This Notice includes information about the transmission and processing of personal data in the context and to manage a portfolio of securitised claims by 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 special purpose company called “Pillar Finance Designated Activity Company”, having its registered office in Dublin, Ireland (Fourth Floor, 3 George’s Dock, IFSC) with Irish Companies Register No 621156 (email address: Ireland@Wilmingtontrust.com, fax: +3531 612 5550) (hereinafter, “Pillar Finance DAC”), is the owner of a portfolio of loan and credit claims (and the guarantees and collateral for said claims) (hereinafter, the “Claims”) included in the annex of the act of registration of the publication form No 146/18-6-2019 under Article 10(8) of Law 3156/2003 in the Public Book under Article 3 of Law 2844/2000 of the Athens Pledge Registry in volume 10 and with serial number 180.
Pillar Finance DAC acquired the portfolio in question from the public limited company with the name “Eurobank Ergasias S.A.”, now “Eurobank S.A.”, based in Athens (8, Othonos Street, 8, PC 105 57, with General Electronic Commercial Registry (GEMI) No 154558160000 and Tax Identification Number 996866969 (the “Bank”), by the provisions on the securitisation of business claims under Articles 10 and 14 of Law 3156/2003.
Pillar Finance DAC, which remains the main and sole beneficiary of the Claims, initially assigned the servicing of the Claims to the company with the name “Do Value Greece Loans and Credits Claim Management Societe Anonyme” based in Moschato Attica (27, Kyprou and Archimidous Street, Postal Code 183 46, Moschato) with General Electronic Commercial Registry (GEMI) No 121602601000 and Tax Identification Number 099755919 (hereinafter, “Do Value”). The initial assignment of servicing to Do Value was registered with the act of registration No 147/18.6.2019 in the Public Book established under Article 3 of Law 2844/2000 of the Athens Pledge Registry in volume 10 and with serial number 181.
Do Value acted as the servicer of the Claims until it was replaced by the societe anonyme with the name “QQuant Master Servicer Single Member S,A.” based in the Municipality of Athens (66, Kifisias Avenue,15125, Marousi, Attiki) with General Electronic Commercial Registry (GEMI) No 143190101000 and Tax Identification Number 800858891 (email address: firstname.lastname@example.org, phone number +30 216 000 2000/fax: +30 216 000 2090 (hereinafter, “QQuant”), which the Bank of Greece has licensed as a loan and credit claims servicer under Article 1 of Law 4354/2015 (Decision 247/1/14.11.2017 of the Credit and Insurance Committee of the Bank of Greece, published in Government Gazette B, No 4171).
The appointment of QQuant as servicer of the Claims in place of Do Value will be effective from the date of the registration of the relevant servicing contract in the Public Book established under Article 3 of Law 2844/2000 of the Athens Pledge Registry (the “Registration Date”), which will be on or about May 15, 2023.
It is stressed that the assignment above of servicing to QQuant 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 Claims in any capacity (such as borrowers, co-debtors, guarantors, third parties providing real property or other collateral, other liable persons (due to seizure in the hands of a third party or due to set-off or due to a pledged claim against them), special or universal successors of the above persons (heirs), curators or persons exercising parental care, guardians, trustees, executors of will, administrators of the estate or other representatives, partners of legal entities, members of collective management bodies of legal entities or legal representatives of legal entities, shareholders and beneficial owners of legal entities or other entities, attorneys, representatives, employees/partners, family members, lawyers or procedural representatives of the above, notaries, bailiffs, etc.) (hereinafter, the “Data Subjects”) that, as a result of the above change of Claims servicer, their personal data related to the Claims (hereinafter, the “Personal Data”), are transmitted by Do Value to QQuant from the Registration Date onwards, by order and on behalf of Pillar Finance DAC, for the purpose of servicing the Claims.
Do Value will continue to hold and process the Personal Data of the Data Subjects associated with the Claims for as long as is necessary to, on the one hand, process, as an Independent Processor, any requests by them to exercise their rights under the Regulation relating to the period of servicing of the Claims by the same and, on the other hand, to the extent imposed by the applicable legislative and regulatory framework or in the context of a trial or to discharge legal obligations or obligations of regulatory compliance and reporting to supervisory authorities of Do Value.
