INFORMATION MEMORANDUM ON PERSONAL DATA PROTECTION

What do we mean by personal data, and why do we process it?

Personal data means any information related to an identified or identifiable natural person that can be identified directly or indirectly; in particular, by reference to an identifier such as name, identification number, location data, online identifier or link to one or more elements specific for the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We only process personal data necessary for achieving a particular purpose of processing. Personal data are always processed for a predefined and legitimate purpose, which could not be achieved without its processing.

Claims Collection Ltd., with a registered office at Národná 16A, 010 01 Žilina, Company ID: 51 875 101 (hereinafter as “Claims Collection”) under Article 7 (4) of the Regulation, is the controller of its own information system in which are processed data of legal entities and personal data of natural persons in accordance with the legal basis and for the purpose defined in this Memorandum.

In our company, we process your personal data solely in accordance with Article 6 (1) (a), pursuant to which the processing of personal data is in accordance with the Regulation, provided that the person concerned has expressed his or her consent to such processing of personal data, in accordance with Article (6) (1) (b) of the Regulation, pursuant to which the processing of personal data is necessary for the performance of a contract of which the person concerned is a party or, upon the request by the person concerned, to take measures prior to the conclusion of a contract, in accordance with Article (6) (1) (c) of the Regulation, pursuant to which the processing of personal data is necessary for compliance with a legal obligation to which the controller is subject or, in accordance with Article 6 (1) (f), pursuant to which the processing of personal data is necessary for the purposes of the legitimate interests pursued by the operator or a third party.

Your personal data are always processed only for a predefined and legitimate purpose of processing, and there must always be an appropriate legal basis for such processing. Hereby, we assure you that your personal data will never be further processed for purposes incompatible with the original purposes of processing.

What is the purpose of processing my personal data?

The purposes of processing the personal data of the data subject are (i) identification of clients; (ii) conclusion of contractual relationships with clients, including pre-contractual relationships; (iii) management of contractual relationships, including making changes and their termination; (iv) identification of debtors in terms of legal relationships between debtors and clients; (v) contacting debtors for the purpose of enforcing legal claims; (vi) and taking legal action to enforce legal claims.

Do you also use my data for marketing purposes?

For the purpose to inform you of the services, innovations, and preferential offers provided by our company, and also in relation to obtaining benefits of the Claims Collection, we process your personal data on the legal basis of your prior voluntary given consent or legitimate interest under Article 6 (1) (f) of the Regulation.

Our company has a legitimate interest in the care of its clients and development of business relationships with them, and thus to inform them about services or preferential offers. In this regard, we may address you without your prior consent, while we inform you of such processing of your personal data and your rights, especially the right to object to the processing of your personal data. Given the above, of course, does not apply if you have opposed or objected to such information.

For the purposes outlined above, we can communicate with you via phone, email, SMS, or other means of remote communication.

In order to customize our offer of services just for you, we evaluate the information we process about you so that you can receive a targeted offer and so limit the sending of non-targeted marketing offers.

Who can be provided with my personal data?

We do not provide your personal data to other entities unless you have given our company consent, written instructions, or if there is another legal basis to provide your personal data to another entity, for example, if it is the legal obligation from our side as a controller.

Is my personal data provided to third countries?

No, your personal data are not provided to third countries under the Regulation, nor will they ever be. We consider the protection of your personal data as our priority, and therefore we would not risk the loss of our integrity by transferring your personal data to countries that do not provide the same or equivalent level of personal data protection as the Slovak Republic.

How long do you keep my personal data?

We keep your personal data, in a form that allows us to identify you, for the period that is necessary to achieve the purposes for which the personal data are processed. If your personal data are processed upon your consent, after the withdrawal or expiry of the consent, your personal data will be kept only for as long a period as it is necessary to prove, apply or defend legal claims. The same procedure applies to the processing of your personal data on a contractual basis.

If your personal data are processed within the performance of a legal obligation, the applicable legislation will determine the period during which we are required to keep your personal data and related documentation.

How do you protect my personal data?

We take reasonable technical and organizational measures to protect your personal data against intentional or negligent deletion, loss or change, and against the unauthorized disclosure of your personal data. Employees of our company as well as our contractual partners who process personal data on our behalf are bound by an obligation of confidentiality, which lasts even after the termination of a contractual relationship.

What are my rights in relation to the processing of my personal data?

With regard to the processing of personal data, you have the right to file a complaint to the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava, Slovak Republic.

You are entitled to correct your incorrect personal data or to complete incomplete personal data. If you find out that we are processing incorrect or incomplete data about you, please do not hesitate to contact us.

If your personal data are processed under your consent in accordance with Article 6 (1) (a) of the Regulation, you are entitled to revoke this consent at any time. However, the revocation of consent does not affect the lawfulness of processing personal data based on the consent given prior to revocation. You are also entitled to the other rights that you have as a person concerned pursuant to the Regulation.

Do I have to provide my personal data?

Without the identification of personal data, we cannot conclude a contract on the assignment of claims with you, as it would not be possible to define contractual relationships between the creditor and the debtor. For the purpose of concluding a contract on the assignment of claims, the provision of personal data is a necessary requirement to conclude such contract.

Do I have the right to object to the processing of my personal data?

As a person concerned, you have the right to object to the processing of your personal data if the processing takes place on a legal basis of legitimate interests. Our company may further process your personal data to legitimate interests only if it proves that the necessary, legitimate reasons for processing outweigh your interests, rights, and freedoms or reasons for proving, applying or defending legal claims.

You are entitled at any time to object to the processing of your personal data for direct marketing purposes, if the processing takes place on the legal basis of legitimate interests. In the case of your objection to the processing of personal data for direct marketing purposes, we will not further process your personal data for direct marketing purposes.

Do I have the right to information related to the personal data you process about me?

As a data subject, you have the right to access your personal data. If you meet the conditions defined by the Regulation, you can request that we provide you with a list of personal data we process about you. Under certain circumstances defined by the Regulation, you can request to limit processing, transfer and also delete your personal data.