This Notice includes information regarding the transmission and processing of personal data in the context and to service the portfolio of claims transferred by the societe anonyme with the name “National Bank of Greece S.A.” (hereinafter, “the Bank”) to the special purpose company “Alpheus Hellas Designated Activity Company,” (hereinafter, “Alpheus Hellas DAC”), in accordance with the applicable national legislation and the European Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter the “Regulation”), as in force.
The Bank transferred to Alpheus Hellas DAC, a special purpose company with a registered office in Dublin, Ireland (2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, Eircode D04XN32, Ireland) and registration number in the Irish Companies Register: 626812, its claims from loan and credit card contracts which in total constitute the designated “Earth” portfolio, by the provisions of Article 3 of Law 4354/2015 and Executive Committee Act No 118/2017, as in force. In accordance with the procedure provided for by the law, the Sale and Transfer contract was legally registered in the public book established under Article 3 of Law 2844/2000 (Athens Pledge Registry, ref. No. 130/2.7.2018, volume 9, page no. 326), in conjunction with the Addendum dated 5.11.2021 to the Sale and Transfer contract which was legally registered with the public book established under Article 3 of Law 2844/2000 (Athens Pledge Registry, ref. No. 587/8.11.2021, volume 13, page number 77). Alpheus Hellas DAC, which remains the sole beneficiary of the above claims, initially assigned the servicing of the claims from the acquired portfolio to the company with the name “QQuant Master Servicer Servicing of Loans and Credits Single Member S.A.” (hereinafter, “Quant”). In contrast, from 5/12/2022, the servicing of the corresponding claims is assigned to the societe anonyme with the name “Intrum Hellas S.A for the servicing of claims from loans and credits” (hereinafter, “Intrum Hellas”), with registered office in the Municipality of Athens, at 109-111, Mesogeion Avenue, 11526, Athens, Attica, legally licensed and supervised by the Bank of Greece as a special and exclusive purpose company for the servicing of claims from loans and credits under Article 1 of Law 4354/2015.
It is stressed that the assignment above of servicing does not affect the position of the debtors or other persons involved, nor the repayment terms of the debts. The present aims to inform the natural persons connected with the above claims in any capacity (such as borrowers, guarantors, third-party guarantors, special or universal successors of the above (heirs), partners of legal entities, members of collective management bodies of legal entities or their legal representatives, shareholders and beneficial owners of legal persons or entities, proxies, representatives, employees/partners, family members, lawyers or procedural representatives of the above, notaries, bailiffs, etc. referred to as the “Data Subjects”) that, as a result of the above change of claims servicer, their personal data will be transmitted by Quant to Intrum Hellas, by order on behalf of Alpheus Hellas DAC, to service the above claims.
It is noted that until its replacement, Quant will continue to keep the personal data of the Data Subjects connected to the claims in the Earth portfolio and to serve, as an Independent Processor, in accordance with the definition in the Regulation, any requests from them for the exercise of their rights arising out of the Regulation and concern the period of servicing of the claims. As of the assignment of the servicing of the Earth portfolio to Intrum Hellas, both the latter and Alpheus Hellas DAC, the legal beneficiary of the claims, shall each act as an Independent Processor, as defined in the Regulation, concerning the processing of personal data and shall determine independently from each other the purposes of the processing with the responsibilities and powers of each being reflected in this Notice. Pursuant to the personal data protection legislation, such as the Regulation, Law 4624/2019 and any other provision that governs the use and security of the personal data of those involved in the serviced claims and in the context of the above replacement of servicer and throughout the servicing period, Intrum Hellas, acting as an Independent Processor, shall collect from the Bank as the seller of the portfolio, as well as, eventually, from third-party sources and publicly accessible records, and shall process personal data of the Data Subjects, on its behalf and on behalf and on the part of Alpheus Hellas DAC, for the purposes of the servicing of the claims and the execution of the contracts imposing legal obligations on Alpheus Hellas DAC or Intrum Hellas, such as e.g. obligations of regulatory compliance and reporting to supervisory authorities, as well as for the judicial or extrajudicial defence and pursuit of the rights and legal interests of Alpheus Hellas DAC regarding the serviced claims, pursuant to Articles 1-3 of Law 4354/2015, as in force.
The categories of personal data that may be processed for the above purposes are, in particular, identification data, contact data, including home/mail address and telephone numbers, as well as financial and property information regarding the claims above and the possibility of servicing them. In the case of a legal entity, the personal data to be collected and processed may concern the natural persons associated with the legal entity, such as legal representatives, beneficial owners, managers or members of collective management bodies, both active and inactive, partners or shareholders, contact or authorised persons or proxies of the above, lawyers, bailiffs, as well as persons against whom it is possible to assert the right of the beneficiary of the claims for the collection of the claim (e.g. third parties in favour of whom seizure can be imposed or against whom a right of set-off can be asserted). The period of retention and processing of personal data shall be the strictly necessary one, i.e. they will be retained only for the period until full payment or otherwise lawful repayment of the acquired/serviced claims unless a longer retention period is imposed by a legal obligation or permitted as part of judicial proceedings. In the context of servicing the claims, third parties, such as debtor notification companies established under Law 3758/2009, legally registered in the Registry kept by the General Secretariat for Consumers of the Ministry of Development, lawyers, bailiffs, notaries, mortgagees and employees of land registry offices, judges and court clerks, providers of postal or courier services who have entered into an agreement with Intrum Hellas for the provision of their services to it, may become recipients of the personal data at the disposal of Intrum Hellas.
Moreover, recipients of the above data may be other debtors, guarantors or persons involved in or connected in any other way with the acquired/serviced claims and their contracts, as well as any persons authorised to contact Intrum Hellas to the extent that such data concern notification, negotiation, settlement, repayment or judicial or extrajudicial pursuit of the serviced claims. From the date of assignment of the servicing to Intrum Hellas onwards, for any issue arising from the servicing of the claims and relates to the processing of personal data or the exercise of rights, as provided for by the applicable legislation on the protection of personal data, such as the right of access, correction, completion, deletion, restriction, objection, portability and withdrawal of consent (where consent is the legal basis for processing) and/or any information regarding the processing of personal data, you may contact the Personal Data Protection Office of Intrum Hellas in the following ways:
- through the form available on the website https://www.intrum.gr/dsr-form/
- by letter to the address 109-111, Mesogeion Avenue, 11526, Athens, Attica or
- by email to the email address: DPOIntrumHellas@gr.intrum.com
It is pointed out that the exercise of the above rights may not be accepted or may not produce the intended effect if it is not based on a legal and valid reason if the conditions of the Regulation are not met, or if there is a legal purpose for the retention and processing in accordance with the applicable legislation on personal data protection. In any case, Intrum Hellas shall respond in writing, with reasons and within the time limit set by the Regulation, to each request to exercise one of the above rights.
We also note that the competent Supervisory Authority for matters related to personal data and the examination of relevant disputes is the Personal Data Protection Authority (www.dpa.gr). You can find more information on how Intrum Hellas collects and processes Personal Data, any third-party recipients, the method of exercising the rights arising out of the Regulation, as well as the retention time, for Intrum Hellas, in the detailed “Information on Personal Data Protection” on the website http://intrum.gr/data-privacy/, and for Alpheus Hellas DAC, in the detailed Privacy Statement which will be posted on the website https://www.intrum.gr/3rd-party-privacy-notice/ after taking over servicing from Intrum Hellas.
Alpheus Hellas DAC
QQuant Master Servicer Servicing of Loans and Credits Single Member S.A.