DATA PRIVACY POLICY CG24 (GROUP) AG

Content

1. Explanation of terms
2. Scope
3. Type of data collected, processed and used
4. Purpose of data collection
5. Disclosure of information to third parties
6. Cookies use
7. Data processing for marketing and analysis purposes
8. Interaction with social networks
9. Direct marketing and online advertising
10. Data security and security of transmission
11. Use of Google Inc. applications by CG24
12. Data retention period
13. Right to information, correction, deletion and complaint
14. Scope
15. Contact
16. Actuality and changes of the privacy policy

CG24 Group AG (formerly CreditGate24 (Schweiz) AG) (hereinafter also referred to as CG24, we or us) attaches great importance to the protection of the personal data you provide. Your trust is of great importance to us. The following data privacy policy provides information on how we ensure data protection at CG24, what types of data are collected and how the data provided is processed and used.

You will be informed on the home screen of our website that you accept this privacy policy when using our website. Please note that we may need to revise the Privacy Policy from time to time. The revised version will be effective as of the published effective date.

You can access this privacy policy at any time in the footer on all pages via the link "Privacy policy". Any third-party websites that can be accessed via our portals are not subject to the principles set out here. We assume no responsibility or liability for the observance of data protection by third party websites.

1. Definitions of terms

Personal data: are all individual details about personal or factual circumstances of a specific (identified) or determinable (identifiable), natural person. It is information that is personally associated with you and can say something about you. For example, the telephone number, credit card or personal numbers of a person, the account data, a license plate of a car, the appearance, the customer number or the address count to the personal data (hereinafter also data).

Processing: any handling of personal data carried out with or without the aid of automated procedures, regardless of the means and procedures used, in particular the acquisition, storage, use, disclosure, archiving or destruction.

2. Consent to the privacy policy

By using our website and, if applicable, creating a personal account, you agree to the privacy policy described below as well as the manner of processing your data described therein.

3. Type and scope of the data

The type and scope of the collection and use of your data differs depending on how you use the website of CG24. It is distinguished whether you use the website purely informative or the use of services (eg registration for the newsletter) and / or the protected access area. The latter is only accessible after prior registration and personal login.

• Use of the website without registration

You can use a large part of our website without registration. As a non-registered customer, no personal data will be collected from you other than your IP address. However, our web server automatically collects computer-related data when you visit the CG24 website. This data includes the (anonymized) IP address, the type of browser software used including settings, the date and time of your visit to our website and the duration of your visit. When calling up Internet pages, this data is technically mandatory and is transmitted by your browser. 

• Collection of your personal data (for registration and/or use of services)

When visiting and using our website as a registered customer, we process the following personal data, among others:

• Personal information (such as name, date of birth, marital status, address, telephone number, e-mail address, etc.) that you provide to us when filling out forms on our website or when registering for the newsletter itself;
• Other information required for the use and provision of our services in accordance with the purpose of the processing.

CG24 observes and complies with the principles of good faith, legality, transparency, purpose limitation, accuracy, integrity and confidentiality and proportionality.

4. Purpose of processing

For what purpose is your data processed?

CG24 processes data, both personal and non-personal, for the following purposes:

• to enable us to provide our services in an optimal, safe, pleasant and efficient manner, including in particular the granting of loans;
• for the efficient management and continuous improvement of our website;
• to analyze visitor or user behavior on our website, record trends and create statistics;
• for a user experience that is optimally tailored to your needs;
• for sending newsletters as well as for (personalized) advertising measures, provided that the clientele has given us the corresponding consent;
• and for other purposes related to the operation of the website;
• to fulfill regulatory and legal obligations (creditworthiness check, combating money laundering and terrorism financing, ...).

5. Disclosure of information to third parties

CG24 may pass on the collected data to affiliated group companies, cooperation partners as well as to commissioned third parties in Germany and abroad for the above-mentioned purposes. The respective data recipients who have access to the data collected by CG24 are obliged to observe data protection. Third party service providers receive data only to a necessary extent and are obliged to use the data exclusively for order processing and not for other purposes (list of order processors). In case of cross-border data transfer, CG24 ensures that the data recipients guarantee adequate data protection.  

