The following privacy policy provides an overview how your data is recorded and processed.

 

With the following information, we would like to give you an overview of how we process your personal data as well as your rights under the Data Protection Act. What specific data is processed in detail and how it will be used depends on the requested or agreed services.

 

1. Who is responsible for data processing and who can I contact?

 

Contact details as follows: 

GRENKE RENTING S.R.L.

Str. Dinu Vintila nr. 11, Cladirea EURO TOWER

Etajul 15, sectorul 2, 021101 Bucuresti, telefon: +40 21 300 1987 

 

You can reach our operational data protection officer at: 

GRENKE RENTING S.R.L.

Data Protection Officer

Str. Dinu Vintila nr. 11, Cladirea EURO TOWER

Etajul 15, sectorul 2, 021101 Bucuresti

E-mail: [email protected]

 

2. What sources and data do we use? 

 

We process personal data that we receive from our customers and partners as part of our business relationship. In addition, we process – as far as necessary for the provision of our services – personal data that we might collect from publicly accessible sources (e.g. debtor directories, land registers, trade and association registers, press, internet) or that was obtained from our distribution partners or from other third parties (e.g. a credit agency). Finally, we process personal data of our shareholders, shareholder representatives, guests of the Annual General Meeting and auditors on the basis of our legal obligations.

 

Relevant personal data includes:

• Personal details (name, address, birthday, place of birth and nationality)
• Contact details (telephone, e-mail address)
• Verification data (e.g. ID data)
• Authentication data (e.g. signature sample)
• Order data (e.g. payment order)
• Data from the fulfilment of our contractual obligations (e.g. sales data in payment transactions)
• Information about your financial situation (e.g. creditworthiness data, scoring/rating data, source of assets)
• Advertising and sales data (including advertising scores), documentation data (e.g. consultation minutes)
• Data in connection with the shareholder position, such as the number of shares, type of shares, type of share ownership or information on the bank account.
• Data in connection with the Annual General Meeting of GRENKE RENTING SRL such as powers of attorney, instructions, etc.

 
and other data comparable to the aforementioned categories.

 

3. What do we process your data for (purpose of processing) and on what legal basis? 

 

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the Law no. 190/2018 regarding the rules for application of the European general Data Protection Regulation (GDPR). 

 

a. For the fulfilment of contractual obligations (Article 6 (1) (b) of the GDPR)

 

Data is processed in order to provide financial services as part of the execution of our contracts with our customers or to carry out pre-contractual actions, which are carried out upon request. The purposes of data processing are primarily geared towards the specific product (e.g. renting, hire-purchase) and may include, but are not limited to, needs analysis, consulting and to perform transactions. Further details on the purposes of data processing can be found in the relevant contract documents and terms and conditions. 

 

b. As part of the balance of interests (Article 6 (1) (f) of the GDPR)

 

As far as necessary, we process your data beyond the actual fulfilment of the contract for the protection of our legitimate interests or those of third parties, in particular: 

 

• Consultation and exchange of data with credit agencies to identify credit risk or default risk

For the purposes of checking any credit or default risks, and to defend ourselves against any criminal acts, we provide credit agency Keysfin SRL, 19 Dr. Staicovici, 1^st floor, Apartment no. 2, Room no. 3, 5^th district, Bucharest, Romania with data concerning the request and the applicant.

The legal basis for sending this data is Article 6 (1 b) and Article 6 (1 f) of the GDPR. Other legal bases for sending the information to Keysfin SRL is Article 6 (1 a) GDPR. Article 6 (1 f) GDPR may only be used as the basis for sending the data if this is necessary for protecting the legitimate interests of us or third parties, and do not prevail over the interests or basic rights and fundamental freedoms of the person affected who needs their personal data to be protected.

The credit agencies will process the data received and also use this to create a profile (scoring), in order to provide their contractual partners in the European Economic Area and in Switzerland and, where necessary, other third party countries (provided there is an adequacy decision from the European Commission for this) with information so they can assess the creditworthiness of their clients.

For detailed information as described in Article 14 GDPR regarding activities undertaken by the credit agencies, please refer to the information provided about the credit agency Keysfin SRL following the link: http://www.keysfin.com/.

