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

With the following information, we, GC Leasing Middle East FZCO Dubai Branch would like to give you an overview of how we process your personal data as well as your rights in respect of such date. What specific data is processed in detail and how it will be used depends on the requested or agreed services.

 

We are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our policies regarding information and data which we collect from you and how it will be treated.

 

We reserve the right to change, add to and cancel any or any part of this Privacy Policy without prior notice to you at any time, at our sole discretion, including by posting a copy of the amended Privacy Policy on our website. It is your sole responsibility to check the Privacy Policy (or both) as available on the website from time to time for any amendments. If the modified Privacy Policy are not acceptable to you, your only recourse is to cease accessing, viewing or otherwise using the website.

 

GC Leasing Middle East FZCO Dubai Branch reserves any rights not expressly granted to you in this Privacy Policy.

 

This Privacy Policy shall be governed by and construed in accordance with the laws of the Emirate of Dubai and the Federal laws of the United Arab Emirates as applicable therein. Disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Emirate of Dubai.

 

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

 

Contact details as follows: 

GC Leasing Middle East FZCO Dubai Branch

Dubai Hills, Park Heights Square, Building 2, Office 102, P.O. Box 371062, Dubai, U.A.E.

Phone: +971 4 873 59 00

 

You can reach our operational data protection officer at: 

GC Leasing Middle East FZCO Dubai Branch Data protection officer

Dubai Hills, Park Heights Square, Building 2, Office 102, P.O. Box 371062, Dubai, U.A.E.

E-mail: [email protected]

 

 

2. What sources and data do we use? 

 

We process personal data that we receive from our customers 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. Finally, we process personal data of our shareholders, shareholder representatives, guests of the Annual General Meeting of the parent company of GC Leasing Middle East FZCO Dubai Branch, and analysts on the basis of our legal obligations.

 

Relevant personal data includes but is not limited to:

 

• Personal details (name, address, date of birth, 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 where applicable 
• 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.
• Data in connection with the Annual General Meeting of GRENKE AG such as the number of the admission ticket, powers of attorney, instructions, proxies and voting forms.

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 applicable UAE law and, in respect of EU citizens or residents, the European General Data Protection Regulation (GDPR), please refer to Article 6(1) of the GDPR: 

 

a. For the fulfilment of contractual obligations

 

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 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

 

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 to identify risk factors, where applicable

• For the purposes of examining possible credit, regulatory and default risks as well as preventing criminal offences, we may provide relevant personal data to our parent company, GRENKE AG, who may in turn provide the same to their regulators or credit agencies or to local credit and risk allocation firms.
• In addition, we may also transfer personal data collected in the context of this contract concerning the application, execution and termination of this business relationship as well as data on non-contractual or fraudulent behaviour to our parent company, GRENKE AG, who may in turn provide the same to credit agencies, where applicable.
• The legal bases of these transfers, in respect of EU citizens or residents, are Article 6 (1) (b) and Article 6 (1) (f) of the GDPR. Transfers on the basis of Article 6 (1) (f) of the GDPR may only be made to the extent necessary to safeguard our legitimate interests or those of third parties and provided these interests do not outweigh the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data. As for non-EU citizens or residents, GRENKE AG and GC Leasing Middle East FZCO Dubai Branch shall ensure that such transfers are conducted in a fair and transparent matter, respecting the protection of personal data at all times.

The data exchange with the credit and risk allocation agencies also serves the fulfilment of legal obligations to carry out creditworthiness checks of customers.

Credit agencies process the data obtained and also use it for the purposes of profiling (scoring) in order to provide their contractors and certain regulators with information in order to, inter alia, make assessments on the creditworthiness of natural persons. Detailed information according to Article 14 of the GDPR on the activities of the credit agencies can be found for the respective credit agency under the following link:

• https://dnbuae.com/ “Dun and Bradstreet - CRIF

 

Detailed information according to Article 14 of the GDPR which enable a pseudonymous analysis of the use of our website. This includes:

• 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, as provided for in the privacy settings of the website
• Asserting legal claims and defence in legal disputes
• Ensuring the IT security and IT operation of our website and company
• Prevention and investigation of criminal offences where legally sanctioned
• Surveillance for the protection of domiciliary rights, and for the collection of evidence in cases of robbery and fraud where legally sanctioned  
• 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

 

Insofar as you have given us your consent to process your personal data for specific purposes (e.g., disclosure of data within the GRENKE AG group of companies, 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. The revocation of consent does not affect the legality of the data processed until the revocation.
 
d. Based on legal requirements, legitimate interests or in the public interest

 

In addition, we are subject to various legal obligations under UAE law. The purposes of the processing include, but are not limited to,  creditworthiness checks, identification requirements, prevention of fraud and money laundering, the fulfilment of tax auditing and reporting obligations, and the assessment and management of risks.

