Data Protection Policy

  DATA PROTECTION POLICY   

In accordance with the General Data Protection Regulation (EU) 2016/679

 

QQUANT MASTER SERVICER S.A is an independent servicer licensed by the Bank of Greece in accordance to Greek law 4354/2015 and is committed as either ‘data controller’ or as  ‘data processor’ to protect personal information which will be processed in accordance with  the relevant provisions of European legislation on personal data General Data Protection Regulation (EU) 2016/679 and Greek law in force.

For this purpose, QQUANT MASTER SERVICER S.A implemented the following Policy:

 

Legal Grounds for Processing Personal Data

During the whole servicing period, QQUANT MASTER SERVICER S.A will collect and process your personal data for the purposes of servicing your Debt according to articles 1-3 of Law 4354/2015, as in force.

Moreover, QQUANT MASTER SERVICER S.A will process the above data, which is subject to the below legal and regulatory obligations that arise from Law 4354/22015, and the Act under number 118/19.5.2017 of the Executive Committee of the Bank of Greece, as each time in force:

  • the Code of Conduct of the Bank of Greece (Decision under number 195/1/29.7.2016 of the Credit and Insurance Committee of the Bank of Greece, and articles 1 and 4 of Law 4224/2013, as each time in force, and any other regulatory and delegated act or decision that is issued in respect of the above);
  • Act under number 2501/2002 of the Governor of Bank of Greece, as each time in force (which imposes information obligations and general transparency requirements, as well as requirements for the servicing of requests and complaints of the borrowers);
  • The legal and regulatory framework as regards the prevention of the use of the financial system for the purposes of money laundering and terrorist financing, as each time in force, (more specifically, Law 3691/2008, decision under number 281/5/17.3.2009 of the Banking and Credit Committee, Directive 2005/60/EC, Directive 2015/849/EC, Recommendations of the Financial Activity Task Force, as well as any relevant Acts, Decisions and delegated circulars of any competent authority);
  • Article 8 of Law 3758/2009, as in force, which imposes the obligation for the record of the content of the telephone communications conducted for the purposes of information of the borrowers for due debts. Any such recorded telephone communication, as well as the record of the relevant telephone communications for the purposes of information of the borrowers for their due debts (article 6 par. 7 of Law 3758/2009, as in force), will be kept for a year and
  • Submission of prudential supervision reports to the Bank of Greece and conduct of controls by the Bank of Greece.

Beyond the above mentioned compliance obligations of QQUANT MASTER SERVICER S.A, the processing of your personal data is necessary to pursue our legitimate interests being the servicing of claims arising under the original credit agreements, to which the legal owners have acquired the claims and appointed us as the master servicer. Before processing your personal data, we consider whether overriding legal grounds for processing out-weigh your rights and freedoms under the GDPR. Your personal data will only be processed with your consent. You have the right to withdraw this consent at any time. However, for the time period before withdrawing your consent the processing of your data, remains validly processed.

 

Collecting and Processing of Personal Data

Personal Data includes all information collected by the Bank/s that provided your credit as well as all data collected by QQUANT MASTER SERVICER S.A during the whole servicing period in the name and on behalf of the legal owners of the receivables for the purposes of managing your Debt.
In particular the personal data that are being processed are the following: Identification information(Name, surname, Know Your Customer), Contact information (e-mail address, postal address, phone number), financial standing and credibility (including but not limited to employment status and details, income and expenditure debts such as loans and credit cards), information regarding your personal status as well as special categories of personal data [ sensitive data] collected according to applicable data protection laws or otherwise collected through publicly accessible sources and for the purpose of implementation of the Code of Conduct of the Bank of Greece, any information in relation to the contract fulfilment, records of the relevant telephone communications for the purposes of information for your due debts, payments records and any correspondence or service notifications exchanged concerning the recovery of your debt.

