Retention of Personal Data Related to Apuraha and Tili Payment Methods
If you made purchases using the Apuraha or Tili payment method before September 3, 2025, when Verkkokauppa.com acted as the credit provider, we retain personal data related to granting and managing financing to fulfill our legal obligations. Starting September 3, 2025, Tili and Apuraha credits are granted and managed by Walley, which is part of Norion Bank AB. You can review Walley's privacy policy here (Ulkoinen palvelu) (Avautuu uuteen välilehteen).
We no longer offer Apuraha or Tili credit, and the data is not used for making new credit decisions. The processing of personal data is based on compliance with legal obligations (GDPR Article 6(1)(c)) and, where necessary, the controller's legitimate interest in establishing, exercising, or defending legal claims (GDPR Article 6(1)(f)). The data is not used for other processing purposes. Retained data will be deleted or anonymized as the statutory or otherwise justified retention period expires.
The categories of personal data retained and retention periods are described below:
| Categories of Personal Data | Retention Period | Legal Basis |
|---|---|---|
| Customer identification and know-your-customer data (KYC) e.g., name, date of birth or personal identity code, address, PEP data, beneficial owner information (UBO), identification source data | 5 years from the end of the credit relationship related to Apuraha or Tili. | Anti-Money Laundering Act (444/2017) Section 3:3.1Consumer Protection Act (38/1978) Sections 6:12c and 7:14–16 |
| Data related to credit applications and credit decisions e.g., application data, contact information, loan amount, loan periods, credit decision, scoring, credit limit, income data, credit rating, payment default information, data obtained from credit information registers | 6 years from the end of the year in which the financial year ended.For approved credit applications, 5 years from when the credit has fully matured. | Consumer Protection Act (38/1978) Sections 7:14 and 7:15–16Act on the Limitation of Debt (728/2003) Section 4Accounting Act (1336/1997) Section 2:10Code of Judicial Procedure (4/1734) Section 17:2Non-Discrimination Act (1325/2014) Section 5:26 |
| Data related to preventing money laundering e.g., suspicious transactions, AML monitoring data, payment default and inspection data | 5 years from the end of the credit relationship related to Apuraha or Tili or from when the suspicious transaction was carried out. | Anti-Money Laundering Act (444/2017) Section 4:4.3 |
| Accounting material related to credit e.g., invoices, installment data, interest histories, accounting entries, account statements and attachments | 6 years from the end of the year in which the financial year ended. | Accounting Act (1336/1997) Section 2:10Consumer Protection Act (38/1978) Section 7:24.1Act on Tax Assessment Procedure for Self-Assessed Taxes (768/2016) Section 28.1 |
Data may be retained for a longer period to the extent necessary for establishing, exercising, or defending legal claims until the matter is settled or resolved.
Who can I contact with questions about Apuraha or Tili?
For questions about the processing and retention of personal data related to Apuraha or Tili, you can contact our customer service (Ulkoinen palvelu) (Avautuu uuteen välilehteen) or by email at tietosuoja@verkkokauppa.com (Ulkoinen palvelu).