Themis Portfolio Management Limited (“Themis”, the “Company”, “we”) is a Servicing, Real Estate management and asset management company that operates in Cyprus. It is a subsidiary of Themis Portfolio Management Holdings Ltd, a credit acquiring company that operates in Cyprus subject to the licence and supervision of the Central Bank of Cyprus pursuant to the Sale of Credit Facilities and Related Matters Laws of 2015, as amended subject to the licence and supervision of the Central Bank of Cyprus pursuant to the Sale of Credit Facilities and Related Matters Laws of 2015, as amended.
The provision of Themis’ Services largely depends on the processing of large amount of information, including personal data.
Themis is the data controller of your personal data, which means that we are responsible for determining the purpose and the means of processing of your personal data.
Our contact and DPO details are as follows:
In relation to your personal data, we will seek to ensure that the data are:
We hold and process various categories of personal data about you which we have collected from your former creditor or directly from you, including, but not limited to the following:
Identity and contact details, such as: full name, address, email address, phone number, date of birth, ID, nationality, gender, marital status, employment history, details about dependants;
Financial/banking information, such as: income and expenses, property ownership, bank account details, debts, investments, house financing data, property evaluation data, securities, insurance data,
Special categories of data, such as: health related data or other sensitive information included in supporting documents provided to your previous creditor or to Themis.
Criminal conviction data, financial sanctions or other related information we collect directly from you or your former creditor.
CCTV footage may also be recorded, when you visit our offices.
We collect personal data about you in a variety of ways. As mentioned above, most of your personal data were collected by Themis from your former creditor (i.e. your Bank or other Credit Institutions). We may also require the collection of additional data directly from you for the purpose of providing our Services.
Furthermore, we may collect data about you from third parties, such as the Artemis Data Registries, other credit reference agencies as well as public authorities such as the Land Registry, the Registrar of Companies, the Central Bank, or any third party with which you have entered into an agreement to represent you in any proceedings or other aspects which affect your relationship with Themis in any manner.
Themis may process your personal data as described below on the basis of at least one of the legal grounds under GDPR Article 6 (1) and the conditions provided under GDPR Articles 9(2) and 10.
Themis relies on the following legal bases when processing your personal data:
As described above, most of your personal data have been collected by Themis as a result of the portfolio transfer from your original creditor to Themis, either at the time of the transfer or subsequently, based on Themis’s own data collection and privacy management procedures.
Pursuant to our contractual, statutory and regulatory obligations we may share your personal data with various organisations/companies, such as debt collection agencies, credit reference agencies, fraud detection/prevention agencies, our legal advisors, credit reference or other agencies as required, in order to facilitate the restructuring or management of your loans by Themis. In addition, public authorities (e.g. the tax authorities) or other supervisory or regulatory authorities (e.g. The Unit for Combating Money Laundering (MOKAS) or the Central Bank of Cyprus) may become recipients of your personal data as required under applicable law.
There may be instances where we may need to allow access to or disclosure of your data to our service providers, such as our legal advisors, property valuers, IT consultants, etc..
At Themis we take all reasonable and necessary steps (either by a direct agreement in accordance with GDPR Art. 28 or by other legally binding arrangements) to ensure that our service providers (data processors) that process personal data on behalf of Themis comply with Data Protection Law and our instructions regarding the processing of your personal data.
GDPR imposes obligations to Data Controllers and Data Processors which in several cases are dependent upon consistent implementation of relevant measures and controls across their own operations as well as those of their Data Processors. Our policy is to process personal data with due regard to the security, privacy and protection of the data we receive, store and process.
Our Policy is not to transfer personal data to organisations located outside of the European Economic Area. In cases where the transfer is made to third countries which are not subject to an adequacy decision by the European Commission, such transfer will only be carried out in accordance with the required safeguards under Chapter V of the GDPR and the respective provisions of the Cyprus Data Protection Law, including but not limited to the EU approved standard contractual clauses or other safeguards under GDPR Article 49.
You have the following rights under GDPR with regards to the processing of your personal data:
You also have the following rights in certain circumstances:
Please note that some of the rights mentioned above are not absolute. They are subject to exceptions under GDPR and applicable depending on the legal basis we rely on in each case.
You may request to exercise your rights by sending an email to email@example.com.
We endeavour to respond to requests within 30 days, although we reserve the right to extend this period to two additional months when the requests require a disproportionate effort. Before assessing any request, Themis will request a valid ID from the data subject.
|1.||Personal Data||Also referred to as “personally identifiable information (or “PII”), personal data is any information relating to an identified or identifiable living natural person (the “data subject”)|
|2.||Legal Basis of Processing||The basis on which the processing of personal data may be based and may be one of the following:|
Our lawful interests in conducting and managing our business to enable us to give you the best services and / or products and secure and private by design experience. In choosing to perform personal data processing under the legal basis of legitimate interest, we seek to ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before doing so.
As a general principle, we do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
|4.||Data Controller||The natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.|
|5.||Data Processor||A natural or legal person, public authority, agency or any other body which processes personal data on behalf of a Data Controller.|
|6.||Data Protection Officer||A Data Protection Officer (or “DPO”) is a security leadership role required by the GDPR. The DPO is responsible for (a) overseeing data protection strategy and implementation within an organization; (b) ensuring compliance with GDPR requirements; (c) the provision of advice to the Data Controller or the Data Processor and their staff in relation to personal data processing; and (d) to cooperate with Data Protection Authorities and supervisory bodies in all privacy and data protection matters.|
|7.||Cross-border Transfers||Transfers of personal data outside the European Economic Area in physical and / or electronic form|