Personal Data Protection Policy

  • Objective(s):

  • Creation of a specific section (new tab) to provide information to individuals about the processing of their personal data. This requirement is based on our interpretation of the obligations of transparency and clarity required under the GDPR (Art. 12, 13 and 14, GDPR). This requirement not only requires comprehensiveness in terms of content, but also working on its presentation so as to be as clear as possible for individuals. The creation of a dedicated section aims, for its part, at making this information easily accessible for the user, and avoids the user having to take any positive action (for example, having to seek out this information amongst other information contained in legal information notices, standard Ts & Cs of Sale and/or Use.

  • Beyond compliance considerations, the prominent display of this policy on Amaro’s website is part of a global GDPR compliance approach, which is a trust factor for customers but also for all other persons with whom your company has dealings (partners, media, etc.). It is also in line with the new principle of “accountability” defined in the GDPR and the reversal of the burden of proof this entails (i.e. all players processing personal data having to be responsible for, and be able to demonstrate compliance with, the GDPR at all times).

  • Actions:

  • Create a new section (tab) titled “Personal Data Protection”,

  • Include in the drafts you sent to us (Ts & Cs of Use and Sale). To find out more: see our Personal Data Protection Policy


Addpaid Services s.r.o
. (hereinafter “Amaro”) makes available to creditors, on its website available at (hereinafter the “Site”), a delinquency management tool on which they can report delinquent payers and, in this way, facilitate their debt recovery (hereinafter the “Addpaid Service“).

Amaro attaches great importance to the protection of privacy and personal data of the visitors and users of its Site. Amaro is accordingly concerned with adopting and complying with applicable personal data protection principles across all of its activities.

The purpose of this personal data protection policy (the “Policy”) is to provide any user of this Site (“You” or “Your”) with comprehensive information, in clear and plain language about the way Amaro (“We”, “Us”, or “Our”), as the controller or joint controller (as applicable), collects and uses data concerning You and about the means available to You to control such use by exercising Your related rights.

Specific information notices are also featured, on each collection form, to ensure that You are fully informed before any processing of Your data. You are also invited to read Our cookie section concerning cookies issued on the Site.


The data of users of the Site are collected and processed by Amaro Services s.r.o., a Czech company with share capital of 200.000 CZK, with its identification number 04730461, registered by the City Court of Prague under number C.252786, having its registered office at Husova 240/5, Staré Město, 110 00 Prague 1, Czech Republic, VAT number , represented by M. Renaud Arnaud Philippe Sassi, , email: (

Amaro’s data protection officer is: Gregor Krzyzanowski.

When You use Addpaid Service, You will provide Amaro with personally identifiable information and personal data concerning third parties, namely delinquent payers. In such case, and for the avoidance of doubt it is specified that You are the joint controller of the processing of such personal data and You confirm having collected such information and data in accordance with applicable legislation.


We collect the following data for the purposes of providing and improving Our Addpaid Service. Depending on the case, such data may be collected directly or indirectly:

  1. When You create a user account, in particular to report a delinquency, dispute it or sign up for alerts:

  • Information about Your user account: We collect – and associate with Your account – the information You provide to Us directly whenever You do things such as set up a user account to report a delinquency or dispute a delinquency report, log onto Your account, sign up for an alerts subscription, report a delinquency or dispute a delinquency report. This data includes Your identification data, namely: Your preferred form of address, surname and first name, email address, identity document, the name of Your company/organization and a short-form certificate of incorporation, where applicable, Your postal address, date of birth, telephone number, and contact history;

  • Your invoicing data: Our Addpaid Service is designed to facilitate the storage, management and payment of Your unpaid invoices. To be able to do so, We store, process and transmit the invoicing data that You have provided to us directly, namely the nature of the receivable, the amount of the delinquent receivable, a copy of the invoice or related supporting document, the amount of any late-payment interest or penalties, the payment due date, etc.

  • Information about delinquent payers: We collect personally identifiable and personal data (ex: identification data, invoicing data, etc.) concerning third parties, namely delinquent payers, that You provide when reporting delinquencies.

We also collect such information and data whenever You use one of Our contact forms or interact with Us through other means (e-mail, phone, social networks, etc.) or whenever You sign up for Our marketing communications (ex: newsletter).

