This Privacy Notice (the Notice) explains how we use personal data for individuals whose loans, mortgages, or other financial products belong to Asopus Limited Partnership, as well as the personal data of their respective guarantors and other third parties such as lawyers bailiffs, notaries, and employees connected to these loans. It outlines how Asopus Limited Partnership (Asopus, we, us) collects and processes your personal data, how we use and protect this data, and your rights in relation to it.
Asopus is the data controller for all your personal data that falls under the scope of this Statement. This Statement specifies which of your personal data we process, for what purpose, and to which legal or natural persons this data may or will be transferred. We may share your personal data with third parties. We always process your personal data by the relevant provisions of the regulatory framework, particularly the General Data Protection Regulation (EU) 2016/679.
Asopus has appointed QQuant Master Servicer Single Member SA (Quant) to manage your loan accounts and debts. Both Asopus and Quant act independently as controllers of your personal data. For more information on how Quant may use your personal data, please refer to the Quant Privacy Policy at https://www.qquant.gr/personal-data-protection-policy-gre/.
If you have any questions, please don’t hesitate to contact us using one of the methods outlined in the “Contact Us” section below.
1. WHAT PERSONAL DATA DO WE COLLECT?
We may collect the following categories of your personal data:
- Identification Data: such as full name (including titles before your name), gender, age, date of birth, and proof of identity (e.g., passport or driving licence).
- Contact Information: email address, residential address, or telephone number.
- Personal and Financial Data: including employment status and related details, bank statements, Social Security Number (AMKA), tax data, card repayment details, savings, debts such as loans and credit card debts, income and expenses, employer and pension benefits, property, and other assets, as well as family, lifestyle, and other circumstances related to the loans.
- Communications with Us or Our Representatives: including notes of our claims managers' communication with you regarding managing the loan, mortgage, or other financial product.
- Sensitive Personal Data: such as disclosures by you relating to health issues or criminal convictions.
- Data from Third Parties, including credit rating assessments.
2. HOW DO WE USE YOUR PERSONAL DATA?
We may use your personal data for the following purposes:
- To identify and verify your data as part of our efforts to prevent money laundering, terrorist financing, tax evasion, and/or fraud.
- To assess and respond to your queries and requests (if applicable).
- To evaluate any request for modification of our security or alternative repayment plan when you face financial hardship.
- To assess your financial ability and suitability for credit throughout our relationship, including analysing your credit data for regulatory reporting.
- To manage your account and our professional relationship with you.
- To manage your account, including processing payments, management fees, and debt repayment.
- To fulfil contractual obligations to third parties related to managing your account.
- To prevent severe and imminent harm to a person or property.
- To respond to inquiries from supervisory authorities, law enforcement agencies, or other government bodies.
- To carry out mandatory communications as required by law or regulations.
- To investigate and resolve complaints.
- To comply with relevant laws, regulations, and other requirements.
3. FROM WHICH SOURCES DO WE OBTAIN YOUR DATA?
In cases where the loan, mortgage, or other financial product has been transferred to us by another lender, we have obtained your personal data and account data from that lender. If you have a loan, mortgage, or other financial product jointly with another person, we may have obtained your personal data from your co-borrower. If you have not authorised your co-borrower to provide your personal data to us, please inform us as soon as possible.
We also occasionally obtain your personal data from the following third parties with whom we collaborate:
- Asset managers, customer service providers, external partners, and liquidators.
- Our legal representatives.
- Credit information organisations.
- Fraud prevention organisations.
- Law enforcement or government agencies.
Additionally, we may collect your personal data from public databases.
4. ON WHAT LEGAL BASIS DO WE USE YOUR PERSONAL DATA?
We use and process your personal data on the following legal bases:
- Because it is necessary for managing, executing, and fulfilling our contract with you.
- To serve the legitimate business interests of Asopus and others, including our affiliates, such as:
- Managing our relationship with you.
- Conducting review, analysis, and reporting activities for strategic business decision-making and internal governance.
- Monitoring and managing our internal business processes.
