Personal Data Protection Notice

(according to the General Data Protection Regulation (ΕU) 2016/679)

At Intrum Hellas REO, we highly value your privacy. When we process personal data, we believe it is essential that you clearly understand what categories of personal data we collect, the purposes for which we process it, the legal basis for such processing, and your rights as a data subject.

We, therefore, invite you to read the following Notification to obtain the necessary information.

Data Controller of your personal data:

The Company named “Intrum Hellas R.E.O. Solutions S.A.” (hereinafter, “Intrum REO” or the “Company”), headquartered at 109-111 Mesogeion Avenue, 11526, Athens, with Tax Identification Number (TIN) 801212579 is the Data Controller of your personal data.

Who does this Notice concerns

This Notice is addressed to natural persons, visitors of the Company’s website, tenants and prospective tenants, prospective buyers of properties managed by Intrum REO, as well as its partners. It is emphasized that if the interested party (tenant or buyer) is a legal entity, this Notice is addressed to the legal representative(s) of the legal entity and/or the beneficial owner(s), provided that their personal data is processed by the Company. Furthermore, this Notice concerns users of the digital platform provided by the Company through its website (realestate.intrum.gr), which allows any visitor who wishes to register and benefit from the available services.

What personal data we collect/process

The personal data we process include:

Identification details (e.g., full name, father’s name, date of birth, etc.),
Your contact details (e.g., addresses, phone numbers, username – email, etc.),
Financial and asset-related data (e.g., tax clearance certificates, other tax-related information, etc.),
Data related to the execution of the contract(s) with Intrum REO and the use of the provided services,
Any information related to the property under management that contains your personal data (e.g., utility bills, etc.),
Data automatically collected when using the Company’s electronic and/or digital services, such as cookie identifiers, IP addresses, domain names, device information (e.g., browser language, browser type), referral information, duration of visit, and number of page views,
Data you enter as visitors on our website through the various available forms, for example, the Contact Form through which requests are submitted to Intrum REO,
Data you provide as users of the website’s digital platform (e.g., full name, email, contact phone), as well as profile information such as your preferences and any comments or information you enter into the digital platform,
Additionally, we process data from existing information to present you with commercial content that may be relevant and of interest to you, provided you have given your prior consent via an explicit opt-in during your registration as a user on the digital platform.

Processing of special categories of personal data

At Intrum REO, we do not process personal data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership in a trade union, nor genetic or biometric data for the purpose of identification, nor health data or data concerning your sexual life or sexual orientation, except if:
a) such data have been disclosed to Intrum REO by you or a third natural or legal person in the context of documenting and safeguarding your legitimate interests,

b) the data have been clearly made public by you,

c) the processing is necessary for the establishment, exercise, or defense of both your legal claims and those of Intrum REO (e.g., incapacity to contract), or

d) the processing is necessary for reasons of substantial public interest (e.g., investigation of a criminal offense under the law for the prevention and suppression of money laundering and terrorist financing), which has been notified to us pursuant to a judicial act, prosecutorial order, or other judicial process by which we have been instructed to take specific actions.

Where we collect your personal data from

At Intrum REO, we collect your personal data from:

Real Estate Operating Companies (“REOCos”) that, through property auction procedures, acquire ownership of properties securing claims from loans/credits transferred via securitization to Special Purpose Vehicles (SPVs),
Intrum Hellas A.E.D.A.D.P., to which the Company provides property management services for properties managed by Intrum Hellas A.E.D.A.D.P., as well as advisory services for property evaluation and commercial promotion. For these purposes, Intrum Hellas A.E.D.A.D.P. transfers personal data of debtors to Intrum REO via a secure platform,
Piraeus Bank, either when it owns the managed properties or acts as an intermediary for the signing of purchase/lease agreements for properties,
External partners who provide specific services to Intrum REO, such as Legal Advisors, Lawyers, Property Appraisers, Technical Offices, and Brokers, etc.
Publicly accessible sources, such as the General Commercial Registry (GEMI), the National Cadastre, Land Registries, etc.,
Yourself and/or your legal representatives, when specific personal data are necessary for the purposes of processing to maintain our transactional relationship, or when you use the Company’s digital platform, or when you complete your details in the forms provided on our website, or simply browse it.

Purpose of processing

The processing of personal data may include the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or deletion of your personal data that have been transferred to Intrum REO or come to its knowledge within the framework of our transactional relationships, or through information received from third parties in the exercise of the Company’s legal rights, or directly from you when you provide your details on our website, including our digital platform.

