PRIVACY POLICY
LEGAL NOTICES
Data Controller:
AXACTOR ITALY SERVICING SRL (hereinafter the “Company”), with registered office in Milan (MI) at Via Santa Marta No. 25, ZIP Code 20123, pursuant to the authorization issued by the Grosseto Police Headquarters, Div. P.A.S.I. – Cat. 13/B2025, ref. no. 13203/25, pursuant to Art. 115 of the TULPS (Consolidated Law on Public Security), Royal Decree of June 18, 1931, 733 et seq., is the Data Processor for the processing of data related to the management of individual cases entrusted to it for the performance of credit protection activities on behalf of individual creditor companies (Clients), which act as Data Controllers for such data.
Data Controller:
At the same time, AXACTOR ITALY SERVICING SRL also acts as the Data Controller for all data pertaining to its employees and contractors, as well as its suppliers, and as a joint Data Controller for the personal data of users collected on this website and its related sections, pursuant to and for the purposes of EU Regulation 679/2016 (GDPR).
Applicable Law:
The processing of personal data is governed by European Regulation (EU) 2016/679, applicable national data protection laws, and the provisions of the Italian Data Protection Authority. This Regulation aims to ensure that the processing of “personal data” is carried out in a manner that respects the rights, fundamental freedoms, and dignity of natural persons, with particular regard to privacy and personal identity.
For these reasons and in compliance with the provisions of Articles 13 et seq. of EU Regulation 2016/679, the Company is required to provide comprehensive information regarding:
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The use of personal data pertaining to individuals with whom the Company has come into contact in the course of its debt collection activities, namely debtors from whom it has requested payment of a debt via a phone call, a written communication, and/or a home visit.
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The processing of personal data of individuals who access the restricted area of the portal designated for making payments, the “Payment Portal.”
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The processing of personal data used for aggregated Business Intelligence analysis.
In order to ensure high quality standards and compliance with industry regulations, including those at the supranational level, the Company collaborates with and maintains a strong membership in the trade association UNIREC(NATIONAL UNION OF CREDIT PROTECTION COMPANIES), with which it works closely to develop and update issues related to the debt collection industry.
Data provided by the user:
The optional, explicit, and voluntary sending of messages to contact addresses, private messages sent by users to social media profiles (where this option is available), as well as the completion and submission of forms on this website, entail the collection of the sender’s contact information—necessary to respond—as well as all personal data included in the communications. Specific privacy notices will be published on the pages designated for this purpose.
Browsing Data:
The computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes the user’s IP address, the date and time of access, and the name and version of the browser and operating system. The system temporarily stores the IP address to enable the website to be delivered to the user’s computer. This requires the user’s IP address to be stored for the duration of the session. The data is stored to ensure the website’s functionality. This data is also used to prevent fraud, secure evidence in the event of cyberattacks or fraud attempts, optimize performance, review security standards, correct errors on the website, and ensure the security of our IT systems. The data will not be analyzed for marketing purposes in this regard. Browsing data is not retained for more than 12 months.
Rights of Data Subjects:
With regard to the processing described in this Privacy Policy, as a data subject, you may, under the conditions set forth in the GDPR, exercise the rights established in Articles 15 through 21 of the GDPR, and in particular:
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Article 15 Right of Access
obtain confirmation as to whether or not personal data concerning you is being processed and, if so, obtain access to your personal data—including a copy thereof—and be provided with, among other things, the following information: the purposes of the processing, the categories of personal data processed, the recipients to whom the data have been or will be disclosed, the data retention period, and the rights of the data subject.
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Article 16 Right to Rectification
to obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or the completion of incomplete personal data.
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Article 17 Right to Erasure (“Right to Be Forgotten”)
to obtain, without undue delay, the erasure of personal data concerning you.
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Article 18 Right to restriction of processing
to have the processing restricted.
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Article 20 Right to data portability
to receive the personal data concerning you in a structured, commonly used, and machine-readable format; to transmit that data to another controller without hindrance; and, where technically feasible, to have your personal data transmitted directly to that other controller, provided that the processing is based on consent and is carried out by automated means.
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Article 21 Right to Object
to object to the processing of your personal data, unless the Data Controller has legitimate grounds to continue the processing.
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Article 77 Right to lodge a complaint with the supervisory authority
to lodge a complaint with the Italian Data Protection Authority, Piazza di Montecitorio No. 121, 00186, Rome (RM).
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Article 82 Right to Compensation
to request compensation for damages resulting from a violation of the law.
Form for Exercising Rights Regarding Personal Data Protection
Personal Data of the Minor:
Please be advised that AXACTOR ITALY SERVICING SRL does not process the personal data of minors.
Therefore, we urge anyone under the age of 18 not to disclose their personal data under any circumstances. AXACTOR ITALY SERVICING SRL reserves the right to deny access to its services and does not guarantee the successful completion of any requested activities or services for anyone who has concealed their minor status.
Privacy Sanctions:
Article 83 of the GDPR, titled “General conditions for imposing administrative fines,” lists the criteria that individual supervisory authorities must apply when deciding whether to impose an administrative fine and determining its amount.
With regard to other sanctions, including criminal sanctions, Article 84 of the GDPR delegates authority to Member States to adopt all necessary measures to ensure their enforcement.
Data Protection Officer:
Requests should be addressed to the Data Protection Officer at privacy@axactor.com. Providing this notice is a general obligation that must be fulfilled before or, at the latest, at the time of commencing the direct collection of personal data. In the case of personal data not collected directly from the data subject, the notice must be provided within a reasonable timeframe, or at the time of disclosure (not registration) of the data (to third parties or to the data subject). The notices for the various categories of data subjects follow.
+ NOTICE ON THE PROCESSING OF PERSONAL DATA