5in5 respects the privacy of visitors to its website www.5in5.nl, particularly visitors’ rights regarding the automated processing of personal data. For complete transparency with our customers, we have therefore formulated and implemented a policy concerning the processing itself, its purpose and the options available to data subjects to exercise their rights as effectively as possible.
For further information about the protection of personal data, please visit the website of the Dutch Data Protection Authority:
By continuing to visit this website, you accept the following terms of use.
Until you accept the use of cookies and other tracking systems on the website, we do not place non-anonymised analytics cookies and/or tracking cookies on your computer, mobile telephone or tablet.
The current version of the privacy policy available on the website is the only version that applies while you visit the website, until a new version replaces it.
What personal data do we process?
Information you provide to us. This includes all personal data you provide to us, including information provided during a loan application. It also includes personal data such as your name, address, email address, telephone numbers and national identification numbers. Information about your business may also be requested, such as business plans, bank-account details and payment history.
Information we collect about you: as part of the credit-assessment process, we must collect certain information about you and your business. We do this to provide you with the best possible credit offer and to meet our legal obligations under Know Your Customer (KYC), anti-money laundering and counter-terrorist-financing laws and regulations. We also collect information from third parties, such as credit-rating agencies and other publicly available sources. This information may include:
- Identification and contact details: name, date of birth, identification number, address, telephone number, nationality, etc.
- Financial information: information collected from third parties, such as details of your income and other credit information.
- Bank details: information from all transactions made through your business and/or personal bank account.
- Credit history: information collected from third parties, such as financial history, adverse credit registrations and previous payment and credit acceptances.
- Information about how you use our services and communicate with us. We collect information about how you use our services, including details of outstanding and historical debts and your payment history with 5in5; technical data such as web-page response times, download errors and personal preferences; your interactions with the 5in5 customer team; and so on.
- Device information: information such as IP address, language settings, browser settings, operating system, platform and screen resolution.
- Geographical information: information about your geographical location.
- Information from external sanctions and PEP lists: we may screen your information against lists of persons subject to sanctions and lists of persons identified as politically exposed persons (PEPs).
- Special categories of personal data: entirely voluntarily, you may choose to provide information that may be classified as “special categories of data” under EU Regulation 2016/679, including information revealing religious, political and/or philosophical beliefs, trade-union membership, or information about health, sex life or sexual orientation. We will never ask for this information in order to provide our services. If you choose to provide such information, it is regarded as entirely voluntary and based on your explicit consent.
- Service-specific information: to provide some of our services, we may collect and process additional personal data that does not fall within the categories above.
Why are we permitted to process your data?
5in5 provides credit. We may collect and use your data because you must comply with the credit agreement. Initially, we process personal data on the legal basis of consent. Processing may also be based on performance of an agreement. When processing is not based on performance of the agreement, we base our processing of your personal data on the legitimate interests of Flow Forward B.V, trading under the name 5in5.
What do we do with this information?
We use this information to provide and improve our services. We process personal data to provide our services and business loans to small and medium-sized enterprises. Part of this process also involves collecting data to improve our services.
With whom do we share your data?
Where necessary for the application and performance of the credit agreement and/or amicable debt-collection activities, we share your data with our external parties. It is sometimes also necessary or even mandatory for us to share data to account for our activities to supervisory authorities, for example.
For our services, we sometimes also engage other organisations or business partners that process personal data on our behalf. We make clear written agreements with them concerning the correct and careful handling of personal data and its security and confidentiality.
Sharing your data outside the Netherlands
Where applicable: if a foreign relationship is involved, we share information with that relationship.
All European countries, Liechtenstein, Norway and Iceland (the European Economic Area) are subject to the same legislation regarding the protection of personal data.
How long do we retain your data?
Your data is not retained for longer than we need it for the purposes for which it was collected or processed. Flow Forward applies different retention periods depending on the purpose and category of data.
If we no longer need the data for the purposes described above, we may still retain it for archiving, legal proceedings or research.
