Debt Collection Agency EAD is a financial institution with a principal activity of buying and collecting receivables in credit debt recovery. In this regard, the Company processes personal data on transferred (assigned) receivables as a new creditor. Personal data are processed for the following purposes:
- Administering the relationships and collecting from the data subjects the amounts due from them under credit or service agreements, concluded with the original creditor;
- Notification of an assignment on behalf of the previous creditor (where this right is granted by the original creditor by virtue of a valid authorization);
- Improving debt collection processes;
- The exercise of the Company’s legal rights and legitimate interests with respect to the receivables, including, but not limited to, the initiation of judicial and extrajudicial debt collection procedures;
- Fulfilment of the Company’s legal obligations (for taxation purposes, those related to the implementation of measures against money laundering and terrorist financing, obligations to disclose information to the Central Credit Register and others);
- Contacting you.
The legal grounds for processing the data shall be: execution of contracts to which the data subjects are parties (for example, the credit agreement, the receivables of which are assigned to the Company), compliance with legal obligations that are applicable to the Company and the legitimate interest of the Company to collect the corresponding assigned amounts.
Debt Collection Agency EAD will process personal data as the case may be and depending on the need for such processing. The data that can be processed shall be names, National number of Identity (EGN) or other similar identifiers, date of birth, place of birth, permanent / current address, correspondence address, telephone numbers, e-mail address, other contact information, place of work and details of the employer, voice data (when recording calls), financial status, any other information about the obligation, data of persons, related to the obligation (e.g. relatives, guarantors, assignees). Information that you share when communicating with us (in meetings, exchanges of letters and emails, telephone conversation, chats, in sending short text messages (sms), emails, etc.) that may contain personal information may be processed if is relevant to the respective debt collection.
Debt Collection Agency EAD should be provided with the information necessary to administer the debt collection relationship. Where such data are required by the data subjects and the data subjects do not provide them voluntarily, legal means and methods of obtaining such data may be used.
Your personal data will be processed by employees of the Company, who have undertaken obligations to protect the confidentiality of the information made known to them in the performance of their official duties and who have received this information specifically in connection with their obligations at the Company. In compliance with applicable law and in the cases provided for by law, your data may be provided to competent administrative and judicial authorities and institutions. Your data may also be provided to the personal data processors and to their subcontractors (providing services, necessary for the activity of the Company), which have concluded contracts, providing for the protection of the relevant personal data protection. Data may be provided to the group, part of which is Debt Collection Agency EAD, and to the related companies in the group, to postal service providers in connection with these services, to banks, credit offices and collection agencies, where such provision to third parties shall be made following a case-by-case assessment of the need to provide such information to them and where technical and organisational measures are in place to protect your data.
Debt Collection Agency EAD will not disclose personal data to countries or international organizations outside the European Economic Area. Should the requirement to transfer personal data, processed by the Company to third countries or international organizations arise in the future, the provisions of the General Data Protection Regulation and applicable national legislation will be complied with, including in the event of subsequent transfer of personal data from the third country or international organization to another third country or organization.
The personal data of specific data subjects shall be processed by Debt Collection Agency EAD during the collection period, and after termination of your relationship with the Company they shall be stored for a period of 6 years, in accordance with the regulatory requirements, which provide for a storage period of 5 years and one year required to organize for the destruction / deletion of personal data from our systems and documentation. Personal data for which there is no explicit legal obligation to retain or other legal basis for doing so will be deleted after the purposes for which the personal data were collected and are processed have been achieved. Our Company complies with the principles of minimisation of the processing of personal data, both in terms of the types of data and the retention periods. In the course of the protection of the legitimate interests of Debt Collection Agency EAD and in the scope required for collection, data subjects may be subject to profiling in order to improve business processes and receivables management. Profiling shall be done with respect to the debt, based on statistical models and expert rules. Debt Collection Agency EAD shall not make automated decisions based on profiling.
The personal data shall be collected by the original creditors, by you and by others in accordance with the applicable law. In order to collect a receivable, the Company may use data from publicly available sources – public registers, property registers, judicial authorities, bailiffs and other persons, in compliance with the applicable legislation and the principles of expediency, necessity and proportionality. Regardless of the source of your data, our Company will process and retain your data in strict compliance with the principles of information security and application of technical and organisational measures.
