CaixaBank and the CaixaBank Group companies listed below are joint data controllers for the analysis of the solvency and ability to repay of applicants and/or holders of products involving financing.
- CaixaBank, S.A.
- CaixaBank Payments & Consumer, E.F.C., E.P., S.A.U.
- Nuevo Micro Bank, S.A.U.
- Telefónica Consumer Finance, E.F.C., S.A.
- CaixaBank Equipment Finance, S.A.U.
- Unión de Crédito para la Financiación Mobiliaria e Inmobiliaria, CREDIFIMO, E.F.C., S.A.U.
- Corporación Hipotecaria Mutual, S.A.U., Establecimiento Financiero de Crédito
- Hipotecaixa 2, S.L.U
- Banco BPI, S.A.
- Wivai Select Place S.A.U.
In accordance with the provisions of the applicable regulations, the Joint Controllers have signed a joint controller agreement for certain processing activities, the essential elements on the following principles:
(ii) All suitable technical and organisational measures have been determined to ensure a level of security that corresponds with the risk inherent to processing the personal data subject to joint processing.
(iii) There is a single point of contact for data subjects to exercise their rights, assuming the duty of cooperation and assistance where appropriate.
(iv) They comply with the duty of secrecy and the requirement to keep confidential personal data which is processed through informed data processing activities.
(v) Regardless of the terms of the joint controller agreement, the data subjects can exercise their data protection rights by contacting any of the joint controllers.
The legal basis of this data processing is that it is necessary to manage contracts you request or for which you are a party, or to apply precontractual measures if you request them, as established in art. 6.1.b) of the General Data Protection Regulation (GDPR).
Therefore, the processing is necessary for you to establish and maintain Contractual Relations with us. If you object to it, we will end these relations, or we cannot establish them if they have not yet started.
Below we provide a description of the purpose (Purpose), the type of processed data (Type of processed data), if applicable, information on the use of profiles (Use of profiles), other relevant processing information (Other relevant information).
Purpose: The purpose of this data processing is to assess whether applicants and/or holders for products or services that involve the repayment of loans or credits, or deferred instalments, have the solvency and repayment capacity needed to make the scheduled payments in the operations that are analysed and/or have been granted.
Detailed information on the solvency and repayment capacity analysis process that will be carried out when you apply for or have already been granted transactions involving the repayment of loans or credits, or the deferred payment of instalments, will be provided in the transaction request you will be required to sign when you apply for these products.
The processing activities carried out to analyse the solvency or ability to repay of applicants and/or holders of products involving financing are:
- Analysis of the repayment capacity of applicants at the time of granting new credit operations.
- Analysis of the solvency of the holders of products involving financing throughout the life of the credit operations maintained with us to manage internal risks and prevent payment defaults.
Types of data processed: The types of data we will process for this purpose (the content of which is detailed in heading 5) are:
- Identification and contact details
- Details of your professional or work activity and socio-economic information
- Contract details
- Basic financial data
- Third-party data from statements and receipts of instant accounts and payment accounts
- Data obtained from the execution of statistical models
- Risk assessment data or scoring
- Data on credit information systems
- Details of Equifax Risk Score
- CIRBE details
- Demographic and socio-economic data
- Details of properties and vehicles associated with you
- Information obtained from public access sources and public records
Use of profiling: For this processing, we will create a risk profile that will be used exclusively to analyse the solvency and repayment capacity of applicants and/or holders of products involving financing.
- Purpose: The purpose of the profile is to determine the probability of default when granting transactions, assess the need to adjust the risk of current transactions and calculate the provisions and capital requirements applicable to CaixaBank.
- Consequences: Risk profiles are tools used to support decisions on whether to grant risk transactions or adjust the limits of existing transactions.
Transactions requested through electronic channels may involve automated decisions on whether to grant the transaction, as detailed in the section "Other relevant information".
- Logic: The applicant's profile will use the information indicated in the "Type of processed data" section above.
This basic information is used to assign a specific value to each piece of data on the applicant, the sum of which produces a score indicating the probability of default or non-compliance with monetary obligations.
The importance of each variable and its influence on the final result is calculated in advance using mathematical models and is included in the institution's internal risk policies.
Other relevant information: The following section includes other relevant data processing information:
- Automated decisions: We will use automated processes to analyse solvency and repayment capacity for applications submitted through electronic channels to check whether the financing is suitable for your needs, depending on your characteristics and the information you have provided.
If the requested financing is deemed unsuitable for your repayment capacity according to the profile calculations employed, you will not be able to contract the product, and your application will be rejected automatically in this channel.
You may resubmit an application for the transaction at one of our branches, where the analysis does not include automated decisions, challenge the automated decision or exercise your right not to be subject to a decision based solely on automated processing by contacting CaixaBank directly through the channels set out in section 4 of this policy.
- Regulatory obligations: In addition to these processing operations being required to perform the contractual relationship between you and us, this processing is carried out in accordance with the provisions of Law 44/2002, on Financial System Reform Measures, Law 10/2014, of 26 June, on the regulation, supervision and solvency of credit institutions, and other obligations and standards set out in regulations on responsible lending, to which we adhere as a credit institution.
- Credit information system enquiries: The credit information systems enquiries required for solvency analysis will be carried out based on our legitimate interest, as detailed in section 6.4.D.
- CIRBE enquiry and communication: The CIRBE enquiries required for solvency analysis are carried out in accordance with the provisions of Law 44/2002, of 22 November, on Financial System Reform Measures. Furthermore, the data necessary to identify the persons with whom credit risks are maintained will be communicated, based on the same standard.