• Review and optimisation of requirements analysis procedures for direct customer contact
• Optimisation and needs-based design of the website
• Advertising or market and opinion research, provided that you have not objected to the use of your data
• Asserting legal claims and defence in legal disputes
• Ensuring the IT security and IT operation of our company
• Prevention and investigation of criminal offences
• Video surveillance for the protection of domiciliary rights, and for the collection of evidence in cases of robbery and fraud
• Measures for building and plant safety (e.g. access control)
• Measures to safeguard domiciliary rights
• Measures for business management and further development of services and products
• Quality assurance to optimize internal business processes

 

c. On the basis of your consent (Article 6 (1) (a)  GDPR)

 

Insofar as you have given us your consent to process your personal data for specific purposes (e.g., disclosure of data within the Group, or analysis of payment transaction data for marketing purposes), the legality of this processing is assured on the basis of your consent. Consent that has been issued can be revoked at any time. This also applies to the revocation of declarations of consent that were issued to us before the GDPR came into effect, i.e. before 25 May 2018. The revocation of consent does not affect the legality of the data processed until the revocation.
 
d. Based on legal requirements (Article 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (-f) GDPR)  or in the public interest (Article 6 (1) (e)  GDPR)

 

In addition, we are subject to various legal obligations, i.e. legal requirements (e.g., the Money Laundering Law no. 290/2019, and tax laws). The purposes of the processing include, but are not limited to, the creditworthiness check, identity and age checks, prevention of fraud and money laundering, the fulfilment of tax auditing and reporting obligations, and the assessment and management of risks.

 

4. Who receives my data?

 

Within our organization, the entities that gain access to your data are those who need it in order to fulfil our contractual and legal obligations. Our service providers and vicarious agents may also receive data for these purposes. These are companies in the categories of financial services, IT services, logistics, printing services, telecommunications, debt collection, advising and consulting, as well as sales and marketing.

 

With respect to the disclosure of data to recipients outside our company, we may only disclose information about you if we are required to do so by law or if you have given us your consent to do so. Under these conditions, recipients of personal data may be, for example:

• Public authorities and institutions (e.g. tax and law enforcement authorities) in the presence of a legal or regulatory obligation.
• Other financial services institutions or
• comparable institutions to which we transfer personal data over the course of our business relationship with you (depending on the contract, e.g., correspondent banks, credit agencies).
• Other companies within the group and legal advisors
• for risk management due to legal or regulatory obligations and recovery procedures.

Other data recipients may be those to whom you have given us your consent for your data to be submitted.

 

5. Is data transmitted to a third-party country or to an international organization?

 

A transfer of data to bodies in countries outside the European Union (so-called third-party countries) takes place, as far as

 

• this is required in order to execute your orders (e.g. payment orders),
• this is required by law (e.g. in order to comply with tax reporting obligations), or
• you have given us your consent.

 

6. How is my data processed on the website?

 

Unless otherwise stated, we process your data on our website either to act by your request (Article 6 (1) (b) GDPR) or based on our legitimate interests (Article 6 (1) (f) GDPR) as follows:

 

a. Usage data

 

Every time you access a page and retrieve a file, this process automatically saves general data to a log file. The storage is exclusively system-related and is purely for statistical purposes or to report criminal offences in exceptional circumstances.

 

We use this data to improve our websites and to present content tailored to your interests on various sites on the internet and on multiple devices. As part of this process, usage data is not merged with personalized data. Should you decide to provide us with your data, this data will be backed up securely during the entry process. The same applies to the storage in our system. For security reasons, we store your IP address. This can be accessed in case of a legitimate interest.

 

We do not save your browser history. A transfer of data to third parties or any other evaluation does not take place, unless there is a legal obligation to do so.

 

In detail, the following data record is saved for each access:

 

• Device used
• Name of the accessed file
• Date and time of access
• Time zone
• Transferred data volume
• Report as to whether the access was successful
• Description of the type of web browser used
• Operating system used
• The previously visited site
• Provider
• User's IP address

 

b. Contact forms and other enquiries

 

In order to be able to give you the best possible advice as part of a request via our contact forms, the appropriate group company that is best suited to respond to your request will be identified after inquiring about your specific interest at the top of the page. If you contact us (e.g. via contact forms), the designated company will save your data in order to process your request (Article 6 (1) (b) GDPR) or in case any further correspondence is required. If several companies are listed there, they will process your personal data as joint controllers within the meaning of Art. 26 GDPR.  Further information on joint controllership can be obtained by sending an e-mail to [email protected]

If you provide specific information about your needs or your person in the context of other enquiries (e.g. during our renting test), we will save your data for the purpose of processing your request (Article 6 (1) (b) GDPR) and in the event that further correspondence should take place.

