Privacy Policy - AS Collections

Privacy Statement

A.S. Collections provides debt collection, insolvency investigation, credit control, legal and dispute resolution services. A.S. Collections operates in a business-to-business market. The products and services offered by A.S. Collections aim to help companies and businesses understand and protect against the default risks associated with the selling of goods and services and, in so doing, safeguard their sales and cash flow.

A.S. Collections acts as a “data controller” when providing our products and services. We collect and process information mainly on companies and businesses. However, in the process of doing so, we also process data that may be qualified as “personal data” under European Union (“EU”) law as it is information relating to an individual (for example, a sole trader, a company director, a beneficial owner, or professional contact).

Your trust in how we handle your personal data is important to us. When you use our website, subscribe to our service, sign-up for newsletters, engage our services as a representative or contact person of our customer, trade with our customers or do business with us as our supplier, it is important to us to use your personal data carefully, securely and in a transparent manner.

In this Privacy Statement, we provide the information we are required to give about the processing of personal data under EU law. We explain the purposes and grounds of the processing of personal data, the categories of personal data concerned, the categories of the sources and the recipients of the personal data, data retention and your rights as a data subject.

Updates to This Privacy Statement

We strive for continuous improvement in our services processes and protecting your personal data rights so that we may update this Privacy Statement from time to time. Therefore, we advise you to check this statement regularly. This Privacy Statement was updated on 14th January 2020.

When do we Collect Personal Data, and When Does This Privacy Statement Apply?

1. If you use our Website

1.1 What Personal Data do we Collect?

We may process the following information on your company or business, which may qualify as personal data:

You submit any personal details such as your name, work address, telephone number, email address, or other information provided during registration for any of our products or services.
Information that allows us to remember you and your preferences in using this website. We use cookies to collect this type of information. Further details on this are available on our Cookie Information page, including how to decline or disable cookies.
Your IP address, which we use to note your visit to our websites.
Your subscriptions to any newsletters, marketing, or email updates.

1.2 Why do we Collect This Personal Data?

We may use your information for the following purposes:

To provide products and services, maintain contact with you and handle complaints.
To optimise our products and services for marketing purposes and market research.
To perform administration within A.S. Collections and manage and protect our information technology infrastructure.

1.3 Legal Grounds for Using Your Personal Data

We process your personal data only if this is allowed under one legal processing grounds. We rely on one or more of the following legal grounds for the processing of your information:

Consent
- We request your consent for the usage of certain cookies via our website. See our Cookie Information page for more details on this.
Legitimate interests
We may process your information as necessary for achieving our legitimate interests.
- For the usage of some cookies, we do not require your consent. Here, A.S. Collections has a legitimate interest in making a functional website available. See our Cookie Information page for further information on this.
- In some instances, you consent to use your personal data to contact you in a few cases. This is, for example, the case if you requested us to contact you via a contact form. We furthermore do not always require your consent to use your personal data for marketing purposes. This may, for instance, be the case if A.S. Collections obtained your email address in the context of the sale of our products or services, and we use this address for direct marketing of our similar products or services.

1.4 Where did we Obtain Your Information?

We automatically obtain some information when you visit our website. We collect such information via cookies. See our Cookie Information page for more details on this. We accept other data when you actively provide it to us. This is, for example, the case when you sign up for any newsletters or email updates. See also the information on our marketing activities in paragraph 2.

1.5 Who will have access to your personal data?

We may disclose personal data to fulfil our purposes to:

A.S. Collections business partners (solicitors) and service providers to provide the service.

2. Marketing

2.1 What Personal Data do we Collect for Marketing Purposes?

In the context of our marketing activities, we may process the below information about you:

Contact details include name, title, phone number, email address, business address, contact history.
You provided information on consent to use your personal data for marketing purposes, including subscriptions to newsletters and email updates.
Information on your interests based on your subscriptions to our service.
Information regarding any of your questions, queries, or complaints.
Other personal data provided by you.

