How your personal data is used
Have you received an invoice with the payment details of the Alektum Group?
Alektum Group assists other companies, i.e. our customers, in managing the administration of invoices, processing payments, sending reminders and, where applicable, providing customer service. In carrying out these services, we process your personal data on the behalf of our customer. For more detailed information on how the personal data is processed, for what purposes, and what rights you have, we would ask you to contact the seller -- i.e., your contractual party. The seller's contact details are always given on the invoice you have received.
Have you received a debt collection letter or other letter of notice?
When carrying out debt recovery services, Alektum Group processes personal data on the categories of data subjects given below.
- those who have a debt to pay (debtors), including their representatives,
- those who need to fulfil an obligation, e.g. to replace goods,
- those who bear joint and several liabilities for the debtor, such as an associate, a guarantor, etc.
We process the data because you have a debt that has become due for payment to us or to one of our customers. We undertake so-called debt recovery measures in order to effectively ensure payment or other discharge, claim establishment and/or enforcement, and so that we will be able to invoice and account for this in a way that complies with the law. The processing is carried out on the basis of Article 6 b, c, e and f of the General Data Protection Regulation. The legitimate interest is to see to it that unpaid debt is cleared on our own or on another person’s behalf.
“Debt recovery measures” is a collective term that we use for all of the actions we take in order to achieve the purpose mentioned above. This can consist of sending a debt recovery claim notice or other letter of notice, or it can consist of administration of settlements, payments, contacts with debtors or their representatives, contacts with the authorities, actions to establish claims, including court proceedings, and enforcement.
To enable us to carry out debt recovery measures, we need to process your contact and address details, including your personal identity number. It is important for the Alektum Group to make sure that the information we are using is correct and up to date. For this reason, we ensure that address details are regularly updated against population registry records, and for this purpose, we use an external contractor who will be able to view some of the personal data in the process.
In the event that you live in or move to another country, the Alektum Group may hire a debt collection agent that operates in that country. Personal data about you and the debt collection case will then be shared with the debt collection agent.
Moreover, we need to process data on the debt that remains unpaid, the contract, and other facts around the purchase on which the debt is based, plus any partial payments made. In order to assess what debt recovery measures we are to take, we also need to know something about your financial situation, living conditions, and other debts, as well as any distraints. For this reason, we collect financial information and debt information from external contractors, such as credit information companies and public authorities; for this purpose, these parties will be able to view some of your personal data. On the basis of this information, we decide what type of demand letter should be sent, and whether we should take legal action, such as petitioning for a payment injunction, initiating court proceedings, or petitioning for enforcement action. In some cases, this is determined by means of methods such as profiling and is part of an automated process. This means that a decision on what measures to take is made automatically based on pre-determined variables, rather than an administrator manually making decisions in each individual case.
There are also other cases where we need to share personal data or make it available, in order for the purposes of the processing to be achieved. Those with/to whom we may share this data or make it available include e.g. the client, external contractors (such as postal and printing companies, IT support and systems suppliers, companies serving legal papers, legal consultants and others who contribute to the provision of our services), and public authorities.
Apart from the personal data mentioned above, there may be isolated data concerning health or criminal records, but only in the event that such information is necessary to enable a legal claim to be established or exercised or defended in an individual case, or if the Alektum Group has obtained consent. In such cases, the information is processed on the basis of Articles 9 a, 9 f, and 10 of the General Data Protection Regulation, together with the provisions of the Data Act.
The information is also used, to a limited extent, for business- and method development, operational planning, statistics, monitoring, and risk management. The information is then used for the purpose of developing and analysing operations and on the basis of our legitimate interest in developing our operations and avoiding credit losses (Article 6 f of the General Data Protection Regulation).
Do you work for one of our clients, contractors or collaborative partners, or for a public authority?
Alektum Group processes personal data on the categories of data subjects mentioned below
- Contact persons and/or associates or guarantors of our customers,
- Contact persons for prospects (i.e., for companies that we would like to become a customer of ours),
- Contact persons for public authorities, including contact persons in specific matters,
- Contact person for contractors or other collaborative partners
The information is used for the management of the contact, the implementation of the contract or collaboration, and for accounting- and invoicing purposes. This information is processed on the basis of Article 6 b, c and f of the General Data Protection Regulation. Personal data processing that is carried out on the basis of Article 6 f is carried out for our legitimate interest in marketing our services and in developing our customer base.
