Privacy Policy

We care about your privacy

GESCOBRO COLLECTION SERVICES, S.L.U. (hereinafter, collectively, and interchangeably called 'GESCOBRO', 'we', 'our' or 'us'), is a leading company in servicing of collection for third parties and in purchase of secured and unsecured portfolios in Spain.

We consider the privacy of people important, both of visitors to our website https://www.gescobro.com (hereinafter, the “website”) and any other affected parties who provide us with information through it (hereinafter and jointly, "you" or the "user" and plural, "you" or "users"), as well as those whose data are processed by GESCOBRO either by the purchase of credit portfolios or by the services that this entity provides to third parties (hereinafter and jointly, "you" and plural, "you"). In this sense, GESCOBRO undertakes to process your data in accordance with the applicable personal data protection regulations in force at all times. Specifically, GESCOBRO will comply with the premises established in: REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter, "GDPR"), the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (hereinafter, "LOPDGDDD") and any other correlative regulations of application in force at any given time. Likewise, GESCOBRO is adhered to the Code of Ethics and Conduct of the National Association of Collection Entities (ANGECO), which is available on the websites www.angeco.com and www.agdp.es.

The purpose of this Data Protection Policy is to explain how we process, control and manage your personal data. You can obtain further information, if necessary, at the time of collecting your personal data. Therefore, before sending any form or curriculum through this website, you will be informed of the processing of your data and the purposes for which they are obtained. Regardless of the above, the user of the website will be solely responsible for the possible consequences of filling in the forms with false, inaccurate, incomplete or outdated data and if in the future GESCOBRO wishes to use it for purposes other than those referred to, we will inform you of these new purposes and request your consent, if necessary.

In connection with the foregoing, we encourage all users to read this Privacy Policy carefully to learn about the standards and practices we have developed to protect personal data and to learn more about our relationships with third parties who may have access to such data.

By using our website, you acknowledge that you have read and agree to this Privacy Policy, our Cookie Policy and our Legal Notice.

The provisions of this Policy shall apply in the following cases:

a) If you decide to provide us with your personal data, GESCOBRO may have the data that appears in each of the forms that you fill in or those that you provide via the different email accounts that GESCOBRO makes available to contact us.

These data are processed when you interact with GESCOBRO and our representatives; when you participate or request to be considered to participate in activities related to GESCOBRO, such as services; when you interact with the website when it asks you to provide personal data, as described in this Privacy Policy and Cookie Policy; when you register on our website or use certain functionalities without registering, such as participating in our interactive services. We also collect your personal data relating to your application for a job, including your contact details, first and last name and details relating to your work and educational experience, when you complete the form in the CAREERS section.

b) In the event that your personal data have not been obtained directly through our forms, it will mean that GESCOBRO has either purchased your debt from the originating entity, becoming the new controller of the processing of your personal data and therefore having legitimacy for the use and processing of the same; or, that such data have been transferred by a third party for the management and collection of legal, valid and enforceable dues.

These data are processed for the management of the payment of the fees, and this party must defend its legitimate interest and/or that of its client, as established in article 6 of the RGPD, and it is not necessary for this party to obtain your consent for this purpose.

c) Personal data that our website obtains from your computer or electronic device:

• Cookies, only for https://www.gescobro.com.

For more information on the use of cookies by GESCOBRO, see our Cookies policy de cookies.

Who is responsible for the processing?

Contact details of the data controller: GESCOBRO COLLECTION SERVICES, S.L.U., with CIF B-65257800 and address at calle Acanto, 22, Planta 5ª, 28045 de Madrid and contact email address compliance@gescobro.com.

We also inform you that GESCOBRO has a Data Protection Delegate, who can be contacted at the following email address: dpo@gescobro.com.

Hereunder we provide information on the use that GESCOBRO will make of your personal data in your condition as a user of the website (the "Website").

How do we use personal data of users?

GESCOBRO communicates to the users to whom it applies, that the personal data that they provide, and/or we collect will be identified in the Register of Treatment Activities owned by GESCOBRO, being used for the purpose of:

• Respond to inquiries or requests for information that users may make.
• Provide our services in accordance with the Legal Notice.
• The use or provision of services, where appropriate, prior user registration, in accordance with the general conditions of use of the Web and the conditions of certain services.
• In the event that the user has ticked the corresponding box for such purposes, keep them informed by sending notifications / newsletters by email and / or other electronic means, the content of which will be mainly about our services, activities, projects, updates and new features of the website. Use them for any other purpose required or permitted by applicable law or for which you have given your consent.
• Personalize and improve the tools and functionalities of the Web, as well as guarantee the technical functioning of the same.
• For the purpose of recruitment for a position with GESCOBRO. We may also request former employers for references from you, provided we have obtained their prior permission or consent.