Data may be transferred to the following third countries:

Third country	Guarantee to ensure data protection
Netherlands	Adequacy decision Federal Council (Annex 1 FADP)
Finland	Adequacy decision Federal Council (Annex 1 FADP)
Belgium	Adequacy decision Federal Council (Annex 1 FADP)
Denmark	Adequacy decision Federal Council (Annex 1 FADP)
Ireland	Adequacy decision Federal Council (Annex 1 FADP)
Germany	Adequacy decision Federal Council (Annex 1 FADP)

Nevertheless, every person who uses the Internet must be aware that most services originate from globally active companies and that, therefore, there always remains a certain residual risk that data may end up in countries without adequate data protection. 

Disclosure of your data to supervisory authorities, judicial authorities or other competent persons is also expressly permitted if required by applicable law.

6. Use of cookies

What are cookies and how are they used on our website?

Technologies used include cookies to collect certain information for the purpose of improving the user experience on our website. Thus, your visit to our website is designed according to your needs and facilitates communication and Internet use. Cookies allow us to make the website experience easier, more pleasant and more efficient.

Cookies do not damage the hard drive of your computer, nor do they transmit personal data of customers to us.

Cookies are small text files that are placed on your local access device (PC, smartphone, tablet, etc.) via your browser when you visit the CG24 website and temporarily or permanently store specific information related to the device. This includes, for example, the recording of the browser type, the pages visited or language settings. This enables our web server to recognize the user's access device on the next visit. The cookie thus helps to provide and present an individualized website tailored to your needs. As a result, you will find your way around more quickly on a subsequent visit and will be able to use the website more efficiently. It is important to note that not the person, but only an identification of the access device takes place.

CG24 also uses cookie technology for statistical, analytical and marketing purposes, provided that you have given your consent. This helps us to identify the potential for improvement of our website and to be able to ensure continuous optimization in terms of user-friendliness, speed and performance. 

Through our cookie banner you can set your cookie preferences. You control a storage of cookies on your access device itself and can also reject them. Furthermore, you are also able to delete cookies that have already been set. You can make the preferred settings in the menu bar of your browser. Please note, however, that deactivating cookies may result in restricted access to our website.

7. Data processing for marketing / analysis purposes

We use various web analysis tools on our website to record and evaluate the usage behavior of our customers. In doing so, we work together with third-party companies. Technically, these tools also work with cookies. The data generated by the tracking code and the cookie about your visit to our website may be transmitted for analysis purposes to third-party providers who provide the service. Cookies used to collect tracking data do not contain any personal data, i.e. your IP address is immediately shortened on your access device and thus anonymized. This ensures anonymized transmission and storage of the data. This data is collected for the purpose of continuously optimizing our website and improving advertising measures. Detailed information about the data collected by the respective providers can be found on the respective website of the third-party provider (please find a description as well as the link immediately below). You can avoid the collection of your data with the help of add-ons. 

• Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), and may create a user ID that enables us to analyze user behavior (for more information, please visit https://support.google.com/analytics/answer/3123662). The latest version of Google Analytics, which is mainly used by CG24, does not log or store individual IP addresses. Google Analytics uses cookies that enable an analysis of your use of the website as well as the mobile application. The information generated by the cookie about the use of the website as well as the mobile application is usually transmitted to a Google server and stored there. However, by activating IP anonymization on our websites as well as the mobile application, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website and the mobile application, compiling reports on website and application activity and providing other services relating to website activity, application activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website or mobile application. You can also prevent the collection of data generated by the cookie and related to your use of the website and the mobile application (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link:

 http://tools.google.com/dlpage/gaoptout?hl=de.

