PRIVACY POLICY

For SCORIA when the Financial Report is requested by an individual.

Effective Date: 01.10.2024.

you directly request a financial health assessment through our SCORIA service, for

example, to prove your solvency to a landlord. In this case, CYGNUS acts as both the

Data Controller and the Data Processor, meaning we are responsible for both deciding

how your personal data is handled and conducting the data processing.

Please read this Privacy Policy carefully to understand how we collect, use, protect,

and disclose your personal information.

1. General Provisions

1.1. Contact Details of CYGNUS as Data Controller and Data Processor

Name: CYGNUS Account Information Service Provider UAB

1.2. Related Legislation

We process personal data in accordance with applicable data protection regulations,

including but not limited to:

 Regulation (EU) 2016/679: General Data Protection Regulation (GDPR);

 Directive (EU) 2015/2366: The Second Payment Services Directive (PSD2);

 Other applicable national and international laws on privacy and data protection.

2. Key Information about CYGNUS’s Data Management

2.1 Purpose of Data Processing

The purpose of data processing is to conduct a solvency assessment based on your

contract. For example, we process your data to generate a financial health assessment

to support your rental application.

2.3 Scope of Personal Data Processed

We process the following personal data:

 Bank Account Information: Transaction history, account balances, outgoing and

incoming cash flows, fraud patterns, and potential solvency issues from the last

90 days or any other period agreed upon.

 Personal Identification Data: Name, bank account number, email, phone

number, address.

 Risk Rating (Score): Based on your financial transactions, a solvency score is

2.5 Transfer of Personal Data

We do not transfer your personal data to third countries or international organizations.

Your data remains within the European Economic Area (EEA), and we ensure it is

protected by strong data privacy measures.

2.6 Automated Decision-Making and Profiling

The SCORIA service uses automated decision-making, including profiling, to evaluate

your financial health. This involves analyzing your banking data using algorithms to

provide a solvency score. This process allows us to assess your financial ability to

meet obligations like paying rent. You have the right to request human intervention or

object to the automated decision-making as described in Section 3.

well as information about how and why your data is being processed.

3.2 Right to Rectification

If your personal data is inaccurate or incomplete, you have the right to request that it

be corrected or completed without undue delay.

3.3 Right to Erasure ("Right to be Forgotten")

You have the right to request the deletion of your personal data under certain

circumstances, including when:

 The data is no longer necessary for the purpose for which it was collected.

 You withdraw consent and no other legal basis for processing exists.

 You object to the processing and there are no overriding legitimate grounds for

the data for legal claims while CYGNUS no longer requires it for processing.

3.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and

machine-readable format, and to transmit those data to another controller where

technically feasible.

3.6 Right to Object

You can object to the processing of your personal data if it is based on legitimate

interest grounds. If CYGNUS cannot demonstrate compelling legitimate reasons that

override your rights and freedoms, we will stop processing your personal data.

3.7 Right to Withdraw Consent

ensure that your personal data is protected against unauthorized access, alteration,

disclosure, or destruction. These measures include:

 Encryption: All data is encrypted both in transit and at rest.

 Access Controls: Strict access controls are in place to ensure that only

authorized personnel have access to your data.

 Audits: Regular security audits and monitoring are conducted to maintain

compliance with industry standards.

5. Automated Decision-Making and Profiling

When you use the SCORIA service, automated decision-making and profiling are

applied to assess your solvency. This means that your bank account information (e.g.,

 Express your views on the outcome of the automated decision.

 Object to the automated decision if it significantly affects you.

6. Changes to the Privacy Policy

CYGNUS reserves the right to update this Privacy Policy from time to time to reflect

changes in our data processing practices or legal requirements. When we make

changes, we will notify you through our website or by direct communication.

7. Contact Information

If you have any questions or concerns regarding this Privacy Policy or your personal

By using the SCORIA service, you acknowledge that you have read and understood

this Privacy Policy and agree to the processing of your personal data in accordance

with it.---------------------------------------------------------------------------------------------------------