- Ensuring business continuity, disaster recovery, and handling emergencies.
- Conducting system tests.
- Analysing complaints to avoid errors and process failures.
- To comply with certain legal and regulatory obligations of Asopus.
- With your consent, where you have consented to the processing of your personal data.
Please note that failing to provide the personal data we request to manage your account may result in our inability to fulfil our contractual obligations, which could jeopardise the loan, mortgage, or other financial product.
5. WITH WHOM MAY WE SHARE YOUR PERSONAL DATA?
5.1 Access to Your Personal Data within Asopus and its Affiliated Businesses
Employees and representatives of Asopus are authorised to access your personal data only to the extent necessary to serve the applicable purpose and perform their duties.
We may also share your personal data with, and where required, transfer it to, our group companies, affiliated entities, and their representatives.
5.2 Access to Your Personal Data by Third Parties
The following third parties may access your personal data when necessary:
- Financial institutions, including lenders and insurance companies.
- Service providers acting on our behalf include claims managers, asset managers, valuers, estate agents, printing services providers, document storage services, IT service providers, analysis service providers, and fraud prevention organisations.
- Professional advisors: including our lawyers, accountants, auditors, liquidators, and business consultants.
- Regulatory authorities and law enforcement agencies.
- Co-borrowers and guarantors on your account and third parties you have authorised to communicate with us.
- Prospective and existing buyers, assignees, and other parties interested in your loan, mortgage, or financial product in the event Asopus, its assets, or its rights to the assets are sold, transferred, or assigned, possibly in the context of a securitisation, financing, or co-investment agreement.
- Any other parties that Asopus reasonably considers customary, necessary, or appropriate for the purposes described in this Statement and in any other way that does not personally identify you (e.g., as part of aggregated or anonymised data).
Where third parties have access to your personal data, we will take the necessary contractual, technical, and organisational measures to ensure that your personal data is processed only to the extent necessary.
6. TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EU
We may send your personal data to recipients in other countries whose data protection laws may not be as strong as those of your home country. Where we do this, we will always implement appropriate safeguards, such as the EU Standard Contractual Clauses, as required by law, to ensure that your personal data is protected and that you can effectively exercise your rights. You can find more information about the EU Standard Contractual Clauses at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
7. HOW ARE YOUR PERSONAL DATA PROTECTED?
We have taken appropriate measures to ensure the confidentiality and security of your personal data. We have implemented suitable technical, physical, and organisational measures to protect personal data from accidental or unlawful destruction, loss, damage, alteration, unauthorised disclosure or access, and all other forms of illegal processing. This includes but is not limited to, unnecessary collection or further processing. Examples include IT security policies, maintaining confidentiality, staff training, and secure data servers.
8. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will keep your personal data for as long as we need it for the purpose we process it. For instance, where you provide information related to a loan, we will keep this information for as long as is necessary to manage your loan and, after that, for a period that allows us to handle or respond to any complaints, inquiries, or concerns and to comply with regulatory obligations. We will also retain your personal data about legal actions or investigations concerning Asopus when required.
We actively review the data we hold and delete it securely or, in some cases, anonymise it when there is no longer a legal or business need to retain it.
9. YOUR RIGHTS
You may be entitled to:
- Ask us questions regarding processing your personal data and request a copy of that data.
- Request correction and/or deletion of your personal data.
- Request the restriction of processing your personal data.
- Object to processing your personal data, especially when they are used for promotional purposes or processed on the grounds of legitimate interests and you believe your interests, rights, and freedoms outweigh ours.
- Where applicable, withdraw your consent for processing your personal data in cases where Asopus processes your data based on your consent. This withdrawal does not affect the lawfulness of processing carried out based on consent
10. CONTACT US
Should you have any questions or requests concerning this Statement or your personal data that we have/keep, or if you require additional information, please contact:
Asopus Limited Partnership, c/o Qquant Master Servicer Kifissias 66, 15125 Maroussi, Athens, Greece, phone +30 211 624 1900, or via email dpo@qquant.gr.