Processing of personal data in the respective relations of contractual partners with Debt Collection Agency EAD

Debt Collection Agency EAD is a legal entity and an employer. In carrying out its activity, fulfilling its legal obligations and for its requirements, the Company shall cooperate mainly with other contractual partner – legal entities (companies providing services to Debt Collection Agency EAD, banks and other financial institutions, debt collection companies). The contractual partners in these relationships shall be represented by individuals for whom personal data are processed. The personal data of such persons shall be processed for the following purposes:

  • In connection with the conclusion, execution and termination of contracts, the receipt of services, payments under contracts, contacts on operational and other matters;
  • In order to administer relations on assigned receivables, in which relations the Company may be an assignor or assignee;
  • In the provision and receipt of communications services (postal, telecommunication, etc.);
  • In relation to the notification of receivables assignment;
  • to improve the debt collection processes;
  • In the fulfilment of legal obligations by the Company;
  • In order to provide benefits to the Company’s employees;
  • In the implementation of measures against money laundering and terrorist financing.

The legal grounds for processing the data shall be compliance with legal obligations that apply to the Company as a data controller and a legitimate interest of the controller as a legal entity and an employer.

Debt Collection Agency EAD will process personal data on a case-by-case basis and as needed. The data that can be processed shall be names, National number of Identity (EGN) (in some specific cases of service contracts in which the employees of the contractual party provide certain services or where such information is provided in proxies), correspondence address, telephone number, e-mail address, other contact details, employment location and employer details, voice data (when recording calls). Information that such persons 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 relationship between the parties and is not used for purely personal purposes.

Where such data are required by the data subjects and the data subjects do not provide them voluntarily, other legal means and methods of obtaining such data may be used.

The 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, data may be provided to competent administrative and judicial authorities and institutions. 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.

Debt Collection Agency EAD will not disclose personal data to countries or organizations outside the European Economic Area. Should the transfer of personal data processed by the Company to third countries or international organizations arise in the future, the provisions of the applicable legislation, including General Data Protection Regulation, 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.

Personal data of individuals – representatives of legal entities – contractual parties, shall be processed by Debt Collection Agency EAD for a period not exceeding the time, required to achieve the respective purpose for which the data were collected or for the statutory period. For example, data will generally be retained for 5 years after the termination of our contractual relationship with the contractual partner and for an additional 1 year to arrange its deletion. However, if there is a legal obligation, for example under the Accountancy Act, under which we are obliged to store your data as a representative of our contractual partner for a longer period of time, the retention period will be that, specified in the applicable legislative act.

The data shall be collected by our contractual partners or by you. Such data may be possible to obtain from public registers, for instance by the Trade Register.