The summary points are not part of the terms.
We are a financial service for everyone aged 18 or older.
When you create a Tink account, you also enter into a contract with us.
This policy sets forth which data we collect about you and why.
You may close your account at any time, and we will delete your personal data.
· 1.1 This integrity policy (the ”Policy”) applies when Tink AB, reg. no. 556898-2192, Vasagatan 11, 111 20 Stockholm, Sweden, e-mail: firstname.lastname@example.org, (”Tink”) provides private financial services via the Tink App (the ”Services”).
1.2 To use the Services, you must be at least 18 years of age and/or otherwise be authorized to enter into contracts, and agree to be bound by this Policy.
1.3 By creating an account in the Tink App and using the Services, you accept that Tink collects and provides information by your mobile phone, tablet or other technical device used and that Tink processes your personal data in accordance with this Policy. By your use of the Services, you also agree to such data referred to in sections 2.1, 2.2, below, and other data regarding your private financials that you have granted Tink access to, including your customer relationship with Tink, being provided to Tink’s collaboration partners in accordance with section 4.1, below.
1.4 You may at any time delete your Tink account. You can delete your account by choosing “Delete account” under "account and settings" in the Tink App or by contacting Tink. Tink will then delete or anonymize information that is referable to you, however, excluding such information that Tink is required by law to retain, normally during five (5) years after you have closed your Tink account. The personal data is only kept for fulfilling such legal obligations.
2. Which data does Tink process about you?
We collect data from e.g. banks and credit institutions.
We also collect data from public registers.
2.1 Tink collects and processes your personal data when you create a Tink account and use the Services, as well as when Tink, from time to time, is provided access to your external user accounts, such as name, contact details, personal identity number, transactions data (amount and time of purchase, type of transaction and relevant goods), positioning data, form of housing, credit amount applied for, repayment period, occupation, salary, civil status, citizenship, granted credits, records on non-payment, income, employment hiring date, household information (number of children and adults, existing monthly credit costs, monthly housing costs and vehicles, if any) and other financial information. Tink also collects information by use of own or third party cookies and other follow-up tools, see section 7, below.
2.2 Tink may also collect data from public registers and information that Tink receives from third parties, such as for the ID Control service. By creating a Tink account, the user agrees that the abovementioned suppliers provide information to Tink and that Tink stores and processes the information for the purposes set forth in this Policy. The user also agrees to Tink providing the user’s personal data to the abovementioned third parties to the extent necessary for the recipient to identify the user and Tink to fulfill its service obligations toward the user and to these third parties having the right to provide information to Tink for the purposes set forth in this Policy.
2.3 The personal data processing in accordance with section 2.1 and 2.2 is carried out to provide the Service to you. Your personal data is kept by Tink only for such time periods as necessary to fulfil the purposes for which the data was collected. However, Tink may retain the data for a longer period of time if required by law or if needed to protect Tink’s legal interests, e.g. in the event of an ongoing legal proceeding. In such cases, the personal data is only kept to fulfill such legal obligations, and for protecting Tink’s legal interests, being a legitimate interest of Tink, respectively.
3. Why does Tink process your personal data?
We use data about you and your finances to provide you with the best service possible.
After anonymizing the data, it can also be used for market research etc.
In the future, you may receive offers and advertising from Tink that are customized for you.
If you do not want offers, you may decline these being sent and we will respect your decision.
3.1 Tink processes your personal data for several purposes. The main purpose of Tink’s processing of personal data concerns providing, administering, developing and adapting the Services and its functionalities, to fulfill the contract with you. Further, it is processed to ensure Tink’s knowledge of its customers, administration of the customer relationship with you and to fulfil security, statutory or other regulatory requirements, to fulfill legal obligations of Tink’s. The data may also serve as material for marketing and customer analyses, market research, statistics, follow-up of business operations and business and methods development, which is carried out based on Tink’s legitimate interest of following-up and analyzing its customers.
3.2 Tink also processes your personal data in order to improve and customize the provision of personal offers and service. Personal data and positioning data may, e.g. be processed and cross-checked, be segmented and analyzed to by means of direct marketing provide information, offers or recommendations of goods and services provided by Tink or Tink’s collaboration partners, that are customized based on the user’s preferences, behaviors, needs or lifestyle in the Tink App or via e-mail. The profiling might have the result that you receive an offer, but no automated decision is made. These activities are carried out based on Tink’s legitimate interest of providing relevant information and offers to its customers.
