This Privacy and Cookies Notice (the “Notice”) applies when you visit Our website https://www.pragroup.pl/ and www.mypage.pragroup.pl/ (the “Website”) (regardless of where you visit it from) or contact Us through the Website, by email, letter or telephone. We respect your privacy and so the security and privacy of your personal information are important to Us. We are committed to safeguarding and preserving your privacy when you visit and use the Website or you communicate electronically or otherwise with Us.
If you are also a customer of Horyzont Non-Standardised Debt Closed End Investment Fund with its registered office in Warsaw (“HORYZONT”), serviced by PRA Group Polska Sp. z o.o., you will have also received a copy of Our Data Protection Notice when We first wrote to you when We acquired your account. The Data Protection Notice sets out how We process your personal data to manage your account, while this privacy and cookie notice sets out how We process your personal data when you visit the Website or you communicate with Us.
This Notice, (together with the Website use Rules of using the website, the Data Protection Notice) sets out the basis upon which any personal information We collect from you, from third parties, or that you provide to Us, shall be processed by Us. It also explains the purposes for which We process your personal data, with whom We may share your personal data and the rights to which you may be entitled.
We may decide or may be legally obliged to amend and update this Notice from time to time so please ensure you read this Notice every time you use the Website or communicate with us.
The Website is operated by PRA Group Polska sp. z o.o. with its registered office in Warsaw, ul. Prosta 68, 00-838 Warsaw, entered into the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the number KRS 0000517951, NIP: 5213568112, share capital in the amount of PLN 11,951,000.00 paid up in full which is the servicing entity of HORYZONT which is a “data controller” of your personal data (“PRA”). In this notice, PRA, itself, or together with any member of its group (“PRA Group”) may be referred to as ‘We’ or ‘Us’ or ‘Our’.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you that is provided to Us by you or a third party, authorised to do so on your behalf, when you or they contact Us, and when making a payment, completing forms, responding to surveys, and any other responses to requests for information on the Website or when We communicate with each other.
We have grouped this personal data as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details, information from your credit file, income and expenditure and further information allowing you to manage your account.
- Transaction Data includes details about payments you have made to Us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
- Profile Data includes your username and password, your feedback and survey responses.
- Usage Data includes information about how you use the Website, including, but not limited to, traffic, click tracking, location, weblogs and other such data, and the resources that you access from the Website and Information you provide when you report a problem with the Website.
- Communications Data includes your preferences in receiving communications from Us and Our third parties and your communication preferences.
- Experience Information includes information about your experience with us that you may discuss with us when communicating with us.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, SMS, Live Chat or otherwise. This includes personal data you provide when you:
- log into your account on Our websites, speak to an agent on the phone, SMS, or chat
- request communication to be sent to you.
- complete a form or survey.
- give Us feedback or contact Us.
- Automated technologies or interactions.
As you interact with the Website, We will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing Our cookies. Please see our cookie section for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data through our service providers which process personal data on our behalf for website analytical activities e.g. Google;
- Contact, Financial and Transaction Data from payment service providers e.g. PayU;
Information from the previous account holders.
- When your account is transferred to Us, as part of the new contractual agreement, We receive information from your creditor to create your account. This allows you to manage your account online and continue to make payments towards your debt. Data includes: your Identity, Contact and Account Information including outstanding balance, payment history and detail of defaults and missed payments.
We use information We collect about you in the following ways:
- To collect your debt and to assist you in managing your account, including setting up of an affordable payment plan and assessing the affordability of such plan;
- To ensure that content from the Website is presented in the most effective manner for you and for your computer, this will include performing tests on our Website to improve your experience on our Website;
- To provide you with information that you request from Us or which We feel may interest you, and where you have consented to be contacted for such purposes;
- To allow you to participate in interactive features of Our service, when you choose to do so;
- To notify you about changes to Our service;
- To allow you to make payments safely and securely on the payments page of the Website;
- For research and analysis purposes, including assessment of your likelihood to make payments to your account;
- To prevent fraud, money laundering and any other criminal activity;
- To discuss your experience of PRA as a result of feedback you have provided;
- For other purposes as set out in Our Data Protection Notice .
Where you have requested that We contact you, and you provide Us with your name, together with your address, telephone numbers or e-mail address for this purpose, you consent to being contacted by these methods, for these purposes.
We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us.
If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.
Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions, and they are subject to a duty of confidentiality.
You should be aware that the transmission of information via the internet is not completely secure and therefore We cannot guarantee the security of any information you send to Us electronically, and transmission of such information is therefore entirely at your own risk.
Where We have given you (or where you have chosen) login details, including a password so that you can access certain parts of the Website, you are responsible for keeping these login details confidential. We will accept no liability for unauthorized use of your login details on the Website.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.
We may disclose your personal information to any member of PRA Group. This includes, where applicable, Our subsidiaries, Our holding companies and their other subsidiaries (if any).
We may also disclose your personal information:
- To prospective purchasers of any or all of our business and/or our business assets and their advisors
- To relevant authorities, where We are under a legal obligation to disclose your information, and to prevent fraud and money laundering
- To any third party who provide services to Us as a data processor
- To payment services providers, to facilitate payments made by you via the payments page of the Website
- In order to protect and enforce Our rights
- Where We are entitled to by law
- To third parties to facilitate credit risk reduction
- To other third parties as set out in the Data Protection Notice
We or some of Our third party service providers (including but not limited to merchant services suppliers) may transfer personal information We or they collect outside the European Economic Area (“EEA”) for processing, storing and related purpose. We will only transfer your personal information outside the the EEA, where We can ensure there will be in place, adequate levels of protection for your personal information. We shall ensure a substantially similar degree of protection is afforded to your personal information to that within the EEA, and that such levels of protection comply with applicable laws.
