Data protection

This website is an offer of PAIR Finance GmbH, Berlin, (hereinafter: “PAIR Finance” or “we”, “us”, etc.).

We value your trust, respect your privacy and take great care to protect your data and its confidentiality.

With this data protection information, we would like to inform you in accordance with Art. 13 and Art. 14 of the European Data Protection Regulation (hereinafter: DSGVO) – Regulation (EU) 2016/679 – how and which personal data

A.) General information on responsibility

and in addition thereto

B.) Data processing in the context of the use of our website,

C.) Data processing through the use of cookies when visiting our website,

D.) Data processing in the context of a business relationship on our service platform, and

Detailed data protection information regarding our legal services provided by the respective PAIR Finance company to consumers and other persons involved in the respective debt collection matter can be found here.

Terminology:

The terms used in the context of this data protection declaration, such as “controller”, “personal data” or “processing”, among others, have the meaning defined in Art. 4 of the GDPR.

“Controller” within the meaning of the GDPR is the person who decides on the purposes and means of data processing.

“Personal data” are basically all information about personal or factual circumstances of an identified or identifiable natural person, such as name, telephone number or address. It is all characteristics or information with which an identification of a person can be made possible.

The “processing” of personal data is any operation related to personal data, such as collection, storage, use, communication or erasure of personal data.

Any processing must be carried out for a predetermined or compatible purpose and on the basis of a legal basis. In the following, you will find out, among other things, for which purposes and on the basis of which legal basis the data processing takes place at our company.

A. General data protection information

I. Name and address of the responsible person

PAIR Finance GmbH is responsible for providing this website:

PAIR Finance GmbH
Knesebeckstr. 62-63
10719 Berlin
Deutschland

Tel.: +49 (0) 30 340 602 950
E-Mail: info@pairfinance.de
Website: pairfinance.com

To assert your rights under data protection law, please contact datenschutz@pairfinance.de.

PAIR Finance GmbH is represented by its management.

II. Contact details of our data protection officer

For all questions and concerns regarding data protection, the data protection team of PAIR Finance is available to you by e-mail at datenschutz@pairfinance.de. In addition, it is also possible to contact the data protection officer by post at the address given in the imprint (keyword: “data protection officer”).

III. purposes and legal basis for our data processing activities

We also process personal data in the form of technical information about the terminal device used and information about the use of the online payment page for the purpose of adapting the presentation of the content for the respective (data subject) using the online payment page and for the purpose of enabling the respective user-friendly and secure repayment of a claim processed by us. More detailed data protection information regarding the use of the online payment page can be found under our data protection information regarding our legal service.
The legal basis for the data processing is the consent of the respective person pursuant to Art. 6 (1) (a) and Art. 7 DSGVO.

We process personal data for the purpose of enabling the visit of our website and to ensure the permanent functionality, availability and security of our systems, i.e. for the proper optimization of our website. You can find more information below under point B.).
The legal basis for this data processing is Art. 6 (1) (f) DSGVO.

If a person contacts us (e.g. via online contact form, email, telephone or via social media), we process the personal data provided for the purpose of contacting the inquiring person and being able to respond to their inquiry. Further information regarding data processing via our online contact form can be found below under point B.).
The legal basis for the data processing is Art. 6 (1) (b) and (f) DSGVO.

If a person from the circle of contractual/business partners and clients participates in an (online) event organised by us, we process the corresponding registration data for the purpose of organising and conducting the event.
The legal basis for data processing is Art. 6 para. 1 letter b) GDPR.

We process personal data for the purpose of (further) developing new or existing products in an appropriately secured environment, if the data is still processed for another purpose.
The legal basis for the data processing is Art. 6 para. 1 letter f DSGVO.

Finally, we process personal data for the purpose of fulfilling legal obligations, in particular for the fulfillment of legal retention obligations (e.g. from the AO or the HGB).
The legal basis for this data processing is Art. 6 para. 1 letter c) DSGVO.

