Credit servicing undertaking for CREDITABLE OPPORTUNITIES FUND SCA SICAV-RAIF

We inform you that on 25.10.2022 the Special Purpose Vehicle FRONTIER ISSUER DESIGNATED ACTIVITY COMPANY (hereinafter “SPV”) proceeded with the sale and transfer of its claims to debt acquiring company CREDITABLE OPPORTUNITIES FUND SCA SICAV-RAIF. Said claims form part of the wider Frontier portfolio, which had been transferred to the SPV in the context of securitisation, in accordance with the provisions of Article 10(8) of Greek Law 3156/2003 and Articles 455 et seq. of the Civil Code, from the NATIONAL BANK OF GREECE SA. The credit servicing of the aforementioned claims will still be performed by doValue Greece in its capacity as servicer, acting henceforth by order and on behalf of CREDITABLE OPPORTUNITIES FUND SCA SICAV-RAIF.

Specifically, in accordance with the provisions of Article 3 of Greek Law 4354/2015, as in force, on 25 October 2022 (hereinafter “Transfer Date”, the SPV proceeded with the sale and transfer of its claims from all types of loans and/or debt to debt acquiring company CREDITABLE OPPORTUNITIES FUND SCA SICAV-RAIF, in relation to the Creditable Opportunities Fund SCA SICAV-RAIF – Sub-Fund 2, domiciled in the Grand Duchy of Luxembourg (1, Boulevard de la Foire, L-1528 Luxembourg) with registration no. B262266 in the Luxembourg Trade and Companies Register (hereinafter “New Beneficiary”). A summary of the relevant transfer agreement has been registered in the Public Register of Article 3 of Law 2844/2000 of the Athens Pledge Registry under agreement publication document registration act no. 813/25.10.2022 of Article 3(3) of Law 4354/2015 (Volume 15, No. 60). As a result of the above, as of the Transfer Date, the New Beneficiary became the beneficiary of all claims stemming from the relevant agreements (including any guarantees, collateral and any other spillover rights) and shall exercise all relevant rights henceforth. Moreover, upon acquiring the aforementioned rights, the New Beneficiary assigned their servicing anew to doValue Greece Loan and Credit Claim Management Company SA, in the context of the relevant agreement between them, in accordance with the provisions of Law 4354/2015, as in force (hereinafter the “Servicer”).

As a result of the transfer of the claims, in accordance with the provisions of Law 4354/2015, and the assignment of their servicing to the Servicer, the personal data of natural persons connected to these claims in any capacity (for example: borrowers, debtors, co-debtors, guarantors, third-party collateral offerers, special or universal successors of the above, and/or natural persons potentially related to the above, such as legal entity partners or their legal representatives, shareholders and true beneficiaries that are legal persons or entities, proxies, representatives, employees/associates, family members, lawyers or proxies of the above, notaries, bailiffs, as well as people against whom the New Beneficiary is entitled to collect the claims, e.g. third parties against whom seizure or the right of offset may be imposed) (hereinafter “Data Subjects”) were transferred from the Servicer to the New Beneficiary, by order and on behalf of the SPV, and shall be processed by the Servicer, as assigned by the New Beneficiary, in the context and for the purposes of their servicing.

As of the Transfer Date, and for as long as the beneficiary of the claims is the New Beneficiary, the Servicer shall process the personal data of the Data Subjects, acting as an independent data controller, specifying independently from the New Beneficiary the purposes for and means of personal data processing. All relevant information on the processing of personal data by the Servicer (such as personal data categories, sources, purpose and legal basis for processing, rights for the protection of personal data, recipient categories, period kept, etc.), is described in the document entitled “Personal Data Processing Notice pursuant to Regulation (EU) 2016/679 and the relevant Greek legislation” of the Servicer, which is available here.

To the extent that the New Beneficiary proceeds with personal data processing, all relevant information (such as personal data categories, sources, purpose and legal basis for processing, rights for the protection of personal data, recipient categories, period kept, etc.) is described in the document entitled “CREDITABLE OPPORTUNITIES FUND SCA SICAV-RAIF – Privacy Policy”, which is permanently here posted here.