You can contact the Data Protection Officer at:
If you are not satisfied with the way we have responded to your complaint regarding the protection of personal data, you have the right to lodge a complaint with the Commission for Personal Data Protection. You can contact the supervisory authority as follows:
I. Principles of personal data collection and processing
We as a company are committed to the protection of your personal data and we do not use them for any other purpose other than providing, maintaining and improving our services and or as required by law. The main principles applied by the Company in the collection and processing of personal data are:
II. Individualization of the personal data administrator
1. The administrator of personal data under this Policy is STICK - CREDIT AD, with registered office and address of management at Novi Pazar, 16 Vasil Levski Str., Ent. 4, fl. 4, ap. 8. The address for correspondence is Novi Pazar, 16 Vasil Levski Str., Ent. 4, fl. 8, ap. 8
2. The administrator processes personal data in connection with the provision of access and registration on the Afranga P2P marketplace, advertising its services, determining the purposes and means for their processing, in compliance with the applicable regulations.
3. The Personal data shall be processed independently by the personal data controller and by assigning personal data processors.
4. The controller may designate one or more persons to be responsible for coordinating and implementing personal data protection measures.
III. Types of personal data collected, processed and stored
1. When we process your basic personal data and the other data described for the purposes of providing the services for access to the Afranga platform, and their fulfillment of your requests / requests / applications, as well as in order to fulfill our regulatory obligations, this processing is mandatory to meet these objectives. Without this data, we would not be able to provide the relevant services or with access to our platform.
2. Your identification data in the context of a contractual relationship:
IV. Personal data processing purposes
1. To access to Afranga’s P2P marketplace platform, provide the services available on the platform to which you are a party and provide the necessary electronic services and documents for entering into Assignment Agreements. Upon registration with the Platform, the personal data of the User is used for: identifying the User, creating a Virtual Account of the user, and providing the Services according to the relevant agreements with the User.
2. For the purposes of opening and maintaining a Virtual Account of the User. In order to create and maintain the Virtual Account, the User’s personal data, contact information, transaction data and communication data is used. This data is also necessary to ensure money transfers and withdraws, daily summaries and notices about transfers, to provide any related services arising from Agreement.
3. Because the processing is necessary to comply with a legal obligation that applies to Afranga; For example, as a registered financial institution whose activity is under the supervision of the Bulgarian National Bank, we have obligations to provide information to the Bulgarian National Bank, the State Agency National Security, the Ministry of Interior and other third parties in accordance with the Consumer Credit Act, the Credit Institutions Act, the Protection Act of consumers, the Law on Measures against Money Laundering, the Law on Provision of Distance Financial Services, Ordinance № 26 on Financial Institutions, adopted by the BNB. The company may provide information to the Consumer Protection Commission or third parties provided for in the Consumer Protection Act, to the Personal Data Protection Commission and all other public bodies in accordance with the applicable legislation;
4. For fraud prevention purposes;
5. For the purpose of collection of receivables;
6. In case the processing is necessary for our legitimate interest - to perform a basic analysis of your data in order to adapt our services to your individual needs and to offer you new services to meet them, as well as to notify you of changes in the services and to maintain communication with you in connection with the repayment of our claim against you.
7. Within the scope of your consent - for example for marketing and promotional purposes. If you have given us your consent for the processing of your personal data for marketing purposes, the processing will only be carried out in accordance with the purposes specified in your consent. Any consent to the processing of personal data for marketing purposes may be revoked by you at any time, and this will not affect in any way the Services we provide. To withdraw your consent, you only need to use the contact details on our website.
V. Categories of persons to which Afranga discloses personal data
We provide your personal data to certain categories of third parties so that we can offer you quality, fast and comprehensive service and our products and services to meet your expectations. We do not provide your personal data to third parties until we have made sure that all technical and organizational measures have been taken to protect this data, and we exercise strict control over the implementation of this purpose. In this case, we remain responsible Administrator for the confidentiality and security of your data.