If you expressly agree to be contacted by e-mail, telephone or post (according to Art. 6 Para. 1 a GDPR) within the scope of the contact form, you grant GRENKE RENTING the opportunity to inform you in future by telephone, e-mail or post about current products and services, in the selected category. We may also store your data for the purpose of sending you our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove your newsletter subscription in case of doubt. You can object to the use of your data for advertising purposes at any time or unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the newsletter.

 If you do not give your consent, your data will be deleted after your request has been processed. Excluded from this is data for which legal or otherwise prescribed storage obligations exist.

 

Within the framework of our contact forms we work with the Eloqua, a service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. For further information on the processing of data by Eloqua, please refer to the additional notes under g.

 

c. Registration

 

The data provided during registration will only be used by us to enable you to use our services (Article 6 (1) (b) GDPR).

 

We collect the following data for the registration process:

• E-mail address
• User name

• Password

 

d. Newsletter

 

We are happy to inform you on the basis of your consent (Article 6 (1) (a) GDPR) about the latest news with our newsletter.

 

In order to receive the newsletter, you must enter your name and e-mail address. You can also enter and submit further optional information. After you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have specified, in which you must click a confirmation link to verify the e-mail address you provided.

 

Your data will be stored by us only for the purposes of sending our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove the newsletter subscription in case of doubt. In addition, in order to measure the success of our newsletter, we collect data on whether the newsletter is opened, when it is opened and which links are clicked.

 

For the delivery of our newsletter we work with the Eloqua service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. Newsletters sent with the help of Eloqua use tracking technologies. We use this data primarily to find out which topics are of interest to you by tracking whether our emails are opened and which links you click on. We then use this information to improve the e-mails we send you and the services we provide, and to link them to existing tracking or profiling information.  We will not be able to track your emails if you have disabled the display of images in your email program by default. In this case, however, the newsletter will not be displayed in full and you may not be able to use all the features. If you display the images manually, the above-mentioned tracking will take place. For further information on using Eloqua, please refer to the additional notes under g.

 

You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the newsletter.  

 

e. Use of cookies

 

aa) General information

 

In order to make your visit to our websites more pleasant and to enable the use of certain functions, we use so-called cookies on various sites. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliates to recognize your browser on your next visit (so-called permanent cookies).

 

Cookies cannot access other files on your computer or identify your email address.

 

bb) Use of cookies

 

Like most websites you visit, our website also uses cookies to improve the user experience on both one-time and repeated website visits. This allows you to quickly and easily switch between sites, save your configurations, and use third-party tools (such as YouTube videos) on the website.

 

Cookies are either placed on our website (first party cookies) or on other websites whose content appears on our website (third-party cookies). These third-party providers (such as Facebook) may set cookies if you are logged in to their pages and visit our website. We have no influence on the cookie settings of these websites. Please visit the third-party websites for more information on their use of cookies.

 

cc) Legitimacy of the storage of cookies

 

The essential, functional and statistical cookies are stored on the basis of our legitimate interests (Article 6 (1) (f) GDPR) for the optimization and needs-based design of our website.

 

Cookies are stored for marketing purposes on the basis of the user's consent (Article 6 (1) (a) GDPR). These cookies are therefore only set if the user agrees to the storage by issuing their consent to the cookie notification on the website.

 

dd) Deactivating and deleting cookies

 

The setting you choose on the first visit in response to the cookie notification will be saved. The selected settings can be adjusted here in the privacy settings at any time.

Most browsers are otherwise set to automatically accept cookies. If the default settings for cookies are stored in your browser, all processes run in the background without any notifications. However, you can change these settings at any time.

 

You can set your browser so that you are informed about the setting of cookies and can decide on a case-by-case basis whether they are to be accepted or deactivated for specific cases or in general.

 

A general objection to the use of cookies for marketing or advertising purposes can be issued for a variety of services via the website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the prevention of cookies can be achieved by switching them off in your browser settings. Please note that this may mean you won’t be able to use all the features of this website.