The purpose of processing your personal data may include:

The performance of a contract to which you are a party (e.g., in the case of tenants) within the framework of your transactional relationship with Intrum REO, subject to your identification.
Intrum REO’s compliance with the applicable legislative and regulatory framework, which includes, but is not limited to:
- Preventing money laundering and other criminal offenses,
- Assessing and optimizing security processes and information systems,
- Managing Intrum REO’s operational and financial risks.
Conducting promotional activities of the Company, provided that we have obtained your explicit consent, for example by entering your email in the designated field on our website and ticking the relevant consent box — consent which you may withdraw at any time or request to stop receiving updates about specific services.
Granting access rights following your registration on the digital platform.
Protecting the legitimate interests of the Company, including but not limited to:
- Assigning the promotion of managed properties to our external partners,
- Ensuring the proper and efficient operation and management of the Company’s website,
- Investigating and resolving technical issues related to the provision of services (e.g., code errors),
- Protecting and securing information systems to prevent, deter, and suppress any illegal acts and to investigate possible violations of the website’s terms of use or this Notice,
- Conducting surveys that allow us to evaluate and improve our products and services.

At Intrum REO we have taken all necessary actions and implemented appropriate technical and organizational measures to ensure the lawful processing of personal data, as well as the secure storage of personal data records, in compliance with the applicable legal framework. Our aim is to safeguard their integrity and prevent any security breaches, such as loss, leakage, alteration, unauthorized access or transfer of data, or any other form of unlawful processing of personal data.

Lawfulness of processing

Intrum REO will process personal data only if the processing is necessary for:

your identification and verification of your details when communicating with representatives of the Company.
the execution of a contract you have entered into and the resulting service, support, and monitoring of your transactional relationships with the Company.
Intrum REO to comply with its legal obligations or to pursue legitimate interests arising from your transactional relationships with Intrum REO or from other rights of the Company under the law.
the performance of tasks that Intrum REO carries out in the public interest under the applicable legislative and regulatory framework.
your access to and browsing of the digital platform, as well as for servicing you in the context of providing requested communication and updates regarding the Company’s services.
promotional activities of the Company’s services, provided that you have given your explicit consent, such as receiving informational material and/or personalized content or if you wish to receive updates about properties available for lease/purchase.

Especially regarding the personal data transferred to Intrum REO by Piraeus Bank, Intrum Hellas A.E.D.A.D.P., or Real Estate Operating Companies, as explained above, the lawfulness of the transfer of your personal data is based on the servicing of the contractual relationship and the lawful management of the property portfolio by Intrum REO, as carried out to fulfill the purposes of the respective agreements entered into.

Automated Decision-Making and Profiling

At Intrum REO, we do not make decisions based solely on automated processing of personal data that produce legal effects or significantly affect the data subjects.

Retention of personal data

At Intrum REO, we retain your personal data for as long as required by the applicable regulatory framework, and in any case, for a period of twenty (20) years from the last calendar day of the year in which your transactional relationship with Intrum REO ended, in accordance with the general limitation period for claims under the Civil Code.

Personal data of buyers are retained for a period of 5 years from the date of the conclusion of the property purchase agreement managed by the Company, unless there is a prosecutorial order, or other judicial process related to a Supervisory Authority, specifying a different retention period.

Personal data of prospective buyers, in cases where their expression of interest in purchasing properties does not lead to the conclusion of definitive contracts, are retained for a period of 5 years from the submission of their offer, with the note that their data will be used only in case of a dispute with the Company. In this case, the 5-year retention period is extended until the final judicial decisions are made regarding the disputed matters.

Personal data of tenants are retained for a period of 5 years from the expiration of the lease agreement, unless otherwise provided by a prosecutorial order, or other Competent Authority act or decision.

In the case of judicial disputes, your personal data will be retained until the conclusion of the pending litigation, even if the above-mentioned period of twenty (20) years is exceeded. If judicial actions are ongoing, the retention period is extended beyond twenty years, until the issuance of a final court decision.

If you register on the Company’s digital platform to receive updates on properties available for lease/purchase, your personal data will be retained for as long as you remain an active user. These data will be deleted upon your request to withdraw your consent for the processing of personal data you provided when activating your account on the Company’s digital platform.

