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Personal data protection policy

iQera

We are fully committed to respecting the privacy of our customers and handling their personal data with the utmost confidentiality, in strict accordance with the applicable legislation.

 

This page presents a simplified version of our data protection policy in the form of a question-and-answer format. Its purpose is to provide you with transparent information regarding the personal data we collect, how we utilize it, and the rights you possess concerning the processing of this data.

 

We emphasize the importance of carefully reviewing this policy. Should you have any additional inquiries, kindly submit a written request to [email protected] .

 

Please note that this Policy is subject to periodic updates, and we encourage you to consult it regularly.

 

 

On what legal basis(s) is (are) your personal data processed ?

The processing of your personal data is conducted based on one or more legal grounds as specified by applicable laws and regulations. These grounds include, but are not limited to:

  • obtaining your prior consent by an entity of the iQera Group,
  • the necessity of processing for the performance of a contract between you and an entity of the iQera Group,
  • compliance with a legal obligation to which iQera is subject,
  • pursuit of the legitimate interests of the iQera Group, provided that your interests and fundamental rights do not override these interests. The processing operations carried out under this ground include:
    • collecting debts acquired by an entity of the iQera Group or entrusted to it by a Principal under a mandate (such as the Common Securitization Fund, Group Customers), if required, within the scope of managing an over-indebtedness procedure;
    • update contact information and creditworthiness data;
    • managing complaints, monitoring the progress of telephone calls, and conducting satisfaction surveys;
    • ensuring regulatory and ethical compliance of our activities, maintaining network and data security, and managing the performance of our activities.

 

The personal data we possess enables us to pursue legal claims and enforce legal decisions.

 

Therefore, the processing of your personal data, which is necessary for the collection and management of our claims, is permissible without requiring your explicit consent, as consent is not deemed necessary in such cases.

For what purposes do we collect your data ?

The comprehensive list of data processing activities is accessible upon request by contacting the DPO department via email at [email protected]. Please inquire about the “Information Notice.”

 

If you are a job applicant: The iQera Group, with whom you are in contact through this website, primarily collects your personal data as the Data Controller to facilitate recruitment processes.

 

If you are a Prospect: As the Data Controller, we process this data with the purpose of identifying potential business opportunities and expanding our business network.

 

If you are a Customer of our Principals: we would like to inform you that entities within the iQera Group, directly or indirectly, may collect personal data during their activities, which include:

  • amicable and judicial management of unpaid invoices, either on their own behalf or on behalf of third parties,
  • management of overindebtedness files,
  • management of healthy loans,
  • optimisation of customer accounts,
  • subcontracting activities, either under a White Label arrangement or under their own name,
  • provision of software in Saas mode to our Bailiffs and Lawyers partners,
  • updating contact ingotmayion or creditworthiness data,
  • customer relationship management or conducting satisfaction surveys,
  • performance management.

The iQera Group is systematically a sub-Processor of the Client for whom we work on a White Label basis. Within the framework of the provision of services, when the iQera Group intervenes on behalf of the Client, depending on the operation adopted with the Order Giving Customers, the Group (iQera SAS or MCS & Asssociés) is either a Sub-Processor or a Data Processor.

 

If your contract has been acquired by a FCT (Financial Contractualization Trust) or an entity of the iQera Group, we would like to inform you that the entities within the iQera Group may directly or indirectly collect personal data as part of their activities, which include:

  • managing unpaid invoices on their own behalf or on behalf of third parties.
  • managing sound loans.
  • updating contact information or creditworthiness data.
  • customer relationship management or conducting satisfaction surveys.
  • performance management.

 

If you are an employee of our Principals or Partners: the collection of your personal data serves the following purposes:

  • ensuring the operational functioning and security of our SaaS solutions as our websites for training and promotion of our services;
  • managing activities and providing application support;
  • facilitating customer relationship management and conducting satisfaction surveys.

 

When you navigate through a website of the iQera Group: The iQera Group entity acts as the Data Controller when it processes your personal data, which it collects during your website browsing experience (referred to as the “Site”). This processing is conducted to handle requests submitted through the “Contact Form” and enhance the quality of the Services provided. The specific purposes and uses of cookies are detailed on the Site’s Cookie Management Policy Page and are also communicated through the Cookie Management Banner.

Which data do we collect ?

In general, the iQera Group ensures that the collection of personal data is limited to those necessary for the purposes mentioned above. Our teams are subject to an obligation of confidentiality.

 

The iQera Group does not collect, store or process so-called “sensitive” data within the meaning of the RGPD, i.e. data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health status or sex life.

 

If you are a candidate for a job offer: the personal data that may be collected about you via the online recruitment form are the following:

  • Identification data,
  • Location data,
  • Photos, images, video,
  • Professional background,
  • Hobbies and association information,
  • your personality skills (if a study is conducted)

In addition, if you have decided, your opinion on the recruitment process can be collected.