 

ee) Overview of the cookies we use

 

Essential cookies

 

Essential cookies are required basic functions such as site navigation and access to secure areas of the website. The website may not work properly without these cookies.

Statistical cookies

 

Statistical cookies collect information about how a website is used e.g. the frequency of site visits and whether the user receives error messages from a page. These cookies do not store information that would allow the user to be identified. The information collected is aggregated and therefore evaluated anonymously. These cookies are used exclusively to improve the performance  of a website and thus the user experience.

 

f. Range analysis using Piwik

 

If you consent (Art. 6 (1) (a) GDPR), we use Piwik, a software for statistical evaluation of user access.

 

Your IP address will be hashed before it is saved. However, Piwik uses cookies that are stored on users' computers and enable the user’s use of the website to be analyzed. In this case, pseudonymous usage profiles of the users can be created from the processed data. The information generated by the cookie regarding your use of this online content is stored on our server and not passed on to third parties. 

 

You can revoke your consent to this data processing as follows:

g. Use of Eloqua

 

If you have consented to the use of cookies for marketing purposes, Eloqua will use corresponding cookies that are stored on your computer and that enable an analysis of the use of the website (hereinafter referred to as usage behavior) If you have already used a website that uses Eloqua, you may already have an Eloqua cookie. Even if this cookie is set on other websites, the information from your visit to our websites is only visible to us and is not shared with Oracle or any other users of the Eloqua system. It is also not possible for us to use this cookie to record or view information about your visits to any other websites.

 

If you enter personal data (e.g. in the contact form) during your visit to the website, these data will be processed with the usage behavior in order to offer you content on the website and in our newsletter that is geared to your interests, as well as to be able to send you news and information about our company or our range of services based on your data, which are geared to your individual interests. For this purpose, it is technically necessary that we combine your accrued and given data in user profiles and evaluate them for the aforementioned purposes. This is done internally and only for the aforementioned purposes.

 

The legal basis for the pseudonymous evaluation of the use of our website is your consent (Art. 6 (1) (a) GDPR), which you may have given us in the course of using our website.

 

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behavior on your device in the future, this is possible via the following link: Eloqua Opt-Out https://www.oracle.com/marketingcloud/opt-status.html.

 

You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy https://www.oracle.com/legal/privacy/privacy-policy.html

 

 h) Use of the Facebook pixel

 

aa) Processed data

On our website we use the so-called “Facebook pixel” from “Facebook” (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland). With the Facebook pixel we can classify the visitors of our website into certain target groups in order to be able to show you advertisements ("Ads") on Facebook. The recorded data (e.g. IP addresses, information about the web browser, the location of the website, buttons clicked, possibly pixel IDs and other features) cannot be viewed by us, but can only be used in the context of displaying certain advertisements. When the Facebook pixel code is used, cookies are also set.

 

If you have a Facebook account and are logged in, your visit to this website will be assigned to your Facebook user account.

 

In order to exchange the respective data, your browser automatically establishes a direct connection with the Facebook server. We have no influence on the scope and further use of the data that is collected by Facebook through the use of this tool and therefore inform you according to our level of knowledge: By integrating the Facebook Pixel, Facebook receives the information that you are visiting the corresponding site of our website and that you have accessed or clicked on one of our advertisements. If you are registered with a Facebook service, Facebook can assign the visit to your account. Even if you are not registered with Facebook or have not logged in, there is the possibility that the provider will find out and save your IP address and other identification features.

 

• You can find out how the Facebook pixel is used for advertising campaigns at https://www.facebook.com/business/learn/facebook-ads-pixel
• You can find more information on Facebook's privacy policy at https://www.facebook.com/policy.php
• Further information on data processing by Facebook is available at https://www.facebook.com/about/privacy

 

bb) Purposes of the processing of data

 

We use these functions in order to be able to present you with offers that match your interests.

 

cc) Legal basis

 

We process your data because you have given your consent (Article 6 (1) (a) GDPR). We obtain your consent when you visit our website via the cookie banner.

 

dd) Storage duration and control options

 

We store your data as long as we need it for the respective purpose (display of interest-based advertising), or as long as you have not objected to the storage of your data or have revoked your consent.

 

The deactivation of the “Facebook Custom Audiences” function is possible for logged-in users at https://www.facebook.com/settings/?tab=ads#.