3.3 If you do not want Tink to process your personal data for direct marketing, you may notify Tink thereof in writing. You may also notify Tink that you oppose profiling for the purpose of receiving offers. Contact details for such notifications to Tink are provided in section 8.
4. Third Parties
When we collect data from third parties on your behalf, we may need to identify you to them in order to collect the correct data.
From time to time, we need to engage collaboration partners and provide them with access to data, but will not share names or personal identity numbers.
We commit to have contracts in place with all collaboration partners that restrict them from disclosing any data.
Occasionally, we need to engage service providers, but Tink will always remain responsible for the correct processing of your personal data.
· 4.1 Personal data which allow for a user to be identified, and information on such user having a customer relationship with Tink, will be provided to Tink’s collaboration partners. The processing is performed for fulfilling the contract on the provision of the Service.
4.2 Personal data may also be disclosed if required under applicable law or a decision of a competent authority, this is in such cases done in order to Tink to fulfill legal obligations. Further, personal data may be processed to protect Tink’s legal interests or to detect, prevent or observe fraudulent behaviors and other security or technical issues, which constitute legitimate interests for Tink for performing the processing.
4.3 Tink may also provide personal data to companies that process personal data on behalf of Tink, i.e. data processors of Tink, such as our IT-suppliers or suppliers engaged by Tink for Tink’s marketing efforts. However, Tink will always be responsible for the correct processing of your personal data.
Your personal data may be transferred to or stored in countries outside of the EU/EEA, provided that there is an adequate level of protection or that Tink and its data processors have implemented appropriate safeguards, such as standard contractual clauses or the Privacy Shield Framework, please see https://ec.europa.eu/info/law/law-topic/data-protection_en. By creating a Tink account, the user agrees to the user’s personal data being transferred and stored outside of the EU/EEA according to the above.
5. Changes to the policy
We are allowed to make changes to the policy terms, but must inform you well in advance.
Tink has the right to, at any time, change this Policy. Tink shall notify the user of upcoming changes to the Policy via its website or the Tink App with reasonable advance notice. If you do not accept the changed terms, you have the right to terminate your contract with Tink prior to the changed Policy enters into force. You terminate your contract with Tink by closing your Tink account.
6. Data security
Processing of personal data is a responsibility of great importance to us.
We aim to ensure that you at all times remain confident in trusting Tink with your personal data. In this respect, Tink has implemented such security measures necessary to protect your personal data from unauthorized access, modification and deletion.
7. Cookies etc.
7.2 When you download the Tink App to your mobile phone, tablet or other technical device, Tink needs to store and collect certain technical information from the device in order for Tink to be able to provide and update the Service. By downloading the Tink App, you agree to Tink’s storage and collection of certain technical information from the device. The information is stored for Tink being able to fulfill the contract with you on providing the Service. If you no longer agree to Tink’s storage and collection of the technical information, you need to uninstall the Tink App.
8. Your rights and contact details
Tink is the data controller and has appointed a data protection officer for the data processing.
Tink cherishes your rights and has implemented functions in order for you to request access to your personal data, data portability etc.
Please contact us if you have any questions.
If you are discontent with us you may contact Tink’s Data Protection Officer.
If you should remain discontent, you may contact the Swedish Data Protection Authority.
8.1 Tink is the data controller and is responsible for the processing of your personal data in accordance with applicable legislation. Tink has also appointed a data protection officer for its data processing, please see below.
8.2 You are entitled to, in accordance with applicable law, request access to and rectification or erasure of your personal data or restriction of processing concerning you and to object to processing as well as to data portability. You are entitled to request this free of charge. In case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, Tink is entitled to charge an administrative fee – in such cases you will be notified thereof beforehand. Tink will normally answer your request within one (1) month from receipt of your request, requests are made via email@example.com.
8.3 Do not hesitate to contact Tink if you have any questions on the processing of your personal data or any complaint. Written or oral questions and complaints shall, at first-hand, be directed to:
Attn: Data Protection Officer
111 20 Stockholm
Telephone: +46 8 50 90 89 00
E-mail: firstname.lastname@example.org write ”Privacy” in the subject field.
You may also request customer support to forward a complaint to the Data Protection Officer. If you should remain discontent after having been in contact with us, you may contact the Swedish Data Protection Authority that is the supervisory authority in respect of data processing, and to which you may submit your complaint.
THE SWEDISH DATA PROTECTION AUTHORITY
P.O. Box 8114
SE - 104 20 Stockholm