 

If you are a Prospect: personal data are identification and professional information, such as your contact details and professional activities, technical data of navigation on our sites. If communicated, your interests may be processed.

 

If you are a Customer of our Principals: the personal data collected by the entities of the iQera Group varies according to the services. Concerning the activities of management of unpaid debts, it is mainly for each debtor, the identification data, the economic and financial information and the data relating to the debt itself for each debtor.

 

If your contract has been bought out by a FCT or an entity of the iQera Group: the personal data collected by the iQera Group entities in charge of the management of unpaid debts mainly concern, for each debtor, identification data, economic and financial information and data relating to the debt itself.

MCS & Associés is the data controller for activities relating to the management of debt collection and overindebtedness.

 

If you are an employee of our Principals or Partners: The personal data collected for BPO and SaaS activities mainly concern the professional details of client users and their own professional relations. It also includes data relating to the use of our SaaS solutions, or responses to our surveys.

 

When you browse an iQera Group site: When you browse a Group Site and use one of the contact forms, the personal data we may collect about you is your identification data (surname, first name, e-mail address, telephone number, message, portfolio code, file reference, date and time of your connection, the pages you consulted or your location data. This data is collected automatically, through the servers you visit and the “cookies” placed on our Site. For more information on what a “cookie” is, what it is used for and exactly what data it collects, please visit the Cookie Policy page.

How do we collect your data?

If you are a candidate for a job offer: The iQera Group entity, acting as the Data Controller, directly collects personal data about you as necessary for the processing activities carried out by the company. This includes, but is not limited to:

  • Applications submitted through our website,
  • Recruitment interviews conducted directly or through a recruitment service provider,
  • Satisfaction surveys.

 

If you are a prospect: We directly collect data from you when you complete the contact form, during events, or in response to calls for tender. Additionally, in certain cases, we may indirectly obtain data from specialized suppliers.

 

If you are a customer of our Principals: The iQera Group entities do not directly collect your personal data used for the purpose of collecting your claims. Typically, this information is provided to us by our Principal, either through a mandate or upon assignment of the receivables. We update this data as part of claims management, either by contacting you or through the involvement of specialized and/or authorized service providers (such as data enrichment or civil investigations).

 

If your contract has been purchased, by a CTF or an entity of the iQera Group: Your personal data, transmitted by the original creditor, is updated within the scope of the collection activity. This may involve contacting you directly or engaging specialized and/or authorized service providers (such as data enrichment or civil investigations).

If you are an employee of our Principals or Partners: the data is provided to us by your employer or is obtained through your use of our tools.

 

When you browse an iQera Group website: During your visit to our website, the majority of your personal data is collected through your active engagement, such as browsing, viewing video content, making a payment, or submitting information via a contact form.

Who are the recipients of your personal data?

To fulfil the aforementioned purposes, we may disclose your personal data to the following parties:

  • Employees of the iQera Group who are authorized to access such information,
  • Our service providers, including our Partners.

 

The iQera Group places great emphasis on maintaining the confidentiality of the data it collects and utilizes. Therefore, any individual granted access to such data is bound by a strict duty of confidentiality, as outlined in their employment contract or through the signing of a confidentiality agreement.

 

Furthermore, the iQera Group takes all necessary measures to ensure that recipients of your personal data implement appropriate technical and organizational safeguards to guarantee the protection of your data.

How we your data protected?

iQera implements a comprehensive set of technical and organizational measures to ensure an appropriate level of personal data protection.

 

These measures are designed to address the following:

  • Access to the premises and facilities where the data is processed,
  • Access to the computer systems and software platforms used, allowing access only to authorized individuals based on the relevant processing operations. This is achieved through the implementation of authorization mechanisms, access rights, access control, and logging mechanisms.
  • Mitigation of risks associated with unauthorized disclosure of personal data by securing all computer exchanges between iQera and its partners, subcontractors, or suppliers through the use of encrypted flows and/or protocols.
  • Establishing traceability of events related to the handling of personal data,
  • Ensuring the availability of personal data through security measures (e.g., service continuity, anti-intrusion devices) and implementing backup measures to safeguard against accidental data destruction or loss.

How long are your data kept?

Your personal data is stored in the iQera databases only for the duration necessary to fulfill the purpose for which it was collected and/or to comply with iQera’s legal and regulatory obligations.

Our primary retention periods are outlined as follows:

  • Debt collection processing: 6 years
  • Over-indebtedness management treatment: 6 years
  • Satisfaction survey management processing: 3 years
  • Processing of civil investigations: 1 year
  • Processing of voice recordings: 3 months

 

Please note that these durations can be customized at the request of our Principals who hold the status of Data Controller.

Do we transfer your data abroad?

iQera may transfer your personal data to countries located outside the European Economic Area, specifically to our entities based in Morocco and Mauritius. In such instances, iQera and its subsidiaries implement appropriate safeguards to oversee these transfers, ensuring a necessary and adequate level of protection for your data. These safeguards may include the implementation of measures such as signing the standard contractual clauses adopted by the European Commission.