IV. Possible recipients of personal data

1. service providers

We transmit personal data to service providers carefully selected, commissioned and controlled by us within the framework of a contract processing relationship pursuant to Art. 28 DSGVO. They are also bound by our instructions and have suitable technical and organizational measures within the meaning of Art. 32 DSGVO to protect the rights of data subjects.

The operation of our online and service offerings requires hosting and infrastructure services, for which we use appropriate service providers.

2. other possible recipients

In the context of debt collection, we also transfer personal data to our customers and, if necessary, to recipients of the following categories, insofar as this is necessary in the individual case and for the respective purpose: assignees, credit agencies, authorized persons, third-party debtors, external consultants, courts, bailiffs, associations, (judicial) administrative authorities.

V. Categories of data we may process

We may process data – depending on the purpose and the person/company from whom we process data – of the following categories:

• Master/Personal Data
• contact data
• contract data
• communication data
• Valuation data
• IP addresses/device data
• Login data
• further technical usage data
• In individual cases, if required by law: data of special categories

VI. Origin of the data

The data may originate

• from our contractual partners/clients who have commissioned us with the respective collection of receivables from the persons against whom we are asserting the claim
• from the persons concerned themselves or from the authorized persons representing them
• service providers

VII. Transfer of personal data to third countries (outside the EEA area)

If we transfer data to service providers who cannot completely exclude the possibility that data will be processed outside the European Economic Area (EEA), this will be done in accordance with the legal requirements. For example, we only transfer data to service providers in countries with a recognized level of data protection for which the EU Commission has taken so-called adequacy decisions, or to those that are subject to a sufficient contractual obligation through so-called standard data protection clauses of the EU Commission or binding internal data protection regulations (Art. 44 to Art. 49 DSGVO).

 VIII. storage period

Our data processing generally takes place in the European Economic Area (EEA). If we transfer data to service providers who process data outside the European Economic Area (EEA) or if the processing takes place using third-party services outside the EEA, this is done in accordance with the legal requirements.

For example, we only transfer data to service providers in countries with a recognized level of data protection or which are subject to a sufficient contractual obligation through so-called standard data protection clauses of the EU Commission or binding internal data protection regulations (Art. 44 to 49 GDPR).

In the event of payment of the outstanding claim or termination of the debt collection procedure for other reasons, we will check after expiry of the individually applicable limitation period, regularly after approx. 3 years, whether we still need your data for further legal prosecution and whether deletion conflicts with statutory retention obligations.

For example, there are obligations to retain data in accordance with Section 147 of the German Fiscal Code (AO) and Section 257 of the German Commercial Code (HGB). These laws are also applicable to your matter, as we, as a company based in Germany, are subject to German tax and commercial law. The retention period based on these legal obligations is generally six or ten years.

IX. Rights of the data subject

If the respective legal requirements are met, every data subject within the meaning of the GDPR has the following rights:

• Right to information about the data stored about you (Art. 15 DSGVO)
• Right to correction of incorrect data (Art. 16 DSGVO)
• Right to erasure (Art. 17 DSGVO) or
• Right to restriction of processing (Art. 18 DSGVO)
• Right to data portability (Art. 20 DSGVO).
  
  
• RIGHT OF OBJECTION (Art. 21 DSGVO): To the extent that we process personal data on the basis of legitimate interests pursuant to Art. 6(1)(f) DSGVO, any data subject has the right to object to the processing of your data pursuant to Art. 21 DSGVO and to provide us with reasons based on their particular situation which they consider to override your legitimate interests. If your interests are not overridden or if the processing serves the assertion, exercise or defense of legal claims, we may continue the data processing even after the objection. If it is a matter of an objection to data processing for direct marketing purposes, there is a general right to object, which will also be implemented by us without giving reasons.

• RIGHT TO REVOKE CONSENT GIVEN (Art. 7(3) DSGVO): Every data subject has the right to revoke consent given to us at any time. This has the consequence that we no longer continue the data processing based on this consent for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

In order to assert the rights described here, you can contact us at any time and not bound to any specific form at the contact details mentioned in A. above.

