Public offer

SIA “LeadProm Media”

Consent

I hereby express my consent and authorize SIA “LeadProm Media” to collect, store and process my personal data, namely:

First name, last name

Mobile phone number

E-mail address

Residence address

I give my consent for the following purposes:

o Maintaining contact with me

o Mailing correspondence to the address provided by me 

o Communication on the specified phones

o Sending SMS to the specified mobile phone number

o Sending messages to the specified e-mail address: in order to transmit information about new services, update and confirm requests, clear applications and verify information received

I hereby confirm the following:

o Personal data were provided on an informed and voluntary basis;

o The data provided in the questionnaires are true and correct;

o This consent is given for five (5) years with an option of unilateral withdrawal at any time by sending an electronic message to the following e-mail address: support@creditron.org.


PUBLIC OFFER

(Agreement)

for the provision of information services through the use of the Service

1. General Provisions

1.1. This public offer (the “Offer”) for the provision of information services is a public offer provided by SIA “LeadProm Media” (hereinafter – the “Operator”) which determines the terms and conditions of using the website https://creditron.org/ and the provision of the Operator`s Services to the Customer (hereinafter - the “User”) (hereinafter – the “Agreement”).

1.2. The Operator and the User, separately, may sometimes be referred to as the “Party” and jointly as the “Parties” in the following agreement.

1.3. This Offer is addressed to legally capable persons being the Users of the website https://creditron.org/. The Offer is an official public offer made by SIA “LeadProm Media” with the purpose of entering into the Agreement.

1.4. The current version of the Offer is available on the Operator`s Website at: https://creditron.org/ so that the User can read it carefully and with due diligence before accepting the terms and conditions of the Offer. The Tariff and Refund Policy as well as the Privacy Policy are available on the Operator’s Website and shall constitute integral documents of this Agreement. 

1.5. This Agreement shall be deemed concluded and effective from the date when the User performs the actions set forth in Clause 3.2 of the Agreement, which means complete and unconditional acceptance by the User of all terms and conditions hereof without any exceptions and / or restrictions.

1.6. Either Party represents and warrants that it has required legal capacity and all rights and powers necessary and sufficient to enter into and perform the Agreement in accordance with the terms and conditions hereof.

2. Terms and definitions used in the Agreement

In this Agreement, the terms below have the following meanings:

Authorization Data shall mean data enabling Authentication of the user. By default, the login and password created by the User constitute the User’s Authorization data. 

Authentication shall mean confirmation of the User’s legal capacity to conduct transactions through the use of the Service and / or to obtain information on transactions through the use of the Service in accordance with the procedure established by this Agreement. To conduct a transaction through the use of the Service, the User must authenticate using the Operator`s software based on the Authorization Data entered by the User.

Privacy Policy - shall constitute a policy that regulates the processing and storage of personal and/or any other data of the User and the Operator throughout the performance of this Agreement. 

Tariff and Refund Policy shall constitute a policy that regulates the payment method, prices and refund policy and any other data related to the matter of payment by the User for the Operator’s Services. The Tariff and Refund Policy for each type of Services and any other payment information shall be determined, specified and regularly updated by the Operator at the Operator’s Website at the following link:

Request shall mean an electronic document created by the User, with indication of Information to be used by the Service.

Information shall mean data on the preferred characteristics of the loan provided by the User and used by the Operator to prepare the Report, as well as data of the User, including his/her Personal Data.

Lender shall mean a separate (from the Operator) legal entity engaged in microfinance activities which grants a loan to the User on the terms established by the Loan Agreement.

Operator shall mean SIA “LeadProm Media”, which provides the Service to the Users and performs other actions related to the use of the Service.

Report shall mean an electronic document generated by the Operator based on the Request, which contains a list of available offers made by the Lenders providing lending facilities in the region specified by the User, and in accordance with the parameters selected by the latter, based on which the list for the User is created and placed in the user’s Personal Account in the Recommended Offers section. At the discretion of the Operator, it can be supplemented with other offers which, in the Operator’s opinion, may also be of interest to the User.

Right to block the User shall mean the unilateral right of the Operator to block the User from the use of Services in the manner provided by article 5.15. of this Agreement and the Tariff Policy.

User shall mean an individual having his/her own user account and affecting access to the Website, who has completed the registration procedure and received personal Authorization Data.

User form shall mean a page on the Operator’s Website where the User shall enter all relevant registration information before gaining access to the Website in accordance with this Agreement and the Privacy Policy hereto.

Operator’s website (Website) shall mean the Operator’s information resource in the information and telecommunication global network (hereinafter –  the Internet) located at: https://creditron.org/, through which the User can use the Operator’s Service.