QQUANT MASTER SERVICER S.A will process the above personal data for the purpose of managing your debt and especially for communicating with you, improving the accuracy of the information already provided to QQUANT MASTER SERVICER S.A understanding your personal, financial and individual circumstances and agreeing on an appropriate payment plan for you, monitoring your payments, taking litigation actions or other measures for the recovery of claims and in general supporting and assisting you with regards to your dealing with us .

 

Recipients of Personal Data

In this context and for the purpose of debt recovery, your personal data may be transferred to:

  • employees of QQUANT MASTER SERVICER S.A, who are responsible for evaluating your requests, the management of your account and the fulfillment of your obligations according to all applicable laws and only if necessary for the purposes described;
  • debtor information companies under Law 3758/2009, as in force, in the case your debt is overdue;
  • lawyers and law firms, court bailiffs, notaries and courts;
  • licensed Servicers by the Bank of Greece in accordance to Greek law 4354/2015 as amended and in force;
  • supervisory, judicial, independent or governmental authorities which are by law appointed to supervise and monitor the servicing activities of QQUANT MASTER SERVICER S.A and
  • services providers (affiliated companies and third parties), that are appointed by QQUANT MASTER SERVICER S.A for specific services including data processing, such as providers of data storage and management of data services or IT providers or providers of printing and sending of periodic statements and written communications including Greek Banks and their collaborating networks for the purpose of making payments against your debt and in general for providing services to you through the branch networks in Greece.

For the purposes QQUANT MASTER SERVICER S.A above may reveal your above personal data to the Bank of Greece and to other competent national authorities (such as the competent authority of article 10 of Law 3759/2009 etc.) or so otherwise required by law or by the order of competent court or authority. In addition, QQUANT MASTER SERVICER S.A may reveal your above personal data to the persons assigned with personal data processing on its behalf according to law (including the Bank for the purposes of providing services to you through its branch network in Greece). The above processing will continue for as long required by law.

Finally, to the extent permitted by law, for the purposes of managing your Debt, QQUANT MASTER SERVICER S.A will proceed to the following:

  • will transfer personal data referring to you to the following databases that are kept with Tiresias S.A.: I) Default Financial Obligations System (DFOS), and/or II) Credit Consolidation System (CSS), and
  • will collect and process your personal data that are registered in the following records that are kept with Tiresias S.A.: I) Default Financial Obligations System (DFOS), and/or II) Credit Consolidation System (CSS), with your prior consent.

The DFOS contains data related to the credit behavior of individuals and companies (e.g. bounced cheques, termination of loan and credit agreements, payment orders, auction announcements, bankruptcies etc.), and the retention period for this data is between 2 and 10 years (depending on the data category). The CSS contains data regarding business and retail-consumer credit (current balance with no delinquency, delinquent balance etc). and the retention period of this data is 5 years. Data controller of DFOS and CSS is “Tiresias S.A.” (Municipality of Amarousio, 1 Alamanas Street, zip code 151 25).

 

Transfers of Personal  Data to Third Countries or International Organizations

QQUANT MASTER SERVICER S.A   may send your personal information to recipients in other countries outside EU. In such cases QQUANT MASTER SERVICER S.A shall always, as required by law, implement suitable safeguards, to ensure that your personal information is protected under GDPR and that you are able to exercise your rights effectively.

 

Safety of Personal Data

In order to pursue the above purposes and to service your account appropriately and fairly, we process your data and information, always subject to appropriate technical and organizational measures, such as access rights and encryption, to keep your information safe; In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information.

 

Rights relating to the Processing of Personal Data

You have all the rights provided by  GDPR and the Greek legal framework regarding data protection to subjects of personal data in respect of the processing of your personal data.You may exercise your rights by addressing a written request to QQUANT MASTER SERVICER S.A  to the following address:

16, Paradisou Str. 15125 Marousi – Telephone number: +30 216 000 2000

As a data subject you have the following rights regarding your information that we hold;

Right to access: You  may at any time  request access to all your personal data  and get  information regarding  the categories of personal data we are processing, the purpose of the processing ,  and who it will be shared with as well as  your rights according to GDPR regulation.

Right to rectification: We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We may ask that you provide reasonable proof to verify your request.