1. Persons who, on the basis of a contract with Afranga or registration on Afranga’s P2P marketplace platform, process your personal data on behalf of the company or have direct / indirect access to the personal data include:
2. Other controllers of personal data to whom Afranga provides personal data include competent authorities, which by virtue of a normative act have the authority to require the Administrator to provide information, including personal data, such as a Bulgarian court or a court of another country, various supervisory / regulatory bodies - Consumer Protection Commission, Regulatory Commission of communications, bodies with powers for protection of national security and public order and others.
VI. Period of storage of personal data
We process your personal data for the entire duration of the Agreement you have concluded with us and store them for a period of five years after its termination and / or after submitting a loan application, in case you have not concluded an Agreement with us, in order to comply with the applicable anti-money laundering legislation, as well as with the expiration of certain limitation periods for filing claims and obligations to provide information to the court, competent state authorities and other grounds provided for in the current legislation (5 years) .
After the expiration of the above deadlines, the Company will delete or anonymize your personal data, unless they are necessary for pending court, administrative proceedings or proceedings to review your complaint before us.
Anonymization is an alternative to deleting data and is a process in which all personally identifiable data (data that allows you to be identified) is permanently deleted. Anonymized data are not personal and are not subject to regulatory requirements for deletion.
Cookies are small text files that are stored on your computer or mobile device when you visit our website. They collect information about how to use the website in order to improve its efficiency and allow us to store your preferences so that you do not have to enter them every time you visit the website or go from one page to another. This way you cannot be personally identified.
VIII. Rights of the users regarding their personal data
You have the following rights in relation with the collection, processing and storage of personal data by Afranga:
The withdrawal of the consent will not affect the legality of the previously given processing based on the given consent before its withdrawal and will not affect the processing and storage of personal data by Afranga in cases where the Company has a legal obligation to keep these data, according to the provisions of the Bulgarian legislation and / or the law of the European Union.
IX. Protection of personal data
The security of your personal data is important to us and that is why we apply various organizational and technical measures to ensure that your data is protected and kept strictly private and confidential. We have systems and procedures in place to prevent unauthorized access, improper modification or disclosure, misuse or loss of personal data and other User information. We protect your personal data by maintaining physical, electronic and procedural measures and rules in accordance with applicable laws, regulations and good industry practices. Some of the measures we take to ensure a high level of security with regard to the management of personal data include:
Please note that you also play an important role in protecting your personal data. When registering on our platform, it is important to choose a password of sufficient duration and complexity, not to disclose this password to anyone and to notify us immediately if you find unauthorized access or unauthorized use of your account and / or mail. Given the nature of communication technology and information processing technology, we cannot guarantee that information, during transmission over the Internet or while stored in our systems or otherwise, will be absolutely safe from intrusion.
Our site may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and Afranga is not responsible for them.
X. Consideration of customers 'complaints
This item has been developed on the basis of the applicable legislation regulating customer complaints in connection with the activity of Afranga. The main goal of this policy is for the complaints of the company’s clients to be resolved fairly and within the pre-established deadlines for response.
Our representative accepts customer complaints and submits them no later than the end of the next business day for consideration by the manager. The manager then gets acquainted with the complaint and stops contact with our customer. When the complaint is fully or partially justified, the manager makes every effort to satisfy the client's claims and prevent potential litigation.
A complaint, within the meaning of this point, is any oral or written expression of dissatisfaction, suggestion or remark of a client regarding the quality of the provided services. Afranga groups the complaints of its clients according to the manner of their receipt as:
Written complaints of clients forwarded to Afranga through supervisory or other administrative and state bodies (Bulgarian National Bank, Consumer Protection Commission, Personal Data Protection Commission, Competition Protection Commission, etc.).
Afranga prepares answers to complaints within 30 business days from the date of receipt of the complaint, and in case of factual or legal complexity the term may be extended, for which the complainant is explicitly notified.
The policy may be amended or supplemented due to amendment of the applicable legislation, at the initiative of Afranga, of individuals, personal data subjects and / or of a competent authority (eg the Bulgarian Commission for Personal Data Protection).