Privacy Notice

Introduction

This Privacy Notice is aimed at being transparent and informing you about the use of your personal data (“Personal Data”).

Who we are

DRS Belgium SRL, with registered address at Rue Joseph Stevens 7, B-1000 Brussels (Belgium) and registered with the Crossroads Database for Enterprises (BCE/KBO) under number 0452.511.928, and 

Deminor Recovery Services (Luxembourg) SA, with registered address at 1, Rue Jean-Pierre Brasseur, L-1258 Luxembourg and registered with the Register of Commerce of Luxembourg under number B175299, (as joint data controllers and collectively “Deminor”, “We”, “Our” and “Us”)

Legal basis

We process Personal Data based on:

  • Consent: your specific consent
  • Contractual obligations: a contract of services or agreement (the “Contract”) concluded with Us.
  • Legal obligations: Our compliance with the law
  • Legitimate interest: a business or commercial reason to use Personal Data, as long as not overridden by your rights and interests.

Whenever the processing of Personal Data is based on your express consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of such processing before the withdrawal of consent.

Information We collect

We collect Personal Data (1) through Our websites https://www.mydeminor.com and https://www.deminor.com (the “Website”) or by other means, including other websites managed by Us or other means of communication (mails, registration forms, etc; (2) during the conclusion of a Contract; and (3) through cookies.

Categories of Personal Data We may process include (as applicable):

  • Identification data: national identification document, signature, gender
  • Contact details: first and last name, email address, contact number, company, profession, title, physical address
  • Technical identifiers: login of the website account, logs, IP address, browser data
  • Financial data: bank account number, transaction data, VAT number if applicable
  • Contractual data: language, interest in a case, registration to a case, household composition, any other necessary information to conclude and/or execute the Contract.

For more information about cookies, please refer to Our Cookie Statement.

Use of Personal Data

Your Personal Data will exclusively be used to the extent necessary to:

  • comply with anti-money laundering and KYC legal requirements
  • conclude and perform the Contract
  • subject to your explicit consent given via Our Website or other websites managed by Us, to inform you about Our activities, events and/or the evolution of a case for which you have shown interest.

We may combine the Personal Data you submit with other data We have obtained about you for the same purposes from other sources, including if you have provided your information to Us in other places or through another medium.

We may use your Personal Data for internal statistical purposes.

We may not use Personal Data for new purposes, which are as yet unforeseen in this Privacy Notice except on the basis of an applicable legal provision or your consent. In any event, prior to using Personal Data for other purposes, We will inform you about such change and in case of consent-based activities, We will offer you the chance to refuse these changes.

Special category of Personal Data

We will not collect or process any special category of Personal Data unless you have explicitly provided Us with such data. The special categories of Personal Data concern information relating to race or ethnical origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health, sex life or sexual orientation.

Direct marketing

We will not use your Personal Data for direct marketing purposes without your explicit prior consent.

If at any time you decide not to receive any commercial or promotional information from Us, you may, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and object to the future processing of your Personal Data for such purposes by sending an email to Us at dpo@deminor.com and mention “opt-out” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any promotional message you receive from Us.

Please note that opting out from receiving promotional messages from Us will not exclude you from receiving information that relates to any Contract you may have entered into with Us.

Automated decision-making

We will not make use of automated decision-making processes, including profiling, unless you have explicitly authorized Us to do so. In such case We would inform you about the logic involved in the decision, as well as the significance and the envisaged consequences of such processing for you.

Sharing Personal Data and transferring Personal Data to third countries

We will not make Personal Data available to any third party and shall not publicly disclose the Personal Data unless such transfers are based on your specific consent, necessary for the performance of the Contract (such as the transfer of Personal Data to a court, to a regulatory authority or to the adversary parties), or when such transfer of Personal Data is compulsory by law or by order of an administration or judicial authority. We may transmit Personal Data within the Deminor group of companies in order to offer you an optimum range of services.

Please note that whenever Personal Data is transferred to processors or third parties located outside the European Economic Area, We ensure one of the following safeguards is implemented:

  • the country is considered by the European Commission to guarantee an adequate level of personal data protection, or
  • We apply the standard contractual terms approved by the European Commission.

We also ensure that appropriate technical and organisational measures are in place within the Deminor group of companies and with any third party processors.

Retention Period

Personal Data is only kept for as long as required, under applicable legal retention rules, and/or to fulfill our legal and contractual obligations pursuant to the Contract, and/or as long as expressly consented for direct marketing purposes.

Security and confidentiality

We have implemented technical and organisational security measures in accordance with standard industry practices to prevent Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Nevertheless, security requires efforts from all parties. We thus encourage you to take appropriate security measures yourself, including using strong passwords and keeping all user names and passwords confidential.

Children on the Website

This Website is not intended for or directed to children under 16. We do not knowingly collect any information from such individuals. If you believe your child has provided Us with Personal Data, please contact Us at dpo@deminor.com

Your rights

At any time, you may exercise the right to:

  • request access to Personal Data, or
  • request rectification of Personal Data, or
  • request erasure of Personal Data, or
  • object to processing of Personal Data, or
  • request restriction of processing to Personal Data, or
  • request the transfer of Personal Data, where technically possible

in compliance with applicable data protection law, by sending a signed request with a copy of your ID card, passport or other proof of identity to dpo@deminor.com or in writing to DRS Belgium SRL (Attn: Data Protection Officer), 19th Floor, Sablon Tower, Rue Joseph Stevens 7, 1000 Brussels, Belgium.

You also have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, your place of work, or the place of the alleged infringement.

The Belgian data protection authority is located at Rue de la Presse 35, 1000 Brussels, Belgium or can be contacted through https://www.autoriteprotectiondonnees.be/citoyen,

The Luxembourg data protection authority is located at 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg or can be contacted through https://cnpd.public.lu/en.html.

Effective date and changes

This Privacy Notice was created on and has been in effect since 10 February 2017. We reserve the right, at Our complete discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. You should check back periodically at this page to read the most recent version of this Privacy Notice as your continued use of this Website following the posting of changes to these terms will mean you accept these changes. Notwithstanding the foregoing, We will not retroactively make material changes to Our use of your Personal Data without your consent. 

Data Protection Officer

Please address questions, comments, and requests regarding this Privacy Notice and Our privacy practices to Our Data Protection Officer at dpo@deminor.com.