 

You can change your settings for advertisements in Facebook at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen,%20provided%20you%20are%20logged%20into%20Facebook

 

1. Use of Google Remarketing and Double Click

 

aa) Processed data

 

Google Remarketing and Double Click (now Google Ad Manager): We use Google Remarketing and Google Double Click from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. With this technology, cookies are set which evaluate how you use our website and which enable your browser to be recognized when you visit websites that belong to the Google advertising network. For this purpose, the Google Analytics tracking code uses so-called double click cookies in addition to the Google Analytics cookies. These collect data on which third-party websites in the Google Display Network you have visited and which advertisements you have clicked on. In addition, data from first-party cookies (e.g. Google Analytics cookies) and third-party cookies (e.g. Google cookie for display preferences) are linked. This enables us to evaluate the display of advertisements and your interaction with these advertisements.

 

Google Ads Conversion Tracking: We use Google Ads Conversion Tracking. With this technology, cookies are set when you interact with one of our advertisements, e.g. click on it. Cookies are used to analyze what happens after you have interacted with an advertisement, e.g. whether you have bought our product, viewed the ad from a mobile phone, downloaded our app or signed up for a newsletter.

 

bb) Purposes of the processing of data

 

Google Remarketing and Double Click (now Google Ad Manager): We use this technology to present you with interest-based advertisements on other websites in the Google advertising network. The advertisements relate to content that you have previously viewed on our website.

 

Google Ads Conversion Tracking: We use this technology to improve our offers.

 

cc) Legal basis

 

We process your data because you have given your consent (Article 6 (1) (a) GDPR). We obtain your consent when you visit our website via the cookie banner.

 

dd) Storage duration and control options

 

The data that are collected via the Google functions are saved and regularly deleted.

 

You can prevent the storage of cookies by making the appropriate setting in your browser.

 

You can also prevent Google from collecting the data and processing the data by downloading and installing the browser add-on available under the following link https://tools.google.com/dlpage/gaoptout?hl=de

 

Google Dynamic Remarketing and Double Click as well as Google Ads Conversion Tracking: You can object to the storage of cookies and the associated data processing by deactivating personalized advertising via your advertising settings http://www.google.com/ads/preferences/html/opt-out.html. You can deactivate the use of cookies by third-party providers via the deactivation website of the network advertising initiative http://optout.networkadvertising.org/#/. Alternatively, you can deactivate double-click cookies by installing a browser plug-in https://www.google.com/settings/u/0/ads/plugin?hl=de

 

 

This can restrict the functionality of our website.

 

You can find further information in the Google privacy policy https://www.google.de/intl/de/policies/privacy/

 

j) Use of LinkedIn Insights and Conversion Tracking

 

aa) Processed data

 

We use the LinkedIn Insight Tag of the provider LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA for this website. The LinkedIn Insight Tag creates a LinkedIn "browser cookie" which collects the following data:

 

• IP address,

• time stamp,

• page activities,

• demographic data from LinkedIn, if the user is an active LinkedIn member.

 

This technology enables us to generate reports on the performance of our advertisements and information on website interaction. For this purpose, the LinkedIn Insight Tag is integrated on this website, which establishes a connection to the LinkedIn server if you visit this website and are logged into your LinkedIn account at the same time.

 

bb) Purposes of the processing of data

 

We process your data in order to evaluate campaigns and to collect information about website visitors who may have reached us through our campaigns on LinkedIn.

 

cc) Legal basis

 

We process your data because you have given your consent (Article 6 (1) (a) GDPR). We obtain your consent when you visit our website via the cookie banner.

 

 

dd) Storage duration and control options

 

We store your data as long as we need it for the respective purpose (campaign evaluation), or you have not objected to the storage of your data or have revoked your consent.

 

The collected data is encrypted. More information can be found here https://www.linkedin.com/help/linkedin/answer/65521.

