Who is responsible for treating your personal data?

The responsibility for treating your personal data lies with JJActivos, Gestão e Recuperação de Activos, Lda. acting as creditor. JJActivos also acts as a subcontractor in name of its creditor and according to the instructions of those responsible for the treatment of data, ensuring these instructions do not violate legal provisions pertaining data protection.

What is the purpose of treating your personal data?
When you provide us your personal data or if we have access to them as subcontractors, we treat your personal data with the following purposes:

  • For the purposes of providing services as a subcontractor, we treat your personal data according the instructions of, under the supervision of, within the limits established by those responsible for treating the personal data for the execution of the service of financial and non-financial assets management and recovery, always having under consideration the strict following of this policy;
  • For the purpose of recruiting, we treat your personal data with the legal ground of executing the required pre-contract due diligence upon request by the owner of the personal data, and according to our legitimate interest in analysing the submitted applications.
  • For the purpose of phone calls via contact centre, we treat your personal data according to our legitimate interest in ensuring that we provide the services within the context of the contracts in force with our partners.
  • In order to comply with the several legal requirements to which we are bound, we treat your personal data with the goal of fulfilling our legal obligations.
  • For the purpose of exercising or defending our rights in an in-court or out-of-court process, we treat your personal data with the goal of defending JJActivos’ rights.
  • For the purpose of replying to complaints or suggestions through the Client Ombudsman, we treat your personal data according to our legitimate interest in providing you a quality tailored service and, if applicable, the execution of the required pre-contract due diligence upon request of the owner of the personal data.

Which categories of personal data do we treat?

Within its professional activity, JJActivos collects and treats personal data required to provide financial and non-financial assets management and recovery. Within this context, and within the contexts in which the company has its activity and according to the applicable purpose, JJActivos treats:

  • Identification such as: name, birth date, gender, address, contacts, ID card details, passport, tax ID number, nationality, etc.;
  • Professional data and professional activity such as: position, role, job description, company, employer address and contacts and etc.;
  • Data pertaining the financial situation of the contracts of which the owner of the data is a signatory such as: financed amounts, contract due dates, financing conditions, financed assets or services, updated situation regarding the amounts to be collected, etc
  • Data pertaining academic qualifications such as: education, qualifications, certifications, languages, CV, etc;

As such, we may proceed with treating your personal data, which is required for the execution of the debt collection service we provide, even if your consent has not been requested nor required for the purpose.

How and how long do we store your personal data?

All the data required for the execution of the activity are stored in private databases with access restricted to qualified staff or in JJActivos’ protected datacentres, supported by a complex security management system.
The legal deadline for us to store your personal data varies according to its purpose. Therefore, we shall store your personal data according to the following deadlines:

  • To provide services as a subcontractor, according to the criteria defined by those responsible for the treatment of data, for as long as it is strictly required for the management of the contract.
  • To reply to your requests or complaints, for as long as it is strictly required for the execution of this purpose.
  • Recruitment: for 2 years from the moment of the reception of the application/CV.
  • To use call recordings made from the contact centre, for a duration of 30 days from the day of the recording.
  • To comply with legal obligations with which we are bound, we shall store your legal data for as long as it is required to comply with the applicable legal obligations.
  • Exercise or defence of a right in an in-court or out-of-court process, up to the date of the transited in rem judicatam judgement or up to the date of its out-of-court settlement.
  • In case of tenders with deadline, should there be several purposes, that which is longer

To whom do we provide your personal data?

JJActivos shall not provide your personal data to a third party, except if complying with its legal obligations which may applicable from case to case or, whenever required to provide the services contracted, to companies subcontracted for management of services vital to the activity. Some examples of external service providers acting as subcontractors include the telecommunications and IT areas.
Thus, JJActivos is follows the most strict criteria in selecting its service providers in order to comply with its legal obligations regarding data protection. JJActivos also commits to celebrate a data treatment agreement with its service providers which includes, among other: to apply suitable technical and administrative measurements, to treat the personal data exclusively for the agreed-upon purposes and exclusively following the documented instructions of JJActivos and to delete or return the data to JJActivos upon the conclusion of the services.

How to access, rectify, change, update or refuse the treatment of your personal data?

  • Right of Access to Information - You may request and obtain information on whether your personal data is being treated, as well as access them, including those in this company’s archives.
  • Right to Rectification - You may rectify your personal data when these are not correct, as well as complete those which are incomplete..
  • Right to Erasure - You may request the erasure of your personal data when, among other conditions, the personal data are no longer required for the purposes to which they were collected within the legal procedures.
  • Refuse Consent - You may request that your personal data are no longer treated. JJActivos shall cease to treat your personal data, except if there are legitimate grounds for the statement, exercise or defence of a right in an in-court process.
  • Right to Restrict Treatment - You may request the restriction of the treatment of your personal data in the following situations:
    • a) During any claim to the accuracy of your personal data;
    • b) When the treatment is not legal and you have refused it and requested the restriction to the use of your personal data;
    • c) When JJActivos no longer requires to treat your personal data, but these are required for exercising or defending a right in an in-court process;
    • d) When you have refused the treatment of your personal data for complying with an obligation of public interest or for the fulfilment of a legitimate interest, so long as those legitimate interests for the treatment prevail over its reasons.
  • Right of Portability - You shall have the right to receive, in a structured format of common use and digital reading, the personal data which were provided to us and those collected from your relationship with JJActivos, as well as to transmit them to another entity.

Should you have any questions or if you wish to enforce the above-mentioned rights, you may send an email to dpo@jjactivos.com, or contact us through our website, in the CLIENT OMBUDSMAN section. In order to exercise your rights, you must provide personal data or a document confirming your identity. You must also indicate the right you wish to exercise.
The exercise of the above-mentioned rights is tendentiously free, however, should the submitted requests be excessive or without ground, JJActivos, after a case analysis, reserves the right to charge an administrative fee of €25.00 within the terms stated within the GDPR.

If you consider that JJActivos did not treat your personal data in conformity with the applicable law, you may submit a complaint to the competent control authorities, through the website www.cnpd.pt.

Details of the entity responsible for the treatment of data:

As the entity responsible for the treatment of data or as a subcontractor, JJActivos is available not only to provide any clarifications required to this matter, but also to receive every request regarding the exercise of the rights described hereby, through the following contacts:

Identification: JJActivos, Gestão e Recuperação de Activos, Lda.
Tax Identification Number: 505 766 469
Headquarters: Rua Alberto Nobre Gusmão Martins Caro, n.º 18, 2665-526 Venda do Pinheiro
Email: info@jjactivos.com
Website: www.jjactivos.com – CLIENT OMBUDSMAN section
Telephone: (+351) 219 669 610
Contact of the entity responsible for the data protection:
Email: dpo@jjactivos.com
Address: Rua Alberto Nobre Gusmão Martins Caro, n.º 18, 2665-526 Venda do Pinheiro

Updates to the Privacy Policy

This Privacy Policy was last updated in May 2018 and is updated according to the (UE) 2016/679 of the European Parliament and Council from April 27, 2016 - General Data Protection Regulation (GDPR) - and to any applicable laws. JJActivos reserves the right to, at any time, adjust or change this Privacy Policy, as long as such adjustments or changes are duly posted.