Privacy policy

Informative report to debtors on the processing of personal data (art. 13 d. lgs. 196/2003)

In compliance with current legislation 30th. June 2003 no. 196 (Privacy Code) we wish to inform you that CAF S.p.A. (“CAF” or “the Holder”), registered offices in Rome, piazza SS Apostoli 73, being entrusted with the collection of debt in your name, will submit any private data, present and future, concerning you to subjects who claim rights or have claimed rights debt in your name.
Therefore, in compliance with regulations on Privacy Code, we wish to inform you that any private data concerning you will be subject to the following conditions:

Art. 1. Processing
The processing of private data (including registration of Company data) is exclusively aimed at achieving the following:
To carry out all tasks involved in credit recovery such as sending reminders, notice of payment, telephone calls, appointing lawyers and carrying out legal action to recover the credit.
To fulfil all obligations provided for the law and current regulations especially those laws governing credit recovery, impeding money laundering, excise and revenues and public security.

Art. 2. Storing data
CAF will process your personal data for the sole purpose of credit recovery, in full compliance with the rules governing the sector and also for internal administration and organization.
Your personal data will be processed by CAF for the sole purpose indicated in Art. 1, without necessarily seeking consent otherwise operations for credit recovery would become practically impossible.
In any case, personal data sent to CAF by clients/principles/credit transferors/in reference to you as debtor, and /or guarantor and/or jointly and severally liable, has been sent to CAF for the sole purpose indicated in Art1. in full compliance with current legislation.

Art. 3 Processing procedures
The processing of your personal data will be carried out mainly by means of electronic or computer based devices according to standard procedure so as to guarantee security and confidentiality of said data in compliance with Law 196/2003.
Specifically speaking, all technical, computerized, organizational, logistic and security procedures will be applied as foreseen by Law 196/2003 along with the Writ of Guarantor 30th November 2005 on “Lawfulness, honesty and competence in credit recovery” so as to guarantee a minimum level of protection of data by granting access only to authorized personnel.
All access to data will be kept under constant control.

Art. 4. Communicating and distributing data
Personal data can be given to:
1)    Third parties, both in Italy and abroad, within the E.U., so as to fulfil the assigned task and, precisely, to the following subjects (i) other debt collection agencies (ii) credit vetting companies, professionals, collaborators, (internal and/or external) (iii) lawyers, public prosecutors, consultants, judicial authorities, banks, credit and financial institutions, insurance companies, partners with whom CAF has a business agreement;
2)    All subjects (including Public Authorities) who have authorized access to personal data;
3)    Companies, consultants or professionals working on the installation, maintenance and updating and, all in all, the management of CAF, hardware and software or those the company uses to carry out its activities;
4)    Companies entrusted with the management of CAF computer or paper files;
5)    All other subjects both public and/or private, natural persons and/or juridical persons (legal, administrative and tax consulting agencies, Bailiff’s Office, Chamber of Commerce, Trade Union Headquarters etc.) whenever communication is made necessary so as to fulfil the onus of contract terms along with any legal obligations.
Only data used for statistics and research shall be made known and shall, in any case, remain anonymous and aggregated.

Art. 5. Holder and Responsible for processing personal data
All your personal data is held by the Holder, registered offices in Piazza Santi Apostoli, 73 Roma
The person responsible for your personal data, in compliance with Art. 29 del Law 196/2003 is Mrs. Antonella Pagano domiciled at the Holder’s offices for the purpose.
All petitions and requests regarding your personal data can be addressed to the above mentioned Holder and Responsible at any of the following:

CAF Piazza Santi Apostoli, 73 00187 Roma (RM)
E-mail: info@cafinv.eu
Fax: (+39) 06.69925139

Art. 6. Filing personal data
All your personal data will be kept on file only as long as it takes to carry out all those activities needed to recover the credit.
Once all the points outlined in Art 1 have been completed and all legal requirements have been respected, all your personal data will be cancelled in compliance with Law 196/2003.
It is, however, understood that all your data shall be kept for administrative reasons for the lapse of time prescribed by current legislation and in particular for accounting documentation or public security and credit protection.

Art. 7. Subject’s Rights
Through Art. 7 and Law 196/2003, you hold the right to:
a) obtain confirmation on whether your personal data is registered or not and if it can be communicated in an intelligible way.
b) obtain from the Holder and Responsible:
i. Information on the sources of the personal data, on the purpose and on processing methods, on the choice made if and when the service was carried out with the help of a computer;
ii. Information on the Holder and those Responsible along with information on the representative assigned by a foreign subject to handle the data in Italy;
iii. Information on subjects or subject categories to whom data can be referred or who can become aware as representatives assigned by the state, by the responsible, or by agents.
c) obtain:
i. The updating, correction or the integration of your data;
ii. The annulment, the anonymous transformation or the freezing of any data processed in infringement of the law, this includes data that does not have to be kept in relation to the purpose for which the data was collected or subsequently processed.
iii. Declaration that operations mentioned in points (i) and (ii) and their contents, have been shown to those to whom the data has been communicated except in the case where said fulfilment appears to be practically impossible or requires a full scale effort which results evidently out of proportion when compared to protection of rights.
d) Partial or total opposition can be made:
i. For legitimate reasons, to the processing of your data even though pertinent to collection.
ii. To the processing of your personal data, to be used for commercial information or receiving advertising material or direct sales, in other words, to carry out market research or convey market news.
All these rights can be enacted both in person or through your representative, as laid down by Arts. 8 and 9 Law 196/2003, by sending an informal request to the Holder or the Responsible. A written request can be forwarded to the Holder or the Responsible by: registered letter, via fax (+39) 06 69925139, or by e-mail to info@cafinv.eu.