Service (Services) shall mean the Operator’s following actions:

the provision of access to an informational service (the Operator’s Website) which contains information on loans and credits available to the User in accordance with the User’s Request and the available Lender organizations;

access to the Operator’s technological system available on the Operator’s Website, which enables to create and submit the User Requests for consideration by the Lenders for obtaining a loan by the User;

actions performed by the Operator, including the collection and processing of Information from the Request of the User, aimed at processing the Request and providing the User with information on the Lenders’ offers that meet the requirements specified by the User when using the Service, as well as the provision of the User Requests to the Lenders in order to issue a loan or credit to the User;

Information service shall mean the Operator’s division, which, at the request of the User, provides the latter with information on the use of the Service (by e-mail with the involvement of the Operator’s employee or by any other means available to the Operator).

Tariffs (Tariff and Refund Policy) shall mean the types and methods of payment as well as prices for each type of Services payable to the Operator by the User. 

Services Delivery Certificate shall mean a document generated by the Operator and sent to the User’s email after every provision of Services to the User.

Period of Service Provision (Periods) shall mean a time period throughout which Services are provided by the Operator to the User. The types of such Periods are determined at the Operator’s website at the following link: https://creditron.org/en/tariff

3. Scope of the Agreement

3.1. This Agreement shall establish the conditions and procedure for the provision of Operator Services to the User.

3.2. Acceptance of the terms and conditions of this Agreement at the time of registration shall mean the User’s full and unconditional consent to the terms and conditions hereof.

3.3. The User shall pay for the Operator Services in accordance with Clause 6 of this Agreement and Tariff and Refund Policy available at the Operator’s Website.

4. Legal Framework

4.1. By using Operator`s Services the User gives its consent to receive the information required for Operator`s Services from the respective data base of its partners in accordance with legislation requirements, and the provisions of the GDPR within the framework of contractual cooperation, subject to the consent of the User.

4.2. The legitimate interest bases on provisions of legislation under which banks, credit institutions, non-bank financial institutions, electronic money institutions, payment institutions has the right to receive such information to credit risk assessment, credit health analysis, or in order to achieve a legitimate interest of the User or of the third party to whom the data is disclosed, provided that this interest is not prejudicial to the interests or fundamental rights and freedoms of the person concerned. Also, legitimate interest comes from the need of carrying out responsible crediting activity by complying with the laws on data protection, assessment of credit health, and managing credit risk. Such Services enable interested persons to evaluate their own credit health, by giving the Operator their consent to process their personal data and making a request for such on the provision of the Services, and also to get an offer from the potential Lenders. The Services enable the potential Lenders to evaluate the credit risks of lending to the relevant User and make a business decision on such information, which is a pivotal part of the process under the applicable laws of lending.

4.3. The Operator does not form the User's credit background and is not responsible or liable to Users for a potential Lender's decision based on the assessment of the User's credit health..

4.4. By using Operator`s Services the User gives its consent to receive the information required for Operator`s Services from the respective data base in accordance with the legislation  on the protection of individuals with regard to the processing of personal data - to achieve a legitimate interest of the User or third party to whom the data are disclosed and agrees that this interest is not prejudicial to the interests or fundamental rights and freedoms of the User concerned under the applicable provisions of legislation. 

4.5. Private data processing is made with a high degree of security, in compliance with the GDPR, and with a high degree of privacy – the information is not public and is available only to the Operator, User and potential Lender if the User makes a request and gives a consent.

4.6. All the matters regarding Your Private Data are governed by Our Privacy Policy and You are giving Your consent to the collection of such information by using the Site; therefore, We recommend You, and You should ensure that You have read the Privacy Policy provisions carefully.

5. Procedure and conditions for the provision of the Service

5.1. Registration on the Website.

5.1.1. To gain access to the Service, the User shall accept the terms and conditions of this Agreement when completing the User Form on the Website. The User’s consent to the terms and conditions of this Agreement at the time of entering his/her data on the Website shall mean the acceptance hereof by the User.

5.1.2. The User shall complete the User Form on the Website by entering the relevant registration information. When entering the data on the Website, the User shall enter his/her full name, date of birth, place of residence, phone number, email address and password.

5.1.3. The User shall provide true, complete and reliable information and keep it up to date. The User shall provide his/her personal data in accordance with Clause 7 hereof and Privacy Policy hereto. 

5.1.4. The User agrees that he/she is solely responsible for maintaining the confidentiality of authorization data used by him/her to access the Website. In addition, the User agrees that he/she is solely responsible to the Operator for all actions performed when entering his/her personal data.

