This policy explains what personal data Aldenburg collects when you use this website and the fit-check form, why we collect it, who we share it with, and the rights you have under the General Data Protection Regulation (GDPR).
The data controller is USW OÜ, trading as Aldenburg, a company registered in Estonia. For any privacy matter, contact us at claims@aldenburg.eu.
Where your enquiry is introduced to our recovery partner, J. van Huuksloot Asset Management B.V. ("JvHAM"), JvHAM acts as a separate, independent controller of the data it receives and processes it under its own privacy policy and its own agreement with you.
We only collect what you choose to give us through the fit-check form and any follow-up correspondence. This typically includes:
We ask you not to submit contracts, statements, account credentials, beneficial-ownership information, or other confidential or special-category data through the form. Please do not include it.
We do not use advertising or tracking cookies on this site. Any submission is sent to our form provider so that your enquiry reaches us.
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| To assess your fit-check enquiry and respond to you | Steps taken at your request prior to entering a contract, and our legitimate interests in operating the referral service (Art. 6(1)(b) and 6(1)(f)) |
| To introduce a qualifying enquiry to JvHAM for assessment | Your consent, given when you submit the form (Art. 6(1)(a)), and our legitimate interests (Art. 6(1)(f)) |
| To keep records of enquiries and correspondence | Our legitimate interests in administration and record-keeping (Art. 6(1)(f)) |
| To comply with legal or regulatory obligations | Legal obligation (Art. 6(1)(c)) |
Where we rely on consent, you may withdraw it at any time by emailing us; this does not affect processing already carried out.
The principal recipient is our recovery partner, JvHAM. When your enquiry fits, we share the information you submitted so that JvHAM can assess it and, if appropriate, contact you about a recovery engagement. JvHAM is an independent controller of that data.
We may also share data with:
We do not sell your personal data, and we do not share it for third-party advertising.
Your data is processed within the European Economic Area where possible. Some service providers may process data outside the EEA; where they do, we rely on an adequacy decision or appropriate safeguards (such as the European Commission's Standard Contractual Clauses) to protect it.
We keep enquiry data only as long as needed for the purposes above: while we assess and act on your enquiry, and for a reasonable period afterwards to maintain records, handle any follow-up, and meet legal obligations. When it is no longer needed, we delete or anonymise it. You may ask us to delete it sooner (see your rights below).
Under the GDPR you have the right to:
To exercise any of these, email claims@aldenburg.eu. You also have the right to lodge a complaint with a supervisory authority — in Estonia, the Data Protection Inspectorate (Andmekaitse Inspektsioon), or the authority in your own country.
We take reasonable technical and organisational measures to protect the information you provide. No transmission over the internet can be guaranteed completely secure, which is one reason we ask you not to send confidential documents through the form.
We may update this policy from time to time. The current version is the one published here, dated above.
For any question about this policy or your data, contact claims@aldenburg.eu.