Privacy Statement Vesting Finance (Extended) - Your privacy and Vesting Finance
This is the privacy statement of Vesting Finance. We need your personal data need to be able to do our job. That's why we think it's important that you know what we do with your data, and how we protect your data from misuse by others. You can read all about that in this privacy statement. This relates to the personal data of our employees, customers, and other relationships, that we process. This privacy statement is valid from 28 March 2018.
Vesting Finance is the data controller with regard to processing the personal data originating from a number of companies that form part of Vesting Finance. These companies are: Vesting Finance Incasso B.V., Vesting Finance Servicing B.V. and Incassobureau Fiditon B.V., having their registered office at Van Asch van Wijckstraat 55F in Amersfoort. Vesting Finance is part of the British company Arrow Global Group PLC. We are obliged to comply with various regulations when processing your personal data. These regulations include:
- The Code of Conduct of the Dutch Association of Certified Debt Collection Agencies (NVI)
- The General Data Protection Regulation (GDPR)
- The Dutch Telecommunications Act
Who is the data controller and who is the processor?
- Vesting Finance’s client is the data controller when it comes to the processing the personal data of the client’s debtors, if this client is the party that determines the purposes and means of the data processing.
- Vesting Finance is the data controller when it comes to processing the personal data of its own customers and customer base. Some of the personal data are processed by other companies and Vesting Finance has concluded agreements with these companies that regulate the processing of these personal data.
This privacy statement explains how Vesting Finance, as a data controller, handles your personal data.
What do we use your data for?
We may use your personal data for:
- Storing, managing and collecting invoices and debts. A debt is the obligation to pay back a loan or credit.
- Determining a credit score. A credit score indicates whether you are able to pay back your debts. In order to do this, we check your payment history. This is also called profiling or credit profiling.
- Running campaigns involving the creation of profiles in order to improve our communication with you and collect debts more effectively.
- Checking and completing the following personal data: name, address and place of residence, date of birth, telephone number(s) and email address(es). This information has to be correct. It must be possible for our clients to contact you when necessary, for example, if you have received too much credit. That is what we call excessive lending. In that case, we can adjust the amount of credit and reduce costs.
- Identifying and preventing fraud, and ensuring that we comply with legal obligations.
- Sharing your personal data with other companies within the Arrow Global Group PLC, such as Focum Solutions B.V. We also share your information with other business partners if necessary in order to provide our services. These may be credit/information agencies, debt collection agencies and bailiffs.
- Offering additional services to help our clients to make their own decisions about credit portfolios, for example, a creditworthiness analysis.
- Determining the value of a (credit) portfolio.
- Quick processing of information you have provided via a website or social media.
What personal data do we process?
What personal data do we process and why?
We need your personal data need to be able to do our job. These data include your name, date of birth, address, place of residence, email address, telephone number, bank account number, details of the agreement of your purchase or credit and (payment) information and financial details, current and past. The amount of personal data we need from you differs per product or service.
We also need your data to determine whether or not you are able to repay the credit, and whether you are receiving too much credit. That is why we need to know if you have had any debts in the past, the amount of those debts and whether you repaid these debts (on time). That will give us an indication of how likely it is that you will repay the credit. This is what we call a risk profile.
How do we collect your data?
Most of the time, you give us your personal data, for example, by entering your data on our website. However, Vesting Finance can also request personal data from other sources. These may be public sources and non-public sources.
Personal data from public sources and non-public sources
- We use data from public sources, such as the Chamber of Commerce, the Land Registry, the Addresses and Building Database (BAG), the Courts and the Dutch Government Gazette (Staatscourant). We do this in order to improve the quality of our services.
- We also use information from sources that are not public, such as debt collection agencies and credit/information agencies. These are companies that collect debts, intervene on time if a customer cannot pay their debts and assess whether someone is eligible to receive credit. We use information from these sources to assess whether we can give you credit and how much.
- We may request your data or have it included in the files from our sister organisation Focum. Focum is a credit agency that collects data in order to assess whether someone is able to repay a loan and whether too much credit is given. For information about their services, please go to www.focum.nl. You can also find out how to Focum handles your data.
We record contact moments
We are in contact with you by telephone, via the Internet, email, chat, apps or social media (Facebook, Twitter, Instagram). A lot of information is also exchanged via letters and forms. We may use the personal data we collect from you or via social media, for example, to answer your questions or improve the quality of our services.
We record telephone calls
We may record telephone calls we have with you. These recordings are used to train and coach our staff, so that we can provide an even better service to you. We also record, for example, the telephone conversations in which a transaction order is given. This means that, if necessary, we can listen back to what we have agreed with you. We can also use this information, for example, to supplement and improve the information on the website or explanations given to customers. The recordings of telephone conversations are deleted after 30 days at the latest.
Sensitive Personal Data and Citizen Service Number
Vesting Finance also processes sensitive personal data and personal data relating to criminal records. These include data relating to your health, possible criminal convictions, bans imposed by the courts and specific evidence that a criminal offence has been committed. In addition, Vesting Finance also processes your Citizen Service Number (BSN).
Who has access to your data?
We also transfer your personal data to other companies. These include our sister organisation Focum, credit/information agencies, debt collection agencies, regulators, lawyers, bailiffs, payment service providers such as IDEAL, banking institutions that arrange payment transfers, debt collectors within the context of our services and government agencies to which we are legally obliged to disclose your personal data, such as the tax authorities.
On what legal basis do we use your data?