Finally, as a data subject, you have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

The supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information. The address is: Berliner Beauftragte für den Datenschutz und die Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, Germany.

X. Necessity of the provision of personal data

In the case of the provision of our contractual or pre-contractual services and obligations with (potential) contractual partners/clients, we require some personal data from them in order to process the (potential) order properly and in accordance with the law and to be able to start and perform our contractual service.

Furthermore, in order to fulfill the respective contract with our respective clients, we require personal data about the persons against whom we are to carry out debt collection in accordance with the contract. Without this data, we cannot fulfill our contractual obligation to perform vis-à-vis our clients.

Otherwise, there are no legal or contractual obligations to provide us with personal data.

B. Supplementary data protection information relating to our website in accordance with Art. 13 DSGVO

In addition to the general data protection information under A., the following applies with regard to the use of our website.

I. General information on calling up the website

1. Description and scope of data processing

When you visit our website, we automatically record certain access data, e.g.

• Date and time of access,
• if applicable, name and website of the requested file, at least method and Uniform Resource Identifier (URI) for each request – i.e. request type (e.g. GET, POST) – as well as the path without protocol and domain,
• website that initiated the request (referrer),
• access status (HTTP status code),
• the web browser used when calling up the website (user agent header),
• the operating system used when calling up the website, if it is transmitted as part of the user agent, and
• the IP address of the requesting device.

2. Purposes and legal basis of data processing

The processing of this data serves the purpose of enabling the visit of our website and ensuring the permanent functionality, availability and security of our systems. The legal basis for this data processing is Art. 6 (1) (f) DSGVO, based on our legitimate interest in the proper optimization of our website.

3. Duration of data storage

The data will be deleted 3 months after your website access.

II. Use of our contact forms

1. Description and scope of data processing

Our website provides a contact form that you can use to contact us and request information about our services. When you use the contact form, we collect and process the following data:

• Name
• Company
• Markets of interest
• Email address
• Date of enquiry
• Source of lead
• Language

Optional information:

• Telephone number
• Message
• Name Referral partner

The data submitted via the contact form is not stored on our website, but is stored and processed as a potential lead in our customer relationship management (CRM) system Monday.

2. Purposes and legal basis of data processing

The data entered via the contact form is processed for the purpose of handling your enquiry as a potential customer.

The legal basis for this data processing is Art. 6 (1) (b) GDPR (implementation of pre-contractual measures) and Art. 6 (1) (f) GDPR (legitimate interest). Our legitimate interest lies in the efficient and effective processing of enquiries and in establishing and maintaining business relationships.

The processing of data in our CRM system Monday serves the purpose of lead management and customer care. The legal basis for this is also Art. 6 (1) (f) GDPR (legitimate interest), as we have a legitimate interest in the structured management and tracking of customer enquiries.

3. Duration of data storage

We store the data collected via the contact form and the resulting leads in our CRM system for as long as is necessary to process your enquiry and potentially initiate a business relationship. If your enquiry does not result in a contractual relationship, we will delete your data after 12 months at the latest, unless you have consented to longer storage or legal retention periods require longer storage.

4. Recipients of the data

The data collected via the contact form is processed in our CRM system Monday. For more information on data protection at Monday.com, please refer to their privacy policy.

III. Use of SalesViewer®

1. Description and Scope of Data Processing

We use SalesViewer® to offer potential debt collection partners even better solutions. For this purpose, a JavaScript-based code is used to collect and utilise company-related data. The data collected with this technology is encrypted using a non-reversible one-way function (“Hashing”). The data is immediately pseudonymised and is not used to personally identify visitors of this website, in particular not for tracking debtors for the purposes of the debt collection process.

Only the following company information is collected and made available to us:

• Name, origin and industry of the visiting company
• Website + keyword from which the request originates
• Visitor behaviour (e.g. pages visited, time of visit, duration of visit)

2. Purposes and Legal Bases of Data Processing

We use the data obtained for marketing, market research and optimisation purposes on the basis of the legitimate interests of the website operator (Art. 6 para. 1 lit. f GDPR).

