balancing test to ensure that our interests in fraud prevention did not prejudice the rights of our clients and users.
Thus, our conclusion is that our interest prevails, as it is a necessary measure to protect the integrity and operation of our services, and to avoid and prevent fraudulent conduct against the interests of both ours and our users. Ultimately, this processing aims to identify those people who may have acted fraudulently, to avoid future hiring or to adopt the necessary measures to protect the interest of the person responsible against fraud.
In any case, you have the right to obtain additional information regarding this processing activity if you request it, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation. that justify said opposition, in the manner indicated in section “7. What rights can you exercise?”
Likewise, you can consult all the WiZink Group companies to which we can communicate your data for the aforementioned purpose in Annex I. WIZINK GROUP COMPANIES.
b.4) Carry out surveys or market studies that allow us to know your opinion about our products, services and processes, as well as to carry out analysis of the reports and statistics obtained from your responses.
At WiZink we have carried out a balancing test to ensure that our interests related to the development of this processing activity do not harm the rights of our clients and users. WiZink's legitimate interest in this case is to be able to offer you WiZink products and services with the highest quality and best experience possible, as well as to incorporate into our processes the value generated by your opinions and suggestions and to identify possible aspects of improvement in our services.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.5) Prevent and detect fraud both in the product requests that you have initiated with us, and in the contracts that you have in force with us. To do this, WiZink:
- It will create anonymized patterns aimed at identifying possible fraudulent operations in the documentation and information you provide. We inform you that, if possible inconsistencies or irregularities are detected, WiZink will stop the study of your application until it carries out the necessary checks.
- WiZink is attached to the Confirma File, in relation to which we inform you of the communication of your data to it, whose purpose is the prevention of fraud. The legal basis for the processing of personal data is WiZink's legitimate interest in preventing fraud. The maximum period of data retention will be two years. Those responsible for the treatment are the Entities Adhered to the Confirma File Regulation, with the person in charge of the treatment being Confirma Sistemas de Información, S.L., with address at Avda. de la Industria, 18, Tres Cantos [28760] Madrid. Applicants may consult the list of Entities that are currently adhered to the Confirma File Regulations on the website www.confirmasistemas.es. Entities that adhere to its Regulations and that in their field of activity may be subject to contracting fraud may participate in the Confirma File. The data communicated to the Confirma File may be transferred to the Entities Adhering to the Confirma File Regulations. The transfer of data to a third country or international organization is not planned. In accordance with current regulations on data protection, the signatories may exercise their rights of access, rectification, deletion, limitation of their processing or opposition, and portability, by contacting the address of the data processor, Confirma Sistemas de Información, S.L. , at the address indicated above. Likewise, the signatories may make use of their right to file a claim with the Control Authority. Confirma Information Systems, S.L. has appointed a Data Protection Officer who can be contacted by email dpo@confirmasistemas.es.
In the event that we detect any attempt at fraud that affects your personal data, and unless a circumstance of public interest or other legal cause prevents it, we will review the available information and, where appropriate, we may request your collaboration and information. additional. Likewise, as a precaution, for security and until we carry out the appropriate checks, we may paralyze any decision regarding your personal data.
In accordance with the content of the weighing test that we have documented internally, WiZink's legitimate interest is to know and identify participants in fraudulent activities, to carry out the necessary actions and thus be able to protect you by applying security measures. security such as automatic or manual blocking of the card and/or account, thus fulfilling its duty of adequate risk control.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.6) In the event that you do not pay the amounts due, in accordance with what is agreed in the contract(s) of the products and/or services that you have contracted with us, complying with the procedures and guarantees established and recognized at all times. current legislation, WiZink will communicate your data to the following entities that have credit information systems, duly complying with the procedures, rights and guarantees established and recognized by current legislation at all times:
- ASNEF - National Association of Financing Entities, responsible for processing the “ASNEF” file, you can access more information about said file on its website: www.asnef.com, and/or
- EXPERIAN BUREAU DE CRÉDITO, S.A, responsible for processing the “Badexcug” file, you can access more information about said file on its website -www.experian.es-].
In accordance with the content of the weighing test that WiZink has documented internally, our legitimate interest is given by our commitment to comply with the duty of adequate control of the credit risk of WiZink, as well as that of third financial entities so that they can know the existence of non-payments in the event of new financing requests, thus safeguarding the well-being of the financial system and helping to prevent non-payment situations for its clients.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.7) In the event of non-payment, we may carry out evaluations and classifications of your data so that, to the extent possible, we can reach a solution adapted to your specific situation. Furthermore, in the event that we cannot locate you on the telephone numbers that you have provided us, we can go to different external sources accessible to the public such as official newspapers and bulletins, public records, telephone directories, lists of people belonging to professional associations; to other external sources such as the internet and the information contained in open profiles on your social networks; as well as reports commissioned from private detectives in accordance with current regulations. We may also contact family or friends and access data associated with the history of our interactions with you and the telephone contacts that you have made available to us in previous contacts, for the exclusive purpose of locating you. Under no circumstances will WiZink provide any information about you or your situation to any third party for the fulfillment of the described purpose.
In accordance with the content of the weighing test that we have documented internally, WiZink's legitimate interest in these treatments is to contact clients who have a debt situation, to avoid the generation of further interests derived from it and reach a payment agreement suitable for both parties.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.8) Preserve and process the recording of telephone calls in order to track the procedures you carry out at all times, as well as prepare statistical reports and volumetric reports on them.
