Privacy Policy

SmartCreditPlus, S.L. (hereinafter, "SmartCreditPlus" or the "Controller"), considers the privacy and protection of the personal data of the users of its website, and of all those who interact with the company in the context of the provision of its services, to be of fundamental importance.

SmartCreditPlus processes personal data in accordance with the data protection legislation in force, in particular:

• Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR).
• Organic Law 3/2018, on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).
• Law 34/2002, on Information Society Services and Electronic Commerce (LSSI-CE).

1. Who is the data controller?

SmartCreditPlus is not currently under a legal obligation to appoint a Data Protection Officer (DPO). However, you may get in touch regarding any data protection matter through the email address provided above.

2. When do we collect your data?

This website is informational in nature and may collect personal data on the following occasions:

a) Contact form or sending an email

When the user completes a contact form or sends an email, identification and contact details are requested in order to respond to their query or request.

b) Registration as a user on the platform

In the event of registration on the SmartCreditPlus platform, the data necessary for the creation of an account, identification and the provision of mortgage brokerage services is collected.

c) Mortgage assessment request or financial services

In the context of the provision of financial and mortgage brokerage services, identification, economic, employment and financial data may be processed and, where applicable, data relating to financial standing and creditworthiness necessary to assess financing transactions.

d) Cookies

Through technical and analytical cookies in accordance with the provisions of the Cookies Policy.

3. For what purpose do we process your data?

The personal data provided will be processed for the following purposes:

• To respond to queries or requests made through the contact form or by email.
• To manage the registration of users on the platform.
• To provide brokerage services in the granting of mortgage loans.
• To carry out financial viability assessments.
• To disclose your data to partner financial institutions for the purpose of assessing the granting of financing.
• To comply with applicable legal obligations.
• To ensure the proper technical functioning of the website.
• To send commercial communications about our own services, where express consent exists.

4. What is the legal basis for the processing?

The legal bases that legitimise the processing are:

• The consent of the data subject.
• The performance of a contract or the application of pre-contractual measures.
• Compliance with legal obligations.
• The legitimate interest of the Controller, where applicable.

5. For how long do we keep your data?

Personal data will be retained:

• For as long as the contractual or pre-contractual relationship is maintained.
• For the periods legally required by tax, commercial or financial regulations.
• For the time necessary for the formulation, exercise or defence of claims.
• In the case of commercial communications, until the user withdraws their consent.

6. To whom do we disclose your data?

The following may access your data:

• Authorised SmartCreditPlus personnel.
• Financial institutions and lenders with whom a partnership agreement exists, where necessary for the provision of the requested service.
• Public bodies, regulatory authorities and financial supervisors where legally required.
• Technology service providers acting as data processors (for example, web hosting, management tools, CRM, etc.), under a contract in accordance with Article 28 of the GDPR.

In the event of international transfers of data outside the European Economic Area, it will be ensured that they are carried out with the appropriate legal safeguards (Standard Contractual Clauses or other valid mechanisms in accordance with the GDPR).

SmartCreditPlus does not sell personal data to third parties.

7. What are your rights?

The user may exercise the following rights:

• Access to their personal data.
• Rectification of inaccurate data.
• Erasure of their data.
• Restriction of processing.
• Objection to processing.
• Data portability.
• Not to be subject to decisions based solely on automated processing.

You may exercise these rights by sending a written request together with a copy of an identification document to:

You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) (www.aepd.es).

8. How do we protect your data?

SmartCreditPlus applies appropriate technical and organisational measures to ensure the security of personal data, including:

• Encryption of communications.
• Access control.
• Internal security policies.
• Contracts with data processors.
• Periodic risk assessments.

However, the user should be aware that security measures on the Internet are not absolutely infallible.

9. Confidentiality

SmartCreditPlus staff and partners are subject to a duty of confidentiality with respect to the information to which they have access in the performance of their duties.

10. Third-party links

The website may contain links to third-party pages. SmartCreditPlus is not responsible for their privacy policies or their data processing practices.

11. Amendments

SmartCreditPlus reserves the right to amend this Privacy Policy in order to adapt it to regulatory or case-law changes. In the event of substantial amendments, users will be informed appropriately.