We process your personal data pursuant to the following legal bases:
- You have given your consent for using your data, for example, for a check with the Dutch Credit Registration Office (BKR).
- We have or would like to enter into an agreement with each other, for example, a credit agreement.
- Vesting Finance must comply with legal requirements. These may be related to taxes, sanction legislation, debt, attachments, the prevention of money laundering, financing of terrorism, fraud and excessive lending.
There is a so-called legitimate interest. This means that Vesting Finance may use your personal data if this is necessary for the proper performance of business activities and for its clients. This is not the case if your rights to privacy and data protection outweigh the rights of Vesting Finance.
If you are reluctant to provide us with certain information that is necessary for an agreement, we are allowed to take the necessary measures if the client can demonstrate that it will suffer damage as a result. Your assets may be seized, the agreement may be terminated, or both.
Profiles and automated decisions
Vesting Finance carries out campaigns. We use profiles in order to improve our communication with you and collect debts more effectively. Vesting Finance has a legitimate interest in drawing up these kinds of profiles, because this information is important to prevent excessive lending and payment arrears.
Any decisions with legal consequences that are made by Vesting Finance are never based solely on a profile that is formed from data that have been processed automatically. The profile is intended to help with decision-making, whereby the process always involves human beings. You can object to your profile being drawn up. We will then weigh up your objections in the light of the legitimate interest of Vesting Finance when drawing up and using a profile.
What are your rights?
Rights with respect to the processing of personal data
You have the right to view and change the personal data that we have collected from you. You have the right to object to the processing of your personal data. In certain cases, you can also ask us to limit the processing of your personal data, erase your data, transfer your data to another data controller or have it deleted. If you wish to do any of these, please send a request to the data protection office, firstname.lastname@example.org and indicate that it concerns a personal data request. Please enclose a copy of your identity document so that we can be sure that you are the person submitting the request. Make sure that you black out your passport photograph and your citizen service number. This is to protect your privacy. Also provide your private address and the file number. You will receive an overview of your data or a response to your request within one month of your request.
If you have given your consent for us to process your personal data, you can withdraw this consent at any time.
Right to make a complaint
You can make a complaint about the processing of your personal data. If Vesting Finance does not meet your request for access, correction, objection, restriction, deletion or transfer of your personal data, you can submit a complaint to the Data Protection Authority. If you are not happy with how the complaint is resolved, you can lodge an appeal with the courts.
Security of your personal data
Vesting Finance takes the protection of your data very seriously. We take measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised changes to your data. The measures we take meet the general data security requirements. We have made agreements about this with the processors and regularly evaluate the measures taken and, if necessary, we will adjust them.
This website may contain links to other websites. We are not responsible for the privacy policies or the content of these other websites. You can read these in the privacy statements on these websites.
For many types of data, the minimum retention periods are the statutory time periods. If there is no statutory period, Vesting Finance stores the data insofar as necessary to provide its services. Your personal data will in any case be deleted or irreversibly anonymised eight years either after the date when final payment was received or after the date when we received your personal data.
Processing outside the EU and EEA
In principle, Vesting Finance does not process data outside the European Union (EU) and the European Economic Area (EEA). However, data are processed in the United Kingdom, which will fall outside the EU after Brexit. Vesting Finance will ensure proper data protection. We comply with the internal rules that apply to multinationals (Binding Corporate Rules) or we use European model contracts (Standard Contractual Clauses). Do you want to know which personal data are processed outside the EU and the EEA? You have the right to inspect your personal data. For more information, see the section entitled 'What are your rights?'
Questions and contact
If you have any questions about the way we handle your personal data, please contact the Data Protection Officer of Vesting Finance. Send your email to email@example.com or send a letter to: DPO, Vesting Finance, Van Asch van Wijckstraat 55F, 3811 LP Amersfoort.
We may amend the privacy statement
Vesting Finance has the right to change this privacy statement at all times. This may happen, for example, in the case of new developments, business activities, online services, or if there are changes in the law or case law. We therefore advise you to check this privacy statement every now and then. You will then be aware of any changes that may have been made. You will automatically be notified of any major changes to the privacy statement.
This page was last amended on 28 March 2018.
Privacy Statement Vesting Finance website
When you visit our website, we collect data to ensure that the connection runs smoothly. If you request a web page, the web server needs to know where to send the page. That is where we use your IP address (Internet Protocol address). This is a number sequence that is automatically assigned to your computer by your internet provider every time you log on to the internet, so that your computer can be recognised.
Vesting Finance may store personal data, such as the IP address, when you visit our website. Vesting Finance will treat this information confidentially in accordance with the General Data Protection Regulation (GDPR). Vesting Finance only uses this information to reply to your questions, to analyse visitor behaviour on the website and for marketing purposes.
What is a cookie?
Using session cookies, we can see which parts of our website you view during your visit. In this way, we can adjust our services to our visitors' search behaviour as far as possible.
The American company Google places cookies via our website, as part of the ‘Analytics’ service. We use this service to record the visitors to our website and obtain reports on how they use the website. Google may supply this data to a third party if it is legally required to do so or if another party processes that data on Google’s behalf. We have no control over that.
Our website includes buttons to promote ('like') or share ('tweet') certain web pages on social networks such as Facebook and Twitter. These buttons use pieces of code by Facebook and Twitter. This code is used to place cookies. We have no control over that. Please read the privacy statements of Facebook and Twitter to find out what they do with the (personal) data that they process via these cookies. These statements change regularly.
Turning cookies on and off, and deleting them
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