5.1.5. If the User becomes aware of any unauthorized use of his/her Authorization Data, he/she shall immediately notify the Operator thereof by contacting the support service by e-mail: support@creditron.org

5.2. During registration on the Website, the User shall not disclose (or, in the case of disclosure, shall be solely and fully responsible) his/her last names, first names, phone numbers, email addresses and other personal data or data of any third parties without their personal consent to such actions, expressly provided by completing the User’s form.

5.2.1. In order to use the Services provided by the Operator under this Agreement, the User shall always follow the Request submission procedure established hereby.

5.2.2. To submit the Request, the User shall provide the Information in accordance with the requirements and give consent by checking the appropriate CoF (Credential on File) box when you place an order for the Services. If you check the appropriate box, you irrevocably and unconditionally agree that we are entitled to process your personal data in accordance with your Consent, as well as the other provisions of the CoF (Credential on File). Please read its provisions before ordering Services.

5.2.3. When creating the Request, the User shall choose the characteristics of the desired loan, namely: the amount, the loan term, his/her name, surname, place of residence and other data required by the Lenders to make a decision.

5.2.4. The Request submission procedure shall be conducted from the User’s Personal Account after the payment transaction carried out by the User for the provision of Services. The User shall pay for the Services under this Agreement in the amount and in the manner specified in Clause 7 hereof.

5.2.5. Upon receipt of the Request, the Operator shall send the Request to potential Lenders for consideration (from the list of Lenders posted on the Website). 

5.2.6. The obligations of the Operator under this Agreement shall be limited to the provision of Services for analysis and selection of Lenders’ financial products (offers). If the Lender provides a loan or credit to the User, the Operator shall not be a party to the agreement concluded between the User and the Lender, and therefore, the Operator shall not regulate or control the compliance of the transaction with applicable laws and standards, the terms of the transaction, as well as the acts and consequences of conclusion, performance or termination of the agreement, including regarding the repayment of the loan, and the Operator shall not consider the User’s claims regarding non-fulfilment (improper fulfilment) of the obligations by the Lender under such agreements.

5.2.7. The Operator shall not guarantee the provision of a loan or credit by the Lenders when the User forms the Request, but shall only select the lending options (offers) and send the Request to potential Lenders for consideration. It is the Lender who makes the decision to grant a loan. Data on the Lenders’ financial products (offers) provided by the Operator in the Report to the User shall not constitute an offer for guaranteed provision of financial  services. 

5.2.8. The Operator shall provide services to the User on a round-the-clock basis. The Operator’s actions for the performance of this Agreement that are not performed automatically shall be carried out on weekdays.

6. Rights and obligations of the parties

6.1. Rights and obligations of the Operator:

6.1.1. The Operator shall provide to the User round-the-clock access to the Website.

6.1.2. The Operator shall have the right to check and pre-moderate the Information disclosed by the User.

6.1.3. The Operator shall consider all the Requests and submit relevant Reports, provided that the User has read and understood the terms and conditions of this Agreement and duly completed the Request.

6.1.4. The Operator shall notify the Users of any changes in the terms and conditions of this Agreement by publishing the latest version hereof on the Website.

6.1.5. The Operator shall have the Right to block the User if the latter fails to perform the full payment of Services in accordance with the provisions of this Agreement.

6.1.6. The Operator may suspend the operation of the Website and / or the Service, as well as hardware and software that ensure interaction between the Parties under this Agreement, in the event of any significant malfunctions, errors or failures, and for the purpose of preventive maintenance and prevention of unauthorized access.

6.1.7. The Operator may limit the User’s requested loan amount to form the Request of Users. Specific limitations under this clause will be displayed on the Website.

6.1.8. The Operator shall have the right to display in the User’s Personal Account other options for loans and credits that fail to meet his/her initially specified requirements as to the amount, the term and other parameters, in order to provide more information on possible loan products.

6.2. Rights and obligations of the User:

6.2.1. The User agrees to comply with the rules of this Agreement.

6.2.2. The User shall further provide reliable information when registering on the Website.

6.2.3. The User shall not reproduce, duplicate, copy, sell or resell, or use any services or parts of the Service for any commercial purposes without the Operator’s written consent.

6.2.4. The User shall obtain access to the Website using his/her Authorization Data only from one device at a time.

6.2.5. The User shall not give access to his account to any third party.

6.2.6. The User shall independently and in a timely manner familiarize himself(herself) with the Information regarding change in Tariffs and the terms and conditions of this Agreement posted on the Website.

