1. WHICH PERSONAL DATA IS USED BY US?
We collect and use personal data, where this is necessary in the context of our business operations to provide to you a high-quality range of individual products and services.
The different types of personal information which we may collect includes inter alia:
Identity information (e.g. name, identity card or passport, driving license, nationality, place of birth and date of birth, sex, photo, IP address);
Contact details (e.g. postal address, email address, phone number);
Information on the family situation (e.g. family status, number of children);
Tax information (e.g. tax identification number, tax status);
Information on training and career (e.g. level of education, professional activity, name of the employer, earnings, etc.);
Bank, finance and transaction data (e.g. bank account, credit cart number, money transfers, assets, investment profile disclosed, credit history, debt level and expenses);
Information on the leasing contract (e.g. customer number, contract number, license plate of the vehicle);
Information on insurance matters (e.g. claims history including claims payments and damage appraisals, information on personal injuries);
Data relating to your habits and preferences:
Data relating to your use of our products and services, in particular finance and transaction data;
Data relating to interactions between you and us (contacts to our branches [contact reports], visits on our websites, use of our apps and social media pages, personal meetings, chat contact, email traffic, surveys, phone calls);
Video surveillance data (including recordings of surveillance cameras) and geolocation data (display of locations for identifying the location of service suppliers for your support or for providing specific services such as car-sharing);
Data necessary to prevent a situation of over-indebtedness.
According to the product or services you selected, the following data may be only collected by us, if you have given your explicit prior consent:
Biometric data, e.g. fingerprint, voice or facial patterns that can be used for identification and security purposes;
Data relating to criminal convictions and criminal or administrative offenses in connection with fines for traffic offenses as part of the "Traffic Ticket Management” service.
Personal data relating to racial or ethnic origin, political opinion, religious beliefs or philosophical views, trade union membership, as well as genetic data and details on the sexual orientation, will generally not be processed by us, unless we are obliged to do so by law.
The data used by us may be provided either directly by you or by the following sources for the purposes of updating or enhancing our own databases:
Publications/databases made available by authorities (e.g. the Federal Gazette);
Corporate customers and/or their branches/subsidiaries (e.g. including your employers) or our service providers;
Third parties such as credit agencies and pools for combating fraud or data brokers who are consulted in compliance with data protection regulations;
Websites / social media pages with information posted by you (e.g. your own website or social media page)
Databases made available to the public by third parties.
2. SPECIAL CASES OF THE COLLECTION OF PERSONAL DATA INCLUDING INDIRECT DATA COLLECTION
In certain cases, we will collect personal data of persons with whom we have, might have or had a direct relationship, and may use this data where appropriate. The persons include for instance:
Under certain circumstances, we may have collected information about you, although you do not maintain any direct relationship with us. This may be the case, if your employer has provided to us information about you or if we have obtained your contact details from one of your customers and you, for example, belong to one of the following groups of persons:
Authorized legal representatives;
Beneficiaries of payment transactions of our customers;
Beneficiaries of insurance policies or trustees;
Debtors of customers (e.g. in an event of insolvency);
Representatives of legal persons (e.g. of customers or service providers);
Employees of service providers or trading partners.
3. WHY AND ON WHAT BASIS WE USE YOUR PERSONAL DATA?
a. To fulfill the legal and regulatory obligations incumbent on us
We use your personal data to fulfill various legal and regulatory obligations, including:
Banking and financial regulations on the basis of which we:
take security measures to prevent misuse and fraud;
detect transactions that differ from usual patterns;
assess your credit risk and your repayment ability;
monitor and report risks to which may be exposed;
record telephone calls, chats, emails, etc., where required;
Responding to official requests by a competent government agency or judicial authority;
Prevention of money laundering and terrorist financing;
Complying with sanction and embargo regulations;
Combatting tax evasion and fulfillment of fiscal monitoring and reporting obligations.
b. To perform a contract concluded with you or to take specific measures upon your request before concluding a contract
With regard to you as driver or also as our individual customer, we use your personal data to conclude and perform our contracts, in particular for the purpose of:
evaluating whether and under which conditions we can offer to you a product or service;
informing you about our products and services;
planning and managing: (I) delivery, return, maintenance and repair of the vehicle (including recalls of vehicles by manufacturers), (II) further services (e.g. fuel cards and toll tickets, if applicable), and (III) selling the vehicle (as “used” car);
settling disputes (e.g. upon debt collection) and supporting you, and responding to your requests and complaints (including handling of insurance claims);
ensuring or facilitating your mobility by enabling you e.g. to use our mobile applications to easily access some of our services directly via your smartphone;
settlement, invoicing and recoveries.