3. Duration of Data Storage

The data stored as part of SalesViewer® will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention obligations preventing its deletion.

You can object to the data processing for this purpose at any time with effect for the future by clicking on this link: https://www.salesviewer.com/opt-out. This will prevent SalesViewer® from collecting data on this website in the future. An opt-out cookie will be placed on your device for this website. Please note: If you delete the cookie in this browser, you will need to object to data processing again via this link.

4. Recipient of the Data

SalesViewer® GmbH acts as our data processor and therefore processes the above-mentioned data on our behalf.
You can find more information on the SalesViewer® website.

C. Supplementary data protection information relating to the use of cookies and usage analysis

In addition to the general data protection information under A., the following applies with regard to the use of cookies and usage analysis.

I. Use of own cookies

1. Description and scope of data processing

When you visit our website, various cookies are set.

In the technical sense, the term “cookies” refers to small text files that are stored in the memory of your web browser and contain information that allows web servers to recognize you on subsequent visits. Cookies cannot run programs or deliver viruses to your computer.

We use our own cookies to note that information placed on our website has been displayed to you so that it will not be displayed again the next time you visit the website.

If you do not accept cookies or prevent cookies from being stored (see c. below for how to do this), you may not be able to take full advantage of all the features of our website.

2. Purpose and legal basis of data processing

The purpose of using our own cookies is to make the use of our services as time-saving and user-friendly as possible. The processing of the respective cookies is based on our legitimate interests to enable a comfortable and individual use of our website. In this respect, the legal basis is Art. 6 para. 1 letter f) DSGVO.

3. Duration of data storage

Cookies are stored on your computer and transmitted from it to our website. Therefore, you as a user also have full control over the use of cookies:

By changing the settings in the Internet browser you use, the transmission of cookies can be disabled or restricted.

Cookies that have already been stored can be deleted at any time. This can also be done automatically by setting you in your browser used.

II. Management and Analysis of Marketing Activities

1. Description and Scope of Data Processing

We employ various marketing activities and wish to further improve these for you. In order to manage these activities and analyse their effectiveness, we use different systems. By means of so-called tags and a tag manager, we can analyse which information is particularly interesting, and use this to steer our marketing activities. The tag managers themselves do not create user profiles or set their own tracking cookies for marketing purposes; they merely facilitate the deployment of other tags.

As part of the measurement and evaluation of the success of our marketing activities, the following data may be processed – depending on your consent and our configuration:

• Online identifiers for the respective tools, e.g., Matomo ID
• Event and usage data, e.g., page views, click path, clicks on adverts, conversion tracking, mouse movements, scroll behaviour, general visitor behaviour, campaign attribution/UTM, visited website (URL), referrer URL (originating page)
• Device and browser data, e.g., user agent, browser/operating system information, language settings, screen resolution, time zone
• Location and IP data, e.g., IP address (possibly truncated/anonymised), approximate geolocation/tracking of location
• Consent/opt-in status from our consent management

The deployment of non-essential tags only takes place after consent has been given. Through our tag manager, we also set rules for data minimisation (e.g., IP anonymisation, removal of personal parameters in URLs) and for blocking tags without consent.

We additionally use Google Ads Conversion Tracking, a service for measuring the effectiveness of our advertising and optimising our offering for potential clients. If you arrive at our website via a Google advert, a cookie is stored on your device by Google Ads. The information generated by this cookie about your use of our website (e.g., clicks on adverts, pages visited, IP address) is transmitted to and stored on a Google server. The cookies are generally valid for 90 days and are not used for personal identification.

2. Purposes and Legal Bases of Data Processing

We use the collected data for marketing, market research, and optimisation purposes on the basis of your consent (Article 6(1)(a) UK GDPR, Section 25(1) of the UK Privacy and Electronic Communications Regulations).

3. Duration of Data Storage

We only store measurement and event data for as long as is necessary for the stated purposes:

The tag manager itself does not store any personal data about you. The storage and processing of data is carried out exclusively by the triggered tags, i.e., Google Ads.