Why do we process your personal data?

GESCOBRO may process your personal data based on any of the following legal bases:

• When you have given your consent.
• when processing is necessary for the performance of GESCOBRO's legal and regulatory obligations.
• When the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.

Who can access your personal data?

Depending on the purposes for which the personal information is collected, the following people can access such information, interchangeably:

• Authorized GESCOBRO personnel or their representatives acting on behalf of GESCOBRO, subject to the applicable data protection laws.
• Regulatory authorities or other third parties in accordance with applicable laws.
• Third parties (service providers that process information as data processor, under the instructions of GESCOBRO). All this only after taking the necessary measures to ensure that we can share such information in compliance with applicable data protection laws. We will not sell or disclose to third parties any information or personal data that you have provided on our website that could directly or indirectly identify you.
• Your personal data may be accessed by third party recruitment service providers who, as a consequence of providing such services, access and process such personal data on behalf of and for the account of GESCOBRO, as processors.

Where is your personal data processed?

• GESCOBRO will not carry out transfers of personal data outside the European Economic Area (EEA). In the event that such transfers were made,
• GESCOBRO would do so in compliance with the applicable data protection laws. Regardless of where your personal data is collected or processed,
• GESCOBRO watches over and guarantees that service providers maintain appropriate administrative, technical, and physical security measures to protect information about you.

For more information on the use of the contract models by GESCOBRO, please contact us at compliance@gescobro.com

How do we protect your personal data?

GESCOBRO maintains the security levels of data protection required by current legislation on the Protection of Personal Data and has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorised access and theft of data that the user provides through the website or that have been collected under the corporate purpose of GESCOBRO.

In any case, GESCOBRO will take appropriate technical and organizational measures, both when designing the data processing system and at the time of the processing itself, to preserve security and prevent unauthorized processing.

However, despite the diligent implementation of such measures, the user must know that Internet security measures are not impregnable, you must bear the terms and conditions of our Legal Notice.

How long will we keep your personal data?

If you have taken part in a selection process, your personal data will be kept until the end of that process. Once the process has been completed, your personal data will be kept, duly blocked, for a period of three years to deal with any possible liabilities that may arise from the processing. However, if you request that your curriculum vitae be taken into account for successive selection processes opened by Gescobro, we may continue to keep your data for a further year without blocking, after which time they shall be kept again, duly blocked, for a period of three years to attend to any possible liabilities that may arise from the processing.

Likewise, in relation to any data we may have received in connection with references to former employers, they will be kept until the end of the selection process and, thereafter, your personal data will be kept, duly blocked, for three years to attend to any possible liabilities that may arise from the processing.

Confidentiality

The professionals who work at GESCOBRO and who have some kind of intervention in the services provided to the user, are committed not to disclose or make use of the information they have accessed. The information provided by the user will, in any case, be considered confidential, without it being used for purposes other than those related to the management linked to their requests and the services contracted from GESCOBRO, when appropriate. In this sense, we undertake not to disclose or reveal information about the user's claims, the reasons for the requested advice or the duration of their relationship with the user.

Similarly, GESCOBRO requires its suppliers to share its own measures of conduct and ethics, as well as care in the treatment of data, and all of them must adhere to the policies we have in this regard.

Social networks

GESCOBRO is present on some of the main social networks on the Internet, and for which it acts as the data controller in relation to the data published by GESCOBRO.

GESCOBRO will process the data in each social network according to the rules established for this purpose by each social network. Therefore, and as long as the contrary is not stated, GESCOBRO can inform its followers in the corresponding social network about our activities, events, and other related topics, including attention to the follower, through the channels that the social network provides for this purpose.

GESCOBRO will not extract personal data from social networks unless the user gives us their express consent.

Creditworthiness files

We hereby inform you that we may communicate, under the conditions and with the requirements provided for in the regulations, the data of non-payment to the following credit information systems:

• Asnef file: Asnef Equifax Servicios de Información sobre Solvencia y Crédito. Apartado de correos10546, 28080 Madrid (sac@equifax.es).
• Badexcug file: Apartado de correos 1188, 28108 Alcobendas (badexcug@experian.com).

Special category of personal data

We will not collect or process any particularly sensitive personal data or included in the special category of users' personal data unless they have been explicitly provided to us. The special categories of personal data refer to information related to race or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, union affiliation, genetic data, biometric data for the exclusive purposes of identifying a natural person, health data, sex life or sexual orientation.

Policy on child use

This website is not designed or directed to children under eighteen (18) years of age, without parental or legal guardian authorization. In this regard, we do not knowingly collect information from such individuals. In any case, if parents or legal representatives consider that their children have sent us personal data, without their consent, contact us by writing to compliance@gescobro.com

Direct marketing

We will not use the personal data obtained for direct marketing purposes without their express prior consent.