6.2.7. The User shall pay for the Services in accordance with the Tariffs, within the time limit and under the terms established by the Operator. The Tariffs for each type of Services shall be determined, specified and regularly updated by the Operator at the Operator’s website at the following link:

6.2.8. The User shall have the right to submit claims to the Operator and shall send requests in the manner and in cases as stipulated by this Agreement.

6.2.9. The User shall have the right to terminate this Agreement at the relevant web-page at the Operator’s website. In case of such termination the User shall lose all access and use the Operator’s website as well as the Operator’ Services without any refund to such User. 

7. Value of services and payment procedure

7.1. The Operator shall set the value of the Operator`s Services in Tariffs published on the Website.

7.2. The Operator shall have the right to unilaterally change fully or partially (that is, increase or decrease), establish new Tariffs and / or cancel existing ones. If the User does not agree with the change (entry into force) of new Tariffs, he may unilaterally repudiate this Agreement.

7.3. The Operator shall provide all services on the basis of 100% prepayment. The User shall make 100% payment in advance, during registration on the Service.

7.4. The User shall pay for the Operator`s Services using a bank card through the Website (or through any other means previously agreed with the Operator, including the use of online technologies that are not contrary to the law).

7.5. After the provision of Services the Operator shall provide a Services Delivery Certificate that shall be generated or signed at the discretion of the Operator and sent to the User via e-mail that is specified in the User Form and Authorization Data . The Services shall be deemed to be properly provided and fully accepted by the User unless the Operator has received from the User written reasonable objections to the quality of the Services provided within one calendar day upon the expiration of the service provision period by e-mail: support@leadprom.com. If during the specified period there are no written objections, the Services shall be deemed to be of proper quality.

7.6. In case of termination of this Agreement by the User, such User shall not receive any refund for the remaining unused Period of Service Provision. 

7.7. By entering into this Agreement the User gives his/her full express consent and acknowledgement that there shall be no withdrawal period or refund policy rules, except the ones that are stipulated in the Tariff and Refund Policy available at the Operator’s Website. The User expresses his/her consent that he will lose his right of withdrawal once the Operator’s Services have been provided to the User.

8. Personal data

8.1. By placing personal data and any other data on the Website, the User confirms that he/she has read, understood and agreed with the Privacy Policy of SIA “LeadProm Media” available on the Website, and that he/she has provided to the Operator his/her consent to personal data processing in order to perform this Agreement.

8.2. The purpose of processing the User’s personal data shall be provision of services to the User, enabling the User to use the Service, participate in advertising campaigns, target advertising and perform other actions described in the Agreement.

8.3. The User’s personal data shall be processed from the moment the User registers on the Website, or order the Services until the Consent to personal data processing is withdrawn.

8.4. The User agrees that the Operator shall send information on advertising campaigns conducted by the Operator and/or its partners (including Lenders), and any other information not prohibited for distribution, to the email address specified by the User.

8.5. The User understands that in order to perform the Services specified herein, the Operator shall receive personal information specified in our Privacy Policy, including the credit health rate of the User either from the User, other public registers, from Central credit register (if such are) directly from Lenders, or Operator's partners authorized by User consent to process such data.

9. Intellectual property

9.1. The website and all of its components are the sole property of Operator.

9.2. The Operator also retains all rights to confidential information, including commercial and marketing strategies, technological know-how, plans and designs for new products, business practices disclosed by each party, and the content of interactions between the parties.

9.3. The User shall be forbidden to dismantle Services, reverse-engineer it, or engineer it to create competitive services; create a product or services based on ideas, traits, abilities, or designs from the Operator’s website or Services; use without authorization any concepts, features, capabilities, or pictures from Services or website; to take any other action which can infringe the Operator’s intellectual property rights.

9.4. Except for the limited rights expressly granted in this Agreement, the Operator retains all rights, titles, and interests in and to the Services, including all related intellectual property rights. Further, than those expressly granted, the User has no other rights under this Agreement.

9.5. The Operator shall be entitled to utilize and incorporate into its services any recommendations, corrections, suggestions, or other feedback regarding Services by the User.

10. Liability of the Parties

10.1. The Parties shall be liable hereunder for failure to fulfil or improper fulfilment of the provisions hereof.

10.2. The Operator shall moderate the Information placed by the User, however, it is not responsible for the consequences of non-compliance by the User with the requirements set forth in paragraphs 5.1.3-5.1.6 hereof.

10.3. The User agrees that the Services provided by the Operator may be protected intellectual property.

10.4. Text content (articles, publications available on the Website) may be distributed if there is an active link to the Website.

