On the behalf of “Debt Collection Agency” EAD (the Company), for us, personally, your personal data protection as well as the transparency are at a great importance. We strictly adhere to the applicable data protection provisions in terms of each data processing operation. Regarding General Data Protection Regulation 679/2016 (“GDPR”), with its effect from May 25, 2018, the same is directly applicable on the territory of the EU, including the Republic of Bulgaria, and pursuant to the requirements, we would like to provide you with information about the type of personal data being processed by the Company.
I. Basic concepts:
– “Personal data” means any information, related to an individual and which, either independently or in a combination with other information, may lead to their identification or to identify a definite individual.
– “Personal Data Subject” – individuals who are identified or being identifiable via the personal data processed.
– “Personal data processing” – any action performed or conducted, using your personal data, including but not limited to, collecting, analyzing or destroying it.
– “Personal Data Controller” means an individual or entity, who has defined the purposes and the means of personal data processing;
– “Personal data processor” means an individual or entity, processing personal data on the behalf of the controller;
II. Details for the Data controller
“Debt Collection Agency” EAD, UIC: 203670940, is a personal data controller, processing your personal data in a lawful, conscientious and transparent manner. You can contact us, using the following contact details:
25, Dr Peter Dertliev Blvd.,
Office-building Labyrinth, floor 2, office 4,
Phone: 0700 45 600, e-mail: firstname.lastname@example.org.
III. Data Protection Officer
The Data Protection Officer of “Debt Collection Agency” EAD is “GUGUSHEV & PARTNERS” Law office – Sofia. The DPO could be contacted at email@example.com.
IV. Personal data processing: Purposes
“Debt Collection Agency” EAD is a financial institution, entered in the financial institutions register, supervised by the Bulgarian National Bank, with its main activity of buying and collecting receivables and as such, the same processes personal data, provided voluntarily by your former creditor in its capacity of an assignor, pursuant to cession contracts, as well as to the new creditor of the transferred receivable, for the following purposes:
- in order to fulfill the obligations, arising under a cession contract;
- in connection with the amounts collection, due under a credit agreement or service contract with your former creditor, as well as to improve the collection processes;
- legal rights realization and legitimate interests of the Company with respect to the obligations, including but not limited to the commencement of judicial and extrajudicial procedures for receivables collection, as well as fulfiling the legal obligations of the Company (tax obligations, obligations, imposed by the provisions of the applicable legislation, including legislation in terms of money laundering and the fight against terrorism, etc.);
- cession notification on the behalf of the former creditor (when such a right has been granted to the Company by the former creditor via a virtue of a valid authorization).
V. Grounds for processing personal data
Your personal data is being processed by the Company on three of the sites, legally gounded in Art. 6 (1) GDPR, namely:
- under item b) – fulfilling the contractual binds
- under item c) – fulfilling the controller’s legal obligation
- under item f) – controller’s legitimate interest.
VI. Personal data categories processed
“Debt Collection Agency” EAD shall process your personal data in such a range, depending on each particular case and necessity: three names, PIN, birth date, birth place, permanent / current address, telephone number, work place, electronic address, other relevant contact information, voice, estate condition, employer and workplace information, any information about the obligation, including details of people, related in any way to the obligation (eg spouses, guarantors, assignees).
Any other information, containing personal information you share during the chat communication (such as meetings, letters, telephone conversations, chat, short messages, emails and other forms) could be also processed, if it is relevant to the particular receivable collection.
VII. Personal data recipients categories
In terms of achieving the above-mentioned objectives, “Debt Collection Agency” EAD shall provide, in accordance with the current legislation provisions, your personal data to the following recipients categories: to competent administrative, judicial authorities and institutions in cases, provided by the law and companies, processing personal data, including their subcontractors (providing services, necessary for the company’s activity) by which “Debt Collection Agency” EAD has had a duly signed contract. The same data may also be provided to the companies, related to “Debt Collection Agency” EAD, part of B2Holding Group, Norway; to companies, providing postal and courier services as well as third parties, incl. banks, credit bureaux and debt collection agencies, whereas such provision can be transmitted; to third parties, only if such has been made on a case-by-case basis, weighting the need to provide the same.
VIII. Personal data transmission to a third country or international organization
“Debt Collection Agency” EAD shall not provide personal data to countries or people outside the European Economic Area. Should any personal data, processed by the Company, be transmitted to third countries or international organizations, the provisions of EU Regulation 2016/679 shall be taken into account, including cases with subsequent personal data transfer from the third country or international organization to another third country or organization.
IX. Personal data storage term
Your personal data is to be processed by “Debt Collection Agency” EAD during the collection period and, after the termination of the relations with the Company, the same shall be kept for a certain period of time – 6 years, pursuant to the regulatory requirements, including an extra year, needed for organizing the friction of your personal data out of our systems and archives. Personal data, for which there is no explicit legal obligation to be stored, shall be deleted once, when the purposes, for which the same personal data is collected and processed, have been achieved.
X. Exercising GDPR Rights
Grounded on Chapter III, General Data Protection Regulation, you have the right to access your personal data; the right to ask for the correction or deletion of the same, when the legal deadlines for their storage expire; the right to require a limit processing in case of data error; the right to object to the processing in case you are automatically taken on a profiling basis. Those rights may be exercised by submitting a written application to the data controller, including electronically, at https://app-de.onetrust.com/app/#/webform/15b7ad56-a47e-47fd-b538-12e38d938ae5 or by the following e-mail: firstname.lastname@example.org. The procedure is to be carried out in compliance with the provisions of the current legislation in the field of personal data. In connection with excersing your rights, you could also contact the Data Protection Officer at: email@example.com
You also have the right to file a complaint at Personal Data Protection Commission at firstname.lastname@example.org, in case you believe your personal data is being processed unlawfully by “Debt Collection Agency” EAD.
XI. More information
1. There is a possibility, in the course of protecting the legal interests of “Debt Collection Agency” EAD as well as in the scope, necessary for the receivable collection, you, personally, to be a subject to profiling in order to improve the business processes and the receivable collection management. Profiling is to be done in terms of the debt, based on statistical models and expert rules. Please, take into consideration that “Debt Collection Agency” EAD does not take an automated decision, based only on profiling.
2. For the purposes of collecting the receivable you owe, the Company may collect data via publicly available sources, such as property registers, courts, bailiffs and other entities, in compliance with the applicable law and the principles of expediency, necessity and proportionality.
3. During receivable collection, “Debt Collection Agency” EAD has a legitimate interest to notify the data subjects for the payment methods as well as the possibilities for debts optimization, using the established communication channels.