Why do we operate dual listening and recording of telephone calls ?

The purpose of “Recording and Dual Listening of Calls” is to enhance service quality, train employees, and combat harassment.

 

Groupe iQera has a legitimate interest in processing personal data for these purposes.

 

Groupe iQera acts as the Data Controller, except when serving as a White Label Subcontractor for our Clients.

 

The collected data includes verbally exchanged information, the telephone number used, and the date and time of the call. The telephone number is provided by individuals involved in the claim, transmitted by our Clients, or obtained from specialized service providers or public sources.

 

Only authorized individuals from our Group, our clients, or our Subcontractors may access this data. These authorized personnel primarily include consultants, their managers, coaches, employees responsible for internal control, internal and external IT teams responsible for service provision and security.

 

The solution is hosted and maintained within the European Union. The processing of personal data by our employees located in Mauritius adheres to the European Commission’s Standard Contractual Clauses.

Regarding call recordings, you have the right to object to their recording, as well as the rights of access, erasure, rectification, data portability, and restriction of processing.

 

Please note that the collected data may also be used as evidence for yourself, our advisors, the iQera Group, or our clients.

 

Records are retained for 3 months in production. If necessary, the training report is kept for 12 months. Recordings are stored outside of production for 3 months for ongoing monitoring purposes and for 36 months when extracted for complaint management or GDPR compliance exercises.

How do we manage satisfaction survey ?

Your personal data is transferred by Groupe iQera (composed of the companies MCS et Associés, iQera, and iQera Services) to Eloquant as part of the “Satisfaction Survey” processing, justified by the legitimate interest legal basis.

 

Eloquant receives, retains, anonymizes, if necessary, processes, and shares your personal data for the following purposes: (i) measuring your satisfaction, (ii) adapting iQera Group’s processes, training, and monitoring compliance with applicable regulations, (iii) generating related statistical results, and (iv) sharing a portion of comments with Groupe iQera’s customers and managers, if you have given your consent.

 

Your personal data is collected from both direct sources (data provided by you, contact information shared during the collection services we have conducted) and indirect sources (data from collection services obtained from private, public, and legal sources). This data is strictly intended for authorized personnel within the iQera Group and Eloquant. In certain cases, it may be transferred to Morocco or Mauritius under the framework of European Commission contractual clauses, if necessary.

 

Unencrypted data is retained by Eloquant for a period of 3 years. Additionally, if you have consented to lifting your anonymity, the iQera Group will utilize your data for 1 year and subsequently archive it in its systems for an additional 2 years.

 

You have the right to exercise your rights of access, rectification, erasure, restriction, portability, and objection by submitting your request to the Groupe iQera’s Data Protection Officer (DPO) at the following address: [email protected].

If you believe that your rights and freedoms have been infringed, you have the option to lodge a complaint with the relevant supervisory authority, namely (i) in France, the CNIL (www.cnil.fr), (ii) in Mauritius, the Data Protection Office (www.dataprotection.govmu.org), and (iii) in Morocco, the CNDP (www.cndp.ma).

What are your rights and how dan you exercise them?

In certain circumstances, you have the following rights:

  • Request access to your personal data. By exercising this right, you can obtain a copy of your personal data held by us and verify that we are processing it in accordance with applicable laws,
  • Request the rectification of your personal data in our possession. Exercising this right allows you to correct any incomplete or inaccurate information pertaining to you,
  • Request the erasure of your personal data. By exercising this right, you can request the deletion of your personal data if we do not have legitimate grounds for continuing their processing. You also have the right to ask us to delete your personal data if you have exercised your right to object to the processing (see below)
  • Object to the processing of your personal data when the legal basis for the processing is our legitimate interest, based on reasons relating to your specific situation. However, this right may not apply if the iQera Group can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or when the personal data is necessary for the establishment, exercise, or defence of legal claims by the iQera Group or the individuals it represents,
  • Request the restriction of the processing of your personal data. By exercising this right, you can request the temporary suspension of the processing of your personal data, for example, if you contest the accuracy of the processed personal data, in order to allow us to verify and, if necessary, update the said personal data,
  • Right to organize the fate of your data: You have the right to define instructions regarding the storage, erasure, and disclosure of your data, which will be applicable after your death.

 

Moreover, if the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time for the specific processing in question.

 

To exercise any of your rights, kindly send your request to the address provided in the “Contact” section, specifying the subject matter of your request. In certain cases, such as the management of bank debts, we may require you to verify your identity by submitting a copy of an identification document. Additionally, we provide you with a supplementary Information Notice that outlines the data processing activities and their legal basis.

 

Lastly, we would like to inform you that you have the option to file a complaint at any time with the Commission Nationale de l’Informatique et des Libertés (French data protection authority)(for more information, visit: www.cnil.fr).

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