Right to restrict processing: If you believe the personal information we hold is inaccurate, unlawful, or that we do not have legitimate interest to process it, you can request that we restrict any processing until this is rectified.

Right to object to processing: Where your particular situation merits that we do not process your information for the performance of a task carried out in the public interest or based on our legitimate interest, you have the right to object to the processing.

Right to  erasure: You have the right to obtain  the erasure of your personal data data, which can be met in certain conditions.

Right to data portability: This right allows you to obtain in a structured, commonly used format, and reuse the information you have provided to us for your own purpose and have it transmitted directly to different services. This applies only to information we use based on your consent or on basis of a contract.

Right to lodge a complaint: You have the right to lodge a complaint with the Greek supervisory authority, Hellenic Data Protection Authority, https: www.dpa.gr, where you have a concern about our data protection practices.

Exercising your rights does not legally affect previous processing of your data by the Company.

Furthermore   QQUANT MASTER SERVICER S.A in many circumstances  will have  to continue processing your data to protect the rights of another natural or legal person, or because it’s an important public interest.

You may also directly contact our Data Protection Officer, using the contact details above or by the following email: dpo@quant.gr

QQUANT MASTER SERVICER S.A shall use its best efforts to respond to your requests and questions regarding data protection practices within thirty (30) days from the time of submission.

 

Duration for which your Personal Data is held

QQUANT MASTER SERVICER S.A will retain your data as long as required for the lawful purpose for which it was obtained, as long as it has a legitimate interest to keep it. In particular:

Personal data (including correspondence) will be retained for (5) years or six (6) years from the last transaction date according to the applicable regulations by Bank of Greece

Personal  data will be retained for  a period of ten (10) years for tax  purposes .

After the end of this period, the data are held in accordance with the applicable legislative framework for the period required to protect QQUANT MASTER SERVICER S.A  rights before a Judicial or other competent Authority.

 

Collaboration with Data Controllers & Processors

For the purpose of debt recovery activities and its contractual obligations QQUANT MASTER SERVICER S.A cooperates with the following Data Controllers & Processors:

 

  • ABS METEXELIXIS S.A.
  • Aglaea Kretsi and Partners Law Firm | 9 Iliou Ilia & Nikomachou Str. , Athens, 11631 | business@kretsi.gr
  • Cepal Hellas Financial Services S.A. | 209-211 Syggrou Av. , Athens, 17121 | cepalcorporate@cepal.gr
  • Charaktiniotis & Partners Law Firm | 10 Merlin Str. ,  Athens, 10671 | info@charaktiniotis.gr
  • Deleti Veroniki Law Office |59 Panepistimiou Av. ,  Athens, 10564 | infolaw@deletilaw.gr
  • Eugenia Giannini & Associates Partners Law Office  | 89 Patision Av.,  Athens, 10434 | info@gianninilaw.eu
  • First Call S.A.  |40 Pireos Av. , Moschato, 18346 | info@firstcall.gr
  • Flambouras & Associates Law Firm |143 Androutsou Str, Piraeus, 18532 | flampouraslaw@fplaw.gr
  • Fragou Law Firm | 3 Korai Sqr, , Athens, 10564 | info@flf.gr
  • Mellon Contact Services S.A |  74A Pireos Av. , Piraeus, 18547 | info.gr@mellongroup.com
  • Mourgelas, Dimitropoulos ,Konstantelias Law Firm (d.t Jure Law Firm) | 21 Amerikis Str. 21, Athens, 10672 | jure@jure.gr
  • Nikolaos A. Andrikopoulos & Associates Law Firm | 35 Kifissias Av. , Athens, 11523 | info@nandrikopoulos.gr 
  • Sioufas & Associates Law Firm | 6A Neou Falirou Str., Agios Ioannis Rentis, 18233 | info@sioufaslaw.gr
  • Tsafaras H. Spyridon Law Office | 3 Zoodochou Pigis Str., Athens, 10678 | tsafaraslaw@tsafaras.gr