Compliance

Credimigo develops and maintains its platform in accordance with relevant European and Dutch laws and regulations. Depending on the modules used, this may relate to, among other things:

• the General Data Protection Regulation (GDPR);
• ePrivacy regulations (cookies and electronic communication);
• consumer legislation;
• the Wki (Dutch Quality of Debt Collection Services Act) and the Decree on Compensation for Out-of-Court Collection Costs (BIK), insofar as applicable to activities of the User and/or Credimigo;
• anti-fraud and anti-money-laundering obligations;
• sanctions legislation.

Credimigo is set up as a software platform with which the User conducts its own accounts receivable management ("self-collection"): the User remains the creditor, communication is sent on behalf of the User, the User retains control over actions sent, and funds in principle flow directly to the User. On this basis, Credimigo assumes that the Wki registration obligation does not apply to its services. When a User wishes to outsource a file to out-of-court or judicial debt collection, this takes place via the Marketplace to an External Partner that itself complies with the Wki (or the rules applicable to lawyers/bailiffs).

AI supports Users with communication, classification, translations and workflow advice. Users remain, at all times, themselves responsible for:

• the communication ultimately sent, even if (partly) drafted by AI;
• the workflows and automation rules configured by them;
• legal decisions taken based on the Platform, including whether or not to outsource or transfer a file.

Important actions within the Platform are recorded in an audit trail, for example:

• upload of invoices or documents;
• sending of communication;
• receipt of payment;
• conclusion of a payment arrangement;
• approval of workflow steps;
• transfer of a file to an External Partner via the Marketplace.

Credimigo supports communication in multiple languages and towards Debtors in multiple jurisdictions. Users remain themselves responsible for the content, tone and legal applicability of their communication in the relevant jurisdiction, including the rules applicable there regarding collection costs, interest calculation and consumer protection.

Complaints about Credimigo's compliance with applicable regulations can be submitted via info@credimigo.com. Data subjects also retain the right to lodge a complaint with the competent supervisory authority, including the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).