Marketing and communication
We may use your contact details to communicate with you. We may do this by conducting customer surveys or sending offers relating to our products and services based on our relationship with you. If you choose not to receive such communications or information, you can contact us at any time at contact@5in5.nl.
To provide tailored offers and discounts, we consider information about your interaction with 5in5, your identification and contact information, information about products and services and your use of those services. This processing may result in profiling (see extract 6 for more information). The information forms the basis for 5in5 marketing and customer analysis and the development of statistical information. We tailor offers based on identification and contact information, information about payment patterns and your interaction with 5in5, which we use to improve our services and offers. We may use information to present personal offers by post, email, text message or other digital channels.
You may opt out of personal, tailored offers by clicking the link in the digital communication or contacting us directly (see the contact details below).
Consent
Where 5in5 processes your personal data on the basis of your consent or explicit consent—for example, when you authorise us to allow a third party to access your information or provide us with additional information constituting sensitive data—you may withdraw that consent at any time by contacting us. Withdrawing your consent does not result in a reduced version of our services, as we do not need this information to provide our services.
Profiling and automated decision-making
“Profiling” means automated processing of personal data to evaluate certain personal aspects relating to you, for example to analyse and/or predict aspects of your financial situation or preferences, such as purchasing interests. We use profiling based on the personal data we hold to make individual or automated decisions about you for the following purposes:
- To predict which marketing content is of interest to you. You may always object and unsubscribe from marketing communications and this profiling by contacting us. For more information about our processing of personal data for marketing purposes, see section 4 above.
- To determine which offers suit you best.
- To determine the most appropriate way to contact you about outstanding debts.
- Some of our services also use profiling to provide the relevant service to you, for example to provide relevant financial insights or select which offers we can make to you in accordance with the conditions of the relevant service.
Your rights regarding your data
Under Article 13(2)(b) GDPR, everyone has the right to access, rectify or erase their personal data or restrict processing concerning them, as well as the right to object to processing and the right to data portability. You can exercise these rights by contacting us at contact@5in5.nl.
Each request must be accompanied by a copy of a valid identity document bearing your signature and state the address at which you can be contacted. You will receive a response within 1 month of submitting the request. Depending on the complexity and number of requests, this period may be extended by 2 months where necessary.
Cookies
1. A cookie is a small text file placed on your computer’s hard drive when you visit our website. A cookie contains data that enables you to be recognised as a visitor each time you visit our website. This makes it possible to tailor our website to you and facilitate login.
2. We use the following types of cookies on our website:
- Functional cookies, such as session and login cookies, for keeping track of session and login information.
- Anonymised analytics cookies, to gain insight into visits to our website based on visitor numbers, popular pages and topics. This enables us to better tailor communication and information to the needs of visitors to our website. We cannot see who visits our websites or from which computer a visit takes place.
- Non-anonymised analytics cookies, to gain insight into visits to our website based on visitor numbers, popular pages and topics. This enables us to better tailor communication and information to the needs of visitors to our website.
- Tracking cookies, such as advertising cookies intended to display relevant advertisements. Personal interests can be inferred from information about websites visited. This allows organisations to show targeted advertisements to website visitors. Tracking cookies make it possible to create profiles of people and treat them differently. Tracking cookies generally process personal data.
- 3. More specifically, we use the following cookies:
- Google Analytics anonymised (analytics cookies)
- Hotjar anonymised
- 4. When you visit our website, cookies originating from the controller and/or third parties may be installed on your equipment.
- 5. For more information about the use, management and deletion of cookies for each operating-system type, please consult: https://autoriteitpersoonsgegevens.nl/nl/onderwerpen/internet-telefoon-tv-en-post/cookies#faq
Images and products offered
No rights may be derived from images relating to products offered on the website.
Applicable law
These conditions are governed by Dutch law. The court in the place where the administrator has its registered office has exclusive jurisdiction over any disputes concerning these conditions, except where a statutory exception applies.
Contact
For questions, product information or information about the website itself, please contact contact@5in5.nl.
