Algebra Capital Lda (“ALGEBRA”) is a Portuguese company dedicated to providing secured and unsecured loan management and loan recovery services.
In compliance with the right to information reserved for data subjects, this Policy supplements the information already transmitted directly to employees, applicants, service providers, clients and other stakeholders, in the procedural, contractual and/or statutory scope.
ALGEBRA observes the best practices in the field of security and personal data protection, having adopted for this purpose all technical and organizational measures deemed appropriate to comply with the GDPR and ensure that personal data processing is lawful, fair, transparent and limited to authorized purposes.
Data Protection Officer
The Data Protection Officer plays a relevant role in the processing of personal data as it ensures, among other aspects, the compliance of data processing with the legislation in force.
Thus, data subjects may address a written communication regarding these matters to the Data Protection Officer appointed by ALGEBRA, using the following contacts:
Algebra Capital Lda
Avenida da Liberdade, 110, 5.th floor
1250-146 Lisbon, Portugal
Purpose and Legal Basis of GDPR
In general, ALGEBRA’s personal data processing is grounded on and intended for the management of the contractual relationship between ALGEBRA, its employees, service providers and Clients, as well as the provision of the services contracted in a manner that adequately meets the existing needs and interests of its Clients.
Personal data may be processed to comply with statutory obligations.
According to the underlying relationship, ALGEBRA may act as the Controller, based on the legal interest of developing the business and to meet contractual and legal obligations.
Furthermore, in the quality of Subcontractor, in the context of exercising its activity, for the purpose of managing and recovering default credit, both in the scope of the Client’s legal interest in the reimbursement of the credits, and for the purposes of fulfilling contractual obligations and and statutory obligations arising thereof.
ALGEBRA processes personal data to the extent permitted by law and with the purposes above identified, processing data from employees and services providers with whom it established a work/service relationship and always in this scope.
Furthermore, it processes personal data from credit holders transmitted by their Clients (“Assignees”, “Creditors”), to the extent strictly necessary for their management and recovery, as well as data collected in public databases, official public records and data collected from data subjects in a consented manner and in the exercise of their rights.
For instance, such data may include name, address, telephone number, email, date and place of birth, nationality, signature, sex, marital status, information about credit application of the creditor, payment history, financial status.
On its website, www.algebracapital.pt/alyx,
Data Subject Rights
In addition to the right to information, ALGEBRA guarantees data subjects the exercise of access, rectification, updating, deletion, limitation, opposition, and portability rights, pursuant to the terms and legal grounds set.
Data subjects are also entitled to submit a complaint to the National Data Protection Commission, the supervisory authority, regarding matters related to the exercise of their rights and the protection of their personal data.
Data subjects may exercise their rights with ALGEBRA, by contacting the Data Protection Officer, who will respond within 30 days, except in particularly complex cases. In the latter scenario, the data subject will be informed about the need to extent the response for a maximum additional period of 30 days and a explanation will be enclosed.
Whenever ALGEBRA considers that it is not possible to meet the requests, data subjects will be informed of the reasons within the terms established above.
The data subject may exercise any of these rights free of charge, except when situations considered excessive, anomalous and/or of ill repute occur. In these cases, ALGEBRA will inform data subjects about the fee charged and respective justification for it, in advance.
ALGEBRA has adequate mechanisms to verify and confirm the identity of data subjects who wish to exercise their rights, and will exclusively attend those whose identity can be confirmed, using a channel that allows to keep a proof of the request and respective response.
Recipients of Personal Data
ALGEBRA will only subcontract the provision of services that require the processing of personal data to third-parties (“Subcontractors” or “Sub-Subcontractors”) provided they present sufficient guarantees in regard to the execution of appropriate technical and organizational measures under the terms of the GDPR, and which ensure the defence of data subject rights. This processing will be contractually fixed and dully authorized, by the Data Protection Officer, in the applicable cases.
Data will only be shared by ALGEBRA in the extent strictly necessary for the provision of these services, being processed by third-parties, in the name, on behalf and in accordance with the instructions given by ALGEBRA, and pursuant to the contractual and statutory provisions.
In addition, ALGEBRA may share personal data, within the scope of legal proceedings or procedures (for instance, lawyers, court rooms, court clerks and other bailiffs), by request of judicial and police authorities, supervisory authorities or other, in the fulfilment of statutory and regulatory obligations.
The possible sharing of data with group companies will be carried out for internal administrative purposes, such as audits to credit management and recovery activities, statistical analysis and analytical reports, including the creation of models related to risk assessment.
Transfer of Data to Third Countries
The provision of certain services by ALGEBRA may imply the transfer of personal data outside Portugal, including outside the European Union or to International Organizations.
In such an event, ALGEBRA will strictly comply with the applicable legal provisions, namely in relation to the suitability of the destination country (countries) with regard to personal data protection and the requirements applicable to such transfers, including, whenever applicable, binding by adequate contractual instruments and which ensure, and observe, the statutory requirements in force.
Data Retention and Archiving
ALGEBRA observes the legal norms related to personal data retention periods, and will thus retain the personal data for the period of time and as long as the legitimate purposes sustaining the processing are in place, in compliance with statutory, regulatory and contractual obligations to which is subject.
After the retention period, data will be deleted or anonymized.
Archived data is kept in physical or digital format for the purpose of business continuity to which are applied the security measures considered appropriate and necessary.