In Matomo, the data is stored for 14 months.

The cookies for Google Ads are generally valid for 90 days and are not used for personal identification.

4. Recipients of the Data

For tag management, we use Matomo, a service of InnoCraft Limited, 7 Waterloo Quay, PO625, 6140 Wellington, New Zealand. Further information can be found in Matomo’s privacy notice.

For advertising reach measurement, we use services of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. Further information can be found in Google’s privacy notice.

III. links to other websites and online offers

1. Description and scope of data processing

Our website may contain links to the websites and online offers of other providers not affiliated with us. When you activate these links, we naturally no longer have any influence on what data is collected by the respective providers and what data is collected by them. Since the collection and processing of data by third parties is beyond our control, we cannot accept any responsibility for this.

Detailed information on data collection and use can be found in the privacy policy of the respective provider.

We also present ourselves as a company within social networks and other online platforms in order to communicate with current and future contractual partners/clients and interested parties as well as potential applicants and to inform them about our services.

2. Purposes and legal basis of data processing

The processing of personal data that takes place in this context is based on our legitimate interests in effective information and communication pursuant to Art. 6 (1) (f) DSGVO. If the data subjects are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 (1) (a), Art. 7 DSGVO.

3. Duration of the storage of the data

For a detailed description of the respective processing and the options to object, please refer to the linked information of the providers:

Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland): Personal Data Sharing Agreement, Privacy Policy.

LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland): Privacy policy.

Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA): Privacy policy.

Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany): Privacy policy.

D. Supplementary data protection notices relating to processing of data of our (potential) contractual partners in accordance with Art. 13 DSGVO.

In addition to the general data protection notices under A., the following applies with regard to processing operations of data of our (potential) contractual partners and their employees (hereinafter referred to as ‘(potential) contractual partners’):

I. Data Processing in the Context of Using Our Service Platform

1. Description and Scope of Data Processing

We regularly collect data, some of it personal, from our contractual partners in the course of our cooperation and communication with them for the purpose of providing our contractual or pre-contractual services and obligations. This includes – as explained in the general data protection information under A. – master data (e.g. names), contact data (e.g. e-mail address and telephone numbers) as well as contractual data (e.g. contract contents, contractual communication, names of contact persons) and, if applicable, payment data (e.g. bank details, payment history).

If you are our contractual partner, you will receive access to our service platform. In order to use the service platform, you must provide your name, an e-mail address and a password. Within the scope of using the platform, we collect login data for the purpose of security checks as well as technical usage data for the purpose of displaying the content.

We also offer white papers for download to provide (potential) contractual partners with access to important information relating to the debt collection process. This offer is explicitly intended for business customers only, not for private individuals.

By prior arrangement, it may be the case that video calls are recorded and later used to facilitate the creation of meeting notes.

II. Purposes and legal basis of data processing

The data processed here, the type, scope, purpose and necessity of the processing are determined by the underlying contractual relationship. The data processing serves the fulfillment of the contract or, before that, the implementation of pre-contractual measures. The legal basis for the data processing is Art. 6 para. 1 letter b) DSGVO.

We process the data you provide us with for downloading white papers for the purpose of processing contact enquiries and providing information to (potential) contractual partners. The legal basis for data processing is Art. 6 (1) (a) GDPR.

Data processing in the context of automated creation of meeting notes is carried out on the basis of our overriding interest in the efficient documentation of partner discussions.

III. Duration of data storage

We store personal data until the named purposes have been fully achieved (see general data protection information under A./ Item III.). When the purposes have been fully achieved (i.e. at the latest after expiry of the statutory retention periods), we delete the data.