In addition to the above, our parent company, GRENKE AG also processes personal data of shareholders, shareholder representatives and, if applicable, guests at its Annual General Meeting to ensure orderly conduct of such Annual General Meetings. Personal data is stored in accordance with legal obligations and then deleted.

 

4. Who receives my data?

 

Within our organisation, 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 authorised agents may also receive data for these purposes. These are companies in the categories of 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 in the presence of a legal or regulatory obligation.
• Comparable institutions to which we transfer personal data over the course of our business relationship with you.
• Other companies within the GRENKE AG group of companies.
• For risk management due to legal or regulatory obligations.

 

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

 

5. A transfer of data to bodies in countries outside the United Arab Emirates 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),  
• you have given us your consent, or
• this is required for us to conduct business within the GRENKE AG group of companies.

 

6. How is my data processed on the website?

 

Unless otherwise stated, we process your data on our website either to action your request or based on our legitimate interests as follows. In respect of EU citizens or residents, please refer to Article 6(1) of GDPR:

 

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 personalised 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 site from which our website has been accessed, where applicable
• Provider
• User's IP address

 

b. Contact forms

 

In order to be able to give you the best possible advice as part of a request via our contact forms, the appropriate GRENKE 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 (in line with Article 6 (1) (b) GDPR, where applicable) 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, where applicable.  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 leasing test), we will save your data for the purpose of processing your request (Article 6 (1) (b) GDPR, where applicable) 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 Article 6 (1) (a) GDPR, where applicable) within the scope of the contact form or another enquiry, you grant GRENKE AG, GRENKE Business Solutions GmbH & Co. KG, GRENKEFACTORING GmbH and GRENKE BANK AG 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.

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, about the latest news in respect of the GRENKE AG group of our companies 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.

 

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, 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 a better experience and to enable the use of certain functions, we use so-called cookies on our websites. 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 recognise 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 experi-ence on both one-time and repeated website visits. This allows you to quickly and easi-ly 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 for the optimisation and needs-based design of our website.
 
Cookies are stored for marketing purposes on the basis of the user's consent. 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 in the privacy settings of our website 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 in order to be able to use our website as they enable basic functions such as site navigation and access to secure areas of the website. The website may not work properly without these cookies.

Functional cookies

 

Functional cookies allow a website to store information that has already been entered (such as preferred language), and to provide the user with enhanced, more personalised features. Functional cookies are used for instance to enable requested functions such as playing videos. These cookies collect anonymised information; they cannot track your movements on other websites.

Statistical cookies

 

Statistical cookies collect information about the use of a website – such as the user’s most frequently visited pages and whether the user receives error messages when using a website. These cookies do not store information that allows the user to be identified. The information gathered is pooled and therefore evaluated anonymously. These cookies are used exclusively to improve a website's performance and thus the user experience.

 

f. Range analysis using Piwik

 

If you consent, we use Piwik, a software tool 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 analysed. 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

 

We use the Eloqua service to collect statistical data about the use of our website, to send our newsletters and to optimize our services accordingly. The Eloqua servers of the supplier ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, Netherlands are located in the EU.

 

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, this 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, 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 .

You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy.

 

For the avoidance of doubt, we are not responsible for the contents of the linked websites referenced above.

 

h) Integration of social media plug-ins

 

We are currently using the following social media plug-ins: Facebook, Instagram, Twitter, LinkedIn.

 

When you visit a page that contains such a plug-in, the browser will connect to the social media providers' servers and provide the information that you have accessed the corresponding sub-page of our website. In addition, the data referred to in paragraph 6a of this declaration will be transmitted, whereby in the case of Facebook, only an anonymous IP is recorded. This happens regardless of whether you have an account with this plug-in provider and are logged in there. If you are logged in to the plug-in provider, this data will be assigned directly to your account. If you click the button, the plug-in provider also stores this information in your user account and informs your contacts publicly. If you do not want your profile to be linked with the plug-in provider, you must log out before clicking the button.  