Any mandatory fields are marked as such by an asterisk (*). If You do not complete those fields, We will unfortunately be unable to process Your request. All other data is optional, meaning that You are free to complete optional fields or not, without this entailing any particular obligation or disadvantage for You.

  1. Whenever You make a payment or transfer funds:

  • Your payment information, i.e. Your banking information (payment card, IBAN, RIB or other national BBAN) and the amount of the payment or of the fund transfer.

  1. Whenever You browse the Site and use the Addpaid Service:

  • Information on usage. We indirectly collect information about the way in which You use the Addpaid Service, including any actions You take in Your account (such as sharing, modifying, viewing or moving files or folders). This data helps us improve Our Service, develop new services and new features, and to protect Our users.

  • Information about Your device. We also indirectly collect information from and about the devices You use to access the Site and the Addpaid Service. This information mainly concerns the IP address, the types of protocols and browsers used to connect to the Site and to transfer data to the Site or else files that enable users to remain connected to their account. Your devices (depending on their configuration settings) may also transmit geolocation data.

  • Cookies and other technologies. We use technologies such as cookies and Web beacons to supply, improve, protect and promote Our Site and the Addpaid Service. For example, cookies help Us remember Your user name upon Your next visit, to understand how You interact with our Site and the Addpaid Service and to improve them on the basis of the information collected. You will be invited to accept the placement of cookies on Your terminal upon Your first connection to this Site. For more information about Our cookies, click here.


We only process Your data to ensure optimal use of the Site, to manage Your user account, ensure the provision of the Addpaid Service and/or of the alerts service offered on the Site, respond to Your questions or requests and keep You informed of Our news.

Amaro needs to collect and process certain data concerning You to the extent such data are, as the case may be, necessary for performance of a service contract, for compliance with legal or regulatory obligations, collected with Your prior consent or in Our or Your legitimate business interests.

It is specified that Amaro only collects data that are adequate, relevant and limited to what is necessary for the purposes for which they are processed.

These objectives are specific and legitimate and under no circumstances will Your data be processed subsequently in a way that is incompatible with such purposes, unless Your prior consent has been obtained.

Accordingly, We may use Your data to:

  • respond to Your requests to sign up for the alerts service or Your contact form submissions;

  • set up a user account;

  • manage Your user account;

  • publish Your delinquency reports;

  • manage delinquency payments made by third parties;

  • manage disputes of delinquency reports;

  • manage any possible complaints and provide You with assistance;

  • prepare statistics;

  • detect fraud;

  • comply with legal requirements, in particular as the host of the content on the Site;

  • optimize our Site and Our service offers.

Your data may also be used for the purposes of direct marketing by email subject to Your prior consent. By exception, and in accordance with applicable legislation, in case Your contact details are collected in the context of a service contract and are used to send you marketing messages promoting similar services provided by Amaro, Your contact details may be used without Your consent. Similarly, Your consent will not be required for phone marketing (telemarketing) or postal marketing. In both cases, Amaro will process Your data for the purposes of interests that qualify as legitimate under applicable legislation, without this having any impact on Your rights. You may object to such processing at any time, as indicated in section 8 of this Policy.

We may also organize surveys in which You are entirely free to take part or not.

Information about the way in which You use Our services will only be used to personalize Your user experience, Our communications and any possible offers made to You. The creation of such a profile is solely intended to enable Us to better respond to Your preferences and needs.


The only persons who are authorized to have access to Your data are the members of Amaro’s customer and/or marketing teams, as well as the IT teams, in this last case to fix any possible bugs.

For the purposes of access to the Site and the provision of the Addpaid Service, Amaro may transfer the personal data of users and delinquent payers to third party sub-processors who provide it with support services, such as financial entities, anti-fraud bodies, technology providers (hosting), and/or transaction analysis services.

We may also disclose Your data in response to legal or regulatory requests, subpoenas, court orders, or legal process, if required to do so under applicable legislation, and in case Amaro transfers all or some of its assets to another company.

Lastly, Your personal data may be disclosed to all visitors and users of the Site in case of the publication of a delinquency report, as well as on the social networks of users making such reports, as the case may be.