2.2 Why do we Collect This Personal Data?

We may use your information for the following purposes:

To get into and maintain contact with you.
To promote and inform you about our products and services.
To inform you of any changes in legislation that may be relevant to your business and our business relationship.
To analyse your interests and possible business opportunities for us.
To obtain your views on some issues, including customer feedback requests.
To deal with questions, queries, or complaints.

2.3 Legal Grounds for Using Your Personal Data

We process your personal data only if this is allowed under one legal processing grounds. We rely on one or more of the following legal grounds for the processing of our marketing activities:

Consent
- If required, we request your consent for processing your personal data for our marketing activities. You can withdraw your consent by clicking on the opt-out link in our emails or by submitting a form online. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
Legitimate interests
- We may process your information as necessary for achieving our legitimate interests when performing our marketing activities. For our business interests, we may, for example, gather, analyse, and interpret information about our customers to find new opportunities to sell and develop products and services to satisfy the preferences and needs of our customers.

2.4 Where did we Obtain Your Information?

For marketing purposes, we primarily obtain information concerning you from yourself. In other instances, we may get your personal data from the various sources displayed below.

Parties who refer us to you or to whom you provided consent to share your data with us.
Third parties engaged by us in the context of our marketing activities.
The internet for as far as allowed under the applicable law.

2.5 Who will Have Access to Your Personal Data?

A.S. Collections may disclose information on you, which may qualify as personal data to:

A.S. Collections personnel, business partners (solicitors) and service providers.

3. If you are a customer, related party, intermediary, co-guarantor, business partner or supplier

3.1 What Personal Data do we Collect?

We may process the following information on your business, which may qualify as personal data if it relates to information relating to an individual (for example, a sole trader, company director, beneficial owner, shareholder, beneficiary, or professional contact).

Contact details and personal identification data, including your name, title, position, phone number, email address, business address, country, entity name.
If your company is not a legal entity, we may also process bank account details, claims history, VAT number and details of the agreement with you.

3.2 Why do we Collect This Personal Data?

We may process the information on your business, which may qualify as personal data, for the following purposes:

To execute and provide services about the agreements. This includes processing transactions, communicating with you, performing recovery actions, providing services and products, conducting debt collection, customer support, handling complaints and disputes.
To perform “know your customer”, anti-fraud & terrorism, money laundering, sanctions list checks and other compliance checks.
To optimise our products and services, conduct market research and statistical analyses.
To perform administration within A.S. Collections and manage and protect our information technology infrastructure.
For marketing purposes.
To establish, exercise or defend legal claims.
To comply with a regulatory/governmental authority order or an obligation under relevant laws or regulations or (voluntary) regulatory, industry or sector codes or guidelines.

3.3 Legal Grounds for Using Your Personal Data

We process your personal data only if this is allowed under one legal processing grounds. We rely on one or more of the following legal grounds for the processing of your information:

Legitimate interests
We may process your personal data as necessary for achieving our legitimate interests when performing our business activities.
- Offering and providing debt collections products and services aims to help you understand and protect against the default risks of selling goods and services.
- It is necessary to enter into and perform agreements with the company or business you are associated with.

We will not process your personal data if your interests prevail.

Performance of a contract – If you are a sole trader company or non-limited partnership, we need to process your personal data to enter into and perform agreements.

Legal obligation – We may process your personal data if necessary to comply with one of our legal obligations, such as performing compliance checks or complying with orders of a regulatory/ governmental authority or following obligations under industry or sector codes.

3.4 Where did we Obtain Your Information?

The personal data that A.S. Collections processes may originate from various sources:
Directly from you or the company you are associated with, including those representing or authorised by you or such company.
From publicly available sources.
From information/data providers.