• Use of Google Remarketing

This website uses the remarketing function of Google Inc ("Google"). This function is used to present interest-based advertisements to visitors of the website within the Google advertising network. The browser of the website visitor stores so-called "cookies": text files that are stored on your computer and that make it possible to recognize visitors when they visit websites that belong to the Google advertising network. On these pages, visitors can then be presented with advertisements that relate to content that the visitors have previously accessed on websites that use Google's remarketing function. According to its own information, Google does not collect any personal data during this process. However, if you do not wish to use Google's remarketing function, you can generally deactivate it by making the appropriate settings at https://support.google.com/accounts/answer/2662856#everywhere. Alternatively, you can deactivate the use of cookies for interest-based advertising via the advertising network initiative by following the instructions at http://www.networkadvertising.org/choices/. Further information on Google Remarketing and Google's privacy policy can be found at: http://www.google.com/privacy/ads/.

• Use of Google AdWords conversion tracking

We use the online advertising program "Google AdWords" and within the framework of Google AdWords the conversion tracking. Google Conversion Tracking is an analysis service of Google Inc.When you click on an ad placed by Google, a cookie for conversion tracking is stored on your computer. These cookies lose their validity after 30 days, do not contain any personal data and are therefore not used for personal identification.

If you visit certain web pages on our website and the cookie has not yet expired, Google and we can recognize that you clicked on the ad and were redirected to this page. Each Google AdWords user receives a different cookie. Thus, there is no way that cookies can be tracked across AdWords customers' websites.

The information collected using the conversion cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. Here, the clientele learns the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to identify users personally.

If you do not wish to participate in tracking, you can object to this use by preventing the installation of cookies through a corresponding setting in your browser software (deactivation option). You will then not be included in the conversion tracking statistics. Further information as well as Google's privacy policy can be found at: http://www.google.com/policies/technologies/ads/, http://www.google.de/policies/privacy/

• Use of Google Tag Manager

We use Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage website tags (keywords) through one interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect any personal data. The tool takes care of triggering other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it remains in place for all tracking tags implemented with Google Tag Manager.

• Use Hubspot

We use Hubspot as a service provider to manage our websites and communicate with customers through various channels. Hubspot Service Hub connects all customer service data and channels on one CRM platform, allowing CG24 to easily manage, retain and grow its customer base. Among other things, Hubspot collects and manages customer data through forms, email traffic, or direct interaction with our employees to provide effective delivery of our services. In addition, Hubspot collects anonymized data about user behavior on our websites via cookies in order to develop analyses for website improvements and adjustments. You can find more information and Hubspot's privacy policy at: https://legal.hubspot.com/de/dpa.

8. Interaction with social networks

We use social plug-ins (hereinafter referred to as plug-ins) from social networks on the Internet. These plug-ins can be recognized by the logo of the network on our website.
When you call up a website with such a plug-in, a direct connection is established with the servers of the corresponding social network. It is important to note that we use a so-called two-click solution of the plug-in for your protection. This means that the plug-ins on our website are initially inactive. Only when you click on one of the logos, the corresponding plug-in is activated and a connection, as well as a data transmission that you are visiting our website, among other things, is granted to the third-party provider. If you are also logged in to this network with user name and password at this time, it is possible that all interactions with the plug-in regarding your profile will be assigned. For example, content from our website can be linked to their profile. Other users of the network may learn of such interactions. CG24 is neither affiliated with nor responsible for the third party operators whose websites are integrated by means of plug-ins. We have no control over the use of such personal data collected by third parties and accept no responsibility or liability. If you are not a member of the social network or are not logged in there, it is still possible that your IP address is transmitted and stored.

9. Direct marketing and online advertising

With your registration and/or use of services on our portal, we may also use your personal data for personalized advertising measures, provided you have given us your consent to do so. This is also the case if you register for the newsletter on our website. This concerns both the personalization of advertising by e-mail, such as e-mails with general information or advertising character (newsletter) and the delivery of personalized content and advertising on our portal. For this purpose, we may automatically evaluate information known to us about your usage behavior on our portals so that we can avoid sending you inappropriate advertising.

With registration on our portal you can also subscribe to one of our newsletters and your e-mail address can accordingly also be used for our own advertising purposes until you unsubscribe from the corresponding newsletter. At the end of a sent e-mail you will find a link that allows you to unsubscribe from the newsletter at any time.

You can also unsubscribe from the newsletter at any time by sending an e-mail to info@cg24.com.