10.5. The Operator shall not be liable for any direct or indirect losses of the User caused by failure to use the Website or some Services of the Website as a result of the User’s bad internet connection, technical difficulties or any other reason whatsoever unrelated to the ability of the Operator to perform duties under such agreement. The Operator shall not be liable for any loss suffered by the User in connection with the use of the Operator’s Services provided under the present Agreement unless such loss arises from bad faith, willful default or fraud on the part of the Operator. 

10.6. The Operator shall not be liable for any acts or omission of the Lenders that provided the loan, as well as for any information or data regarding the provision of the loan disclosed by the Lender. The Lenders shall make a decision to grant a loan, the Operator shall not guarantee granting loans or credits, but shall only select to the User the most suitable loan options.

10.7. The Operator shall not be liable for the achievement of any results by using the information disclosed to the User in the Report. The User agrees to use any information on the Lenders’ offers provided by the Operator, at his/her own peril and risk.

10.8. The Operator shall not be liable for the inconsistency of the Service with the User’s expectations and / or his/her perception; such inconsistency with expectations and / or negative perceptions shall not constitute grounds for considering the Services to be of poor or insufficient quality.

10.9. The Services provided “AS IS” and the Operator shall not be liable for the inconsistency of the Service with the User’s expectations and/or his/her perception; such inconsistency with expectations and/or negative perceptions shall not constitute grounds for considering the Services to be of poor or insufficient quality.

10.10. The Operator's liability, including but not limited to the User`s claims of contributions and indemnification related to third party claims arising out of the Services rendered by the Operator, and for any losses, injury or damages, shall be limited to the last payment received by the Operator from the User for the particular Services provided giving rise to the claim. Notwithstanding anything to the contrary in this Public Offer, the Operator shall not be liable for any special, indirect, consequential, lost profits, or punitive damages. The User agrees to limit the Operator’s liability to the User and the Operator shall not be liable for any Lender actions, any damage on account of any error, omission or negligence. 

10.11. The User explicitly agrees that the Operator does not form the User's credit history and is not responsible or liable to the Users for the potential Lender's decision based on the assessment of the User's credit health.

11. Force majeure circumstances 

11.1. The Parties shall not be held liable for any delays in the performance or for nonperformance of their obligations under the present Regulations if the delay or non-performance was due to circumstances or reasons beyond the control of the Parties, such as a war (including civil war), riots, sabotage, embargo, fires, floods or other acts of God, explosions, actions or omissions of government authorities, strikes. All and any of these circumstances shall be regarded as force majeure circumstances. Within 24 (twenty-four) hours upon receipt of information about commencement of any force majeure circumstances which delay or interfere otherwise with the performance of the Regulations, the Parties shall notify each other in writing.

11.2. The Parties shall not be held liable for any damages, losses, claims or other expenses that may be incurred as a result of force majeure circumstances.

11.3. If force majeure circumstances interrupt or make impossible the performance of obligations of the Parties for a period longer than 30 days either Party may terminate this Agreement serving a prior written notice of termination on the other Party.

11.4. In the event that the Operator determines in its reasonable opinion that a Force Majeure Event exists, the Operator shall be entitled without notice and at any time take one or more of the following steps:

(a) suspend or modify application of any or all of these Provisions of the present Agreement to the extent that the Force Majeure Event makes it impossible or impractical for the Operator to comply with these clauses; or

(b) take any other actions as the Operator may consider to be reasonable under the circumstances in relation to the position of the Operator, the User and the Operator’s other Users.

12. Dispute settlement procedure

12.1. All disputes and disagreements that arise or may arise out of this Agreement at the User’s initiative shall be settled on an out-of-court basis.

12.2. In case of a dispute and/or disagreement that may arise out of this Agreement the Parties within 10 (ten) working days shall send each other written complaints at the following addresses: 

12.2.1. If the written complaint is addressed to the Operator - the legal address of the Operator

12.2.2. If the written complaint is addressed to the User - the email stipulated by the User in his/her Personal Data and/or User Form. 

12.3. If the parties have not been able to resolve the dispute within ten working days of receipt of the written complaint, the parties shall refer the dispute to the relevant judicial authority.

13.  Governing Law

13.1. This Agreement will be construed in accordance with and governed by the laws of Latvia.

13.2. For all matters not covered in this Agreement, Parties shall be governed by the laws of Latvia.

14. Miscellaneous

14.1. Electronic Communications. The Operator shall send information relating to the User’s account (e.g. payment authorizations, invoices, changes in password or Payment Method, confirmation messages, notices) in electronic form, for example via emails to your email address provided during registration in User’s Form/Authorization Data. 

14.2. Survival. If any provision or provisions of this Agreement shall be held to be invalid, illegal, or unenforceable, the validity, legality and enforceability of the remaining provisions shall remain in full force and effect.