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Privacy Policy

Introduction

This Privacy Policy is designed to inform you about the personal data relating to you which DRS Belgium SCRL / CVBA, with registered office at Rue Joseph Stevens 7, B-1000 Brussels (Belgium) and registered with the Crossroad Bank for Corporations (BCE/KBO) under number 0452.511.928, and Deminor Recovery Services (Luxembourg) SàRL, with registered office at 1, Rue Jean-Pierre Brasseur, L-1258 Luxembourg and registered with the Register of Commerce of Luxembourg under number B175299, (acting as joint data controllers and hereinafter collectively referred as “Deminor”, “We”, “Our” and “Us”) collect via the website https://www.mydeminor.com (referred to hereinafter as the “Website”) or by other means, why We collect such personal data, on which basis, and how We will handle personal data you provide Us with and personal data We learn about you from your visit to the Website.

 

Legal basis

We process your personal data either on the basis of your specific consent granted via our Website or on the basis of the contract of services (referred to hereinafter as the “Contract”) you have chosen to enter into with Us.

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

 

Personal data collected

We collect personal data (referred to hereinafter as “Personal Data”) relating to you in three ways:

  • In the course of the conclusion of the Contract.
  • Through registration and sending of information that you choose to enter on certain pages of the Website. The information marked with the “*” symbol must be provided, in order to enable Us to fulfill the processing purposes, as mentioned below. Such Personal Data directly collected from you include your first and last name; personal address; company; profession; title; mobile or other phone number; login of the website account; logs; IP address; fax number; transaction data; VAT number; two-sided copying of the identity card; remarks; language; date of birth; place of birth, country of birth; household composition; interest in a case; registration to a case; any other information that We will need to process in order to enter into and/or execute the Contract.
  • Through cookies. For more information about cookies, please see below.

 

Use of Personal Data

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

  • register to the Website in order to obtain certain information
  • enter into and sign the Contract
  • execute the Contract
  • and, subject to your explicit consent given via our Website, to inform you about our activities 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 your Personal Data for new purposes, which are as yet unforeseen in this Privacy Policy except on the basis of an applicable legal provisions or your consent. In any event, prior to using Personal Data for other purposes, We will inform you about such change to this Privacy Policy and in case of consent-based activities, We will offer you the chance to decline participation in these changes.

 

Special category of personal data

We will not collect or process any special category of personal data relating to you 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 oppose to the future processing of your Personal Data for such purposes by sending an email to Us at drs@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 your 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.

Please note that whenever your Personal Data are transferred to processors or third parties located outside the European Economic Area in countries which are not considered by the European Commission to guarantee an adequate level of personal data protection, We will ensure that appropriate measures are implemented according to the applicable national and European legislation relating to data protection. You may obtain a copy of the appropriate safeguards taken by sending an email to Us at drs@deminor.com.

 

General information about the cookies used

Our website is hosted on a Hubspot environment. HubSpot's tracking code sets a number of tracking cookies when a visitor lands on your site. These cookies fall into two general categories:

• Essential/necessary cookies: essential cookies which do not require consent.
• Consent banner cookies: cookies included in the consent banner under GDPR.

Essential/necessary cookies

__hs_opt_out
This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt-out of cookies.
(Expires: 13 months)

__hs_do_not_track
This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, as it still allows anonymized information to be sent to HubSpot.
(Expires: 13 months)

hs_ab_test
This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before.
(Expires: end of the session)

<id>_key
When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page.

hs-messages-is-open
This cookie is used to determine and save whether the chat widget is open for future visits. It resets to re-close the widget after 30 minutes of inactivity.
(Expires: 30 minutes)

hs-messages-hide-welcome-message
This cookie is used to prevent the welcome message from appearing again for one day after it is dismissed.
(Expires: 1 day)

__hsmem
This cookie is set when visitors log in to a HubSpot-hosted site.
(Expires: 1 year)

Consent banner cookies

__hstc
The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
(Expires: 13 months)

hubspotutk
This cookie is used to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.
(Expires: 13 months)

__hssc
This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
(Expires: 30 min)

__hssrc
Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
(Expires: end of session)

If you are logged in to HubSpot, HubSpot will set additional authentication cookies. Learn more about cookies set in the HubSpot product. You can also see whether a contact accepted these cookies in their timeline.

messagesUtk
This cookie is used to recognize visitors who chat with you via the chatflows tool. If the visitor leaves your site before they're added as a contact, they will have this cookie associated with their browser. If you chat with a visitor who later returns to your site in the same cookied browser, the chatflows tool will load their conversation history. This cookie is controlled by the Consent to process setting in your chatflow.
(Expires: 13 months)

 

Additional information about specific cookies

Google Analytics: This Website uses Google Analytics, which is a web data analysis tool of Google Inc. (Google). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.

Since we have activated the anonymization of IP-addresses transferred, Google will prior to such transfer truncate/anonymize the last octet of the IP address within Member States of the EEA. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/.

Please note that on this Website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking).

 

How to prevent cookies to be set

You may prevent cookies to be set by adjusting your browser accordingly. Indeed, most web browsers allow some control of most cookies through the browser settings. To find out more about how to prevent cookies to be set, visit http://www.allaboutcookies.org.

However, in such case, certain features of the Website may not work properly and some functionalities of the Website might no longer be available to you.

 

How to delete/deactivate cookies

In order to delete/deactivate all cookies set on your computer, the majority of web browsers allow you to disable completely the use of cookies, or to delete cookies created by specific domains/websites. To find out how to do it, please refer to your browser’s help page:

You can specifically prevent Google’s collection and use of data (cookies and IP address) for any website you visit by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.

You may also specifically refuse the use of Google Analytics on this Website by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this Website:
<a href="javascript:gaOptout()">Disable Google Analytics</a>.

 

Links to third parties websites

On certain areas of this Website, We may provide links to third parties websites. These links are provided as a convenience to you; however please be aware that We do not control the third parties or their websites and that those third parties will have a different privacy policy applying to information collected from you when you are on those third parties’ websites. You should read the privacy policies of all websites carefully before providing personally identifiable information.

 

Storage duration

We will retain your Personal Data only as long as necessary for the fulfilment of the purposes described above or as required by law

 

Security and confidentiality

We have implemented technical and organisational measures in accordance with standard industry practices to ensure an appropriate level of security of the Personal Data processed. Nevertheless, security requires efforts from all actors involved. We thus encourage you to contribute to these efforts by taking 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. Parents, if you believe your child has provided Us with Personal Data, please contact Us at drs@deminor.com.

 

Your rights

At any time, you may exercise your right to request access to or rectification of and, as the case may be, erasure of any Personal Data relating to you, or to object to processing, or restriction of processing, as well as your right to data portability, in compliance with applicable data protection law, by sending a signed request form with a copy of your ID card, passport or other proof of identity to drs@deminor.com or in writing to DRS Belgium SCRL/CVBA (Attn: Back Office), 19th Floor - Sablon Tower – Rue Joseph Stevens 7, B-1000 Brussels - Belgium.

As a data subject, you have a right to lodge a complaint with a supervisory authority if you consider that the processing of Personal Data relating to you infringes the applicable legislation relating to data protection.

 

Effective date and changes

This Privacy Policy was created on and has been in effect since February 10th 2017. We reserve the right, at Our complete discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. You should check back periodically at this page to read the most recent version of this Privacy Policy 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.

Thank you for visiting this Website. This policy was last updated on January 31st 2020.

Data Protection Officer

If you have any question/remark, or if you want to make a complaint related to our Privacy Policy, you can reach out to our Data Protection Officer by email : dpo@deminor.com