1Introduction

By providing their personal data, the User expressly consents to TEAM4 processing that data in accordance with the terms of this Privacy and Data Protection Policy clause and for the purposes set out herein, and shall be solely responsible for the accuracy of the data provided.

Users are hereby informed that their personal data may only be collected for processing where such data is adequate, relevant and not excessive in relation to the specific, explicit and legitimate scope and purposes for which it was collected. Such data shall be erased when it is no longer necessary or relevant for that purpose, or when the data subject requests it in the exercise of their right to erasure.

TEAM4 is committed to complying with the data protection legislation in force at any given time.

2Processing of personal data

Data controller

TEAM4 COLLECTION AND CONSULTING, S.L. (hereinafter ‘TEAM4’), with tax identification number (NIF): B-85604601, registered address at Calle José Echegaray 6, 28232, Las Rozas, Madrid. Data Protection Officer (DPO) contact: dpd@team4collection.com

Purposes of data processing and legal bases

• To respond to requests for information submitted via the designated channels (email, WhatsApp and telephone) and/or forms. The legal basis for the processing is the data subject’s consent, given when they contact TEAM4 or complete the contact forms.
• Debt recovery through the management of payments via the designated section on the website and the issuance of payment receipts. The payment method available is a bank card for debt recovery via a POS terminal. The legal basis for the processing is the performance of the contractual relationship; specifically, the debt recovery process entrusted to TEAM4 by the Client to whom you owe the debt, pursuant to the contracts signed between TEAM4 and the Client.
• To include candidates in a potential recruitment process and to assess the skills listed on their CVs using the form provided in the ‘Work with us’ section. The legal basis for processing the data is the data subject’s consent, given when they submit their job application by completing the form provided.

Retention period

Contact details will be retained for as long as is necessary to fulfil the intended purposes and, in any event, in accordance with the applicable statutory time limits and limitation periods.

Data associated with candidates’ CVs will be retained for a maximum period of 2 years.

Planned transfers

For the purposes of debt recovery, data may be disclosed to financial institutions and banks for the processing of collections and payments, as well as to the customer to whom you owe the amounts in question, in order to provide proof of the payment made.

Planned international transfers

None are planned.

Rights of data subjects

You may exercise your rights of access, rectification, erasure, data portability, and restriction or objection (Articles 15 to 22 of the GDPR) by writing to the addresses given above, or to TEAM4’s Data Protection Officer:

In addition:

• You have the right to withdraw your consent where the processing is based on that consent.
• You have the right to lodge a complaint with the Supervisory Authority (Spanish Data Protection Agency: www.aepd.es) if you consider that your rights have not been properly upheld.

3Compliance Programme

As part of the Company’s commitment to the monitoring and operation of the Regulatory Compliance Management System implemented within the Company – the purpose of which is to promote a corporate culture that emphasises responsibility for compliance with current regulations and our Code of Ethics – the relevant policies on Criminal Compliance, Data Protection, Information Security and Quality have been approved.

These documents are available to business partners and stakeholders upon request via: cumplimiento.normativo@team4collection.com

Anyone who is aware of or suspects any breach, illegal act, inappropriate behaviour, etc., may, in addition to reporting it to TEAM4, use the following channels:

• Ethics channel: https://team4.canalhelas.com/home
• Postal address: for the attention of the Head of Regulatory Compliance, C/ José Echegaray 6, 28232, Las Rozas, Madrid.

These channels serve both as a means of reporting any breach of legislation and/or internal regulations, and as a means of resolving any queries that may arise in the course of the organisation’s activities, whilst ensuring at all times that the matter in question is treated confidentially and that there are no reprisals for lodging a complaint.

We wish to inform you that the processing of data via this internal communication channel is lawful pursuant to the provisions of Article 6(1)(c) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, Article 8 of Organic Law 3/2018 of 5 December, and Article 11 of Organic Law 7/2021 of 26 May; where, in accordance with the provisions of Articles 10 and 13 of Law 2/2023 of 20 February, governing the protection of persons reporting regulatory breaches and the fight against corruption, the implementation of this channel is mandatory under the legal obligation applicable to the data controller, and reports may be made anonymously at the complainant’s discretion.

4Security measures for personal data

The necessary technical and organisational measures are taken to ensure the security of personal data and to prevent its alteration, loss, unauthorised processing or unauthorised access, taking into account the state of the art, the nature of the data and the risks to which it is exposed.

The Website has an SSL (Secure Sockets Layer) certificate to ensure the security of data transmission between your browser and our Website.

The secure server establishes a connection so that the information is transmitted in encrypted form, ensuring that it is only intelligible to the user’s device and the Website’s server. Thus, the use of the SSL protocol guarantees:

• That the user is transmitting their data to the website’s server and not to any other party.
• Data transmitted between the user and the Website is encrypted, thereby preventing it from being read or tampered with by third parties.

To check that you are in a secure environment, you can:

• Check that the web page’s address begins with https://.
• Check that a padlock icon appears in your browser’s address bar.
• Check that the SSL certificate is present by viewing the page’s properties in your browser.

5Changes to the Privacy Policy

Any changes made to the Privacy Policy and information management practices will be reflected in a timely manner, and the Privacy Policy may be added to, amended or deleted as deemed necessary.

Under no circumstances will policies or practices be amended in such a way as to render them less effective in protecting personal data without the prior consent of the data subjects.

Last updated: 2 June 2024.