Debt collection policy

1. Information for debtors according to Art. 13/14 of General Data Protection Regulation (GDPR)


Identity of the Data Controller:

EOS KSI, Upravljanje terjatev d.o.o.,
Letališka cesta 33,

Contact details of the data protection officer:

Urša Groznik,
EOS KSI, Upravljanje terjatev d.o.o., 
Letališka cesta 33, 
SI-1000 Ljubljana

Processing purposes and legal basis:

The data is processed for the purpose of contract performance or legal action. According to Art. 6 (1) (b) GDPR, the processing of your data is necessary for the fulfilment of a contract with the aforementioned creditor due to the delay in payment by you. Another purpose of data processing is debt management in accordance with Art 6 (1) (f) GDPR, which also includes the data-based control of collection measures optimised for you. Data processing is therefore necessary to protect our legitimate interests or those of a third party.

Data categories and data sources:

We process the following categories of data:
Master data (first name, last name, address, EMŠO number (Citizen's Personal Reg.No.), TAX number, communication data (telephone number, email address), contract data, receivables data, payment information, if applicable.

The data from the aforementioned data categories were transmitted to us by the aforementioned creditor or one of the recipients named below, as well as from national authorities based on our sent requests (external skip tracing) in accordance with national legislation.


In the context of the collection procedure, we will transfer your data to the aforementioned creditor and, if necessary, to the following categories of recipients, insofar as this is necessary to collect the claim: assignees, credit information agencies, service providers, third-party debtors, registration offices, courts, bailiffs, lawyers, as well as our national authorities based on our sent requests (external skip tracing) in accordance with national legislation.

Duration of storage:

After payment of the outstanding claim or termination of the collection procedure, we check after five years whether we still need your data and are opposed to deletion of legal retention periods. In some other cases the legal retention period could be up to ten years (in accordance with national legislation).

Rights of the data subject:

If the legal requirements are met, you have the following rights under Articles 15 to 22 GDPR: right to information, correction, deletion, restriction of processing and data portability. Furthermore, pursuant to Article 14 (2) (c) in conjunction with Article 21 GDPR, you have a right of objection to the processing based on Article 6 (1) (f) GDPR.

Right of complaint to the supervisory authority:

According to Article 77 GDPR, you have the right to complain to the supervisory authority if there are valid reasons or indications that the processing is not lawful.

The address of the supervisory authority responsible for our company is:

Republika Slovenija
Informacijski pooblaščenec
Zaloška 59
1000 Ljubljana
Telefon: 01 230 97 30
Faks: 01 230 97 78