How do we obtain your personal data?
We may receive your personal data in the following ways:
• From our clients: When a client hires us to collect outstanding debts, we receive the personal data necessary for this. This is required to carry out our debt collection services.
• Directly from you: You may provide us with personal data yourself, for example when you contact us and share information about yourself.
• From public sources: We may obtain data from public registers.
• From third parties: Sometimes we receive information from other parties, such as bailiffs or lawyers. This only happens if it is legally permitted and necessary for our work..
What personal data do we process?
In carrying out our work ACCS processes various personal data, including but not limited to:
• Name, address, and place of residence
• Date and place of birth
• Gender
• Contact details, such as email address and phone number
• Bank account number
• Financial information
• Data related to the claim (such as claim details, invoice number, vehicle registration number, payment information, recovery options, insolvency data, information resulting from a bailiff’s writ issued on behalf of ACCS, data from public registers, correspondence, etc.)
• Footage from security cameras
Which personal data we process depends on the specific situation.
Sensitive and special categories of personal data
ACCS recognizes that financial data are sensitive personal data. However, processing these data is necessary to perform our duties properly. There is no less intrusive way to do this. We only process data that are strictly necessary, this is called data minimization.
In principle, ACCS does not process special categories of personal data. In exceptional cases we may do so based on a compelling legitimate interest or laws that permit this in certain circumstances or activities.
On what legal grounds do we process your personal data?
Any organisation that processes personal data may only do so if there are legitimate purposes. We process personal data on the following legal grounds:
• The data subject has given their explicit consent for the processing of their personal data.
• The processing is necessary for the performance of a contract to which the data subject is a party.
• The processing is necessary for compliance with a legal obligation to which the data controller is subject.
• The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party to whom the data are disclosed.
How long do we keep your personal data?
We keep your personal data only as long as necessary for the purpose for which we collected them. If we no longer need your data for that purpose, we delete them. However, sometimes we are legally required to keep your data for a longer period.
In most cases ACCS keeps your personal data for up to 7 years after closing your file. After that, we delete your data from our systems.
With whom do we share your personal data?
ACCS shares your personal data with other parties only if necessary to perform the contract or to comply with a legal obligation. We enter into data processing agreements with companies that process your data on our behalf. These agreements include strict requirements to protect the security and confidentiality of your data. This way, we ensure your data are well protected.
If we transfer your personal data to companies located in a third country, we ensure appropriate safeguards are in place.
How do we protect your personal data?
To protect your personal data, ACCS has implemented various measures:
• Technical measures, such as secure systems and encryption
• Human measures, including training our staff on privacy
• Physical measures, such as secured buildings and access controls
• Technological controls to reduce risks
We comply with recognized quality standards, including ISO 9001:2015 and ISO 27001:2022. Additionally, we ensure ongoing compliance with applicable privacy laws.
What privacy rights do you have?
You have several rights to control your personal data. These include:
• Right of access. You can ask which personal data we use about you.
• Right to rectification. If your data are incorrect or incomplete, you can ask us to correct or complete them.
• Right to erasure. In certain situations, you can ask us to delete your personal data.
• Right to withdraw consent. If you previously gave us permission to use your data, you can withdraw that consent at any time.
• Right to object. In certain cases you can object to the use of your personal data, for example for specific personal reasons. We will carefully consider and weigh your request.
• Right to lodge a complaint. If you disagree with how we process your data, you can contact our Managing Director. You also have the right to file a complaint with the data protection authority.
Contact
Do you have questions or complaints about privacy? You can contact:
Name: Didier van Wordragen (Managing Director)
Address: Julianaplein 39-D, Willemstad, Curaçao
Phone: 0059 99 788 00 61
Email: info@accs-caribbean.com
The Managing Director will, where necessary, liaise with the Privacy Officer of the Dutch sister organizations.
