Privacy notice

Controller

The controller for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

Recovio GmbH Milchgasse 5 94032 Passau Germany

Registered seat: Munich. Register court: Amtsgericht München, HRB 316125. Managing director: Marc Nickel.

Email: datenschutz@recovio.de

We have not appointed a data protection officer, as the statutory conditions for doing so do not apply. Please direct data protection enquiries to the address above.

Whose data we process

This notice covers two groups, whose data we process differently.

Visitors to this website

Anyone who opens the site without contacting us.

People in receivables matters

People against whom a creditor is pursuing an unpaid invoice, and whom we contact on that creditor's behalf. We receive the data from the creditor, not from the person concerned.

Use of this website

This website is a static site. We set no analytics or advertising cookies and embed no tracking services.

Technically necessary connection data is processed when the site is requested, such as IP address, time of the request and the address requested. The legal basis is our legitimate interest in operating the site securely (Art. 6(1)(f) GDPR).

Data in receivables matters

On behalf of the relevant creditor, we process the data required to deal with one specific unpaid invoice:

Identifying data

Name, address, telephone number, email address.

Account data

Invoice number, amount, due date, payments, payment commitments and the state of the matter.

Communication data

The content and time of calls, text messages, emails and letters, and your response to them, including any refusal of further contact.

Call recordings

A recording and transcript of a call, but only where you expressly consent at the start of that call.

Purposes and legal bases

We process this data to resolve one specific unpaid invoice out of court: to reach the person concerned, establish the position, make payment or a payment arrangement possible, and document the matter.

The legal basis is Art. 6(1)(f) GDPR. The legitimate interest is the enforcement of an existing debt, held by the creditor and by us as the instructed service provider.

For recording a call we rely solely on your consent under Art. 6(1)(a) GDPR. You may withdraw it at any time with effect for the future; this does not affect the lawfulness of processing carried out beforehand.

Where we are under a statutory retention obligation, for example under commercial or tax law, processing is based on Art. 6(1)(c) GDPR.

Calls with an AI voice assistant

Calls in receivables matters are made by an AI voice assistant. This is not concealed automation: at the start of the call the assistant states that it is a Recovio AI assistant and on whose behalf it is calling, before any detail of the matter is raised.

Before any account detail is given, the assistant confirms it is speaking to the right person. We do not disclose the existence of a debt to third parties.

A call is recorded only if you expressly agree. Without clear agreement the call continues but is not recorded. Speech is processed in real time using Microsoft Azure language models within the European Union.

You may refuse further calls at any time. Such a refusal is stored and immediately blocks further calls to you.

Recipients and processors

We pass data to the creditor on whose behalf we act, and to service providers acting for us as processors under Art. 28 GDPR. Data processing agreements are in place with them.

Hetzner Online GmbH

Server operation. Data centre in Germany.

Microsoft (Azure)

Database, language models and email delivery. Processed in data centres within the European Union.

Twilio

Telephony and text messages. We use the Ireland region, so call data and recordings are processed within the European Union.

Cloudflare

Delivery and protection of this website.

Payment and postal providers

We use specialist providers for payments and, where enabled, for postal delivery.

No transfer to a third country takes place. Should one become necessary, it will occur only on the basis of an adequacy decision or appropriate safeguards under Art. 46 GDPR.

Retention

We keep data about a matter for as long as is necessary to deal with it, and beyond that where statutory retention periods apply. Commercial and tax law periods are generally six and ten years respectively.

Recordings and transcripts are deleted once the documentation purpose has ceased, and at the latest when the retention period for the matter expires. If you withdraw your consent we delete the recording, unless a statutory retention obligation prevents it.

A stored refusal of further contact is retained, because keeping it is the only way to ensure it is honoured.

Your rights

You have the following rights under the GDPR, which you may exercise against us free of charge:

Access (Art. 15)

What data we process about you and where it came from.

Rectification (Art. 16)

To have inaccurate data corrected.

Erasure (Art. 17)

To have data deleted, where no retention obligation applies.

Restriction (Art. 18)

To have processing restricted.

Portability (Art. 20)

To receive your data in a common format.

Objection (Art. 21)

To object to processing on grounds relating to your particular situation.

Please write to datenschutz@recovio.de. We reply within the statutory period of one month.

You may also complain to a data protection supervisory authority, such as the Bavarian Data Protection Supervisory Authority or the authority where you live.

Changes to this notice

We update this notice when our processing changes. The version published here, bearing the date above, is the one that applies.