Privacy Policy

Effective Date: 2025-01-01

1. Introduction
   We at Oddcoll AB (“Oddcoll,” “we,” or “us”) value your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you (i) visit our website www.oddcoll.com, (ii) create an account with us, or (iii) otherwise interact with our services.

2. Data Controller
   Oddcoll AB (Company Registration No. 559047-7336), located at Stampgatan 15, 41664 Göteborg, Sweden, is the data controller for the personal data described in this policy, except where we act as a data processor on behalf of our corporate customers (see Section 3).

3. Roles in Our Debt Collection Services

   • Customer (the Company) typically acts as the data controller for the personal data it uploads (e.g., debtor information).
   • Oddcoll acts as a data processor when processing data on behalf of the customer, under Article 28 of the GDPR.
   • Local Debt Collection Agencies (Under-processors) handle debtor data on behalf of Oddcoll and the customer.

4. What Personal Data We Process

   • Contact Details: Name, email, phone, and address of corporate representatives.
   • Billing Information: Invoicing details, payment history, etc.
   • Debtor Data: Name, address, debt amount, and any other relevant data provided by the customer in a debt collection case.
   • Technical Data: IP address, device info, cookies, and logs from our website.

5. Purposes and Legal Basis

   • Providing the Service: To manage debt collection through local agencies and administer customer accounts. Legal basis: Contract (Art. 6(1)(b) GDPR).
   • Support & Communication: To handle inquiries and provide customer support. Legal basis: Contract or Legitimate Interest (Art. 6(1)(f)).
   • Billing & Accounting: To comply with bookkeeping and accounting obligations. Legal basis: Legal obligation (Art. 6(1)(c)).
   • Marketing (limited): To send newsletters or promotional info to company representatives, where permitted. Legal basis: Legitimate Interest (Art. 6(1)(f)) or Consent if required by law.

6. Retention Period
   We retain personal data as long as necessary for the purpose or as required by law:

   • Customer and billing records: Typically 7 years (accounting regulations).
   • Debt collection cases: As long as the case is active plus any legal limitation period.

7. Sharing of Personal Data

   • Under-Processors: Local debt collection agencies required for pursuing claims. They are bound by data processor agreements under our responsibility.
   • IT Providers: E.g., hosting, CRM systems. All are bound by contractual obligations ensuring GDPR compliance.
   • Authorities: If required by law or a binding court/administrative order.

8. International Transfers
   If personal data is transferred outside the EU/EEA (e.g., to a debt collection agency in a non-adequate country), we ensure adequate safeguards (e.g., Standard Contractual Clauses).

9. Your Rights
   You have the right to:

   • Access, rectification, erasure, restriction, and data portability
   • Object to certain processing based on legitimate interest
   • Contact us at info@old.oddcoll.com to exercise these rights.

10. Security
    We implement technical and organizational measures to protect personal data against unauthorized access, loss, or destruction.

11. Changes to this Policy
    We may update this policy as needed. The latest version will always be available on our website.

12. Contact
    For questions or concerns about our data handling:

    • Email: info@old.oddcoll.com
    • Address: Stampgatan 15, 41664 Göteborg, Sweden
    • Phone: +46 31-360 80 96

(c) Oddcoll AB, 2025