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Privacy Policy for Customers

In this Privacy Policy we will give you information on the processing of your personal data in connection with our services such as collection and debt purchase.

Why have we access to and process your data?

Your personal data may be passed to us for the purposes of debt collection in the event that repayments are not made as agreed under the terms of your original agreement. Your personal data may also be passed to us in case we have purchased your debt. We also provide other services such as invoice delivery, invoicing, ledger, credit information and financing services. To be able to deliver these services we may have been provided with, and will process, your personal data.

We will only process your personal data if we have a legal ground to do so. Processing may be necessary for the purposes of the legitimate interests pursued by your previous agreement party or us or for the performance of a contract to which you are party. Processing may also be necessary to fulfill our legal obligations. Hence, processing of your personal data is allowed, even if you do not consent to the processing. In accordance with performance of a contract or for purposes of our legitimate interest verify that the data we hold is correct, enrich your data by combining it with data from different sources e.g. Credit Reference Agencies, historical cases we hold on you and public registers. We may also use credit scoring to be able to choose the appropriate means for collection and share your data with approved third parties such as other collection servicers, Credit Reference Agencies or public authorities

Your consent is neither required in relation to our debt purchase services. When the debt has been purchased, we will be your new agreement party. When we later on collect these debts, we process your personal data for the performance of the contract based on our legitimate interest.

Based on your approval information about your collection cases and collection history can nonrecurringly be shared with credit provider or service provider as a part of credit application process.

Your data will be held securely in compliance with data protection legislation.

What personal data are you processing about me and why?

We hold information that is necessary to be able to provide our services. To be able to communicate with you and to ensure safe and true identification we need your name, personal identity number, date of birth and contact details such as address, telephone number and email.

To evaluate your ability to pay, make payment plans and debt surveillance, we may also hold financial information about you such as default details and credit history information, information on your debt, income, assets, credit, payment history and credit rating. 

To better understand your specific situation and to make a well informed decision on how to handle your case we also keep your reasons for non-payment depending on the information you provide to us, e.g. individual or family circumstances, work-related issues, etc.

The personal data we hold is also needed for us to be able to present legal claims or obtain other execution or enforcement. We also use your personal data to ensure good debt collection practices. E.g. your payment history may be used for scoring for choosing the appropriate collection method. Your personal data may be used and phone conversations taped to train our personal and to document your rights. Unless we have legal obligations to keep the records we will delete them after six months.

We have a legal obligation to provide your personal data when we are audited by the authorities. We also have a legal obligation to prevent and monitor fraud, money laundering and other criminal activities and to disclose related evidence to authorities.

As part of our corporate responsibility and our services we also produce anonymized statistics, scorecards and analyses where your data may be used as a base.

The information we have on you may be anonymized and used for developing our business. However, when necessary to secure your personal data in connection with changes in our IT system it may be used as-is.  

Unless otherwise agreed with you or it is necessary for the establishment, exercise or defense of legal claims, we will not include special categories of personal information (see below).  

Are you processing any sensitive data regarding me?

Unless otherwise agreed with you or is necessary for the establishment, exercise or defense of legal claims, we will not include special categories of personal information often known as ‘sensitive personal data’ such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life. 

It may however benefit you to notify us of such personal information or social force majeure that may impact your ability to repay your account. This will allow us to take reasonable steps to accommodate your needs or requirements such as allowing sufficient breaks in your payment arrangement, providing breathing space to seek free independent debt advice, or adjusting your payment arrangement. Apart from social force majeure we will not record any sensitive personal data in our IT systems.

This information will be used by us to assist you and will be kept as long as it is required for this purpose or it is necessary for the establishment, exercise or defense of legal claims. 

Do I have to provide you with my personal data?

You do not have to provide us with any personal data. Most personal data that we process about you comes from another source than yourself. We obtain data from your original contract party and we enrich the data with information from Credit Reference Agencies, public registers and service and your earlier payment history to us.

However, you may choose to provide us with additional personal data. Such information may even help us handle your case, and it is usually to your benefit. For example, you may have a valid reason for why you have not paid your debt which you may want to share with us, or if we agree to set up a payment plan to help you pay your debt you may want to provide certain details for making the payment plan reasonable and attuned to your specific situation.

Will you share my personal data with others?

We may share your personal data with our suppliers that facilitate or provide parts of our services, e.g. printer and mail services, phone and messaging service providers and legal representatives as well as service providers withing Intrum Group. We may also share your personal data with our Client (your agreement party), credit check institutes and public authorities.

Our employees will have access to the personal data. In such a case, access will be granted only if necessary for the purposes described and only if the employee is bound by an obligation of confidentiality.

Will my personal data be transferred to another country?

As we are part of the Intrum group, we may transfer your data to another country. If we do, we will ensure there are suitable safeguards in place to comply with EU General Data Protection Regulation (GDPR). Generally, your personal data will not be transferred outside of the European Economic Area (EEA). However, in case of international debt collection, your personal data may be transferred to one of our agents working in the relevant country. We also use third-party service providers to store the personal data we process. These service providers, which may be located outside of the EEA, including, but not limited to the United States, may access your data. We will never transfer your personal data outside of the EEA without ensuring the safety and protection of your personal data. Therefore we make sure that any recipients have signed the EU Standard Model Clauses, to justify the transfer, or that the European Commission has deemed the country to guarantee adequate level of data protection. We may disclose information outside of these groups to help prevent fraud, or if required to do so by law. 

