1. Information about the processing of personal data
Your data security is important to us, and we therefore take great care to ensure that your personal data is handled responsibly. Below you can read how DAHL Advokatpartnerselskab (hereinafter DAHL, "we", "us" or "our") processes personal data about you when we act as data controller. You can also read about your rights in relation to our processing.
2. DAHL's role as a data controller
DAHL is the data controller as regards the processing of personal data collected and received about a debtor in collection proceedings where DAHL, representing the creditor, has been requested to collect the receivable from the debtor.
If you have any questions regarding our processing of your personal data, please contact DAHL here:
Central Business Reg. No. (CVR) 37 31 00 85
If you are a debtor in collection proceedings (including if you are a party to a lawsuit arising from such collection proceedings), which DAHL is conducting on behalf of the creditor, this will mean the following for you:
3. What personal data we collect and why
DAHL processes personal data about you in connection with debt collection proceedings and forced sales.
The creditor will provide DAHL with personal data about you in the form of your name, address and information about the debt. DAHL may receive information about your civil registration number, email address, phone numbers, contact information and financial, work-related, social and health issues or information about criminal charges, if any, if the creditor is aware thereof.
DAHL may also receive personal data from others who are aware of your debt owed to the fact that they are representing you in DAHL's processing of the matter. This may for instance be your lawyer or another adviser.
DAHL may furthermore collect personal data about you from publicly available sources, including social media and databases, on the basis of which DAHL will continuously update your master data in the form of your name, civil registration number and address with the only purpose of being able to identify and localize you with certainty.
In your capacity as debtor, you may furthermore provide DAHL with your personal data, either in writing, orally, by phone or during court meetings.
4. The purposes for which we process your personal data
DAHL will only use the personal data collected about you for the purpose of collecting the creditor's claim against you.
As part of this processing, execution may be levied on any of your assets suitable for execution pursuant to the rules of the Danish Administration of Justice Act (retsplejeloven) in order to, if necessary, make a forced sale of appropriated assets to satisfy the creditor's claim against you.
Personal data collected and received will only be used to the extent necessary to determine and collect the creditor's claim against you.
5. Our basis for processing
The processing of your personal data is based on the balancing of interests rule set out in Article 6(1)(f) of the General Data Protection Regulation and Articles 9(2)(e) and 9(2)(f) of the General Data Protection Regulation. The legitimate interest that justifies the processing is the creditor's interest in obtaining payment of the claim against you. It is not necessary for DAHL to obtain consent for the processing of personal data about you for this purpose.
In order to process information about your civil registration number (CPR) we use Article 11(2)(4) of the Danish Data Protection Act and Article 9(2)(e) and/or article 9(2)(f) of the General Data Protection Regulation.
6. Disclosure of your personal data to others
As part of the processing it may be necessary to disclose personal data about you to the following:
- The creditor
- The courts
- Approved debt collection consultants
- Liaison lawyers representing DAHL in court
- Carriers, locksmiths, workmen and similar, which DAHL may engage as part of the process
- The Danish Tax Authorities, your landlord or others who must be notified about charges against your assets
- Auction houses that are to handle the sale of appropriated assets
- Credit rating agencies
- Potential auction buyers in auction cases
- Advertisements on itvang.dk, statstidende etc.
DAHL may also disclose your personal data to a public authority in situations where we are specifically obliged to disclose your personal data pursuant to legislation and notification obligations to which we are subject.
We try to limit the disclosure of personally identifiable information and thus the disclosure of information that can be attributed to you personally.
7. Retention period, data integrity and security
Your personal data will not be kept longer than is necessary for the purpose. When your personal data is no longer needed, we will ensure that it is deleted in a secure manner.
In general, DAHL will store your personal data for ten years after the collection proceedings have been finally terminated. The storage period may, however, in specific circumstances be shorter or longer. In special cases, you may request to have your personal data deleted earlier than the general rule on deletion after ten years.
When DAHL is to determine how long your personal data will be stored, particular consideration will be given to whether the debt has been repaid, whether disagreements have arisen regarding the claim or the processing, and how long any liability may be claimed towards DAHL on the occasion of the processing.
It is our policy to protect personal data by taking adequate technical and organisational security measures. We have implemented security measures to ensure data protection for all personal data that we process. We conduct regular internal follow-ups on the adequacy of and compliance with policies and measures.
8. Your rights
As a data subject, you have certain rights under the General Data Protection Regulation. If you want to exercise your rights, please contact us.
You can also – unconditionally and at any time – object to our processing when it is based on our legitimate interests.
If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. However, please be aware that this does not take effect until the time of such withdrawal. Consequently, it does not affect the legality of our processing of your personal data until the time when you withdraw your consent.
Your rights also include the following:
- Right of access: You have the right to access the personal data we process about you.
- Right to rectification: You have the right to obtain rectification of any inaccurate and incomplete personal data about you.
- Right to erasure (right to be forgotten): In exceptional cases, you have the right to obtain erasure of information about you before the time when we would normally delete your personal data.
- Right to restriction of processing: In certain situations, you have the right to restrict the processing of your personal data. If you have the right to restrict the processing of your personal data, we may only process personal data in the future – apart from storage – with your consent, or for the establishment, exercise or defence of legal claims, or to protect an individual or important public interests.
- Right to object: In certain situations, you have the right to object to our processing of your personal data, and always if the processing is for direct marketing purposes.
- Right to data portability: In certain situations, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those personal data transferred from one data controller to another.
- Right to lodge a complaint: You can lodge a complaint at any time with the Danish Data Protection Authority about our processing of personal data. See more at datatilsynet.dk/english where you can also find further information on your rights as a data subject.
9. special circumstances for lessees, potential customers and auction purchasers of assets
As part of DAHL's debt collection proceedings, DAHL will contribute to a forced sale of appropriated real estate or goods by selling such assets in a forced sale.
The personal data which DAHL collects or receives from persons involved in a forced sale, e.g. the lessee of the asset, a potential customer or an auction purchaser of the asset, will be processed by DAHL in the same way as described above with the same rights for the said persons.