The transfer of your personal data outside the EEA is based on the relevant GDPR regulations, including the EU Commission’s adequacy decision, or binding corporate rules (BCR) or standard contractual clauses (SCCs). You have the right to obtain from us a copy of the BCR or SCCs in this regard. We assure you that we will take all reasonable steps to make sure that your personal data is safe, and that their processing and storage is carried out in accordance with applicable law.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you.
To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask Us to delete your data: see section “Your rights” below for further information.
In some circumstances We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.
If you provide Us with personal information about another person, you confirm that they have appointed you to act for them, and that you have informed them of Our identity and the purposes for which their personal information will be processed as set out in this Notice.
Under data protection laws you have certain rights in relation to your personal data. Please note that many of these rights are not absolute and We may have grounds to not fully comply with your request (for example where We are required by law to process your personal data in a way that is incompatible with your request or b. able to rely on exemptions under data protection law which entitle Us to process your personal data in a way that is incompatible with your request). Where such circumstances exist, We will inform you at the time you make a request to exercise your rights.
- Right to access your personal data – You have the right to ask for a copy of the personal data We hold about you.
- Right to rectification of your personal data – If you believe that any of the personal data We hold for you is incorrect, it is important that you make Us aware as soon as possible, so that We can rectify Our records.
- Right to erasure (right to be forgotten) – You have the right to request that We delete data relating to you.
- Right to restriction of processing – You have the right to request restriction of processing of your personal data.
- Right to data portability – You have the right to receive the personal data you have provided to Us in a structured, commonly used and machine-readable format and the right to have that personal data transmitted to another data controller.
- Right to object to processing – You have the right to object to processing based on legitimate interest and where legal conditions for such objections are met.
- Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you – As noted above We may use the personal data We hold about you to conduct profiling and make decisions solely by automated means (for example, to predict how likely you are to be able to pay your debt, or how best to manage Our relationship with you). However, We do not believe that this processing has either a legal effect or similarly significant impact on you.
- Right to withdraw consent – Where processing of your personal data is based on consent given to Us for one or more specific purposes, you may withdraw your consent at any time providing it will not affect the lawfulness of processing based on consent before its withdrawal.
If you wish to withdraw your consent, or for any other data protection requests, please contact: firstname.lastname@example.org.
- Right to complain – You have the right to complain if you consider that the processing of your personal data by Us infringes your rights or applicable data protection laws. Contact details for complaints to Us are as follows:
RA Group Polska sp. z o.o.
ul.Prosta 68, 00-838, Warsaw
tel: (+48) 22 276 6600
You also have the right to complain to a competent supervisory authority. If you believe that the processing of your personal data is unlawful, you have the right to make a complaint to the competent supervisory authority. The name and address of the relevant competent supervisory authority is:
Personal Data Protection Office
- Stawki 2, 00-193, Warszawa
You can also complain using their website at https://uodo.gov.pl/.
In the event that you wish to exercise any of these rights you may do so (i) by contacting Us using any medium you wish, including in writing, by telephone, by SMS or electronically or (ii) through a third party whom you have authorised for this purpose. However, please note that as part of security measures, to protect your personal information, We may need to request further information from you to verify and confirm your identity.
We may gather certain information automatically and store it in log files for statistical purposes. These log files contain standard information collected by web servers, such as client IP addresses, browser type, internet service provider (ISP), operating system, etc. This information is only used by PRA and PRA Group. This information is not distributed or sold to a third party. We use this information to analyse trends, to administer the Website and to gather demographic information about the Website users as a whole.
Cookies are small text files that are placed on your computer or mobile device by websites that you visit. These cookies are stored on the hard drive of your computer or mobile device. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
There are two types of cookies: session and persistent. They are used for different things and contain different information.
Session cookies contain information that is used within your current browser session. These cookies are automatically deleted when you close your browsers. Nothing is persisted on your machine beyond the time you spend on the Website.
Persistent cookies are used to hold information that is used between visits. This data allows websites to recognise that you are a returning visitor and react accordingly. Persistent cookies have a lifetime value that is set by the website which can vary between a few minutes or several years.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can also change the settings on your internet browser to accept all cookies, to notify you when a cookie is set, or not to receive cookies at any time. However, doing any of these may prevent ‘essential cookies’ (cookies that are essential for the safe and secure operation of the website) from loading and prevent you from taking full advantage of the Website, you may lose some of the functionality of the Website as a result. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.
PRA Group uses a cookie management tool to allow customers to ‘opt in’ and consent to non-essential cookie (those that are not essential for the safe and secure operation of the website).
If you ‘opt in’ and accept using Google Analytics cookies with our cookie banner, we use Google Analytics cookies and Google Analytics to collect general and anonymised statistical data to help us understand how our visitors use and interact with our website.
Google Analytics stores information about: page visits, actions on site, length of time spent on site, how you got to the site, clicks during visit, information on browser and device using anonymised IP.
This and other settings in Google Analytics ensure that the masked IP address collected from your browser is not merged with any other Google data products outside of Google Analytics. Google may transfer and process data on it’s servers in the US.
More details about how Google Analytics collects and processes data are available at www.google.com/policies/privacy/partners.
For help in deleting Our cookies please refer to the relevant link below:
Microsoft Internet Explorer: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
For further information about cookies and how to disable them please go to: www.aboutcookies.org.
RA Group Polska sp. z o.o.
- Prosta 68, 00-838, Warsaw
tel: (+48) 22 276 6600
ul.Prosta 68, 00-838, Warsaw
Date of publication: [include date]