II. Management of leads and client contacts in a CRM

a. Description and scope of data processing

We use Monday as our customer relationship management (CRM) system. In this system, we process data from potential clients with whom we are in contact or whom we would like to approach, as well as from active clients. The personal data processed includes the following data points for the respective contact persons in the companies concerned:

• Names
• Email addresses
• Telephone numbers
• Positions within the company, if applicable
• Other data relevant to contract processing

We maintain lead lists for potential customers, while for active customers we store data on contact persons and other employees relevant to the collection process.

b. Purposes and legal bases of data processing

We process this data for the purpose of effectively managing our business relationships with potential and current customers. The legal basis for this processing is Art. 6 (1) (f) GDPR (legitimate interest). Our legitimate interest lies in the efficient design and maintenance of our business relationships and in the optimisation of our sales processes.

c. Duration of data storage

The data is stored for the duration of the business relationship. For active customers, we delete the data after the contractual relationship has ended or when the employee in question has left the customer company. For potential customers (leads), the data is deleted if the lead has not been activated or if the data subject has objected to the data processing.

You have the right to object to the processing of your personal data at any time. To do so, please reply to the email or message we have sent you.

d. Recipients of the data

The data stored in Monday is transferred to monday.com Ltd., 52 Menachem Begin St., Tel Aviv 6713701, Israel, as a data processor. We have agreed with Monday that your data will only be processed in Germany. Further information on data protection at Monday.com can be found in the data protection information.

III. Targeted display of LinkedIn ads

a. Description and scope of data processing

We use the ‘LinkedIn Matched Audiences’ feature. This feature allows us to target specific audiences for our marketing activities on LinkedIn. We use ‘Company Targeting’ and possibly also ‘Contact Targeting’.

Company Targeting uses company data to target advertising to employees of specific companies. For Contact Targeting, we manually upload contact lists from our CRM system to LinkedIn. These lists only contain the data necessary for the delivery of advertising, such as the names and email addresses of business contacts.

b. Purposes and legal basis of data processing

We use LinkedIn Matched Audiences to target our marketing activities to relevant audiences and improve the efficiency of our advertising campaigns. Processing is based on our legitimate interests in optimising our marketing activities in accordance with Art. 6(1)(f) GDPR.

c. Duration of data storage

LinkedIn stores the data we upload for Matched Audiences for a maximum of 90 days, unless we remove or update it earlier. After this period or after an update, the data is deleted or overwritten by LinkedIn.

d. Recipients of the data

The data is transferred to LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, and processed on their platform. For more information about data processing by LinkedIn, please refer to their privacy policy and the information about the specific service.

IV. Targeted display of Google Ads

1. Description and scope of data processing

We use Google Ads, a service provided by Google Ireland Limited, to place our advertisements on the Google advertising network and to measure their effectiveness. When you access our website via a Google advertisement, Google Ads stores a cookie on your device. This cookie contains a unique cookie ID, information about the number of ad views, campaign IDs and timestamps.

The following data may be processed:

IP address

Cookie ID

Campaign and ad information

Time of click

Conversion data (e.g. form completions, newsletter registrations)

The cookies are usually valid for 30 days and are not used for personal identification.

2. Purposes and legal basis of data processing

We use Google Ads to target potential debt collection partners and measure the effectiveness of our advertising measures. This enables us to optimise our offering for potential clients.

The legal basis for this data processing is your consent in accordance with Art. 6 (1) (a) GDPR.

3. Duration of data storage

The data collected by Google Ads is deleted after 30 days, unless you have consented to storage for a longer period.

4. Recipients of the data

1. Google Ireland Limited

The data is transferred to Google Ireland Limited as a processor. Google may also transfer this data to servers in third countries. In this case, we have agreed standard contractual clauses with Google to ensure an adequate level of data protection.

You can prevent the storage of cookies by adjusting your browser software settings or deactivating Google Ads cookies via Google’s advertising settings. Please note that in this case you may not be able to use all the functions of this website to their full extent.

Further information on Google Ads and the handling of user data can be found in the privacy policy.

1. Consent Manager

The Consent Manager is used to comply with the legal requirements for consent to the use of cookies and to give you, the user, control over the cookies stored on your device. We are permitted to use

For consent management, we use Consent Manager, a service provided by consentmanager AB, Håltegelvägen 1b, 72348 Västerås, SE.

1. Agency

We also receive support in setting up campaigns from an agency called demand gap, Wehlistraße 291, Vienna 1020, AT.