Privacy Policy for Borrowers and Prospects

Aware of the importance of ensuring the confidentiality of personal data and informing you of your rights and how your personal data is handled, SILVR ("SILVR" or "we") has prepared this privacy policy.

The privacy policy describes how SILVR processes the data of prospects (“prospects” or “users”) during the loan request analysis, and if the loan can be granted, of borrowers and, where applicable, their staff, during the performance of their loan agreement with SILVR.

2.   Purposes and lawful bases for the processing

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SILVR processes your personal data only for a limited set of purposes. These purposes each have a lawful basis, as detailed below.

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2.1.   Personal data of prospects

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With respect to prospects, SILVR processes the personal data of prospects and, where applicable, their staff, for the following purposes:

• ‍To respond to requests for information or questions from prospects received by SILVR. The legal basis for this processing is SILVR's legitimate interest in responding to prospects' requests and providing them with any clarification that may be necessary.‍
• To carry out direct marketing by email or telephone with your professional email or your professional telephone, which we have obtained directly from you or indirectly and for which you have received this privacy policy or have been informed that they will be used for the purposes of commercial prospecting related to our services. The lawful basis for this processing is SILVR's legitimate interest in publicizing and promoting its services.‍

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2.2.   Personal data of borrowers

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With respect to borrowers who have signed a contract with SILVR, we process the personal data of borrowers and, where applicable, their staff for the following purposes:‍

• ‍Verifications (identification, verification of identity and knowledge of clients ("Know Your Client")) relating to the fight against money laundering and terrorist financing. The lawful basis justifying this processing is SILVR's legal obligation to set up an appropriate monitoring system for the fight against money laundering and terrorist financing;‍
• Signing, monitoring and performance of the contract with SILVR. The lawful basis for this processing is the performance of the contract (NDA or loan agreement contract) concluded with SILVR;
• ‍Record-keeping and management of accounts relating to the performance of the contract concluded with SILVR. The lawful basis that justifies this processing is SILVR's legal obligation to keep accounts and retain necessary supporting documents;‍
• Direct marketing activities for services similar to those that borrowers have purchased with SILVR. The lawful basis for this processing is SILVR's legitimate interest in publicizing and promoting its services;‍
• Management of pre-litigation, out-of-court settlements and, where applicable, litigation. The lawful basis for this processing is SILVR's legitimate interest in defending its interests and asserting its rights in the event of a dispute or litigation.
  

3.   Retention period of your personal data

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For the purposes described below, SILVR retains your personal data for a limited period of time and proportionate to the purposes described above.

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With respect to prospects, their personal data is retained:

• For answering the prospects’ requests, for the period necessary to answer or supply information;
• For commercial prospecting with directly or indirectly collected data, for 3 years following the collection of data or last contact with the prospect or as long the prospect has not objected to the use of his data for direct marketing purposes.

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With respect to borrowers and, where applicable, their staff, personal data is retained:

• For the signing, monitoring and performance of the contract with SILVR, during the entirety of the contractual relation and, after its term, archived for the duration of the applicable statute of limitations;
• For the invoicing and accounting related to the performance of the contract with SILVR, for ten (10) years in accordance with the provisions of article L. 123-22 of the French Commercial Code;
• For commercial prospecting, during the entirety of the contractual relation and, after its end, for three (3) years;
• For management of pre-litigation, out-of-court settlements and, where applicable, litigation, for the duration of the pre-litigation or legal proceedings.
  

4.   Recipients of personal data

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In accordance with the purposes set out in this policy, SILVR may share your personal data with:

• Duly authorized SILVR’s employees and managers. Any SILVR’s employee who has access to your personal data is subject to strict confidentiality obligations;
• Partners essential to the provision of SILVR's services such as, but not limited to, our payment partner and our debt collection partners in the context of managing disputes or unpaid bills;
• Service providers to perform services related to SILVR's services, notably email service providers;
• Competent authorities, if any, such as public authorities and administrative or tax authorities.