As a result of your consent, we are entitled to commission third parties with the technical processing of advertising measures and advertising for ourselves and are entitled to pass on your data for this purpose.

 

10. Data security and security of transmission

The data collected by CG24 is subject to the highest standards of confidentiality and is treated with the utmost care and discretion. To protect against unauthorized access, destruction, misuse, disclosure and/or manipulation, CG24 has implemented adequate technical and organizational measures. CG24 uses servers in Switzerland or Europe to store your data. Their data centers meet the highest security requirements and are ISO 27001 certified. Furthermore, we would like to point out that we also take internal company data protection seriously. All our employees and the service companies we commission are committed to data protection and confidentiality and are informed about the legal requirements.

The communication via the website takes place with a secure SSL encryption (Secure Socket Layer). Please note that it is nevertheless possible that data which you transmit to CG24 via the Internet or an e-mail service can be viewed by third parties without permission.

However, CG24 can assure you that your data will be handled in accordance with the applicable data protection regulations and that further measures will be taken to protect against unauthorized access by third parties. Nevertheless, we cannot guarantee the confidentiality and complete protection of the messages and therefore cannot assume any liability.

If you are registered as a user at CG24, access to your account is only possible after entering your personal password in each case. You should always keep payment and access information confidential and close the browser window when you have finished communicating with us, especially if you share the computer with others.

11. Use of Google applications by CG24

CG24 is itself a user of Google Inc ("Google") applications. As a user, CG24 is bound by the applicable terms of use of Google and has no influence on their respective changes by Google.  

At this point CG24 officially informs about the use of Google applications. This may also affect your data. 

CG24 ensures in its own CG24 user profile of Google that only Google servers in Europe are used. This ensures the legally required level of data protection. 

By explicitly accepting this Privacy Policy, using our website and, if applicable, creating a personal account, you consent to CG24's use of Google Applications.

You can find Google's privacy policy and terms of use here: https://cloud.google.com/privacy/gdpr?hl=de

12. Data retention period

We keep your data only as long as it is legally required or according to the processing purpose. In the case of analyses, we store your data until the analysis is completed. If we store data on the basis of a contractual relationship with you, this data remains stored for as long as legal or contractual retention obligations exist.

13. Right to information, correction, deletion and complaint

You have the right to assert your data protection rights at any time and to request information about whether and what personal data about you is being processed by us. You can also have your personal data corrected, blocked or, insofar as technically possible and legally permissible, deleted at any time by sending written notification and appropriate proof of your identity to the following address:

info@cg24.com

Please note that even after your request for the blocking or deletion of your personal data, we must retain some of this data within the scope of our legal or contractual retention obligations (for example, for billing purposes) and in this case only block your personal data to the extent necessary for this purpose. Furthermore, deletion of your personal data may mean that you can no longer obtain or use the services you have registered for. Under certain conditions, you are entitled to have us pass on your personal data to you or a third party designated by you in a common format.

You also have the right to lodge a complaint with the competent supervisory authority regarding data processing. You can do this at the supervisory authority at your place of residence, place of work or the place of the alleged data protection violation. Under the following link you will find the data protection authority of Switzerland with its own website: Data Protection - Switzerland

14. Scope

This privacy policy applies to all data that we receive as a result of your use of our website. It does not cover the content of third-party websites, even if you access those third-party websites via links on our website. We have no influence on the content, data processing and handling of third-party websites and consequently cannot accept any responsibility for them. We ask you to observe the specific data protection declarations of the respective third-party websites.

When processing your personal data, CG24 is subject to Swiss data protection law. Other data protection laws may apply if your data is processed abroad (e.g. by a contracted service provider).

15. Contact person

If you have any questions about data protection on our website, would like to request information or would like to request the deletion of your data, please contact our contact person for data protection law by sending an e-mail to info@cg24.com or by mail to:

CG24 Group AG
Data protection
Letzigraben 89
8003 Zurich

16. Up-to-dateness and changes of the privacy policy

You can also access and print out the current data protection declaration at any time on our website. The original data protection declaration is in German. The translated versions are merely for better comprehensibility. In the event of any dispute, the German text shall prevail.

Version September 2023