Here you will find the LinkedIn privacy policy https://www.linkedin.com/legal/privacy-policy and the LinkedIn opt-out https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

 

 

 

k.Integration of Google Maps

 

We integrate the maps of the service "Google Maps" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, but is not limited to, the IP addresses and location data of users, which, however, are not collected without their consent (usually performed as part of the settings of their mobile devices). Unless you have expressly consented to the use, our legal basis for this data processing is our legitimate interest (Art. 6 Para. 1 S. 1 lit. f DS-GVO) in order to design our website to meet your needs. The data could also be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

 

l.Your consent to the integration of external content

 

When the video is played, personal data such as your IP address or browser information may be transmitted to YouTube and, if necessary, merged with existing data. YouTube is a service provided via a European subsidiary by a provider from the USA (Google LLC), where the level of data protection is inadequate by EU standards. Access from this side or from US authorities cannot be completely ruled out.

By playing the video, you consent to the processing of your personal data as described. Your consent is voluntary and can be revoked at any time with effect for the future (e.g. by email to [email protected]). For details on data processing, please refer to our privacy policy https://www.grenke.ro/en/privacy-policy/, Google privacy policy https://policies.google.com/privacy?hl=en and YouTube Terms of Service https://www.youtube.com/static?gl=RO&hl=ro&template=terms

 

 7. How long will my data be stored? 

 

Unless explicitly stated in this privacy statement, the usage and registration data stored with us is deleted as soon as it is no longer required for its intended use and the deletion does not conflict with any statutory retention obligations.

 

We process and store other personal data as long as it is necessary for the fulfilment of our contractual and legal obligations. It should be noted that our business relationship is a continuing obligation, which is designed to last for years. If the data is no longer required for the fulfilment of contractual or legal obligations, it is regularly deleted, unless its - temporary - further processing is necessary for the following purposes:

 

• Fulfilment of commercial and tax-related retention obligations: the Fiscal Code and fiscal regulations, the Money Laundering Law no. 290/2019 must be mentioned here. The deadlines for retention and documentation are two to ten years.

• Preservation of evidence in the context of the statutory limitation periods. These statutes of limitation can be up to 10 years in duration, although routinely the period tends to be three years.

 

8. Which data protection rights do I have?

 

Every data subject has with respect to us

• the right of access under Art. 15 GDPR,
• the right to rectification under Art. 16 GDPR,
• the right to erasure under Art. 17 GDPR,
• the right to restriction of processing under Art. 18 GDPR,
• the right to object from Art. 21 GDPR,
• and the right to data portability under Art. 20 GDPR.

 

In addition, there is a right to appeal to a competent data protection supervisory authority (Article 77 GDPR).

You may revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the GDPR came into effect, i.e. before 25 May 2018. Please note that the revocation is only applicable for the future. Processing that took place before the revocation is not affected.

 

 

9. Am I obligated to provide data?

 
As part of our business relationship, you must provide the personal data required in order to enter into a business relationship and perform its associated contractual obligations, or the personal data that we are required to collect by law. Without this information, we will generally not be able to conclude or execute the contract with you.

 
In particular, according to the money laundering regulations, we are obligated to identify you prior to entering into a business relationship with you on the basis of your identification document and to record and save your name, place of birth, date of birth, nationality, address and identification data. In order for us to be able to fulfil this legal obligation, you must provide us with the necessary information and documents in accordance with the Money Laundering Act and immediately notify us of any changes during the course of the business relationship. If you do not provide us with the necessary information and documents, we may not enter into or continue your desired business relationship.

 

10. To what extent is there an automated decision-making process?

 
In principle, we do not use any fully automated decision-making processes pursuant to Art. 22 GDPR in order to justify or maintain the business relationship. If we do use these procedures in individual cases, we will inform you about this separately, if this is required by law.

 

11. Does profiling take place?

 We sometimes process your data automatically with the aim of evaluating certain personal aspects (profiling). For example, we use profiling in the following cases:

• Due to legal and regulatory requirements, we are committed to combating money laundering, the financing of terrorism, and property-related offences. At the same time, data evaluations are also carried out (inter alia in payment transactions). These measures are also in place for your protection.
• In order to provide you with targeted information and advice on products, we use evaluation tools. These enable needs-based communication and advertising, including market and opinion research.
• We use the scoring to assess your creditworthiness. This calculates the probability with which a customer will meet their payment obligations in accordance with the contract. The calculation may include, for example, income, expenses, existing liabilities, occupation, employer, duration of employment, past business experience, past repayment of the loan, and information from credit reporting agencies. The scoring is based on a mathematically-statistically recognized and proven procedure. The calculated scores help us make decisions within the context of product sales and are part of ongoing risk management.