In accordance with the content of the weighing test that we have documented internally, WiZink's legitimate interest is to improve the quality of the service (for example, by speeding up responses to your queries), ensure security and retain evidence of the actions you have taken. , as evidence and to be able to use them either in the judicial or extrajudicial phase.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.9) When the information you provide us regarding the name of your employer or your bank account is incongruent or inconsistent, we may confirm the name of your company with your employer and your account information with your bank.
In accordance with the content of the weighing test that WiZink has internally documented, our legitimate interest is to verify the accuracy of the data you have provided to us to evaluate your solvency, verify your identity to prevent fraud and money laundering and financing of terrorism.
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
b.10) Contact you to help you finalize your request for contracting WiZink products and services, in those cases in which this has not been completed.
According to the content of our weighing test, WiZink's legitimate interest is to improve the quality of our recruitment processes (for example, streamlining it, or improving your customer experience).
You have the right to obtain additional information regarding this processing activity, as well as request your right to object, indicating the specific processing to which you object and the reasons related to your particular situation that justify such opposition, in the manner indicated in the section “7. What rights can you exercise?”
In any case, WiZink carries out all these activities respecting your rights and freedoms. You may object to these treatments as indicated in section “7. What rights can I exercise?" Opposing these treatments will not affect the services you have contracted. Remember that you can always and at any time oppose any of the treatments indicated in this section.
WiZink will process your data based on your consent for the following purposes:
c.1) To respond to requests that you may make to us through the spaces or channels enabled for this purpose.
c.2) WiZink will process your biometric data, which will be kept with the required security measures and may only be used for the purposes that, at any time, you expressly and explicitly consent to:
Verify your identity, in the event that as part of the contracting process for any of WiZink's products, you authorize verification of your identity via video call. In these cases we can use the recording that contains your image and voice.
Formalize contracts for WiZink products, using a biometric digital signature in the event that you authorize the contract to be carried out in this way. In these cases we can make use of pressure, speed and inclination data, among others.
c.3) As part of the process of processing requests for our products initiated by you, and with the purpose of keeping your data updated in our systems, to consult on your behalf the General Treasury of Social Security, information about your economic activity, so that WiZink can carry out a verification of it in compliance with the regulations for the Prevention of Money Laundering and Financing of Terrorism.
c.4) As long as you are not a client of this entity and you have given us your authorization, WiZink may send you communications to inform you about the products and services of this entity by any means, including electronic means.
c.5) If you are a client of any of the Group's entities (See Annex I. WIZINK GROUP COMPANIES), and you have given them your authorization, WiZink may contact you to inform you about our products and services.
c.6) WiZink may inform you about the products and services marketed by this entity, which are not similar to those you have already contracted, as well as request additional information about your preferences for these products for marketing purposes, provided that you have given us your authorization.
c.7) Process the information obtained through the cookies used on the WiZink web pages, for the purposes established in the Cookies policy (https://www.wizink.es/security-internet#cookies) summarized in allowing the correct functioning of the website, analyzing your preferences and offering you services or products, which based on the information you have provided us as well as that derived from your contractual relationship, adapt to your preferences and measure the effectiveness of the campaigns we run. .
c.8) As long as you have contracted any of WiZink's financial aggregator services, or have provided us with your credentials in other entities, and in any case you have authorized us to do so, we may access the information available from your accounts in other entities at through your electronic banking, to evaluate your solvency and/or to include this information in your commercial profile and personalize it, in order to offer you other products and services marketed by WiZink and third-party collaborating companies, as well as benefits or better conditions for your acquisition. The processing of your personal data will be limited to what you have consented to at any given time.
c.9) WiZink may share your data with other companies in the WiZink Group or with other WiZink collaborating companies so that they can contact you and offer you their products and services, as long as you have given us your authorization. You can consult all the WiZink Group companies to which we can communicate your data for the aforementioned purpose in Annex I. COMPANIES OF THE WIZINK GROUP, as well as the collaborating companies to which we can communicate your data for the aforementioned purpose in Annex III. WIZINK COLLABORATING COMPANIES.
c.10) If your device allows it, and you authorize it, WiZink may access the geolocation of your mobile device to provide you with the location of CEPSA ATMs and gas stations, and detect possible cases of fraud or identity theft.
c.11) In the event that you are a user of the WiZink mobile application (from now on App) and you want to share some file with WiZink with us, you can make use of the functionality of the App that allows you to upload images or files that you already have saved on your device or activate the camera. To do this, WiZink will ask you for authorization to allow the App access to this type of content stored on your device. Likewise, in the event that you want to download your statements or other documents available through your App, WiZink will ask you for this same authorization to download them to your device. WiZink will not access the rest of the information stored on your device, nor will it use the images or files to which it has access for purposes other than those mentioned.
c.12) In cases where the holder has a “co-branded” credit card issued by WiZink and a WiZink partner, they may share the data of said customers to be able to manage the loyalty program of said card.
In section “7. What rights can you exercise?” We tell you what your rights are, including your right to revoke the consents you have given us if you do not want us to carry out these treatments and how to exercise them. For these purposes, you should know that the revocation of your consents will not be retroactive.