3.5 Who may have Access to Your Personal Data?

We may disclose personal data to fulfil our purposes to:

Parties authorised by you or the company you are associated with.
A.S. Collections personnel.
Third parties such as solicitors, crime or fraud detection and prevention agencies, business partners, auditors, lawyers, debt collectors and other service providers.
Advisers or other professional parties to establish exercise or defend legal claims or protect our business operations or legal rights.
Law enforcement agencies, regulatory/governmental authorities: when required by law, or as necessary to protect our rights.

4. If you or Your Company Trade With our Customers

4.1 What Personal Data do we Collect?

We may process the following information on your business, which may qualify as personal data, in so far as it relates to information relating to an individual (for example, a sole trader, company director, beneficial owner, shareholder or professional contact).

Contact details and personal identification data, including your name, title, position, phone number, email address, business address, country, date and place of birth, identification details, entity name.
If your company is not a legal entity, we may also process bank account details, payment history, VAT number, financial information, insolvency status.

4.2 Why do we Collect This Personal Data?

We may process the information on your business, which may qualify as personal data, for the following purposes:

To execute and provide services about the agreements we have with our customers. For example, processing transactions, we are communicating with you, performing recovery actions, conducting debt collections, handling complaints and disputes.
To perform fraud, money laundering, anti-terrorism and sanctions list checks and other compliance checks.
To optimise our products and services, conduct market research and statistical analyses.
To perform administration within A.S. Collections and manage and protect our information technology infrastructure.
To establish, exercise or defend legal claims.
To comply with an order of a regulatory/governmental authority, or an obligation under relevant laws or regulations or voluntary regulatory, industry or sector codes or guidelines.

4.3 Legal Grounds for Using Your Personal Data

We process your personal data only if this is allowed under one legal processing grounds. We rely on one or more of the following legal grounds for the processing of your information:

Legitimate interests
- We may process your personal data as necessary for achieving our legitimate interests when performing our business activities.
- Offering and developing debt collections products aim to help companies understand and protect against the default risks of selling goods and services.
- It is necessary to enter into and perform agreements with our customers.
- To establish, exercise or defend legal claims.

We will not process your personal data if your interests prevail.

Legal obligation

We may process your personal data to comply with our legal obligations, such as performing compliance checks or complying with orders of a regulatory/governmental authority or following obligations under industry or sector codes.

4.4 Where did we Obtain Your Information?

The personal data that we process may originate from various sources:

Directly from our customers or you, including those representing the customer or you.
From business partners of A.S. Collections.
From publicly available sources.
From information/data providers.

4.5 Who may Have Access to Your Personal Data?

We may disclose personal data to fulfil our purposes to:
Our customers and parties authorised by the customer (such as intermediaries, representatives, companies belonging to the customer’s group).
A.S. Collections personnel.
Third parties such as solicitors, crime or fraud detection and prevention agencies, business partners, auditors, lawyers, debt collection and other service providers.
Advisers or other professional parties to establish exercise or defend legal claims or protect our business operations or legal rights.
Law enforcement agencies, regulatory/governmental authorities: when required by law, or as necessary to protect our rights.

5. How do We Protect Your Personal Data?

We are committed to ensuring that your personal data is kept secure. To prevent unauthorised access or disclosure, we have put appropriate physical, technical and organisational measures to safeguard the information we collect and process.

6. How Long do we Retain Your Information?

We shall retain personal data only: (i) for the period required to serve the applicable business purpose; (ii) to the extent reasonably necessary to comply with any applicable legal requirements; or (iii) as advisable considering an applicable statute of limitations. A.S. Collections may specify a time for specific personal data categories will be kept.

7. How can you Contact us, Access and Update Your Information?

As a data subject, you have certain rights concerning our processing of your personal data. You can:

request access to your personal data held by us
ask us to rectify or complete your information if you believe that your personal data is inaccurate or incomplete
ask us to erase certain personal data
ask us to restrict the processing of your personal data object to our processing of your personal data

You may send us your request or complaint by submitting a form online. We will handle your proposal carefully and in line with the applicable data protection laws.

The A.S. Collections Data Protection Officer can be contacted by emailing pt@ascollections.co.uk.