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Privacy Notice

Dedicated privacy notice for the Jinius Dealers Portal

1. Who We Are and What This Notice Covers  

Jinius Ltd (“Jinius”, “we”, “us”) operates the Jinius Dealers Portal, through which authorised vehicle dealers (“Dealers”) may present customers with indicative and/or personalised financing options offered by Bank of Cyprus (“BoC”).

This Privacy Notice explains:

  • which personal data are collected through the Dealers Portal,
  • for which purposes,
  • with whom the data are shared,
  • for how long they are retained,
  • the rights available to the customer.

This Notice supplements the general Jinius Privacy Statement and applies exclusively to the Dealers Portal.

2. Roles and Responsibilities (GDPR Controller / Processor Structure)

  • The Dealer acts as the Data Controller for the personal data collected directly from the customer for submission through the Portal.
  • Jinius acts as a Data Processor on behalf of the Dealer by providing the technological platform.
  • Bank of Cyprus acts as an independent Data Controller with respect to the data it receives for financing assessment purposes.

3. Data We Collect

The following categories of data may be collected through the Dealers Portal:

(a) Contact Details

Full name, telephone number.

(b) Financial and Transactional Data

Basic financial information required for generating an indicative financing offer.

(c) Vehicle Data

Vehicle technical specifications, pricing information.

(d) Technical and Operational Data

Device information, logs, and metadata for security and monitoring purposes.

(e) Information Entered by the Dealer during the process

Such data are transmitted to Bank of Cyprus upon voluntary scanning of the relevant QR code generated upon completion of the indicative financing offer.

4. Purposes of Processing

The data are processed solely for the following purposes:

  1. Presenting an indicative financing proposal to the customer.
  2. Submitting a financing request to Bank of Cyprus.
  3. Enabling BoC to conduct AML/KYC and other compliance checks.
  4. Pursuing the legitimate interests of Jinius and the Dealer in providing the Dealers Portal service.
  5. Relying on the customer’s consent for any marketing-related or optional processing activities.
  6. Ensuring quality assurance, logging, and operational monitoring of the Portal.

No marketing activities are conducted unless the customer provides separate and explicit consent.

5. Legal Bases for Processing

Depending on the data flow, the applicable legal bases may include:

  • Performance of a contract (indicative or personalised financing proposal).
  • Legal obligation (AML/KYC and anti-money laundering legislation).
  • Legitimate interests (system security, fraud prevention, monitoring).
  • Customer consent, where required, including the use of electronic communication means.

6. Automated Decision-Making & Profiling

For financing assessment purposes, BoC may use:

  • creditworthiness evaluation tools,
  • risk-scoring mechanisms,
  • AML risk assessments,
  • technical fraud prevention checks.

Customers have the right to:

  • request human intervention,
  • express their views,
  • contest any automated decision.

7. Data Sharing

Data may be shared with:

  • Bank of Cyprus, as an independent Data Controller,
  • the authorised Dealer,
  • hosting, cloud, and security service providers,

No transfers to third countries outside the EU occur unless valid legal safeguards are in place.

8.Transfers to Bank of Cyprus

Data entered in the Dealers Portal are transmitted to Bank of Cyprus solely for financing assessment purposes. BoC processes these data independently, in accordance with its own privacy statement and applicable regulatory framework.

9. Data Retention

  • Indicative offer data: retained for up to 30 days.
  • Personalised offer/application data: retained for up to 90 days.
  • AML/KYC data: retained for 5+ years in line with legal requirements.
  • Operational logs: retained in accordance with the Jinius Retention Policy.

Where legally necessary, data may be retained for longer periods.

Upon expiry of the relevant retention periods, data are deleted or anonymised.

10. Data Subject Rights

Customers have the right to:

  • access,
  • rectification,
  • erasure,
  • data portability,
  • restriction of processing,
  • objection,
  • withdrawal of consent.

Requests may be submitted to:

  • the Dealer (as primary Data Controller)  ,
  • Jinius (for Portal-related processing),
  • Bank of Cyprus (for financing related processing), depending on the allocation of roles.

11. Contact for Privacy Matters

For any request or query regarding this Notice:

  • Dealer: primary Data Controller,
  • Jinius DPO: privacy@jinius.com.cy ,
  • BoC DPO: as per the BoC privacy statement.