Information for debtors and owners

Who processes your data

ORENES & ASOCIADOS ABOGADOS-CONSULTORÍA LEGAL, S.L.P., tax ID B05560313, Avenida de la Libertad 5, 1.º A, 30009 Murcia (Spain), email [email protected], owner of the InversionNPL platform. We have not appointed a Data Protection Officer; you may write to the email above with any question about your data.

What data and where it comes from

We process data relating to the loan and the property that secures it: cadastral reference, address, property characteristics, outstanding debt amount, stage of the court proceedings, encumbrances and, where applicable, the associated contractual, registry and court documentation. Files under management may also contain identification data of the parties and occupants.

The data comes from the financial institutions, funds and servicers that own the loans or the properties and instruct us to market them, and from publicly accessible sources: the BOE Auction Portal, the Cadastre Electronic Office, the Land Registry and court decisions.

What for and on what legal basis

• Management, valuation and marketing of loans and assets on behalf of their owners — our own legitimate interest and that of the assignors (Art. 6.1.f GDPR), consisting of realising the loan and of the legally recognised transfer of rights (Arts. 1526 et seq. of the Civil Code), balanced against your rights: the identity of persons is not published, the public pages show only partial data (cadastral parcel and street without number) and the detail is reserved for registered users bound by confidentiality.
• Formalising assignments and procedures before notaries, registries and courts — performance of the assignment contract and legal obligations.
• Analysis of documentation using artificial intelligence tools from providers acting as processors — legitimate interest, with no automated decisions having legal effects.
• Contact to propose solutions to the default (recovery channel) — legitimate interest of the creditor, with full respect for your right not to be contacted outside legal channels.

Who can see your data

Registered users of the Platform (investors) who have accepted a confidentiality agreement prohibiting them from disclosing the information, publishing it on portals or social media and contacting you outside the Platform. In addition, assignees who acquire the loan, notaries, registries, courts and authorities where the law requires, and the technology providers that serve us as processors (some in the United States, with the safeguards of the EU-US Data Privacy Framework or standard contractual clauses).

How long

While the loan or the property is published or under management and, afterwards, blocked for the limitation periods of legal liabilities (generally five years, and ten years for anti-money-laundering documentation where applicable).

Your rights

You may exercise your rights of access, rectification, erasure, objection and restriction of processing, and ask us to correct any inaccurate data about the loan or the property, by writing to [email protected]. We will reply within one month. If you object to the processing, we will weigh your particular situation against the creditor's legitimate interest and inform you with reasons.

If you consider that your rights have not been honoured, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

If you wish to propose a solution to the default (payment, deed in lieu, agreed sale or any other route), you can do so on the "Recovery" page of the Platform or at the email above; the recovery team will study your case without this constituting any promise of outcome.