From the Registration Date onwards and throughout the servicing of the Claims, both QQuant, as the servicer of the Claims and Pillar Finance DAC, as the main and legal beneficiary of the claims, shall each act as an Independent Data Controller for the processing of Personal Data and each alone shall determine the purposes and manner of processing Personal Data.
According to the personal data protection legislation, i.e. the Regulation, Law 4624/2019 and any other provision governing the processing and security of personal data, as of the Registration Date and throughout the servicing period, QQuant, acting as an Independent Processor, shall collect from the Bank as the seller of the Claims portfolio, Do Value as the previous servicer of the Claims as well as, eventually, from third-party sources and publicly accessible records and shall process on its behalf and on behalf of Pillar Finance DAC, the Personal Data of the Data Subjects that are necessary for servicing the Claims and executing any contracts imposing legal obligations on Pillar Finance DAC or QQuant, 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 Pillar Finance DAC regarding the serviced Claims. The categories of personal data that may be processed for the above purposes are, in particular, identity, contact information (home/mail address and telephone numbers), as well as financial and property information regarding the Claims and the possibility of servicing them. In the case of a legal entity, the Personal Data that may be processed involve the natural persons associated with the legal entity, such as indicatively, legal representatives, beneficial owners, managers or members of collective management bodies, both active and inactive, partners or shareholders of legal persons or entities, who are contact or authorised persons or proxies or agents or employees/partners of the above. Moreover, the above includes Personal Data of persons related to the Claims, such as lawyers or procedural representatives, notaries, and bailiffs, as well as persons against whom the claimant’s right to collect the claim can be asserted (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 by QQuant shall be the strictly necessary one, i.e. the Personal Data shall be retained for the period until full payment or otherwise lawful repayment of the serviced Claims unless a longer retention period is required by the applicable legal and regulatory framework or in the context of a trial or to meet QQuant’s legal or regulatory compliance and reporting obligations. In the context and to service the Claims, QQuant may, as appropriate, transmit the Personal Data to debtor notification companies established under Law 3758/2009 as amended and in force, legally registered in the Register 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 a contract with QQuant for the provision of their services to it and have committed themselves to protect Personal Data by the requirements of the legislation on the protection of personal data.
Moreover, to the extent required for the servicing of Claims, QQuant may transmit Personal Data to other debtors, guarantors or other persons involved or connected with a specific serviced Claim and the relevant contracts as well as to any persons authorised to communicate with QQuant, in particular for notification, negotiation, settlement, repayment or judicial or extrajudicial pursuit of the serviced Claim in question. From the Registration Date onwards, for any question regarding the servicing of the Claims or 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), you may contact the Personal Data Protection Office of QQuant in the following ways:
- online on the website https://www.qquant.gr/personal-data-protection-policy-gre and specifically by filling out the form for exercising your rights above arising out of the Regulation [Model 1],
- by letter to the postal address 66, Kifisias Ave., 15125 Maroussi, Attica or
- by email to the email address: email@example.com
It is pointed out that the exercise of the above rights may not be accepted or may not produce the intended effect if the conditions of the Regulation are not met or if otherwise provided for in Law 4624/2019, 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, QQuant 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 complaints is the Personal Data Protection Authority (www.dpa.gr).
You can find more information on how QQuant collects and processes Personal Data, the categories of Personal Data, the sources, purposes and legal basis of processing, any third party recipients, the way to exercise the rights granted under the Regulation and Law 4624/2019, as well as the time of retention of Personal Data by QQuant in the Personal Data Protection Policy on the website https://www.qquant.gr/personal-data-protectionpolicy-gre.
To the extent that Pillar Finance DAC processes Personal Data, all relevant information (such as categories of personal data, sources, purposes and legal basis of processing, the rights to protect personal data, categories of recipients, retention period, etc.), are described in the detailed Privacy Statement which is posted on the website https://www.qquant.gr/personal-data-protection-policy-gre from the Registration Date onwards.
For Pillar Finance Designated Activity Company
For QQuant Master Servicer Servicing of Loans and Credits Single Member S.A.