If at any time you decide to stop receiving commercial or promotional information from GESCOBRO, you can, free of charge and without having to provide a justification, unsubscribe from direct marketing campaigns and oppose the future processing of your personal data for such purposes by sending us an email to compliance@gescobro.com or by clicking on the 'opt-out' (unsubscribe) in the subject of the email. You can also use the unsubscribe procedure provided in any promotional message you receive from GESCOBRO.

Note that even if you decide not to subscribe or unsubscribe from promotional emails or newsletters, we may still need to contact you regarding important non-commercial information, such as troubleshooting, error detection and prevention or in general to comply with the Legal Notice and / or Terms and Conditions of the website or our corporate purpose.

Automated decision making

We will not use automated decision-making processes, including profiling, unless you have explicitly authorized us to do so. In that case, we would inform you about the logic used in the decision, as well as about the meaning and expected consequences of such processing for you.

Links to other websites

On the GESCOBRO websites there are links to other websites that we consider potentially useful and informative for you. However, keep in mind that we do not endorse or recommend the content or services of such websites, nor are we responsible for their privacy policies. We recommend that you consider and read the privacy policies of all the sites you visit. Remember that what is indicated in this Privacy Policy only applies to the data that GESCOBRO collects and / or processes.

Modifications and integrity of our Privacy Policy

We will only use your personal data as established in the Privacy Policy in force at the time we collect your personal data. GESCOBRO reserves the right to modify this Privacy Policy at any time, publishing such modifications on our website, so we recommend that you visit it each time you access the Privacy Policy. If at any time we decide to use personal data in a different way than what was declared at the time it was obtained, we will notify you by email, as long as we have it. At that time, you will be given the option to authorize other uses or disclosures of the personal data that you have provided us before the modification of our Privacy Policy.

In the event that any clause of this Privacy Policy is annulled or considered void, the rest of the conditions will not be affected, fully preserving their validity and, in accordance with current regulations applicable at all times.

What are my rights?

• Right of access: You may exercise this right to know whether or not GESCOBRO is processing your personal data and, in the event that such processing is being carried out, to obtain information about the purpose of the processing, the origin of the data and the communications/transfers carried out or planned.
• Right of rectification: You may request the exercise of this right in order to obtain the rectification of your personal data that are inaccurate without undue delay.
• Right of opposition: You must request the exercise of this right when you wish to oppose GESCOBRO's processing of your personal data.
• Right of erasure: This right should be exercised when the purpose is the erasure of your personal data, bearing in mind that this may be effective: when your personal data is no longer necessary in relation to the purposes for which it was collected or processed, if the processing was based on consent when consent is withdrawn, if your personal data has been processed unlawfully, etc.
• Right of limitation: You may exercise this right to obtain the limitation of the processing of your data by GESCOBRO whenever the accuracy of the data is contested, when you have objected to the processing of your data on the basis of legitimate interest or public interest mission, when the processing is unlawful, when the data is no longer required for the purposes of the processing, etc.
• Right of portability: This right can be exercised when you wish to ask GESCOBRO to provide your data to another entity, it will be executed when the processing is carried out by automated means, you receive your personal data in a structured, commonly used, machine-readable and interoperable format, and you can transmit it to another data controller, provided that the processing is legitimate on the basis of consent or within the framework of the performance of a contract.
• Right not to be subject to automated individual decisions: You must exercise this right in order not to be subject to a decision based solely on the processing of your data, including profiling, which produces legal effects concerning you or similarly significantly affects you.

How can I exercise my rights?

You may at any time exercise your rights of access, rectification, opposition, deletion, limitation, portability of your personal data, as well as to withdraw your consent and not to be subject to an automated decision, in accordance with the regulations in force.

You may request to exercise these rights through any of the following channels:

• By e-mail to: compliance@gescobro.com.
• By post to the following address: Calle Acanto, nº 22, 28045 Madrid.

In order to process your request in accordance with the regulations, as well as to be able to identify you correctly, we may contact you to request additional information before responding to your request.

Regarding to processing based on legitimate interests, you may request information concerning the weighting carried out by GESCOBRO, as well as opposition to any such processing.

In any case, you may request the protection of the Spanish Data Protection Agency through its website: www.aepd.es.

GESCROBRO will at all times try to provide you with a response within the established legal period, which does not exclude that, occasionally, this period may have to be extended, up to two more months, because we have received a large number of requests or particularly complex requests, which prevent us from being as effective as we would like to be. However, should this happen, you will be always informed of this need.

Please note that in the event that we are the data controller of your personal data, your request can only be dealt with by the data controller, however, we will be at your disposal to tell you how to proceed.