Personal data relating to contact persons that is held by public authorities are used, moreover, for the implementation of actions that are necessary in legal matters concerning claims, such as establishment, enforcement, debt restructuring and dispute resolution. This information is processed on the basis of Article 6 c, e, and f of the General Data Protection Regulation. Personal data processing that is carried out on the basis of Article 6 f is carried out in our, or our customers’, legitimate interest in effectively securing payment of an unpaid debt that has become due.
Personal data concerning associates, guarantors and contact persons that is held by collaborative partners and customers is also used in cases where we need to carry out supervisory measures related to money laundering, and for the assessment of ability to fulfil financial commitments, and otherwise of security and economic solvency. Only the information that is necessary to achieve the purpose will be processed, but this includes data on the person’s assets, debts, and income.
Sensitive information will only be processed if this is required for us to carry out our supervisory measures related to money laundering. The information is processed on the basis of Article 6 b-c of the General Data Protection Regulation and, where applicable, Chapter 5, Section 6 of the Act (2017:630) on Preventive Actions against Money Laundering and the Financing of Terrorism.
The information is also used, but to a limited extent, for business- and method development, marketing analysis, statistics and risk management. The information is then used for the purpose of developing and analysing operations and on the basis of our legitimate interest in developing our operations and communicating with our contacts (Article 6 f of the General Data Protection Regulation).
How long your personal data is stored
Alektum Group is responsible for removing the personal data of its own accord when it is no longer necessary for achieving the purposes stated. Hence, the time of storage varies, and a description is given below of how Alektum manages storage times depending on the main purpose involved.
Personal data that has been collected during a debt recovery case is stored for 36 months after the case is concluded.
Personal data that has been collected in order to manage customer relationships and, if applicable, to assess the creditworthiness of a customer, associate or guarantor, is stored for 36 months after the customer relationship ends and the parties’ reciprocal claims have been conclusively settled, or at any earlier time when the data ceases to be relevant for the purpose.
Personal data that has been collected in order to carry out supervisory measures related to money laundering is stored for five years, or for the time that is specified by law. The time period is to be calculated from when the actions or transactions were carried out or, in cases where a business relationship has been established, when that relationship has ended.
Data that has been collected in order to develop, analyse and market Alektum’s operations is stored for a period of 36 months after the last contact. If you unsubscribe from newsletters or similar, the data will be deleted immediately.
Regardless of the aforementioned storage times, the Alektum Group may store data for longer periods for the purpose of defending and safeguarding legal claims. Personal data that is necessary for invoicing and accounting for bookkeeping purposes is always stored up to and including the seventh (7) year after the end of the calendar year in which the accounting year ended.
You are safe with us - we always protect your personal data
Alektum Group is always obliged to protect your personal data, even when we hire an external party to carry out the processing. We never disclose the personal data unless we have to in order to achieve our objective or unless we are obliged to by law. Moreover, we are bound by statutory confidentiality obligations in some of our services.
We are also careful to limit the distribution of personal data internally within the Alektum Group, in such a way that only those staff who need to see the personal data in order to carry out their work duties have access to it.
Furthermore, we ensure that all our IT systems and other locations where we have personal data stored are protected against access to the information by unauthorised persons (e.g. through firewalls, virus protection, strict requirements for passwords, logging in the systems, etc.).
When we need to transfer personal data between ourselves and a party outside of our environment -- for example, one of our customers -- we make sure to use a secure method of transfer.
Finally, we make sure that backup copies of our systems and records are made in order to avoid the loss of important information about you.
You have control over your personal data. These are your rights
When the Alektum Group processes your personal data, you have a number of statutory rights. These are stated below. You can exercise your rights by contacting us by using the form at the bottom of this page, or via your Plan&Pay. You can, of course, also contact us by phone, at the number given in the footer.
- You have the right to obtain information from us about the use of the personal data that pertain to you, and a copy of this personal data (a so-called extract from the register).
- At your request, or of our own accord, we will correct or remove information that is incorrect or no longer necessary, or alternatively, we will limit the use of such information.
- You have the right to object to our use of your personal data for the implementation of a task of public interest, or for our legitimate interest.
- You have the right to request that your details not be used for direct marketing purposes, in the event that we undertake such actions.
- You also have the right to view the personal data we process in the execution of a contract with you, and/or if you have given us your consent, in a machine-legible format (if technically possible, we can help you to transfer this data to another party).
- If we use your personal data on the basis that you have given us your consent to do so, you have the right to withdraw this consent at any time.
Are you dissatisfied with our personal data processing? If so, you may make a complaint
If you are dissatisfied with the way we process your personal data, you may contact the supervisory authority in the country in which you live.
You can always contact us if you have any queries about the above. Contact information and contact form are available in the footer of this page.