 

The plug-in provider stores this data as usage profiles and uses it for the purposes of advertising, market research and/or tailored website design. Such an evaluation is carried out in particular (also for non-logged-in users) to present needs-based advertising and to inform other users of the social network about your activities on our website. You have a right to object to the formation of these user profiles; you must contact the respective plug-in provider to exercise them.

 

For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the privacy statements of these providers, which can be found below. You will also find further information about your rights and settings options to protect your privacy here.

 

Addresses of the respective providers and URLs with their privacy policies:

 

• Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, more information on data recording: https://www.facebook.com/about/privacy, https://www.facebook.com/help/186325668085084. Facebook has submitted itself to the EU-US Privacy Shield (see https://www.privacyshield.gov/EU-US-Framework).
• Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, more information on data recording: https://www.instagram.com/about/legal/privacy, https://www.facebook.com/help/186325668085084. Instagram has submitted itself to the EU-US Privacy Shield (see https://www.privacyshield.gov/EU-US-Framework).
• Twitter Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/de/privacy. Twitter has submitted itself to the EU-US Privacy Shield (see https://www.privacyshield.gov/EU-US-Framework).
• LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn has submitted itself to the EU-US Privacy Shield (see https://www.privacyshield.gov/EU-US-Framework).

 

For the avoidance of doubt, we are not responsible for the contents of the linked websites referenced above.

 

i) 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 such use, our legal basis for this data processing is our legitimate interest  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

 

j) Integration of YouTube videos
 

aa) Processed data

We have embedded YouTube videos on our website, which are hosted by YouTube but can be played directly from our website. These are all embedded in "extended data protection mode", i.e. according to YouTube's own statement, the playback of a video is not used for the personalisation of advertising to the user. However, we have no influence on this. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

In order to increase the protection of your data when visiting our website, the videos are initially deactivated and integrated into the page using a so-called "2-click solution". This integration ensures that when you call up a sub-page of our website that contains such videos, no connection is established with the YouTube servers. Only when you activate the videos does your browser establish a direct connection to the YouTube servers. 

By activating the video, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, basic data such as IP address and time stamp are transmitted. This takes place regardless of whether YouTube provides a user account via which you are logged in or whether no user account exists. If you are logged in to YouTube, your data will be directly assigned to your account. If you do not want your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or designing their website to meet your needs. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and to exercise this right you must contact YouTube or Google, e.g. at https://about.google/contact-google/.

The information collected is stored on Google servers, also in the USA as an unsafe third country. For these cases, the provider claims to have set itself a standard that corresponds to the former EU-US Privacy Shield and has promised to comply with the data protection laws applicable to the international transfer of data. We have also agreed so-called standard contractual clauses with YouTube, the purpose of which is to maintain an appropriate level of data protection in third countries.

For more information on the purpose and scope of data collection and processing by YouTube, please see Google's privacy policy. There you will also find further information on your rights and setting options to protect your privacy: www.google.de/intl/de/policies/privacy.
 

bb) Purposes of the processing of data

The data is processed and transmitted for the purpose of integrating and displaying YouTube videos.
 

cc) Legal basis

The legal basis for the display of the videos is Art. 6 para. 1 lit. a) DSGVO, i.e. the integration only takes place after your consent. 
 

dd) Duration of storage and control options

We store your data as long as we need it for the respective purpose, or as long as you have not objected to the storage of your data or have revoked your consent.
If you do not want data to be processed by YouTube, you can refuse or revoke your consent in this respect. 

 

For the avoidance of doubt, we are not responsible for the contents of the linked websites referenced above.

 

 

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, regulatory and legal obligations. It should be noted that these are  continuing obligations, which are designed to last for a significant period. If the data is no longer required for the fulfilment of contractual, regulator 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: under UAE law.
• Preservation of evidence in the context of the statutory limitation periods as provided for under UAE law.

 

8. Which data protection rights do I have?
 

Every affected person has with respect to us

• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restriction of processing;
• the right to object; and
• and the right tto data portability.

 

In respect of EU citizens and residents please refer to the following GDPR provisions:

 

• 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 (we refer to Article 77 of GDPR in respect of EU citizens and residents).
You may revoke your consent to the processing of personal data at any time. 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 not be able to conclude or execute a contract with you.
 
In particular, according to applicable money laundering regulations and know-your-client requirements, 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 and consent to the provision of necessary information and documents .You must 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?

 

 We do not use any fully automated decision-making processes pursuant to 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 may 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 recognised and proven procedure. The calculated scores help us make decisions within the context of product sales and are part of ongoing risk management.