Subject to having obtained Your express prior consent, Your email address and phone number may also be transmitted to Our partners for the purposes of direct marketing by email and/or SMS text messages and benefiting from their services.

We do not sell Your personal data. If Amaro transfers Your personal data to third parties located outside the European Union, such transfers will always comply with the provisions of the GDPR, Amaro taking all appropriate measures to protect Your data, in particular through the use of standard contractual clauses approved by the European Commission or of the Privacy Shield for the United States.


Your data will be kept by Amaro for as long as You use the Addpaid Service, and will be erased no later than three (3) years after the date of the last contact between us, except in case of anonymization or the existence of a legal requirement to keep certain data for a longer period.

Your connection data to the Site will only be kept for a period of thirteen (13) months.


Protecting Your privacy and data is a priority for us. We invite all registered users to create a password and to keep it secret. We also recommend that You restrict access to Your computer or mobile device and that You log off after having used the Addpaid Service.

At Amaro, We take appropriate security measures, in particular technical and organizational measures, to protect Your data against accidental loss, destruction, misuse, damage and unauthorized or illegal access.

All personal data being confidential, access thereto is restricted to Amaro’s employees or service providers on a need-to-know basis for the performance of their services.

All persons with access to Your data are under a duty of confidentiality and face disciplinary measures and/or other penalties if they do not comply with this duty.

Any third-party recipient will be under a contractual duty in view of ensuring the protection of Your personal data and compliance with Your rights.


You have, subject to the limits laid down under applicable legislation, the following rights in relation to the processing of Your data:

  • The right to be informed of the use of Your personal data;

  • The right to access the personal data We hold about You;

  • The right to request the rectification of any inaccurate personal data We hold about You (in this respect, You can also make the rectification directly in the “My Account” section, where such a section exists);

  • The right to request Us to erase Your data or, in some cases, to stop processing or collecting such data. However, in such case, it is possible that You may no longer be able to access the Addpaid Service;

  • The right to withdraw Your consent to receiving Our news and to object to the processing of Your data (in particular for the purposes of being able to send You direct marketing messages;

  • The right to ask Us to hand over Your data to You or to transfer it to another service provider (right to “portability”);

  • The right to issue specific or general instructions about the retention, erasure and disclosure of Your data after Your death.

  • The right to make a complaint to the competent data protection authority.

If You have any question or request and/or wish to exercise Your rights, You can contact Us by email at: or by postal mail at: Amaro s.r.o., Husova 240/5, Staré Město, 110 00 Prague 1, Czech Republic, and include or attach a copy of any valid identity document).

To stop receiving messages marketing from Amaro, You can also click on the unsubscribe link provided in each of Our messages.

Amaro promises to reply to You without undue delay, and in any event within one month of receiving Your request.

This period may be extended by two further months where necessary, taking into account the complexity and the number of requests made to Amaro. In such case, You will be informed of this extension and the reasons for the delay.

If Your request is made electronically, the information will also be provided electronically where possible, unless otherwise expressly requested by You.

If We do not take action on Your request, We will inform You of the reasons for not taking action and You will have the possibility of lodging a complaint with a supervisory authority and/or seeking a judicial remedy.


To follow Our news, You can go to Our Twitter account or Facebook page from Our Site. The only data We will collect will be anonymous and processed for purely statistical purposes (for example, to track the number of subscribers to Our account).

Note that We are not responsible for any processing of Your data that may be carried out by such social networks. For more information on such processing, about Your rights in this respect and on how to configure your option settings to protect your confidentiality, We invite You to consult the respective policies on the website of the social network concerned.



Amaro being based in the Czech Republic, We are subject to the law of August 1st, 2018 on the organization of the National Data Protection Commission (Commission nationale pour la protection des données), to the general data protection system and, more generally, to General Data Protection Regulation 2016/679 of April 27th, 2016 (“GDPR”).

In case of any dispute that cannot be resolved amicably, the court of competent jurisdiction shall be determined in accordance with applicable procedural rules.


This Policy is subject to change. If We consider any change to be significant, We will bring it to Your attention and, where necessary, request Your consent.

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