Recipients of your personal data

Access to your personal data is granted to the staff of Intrum REO within the scope of their responsibilities and, potentially, other companies within Intrum Group, as part of the support they provide to Intrum REO for the proper execution of its contractual, legal, and regulatory obligations. Additionally, the Company’s appointed auditors may have access to your data, provided they have entered into contractual commitments regarding the protection of personal data.

As part of our processing of your personal data, we may transfer data to the following recipients:

Lawyers, law firms, bailiffs, notaries, engineers, appraisers, auditors, and accountants, insurance companies, we cooperate with, to whom we transfer personal data when required to initiate or continue a business relationship.
External partners such as real estate agents and property promotion companies, for the purpose of promoting the properties under management for sale/rent.
Where required by the applicable regulatory and legislative framework or judicial decision (e.g., transfer to judicial authorities, tax authorities, supervisory bodies, mediation bodies).
Third-party partners who provide IT services and/or support for electronic systems and networks, investigation of incidents related to security, protection against fraudulent or illegal activities, software hosting, cloud computing, customer service, request processing, advertising or marketing services, analytical services, and conducting internal research for development purposes.

In cases of collaboration with third parties acting as Data Processors, we ensure that they meet the necessary requirements and provide sufficient assurances regarding the implementation of appropriate technical and organizational measures to safeguard your personal data, while they have entered into an agreement with the Company, outlining their obligations when processing your personal data.

Finally, if it becomes necessary to transfer your personal data outside of the European Union/European Economic Area as part of our collaboration with third parties, such transfer will be conducted under a contract that includes standard contractual clauses for the protection of personal data, in accordance with the applicable regulatory framework.

Your GDPR rights

As a data subject, you have the following rights:

Right of Access: You have the right to access your personal data if processed by Intrum REO as the Data Controller, including information on the source of the data, the purposes of the processing, the categories of data, any recipients, and the retention period (Article 15 GDPR).
Right to Rectification: You have the right to request the correction of inaccurate data or the completion of incomplete data without undue delay (Article 16 GDPR).
Right to Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal data, subject to the legal obligations and rights of Intrum REO to retain them under applicable legislative and regulatory provisions, if the data are no longer necessary for the purposes for which they were collected or processed, or as a result of the withdrawal of your consent on which the processing is based, provided there is no other legal basis for processing the corresponding data (Article 17 GDPR).
Right to Restriction of Processing: You have the right to request the restriction of the processing of your personal data if, for instance, the accuracy of the data is disputed, the processing is unlawful, or the purpose of processing has been fulfilled, provided there is no legal reason for retaining the data (Article 18 GDPR).
Right to Data Portability: You have the right to request the transfer of your personal data to another Data Controller, provided that the processing is based on your consent or a contract and is carried out by automated means. This right is subject to the legal rights of Intrum REO to retain the data and fulfill its obligations in the public interest (Article 20 GDPR).
Right to Object: You have the right to object, on grounds relating to your particular situation, to the processing of your personal data if they are being processed for the performance of a task carried out in the public interest or for the purposes of the legitimate interests pursued by Intrum REO or a third party (Article 21 GDPR).
Right to Withdraw your Consent: You have the right to withdraw your consent at any time, in cases where we have requested your consent for specific purposes, such as receiving information via electronic services, registration on our digital platform, sending marketing materials, or providing personalized content, among others. It is emphasized, however, that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights and File a Complaint

To exercise the above rights, where the Company acts as the Data Controller, you may send your request to the Personal Data Protection Office of the Company at 109-111 Mesogeion Avenue, Athens, 11526, or email at DPOIntrumREO@gr.intrum.com.

Upon receiving your request, we will make every effort to respond within thirty (30) calendar days. In case the complexity of the request requires additional time for evaluation and response, we could extend the response time by an additional sixty (60) calendar days. In such cases, Intrum REO will notify you in writing within thirty (30) days of receiving your request, along with the reasons for the extension.

Should we refuse or unreasonably delay fulfilling your request regarding the exercise of your rights, you have the right to file a complaint with the Hellenic Data Protection Authority (HDPA), the competent supervisory authority for the implementation of the GDPR. In any case, you retain the right to lodge a complaint with the relevant supervisory authority if you believe that your personal data is being processed in violation of the applicable law. For more information, you can visit the HDPA’s website at www.dpa.gr.

We note that we monitor the legislative and regulatory framework as it applies to the processing of personal data, as well as the Policy and Guidelines of Intrum Group, retaining the right to revise this Data Protection Notice as appropriate.

Intrum REO Solutions

Last Update: September 2025

Personal Data Protection Notice

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