How long do you store my personal data?

We will retain your data as long as required for the lawful purpose for which it was obtained, as long as we have legitimate interest to keep it. The retention period may be based e.g. on requirements stated in Act on Registration of Collection Agencies or Accounting Act. We also hold the data until the statute barring period is due to be able to defend ourselves against legal claims. We are also legally obliged to keep your personal data for a period of time to prevent, detect and evidence fraud and money laundering as well as for financial audits. For statistical purposes we will only keep strict anonymized data.

As far as our backups are concerned, we will delete your data in our backups when the back-up tape comes up for restore according to our backup policy. When the backup comes up for deletion as per back up policy, we will fully delete your data. 

How long do you store my personal data?

To choose the most appropriate collection method and to avoid unnecessary collection costs, we may use automated decision-making. It is also necessary for handling of your case in an efficient and timely manner.

A score may be used in relation to automated decision-making to indicate how we will handle your case. The score is based on our payment surveys which help us to predict your future payment behaviour together with your earlier payment history, public tax and payment default information as well as your age and residence. A score is awarded by automated means, and the score decides, for example, whether we will continue amicable collection or if we should forward your case to legal collection or enforcement. We do not consider the automated decision-making to produce legal effects or similarly significantly affect you as it does not affect your rights and obligations based on your earlier contract. 

You will generally not receive any information on the individual score that has been awarded to your case, but if you believe that we have handled your case wrongly due to the score, you may ask us to manually reconsider the score by human intervention.

Will I be subject to automated decision-making?

To choose the most appropriate collection method and to avoid unnecessary collection costs, we may use automated decision-making. It is also necessary for handling of your case in an efficient and timely manner.

A score may be used in relation to automated decision-making to indicate how we will handle your case. The score is based on our payment surveys which help us to predict your future payment behavior together with your earlier payment history, public tax and payment default information as well as your age and residence. A score is awarded by automated means, and the score decides, for example, whether we will continue amicable collection or if we should forward your case to legal collection or enforcement. We do not consider the automated decision-making to produce legal effects or similarly significantly affect you as it does not affect your rights and obligations based on your earlier contract. 

You will generally not receive any information on the individual score that has been awarded to your case, but if you believe that we have handled your case wrongly due to the score, you may ask us to manually reconsider the score by human intervention.

What rights do I have?

It is important you understand that we process your personal data in a reliable and safe practice. Even if we do not need your permission to process your personal data, you have many rights in relation to the processing of your personal data.

Your rights - What does it mean?

Right to access:

You may request information on how we process your personal data, including information on:

  • Why we process your personal data
  • What categories of personal data we process
  • Who we share your personal data with
  • How long we store your personal data or the criteria for determining this period
  • What rights you have
  • From where we have received your personal data (if we have not received it from you)
  • If the processing includes automatic decision making
  • If your personal data has been transferred to a country outside of the EEA, how we ensure the protection of your personal data.

All the above information regarding principles relating to processing of personal data is available in this Privacy Policy.
You may also request a copy of the personal data we process about you. However, additional copies will be combined with a fee.

Right to correction:

It is important that we have the right information about you and urge you to let us know if any of your personal data is incorrect (e.g. if you have changed your name or moved).

Right to be forgotten:

If you consider that we process your personal data in an unlawful way, for example if we process your personal data longer than necessary or for no reason, you may ask us to delete this information.

Right to restriction:

From the time you have requested we correct your personal data or if you have objected to the processing and until we have been able to investigate the issue or confirm the accuracy of your personal data or changed it in accordance with your instructions, you are entitled to restricted processing. This means that we may process your personal data only in accordance with your consent, if necessary with reference to legal claims, to protect someone else's rights or if there is an important public interest in the processing.
You may also request that we restrict the processing of your personal data if the processing is unlawful but you do not want us to delete the personal data.

Right to objection:

If you want an automated decision to be reconsidered, you may object to our processing. On grounds relating to your particular situation, you may also object to processing we carry out on the basis of our or our client’s legitimate interest. In such cases, we may continue processing only if we can show compelling justifying reasons that out-weigh your interests, rights and freedoms. However, we may always process your personal data if it is required for the determination, exercise or defense of legal claims. You also have the right at any time to object to direct marketing.

Right to data portability:

You may request to have your personal data that you have provided to us for processing based on consent or to fulfil a contract, provided to you in a structured, widely used and machine-readable format. You also have the right to request us to transfer that information to another data controller.

Right to lodge a complaint:

If you consider that we do not follow the applicable data protection legislation, you are entitled to lodge a complaint with the competent data protection authority. You can find further information about the Data Protection Ombudsman and their complaints procedure at www.tietosuoja.fi.

Withdrawal of consent:

In situations where our processing activities should be based on your consent, you have the right to withdraw it and we will consequently stop the processing activities based on this legal ground.

We will also notify others we may have shared your personal data with of your requests. 

How to complain about the use of your data or exercise my rights?

If you wish to raise a complaint about how we handle your personal data, including in relation to any of the rights outlined above, you can contact our Data Protection Officer and we will investigate your concerns.

Data Protection Officer: tietosuoja@intrum.com

If you have any further questions on how we process your personal data you may contact us through our Data Protection Officer.