We, A³ Handelspartner GmbH, welcome you to our website (hereinafter also referred to as “Website”). We appreciate your interest and would like to make your visit to our website as pleasant as possible.

We are the “controller” within the meaning of Art. 4 No. 7 GDPR for the processing of your personal data on this website.

You can contact us as follows:

A³ Handelspartner GmbH, Kaiserdamm 85, 14057 Berlin
Tel.: +49 30 91449115
Email: office@a3partner.com

You can contact our data protection officer as follows:

Email: datenschutz@a3partner.com
Please use this email address if you wish to exercise your rights or have a general question about the processing of your data by A³ Handelspartner GmbH.

This privacy policy applies to the website offered by A³ Handelspartner GmbH. If offers from other providers (“third-party offers”) are accessible from our website, our privacy policy does not apply to these third-party offers. In this case, we are also not responsible for the processing of your personal data within the scope of such third-party offers within the meaning of Art. 4 No. 7 GDPR.

 

Personal and non-personal data – Surfing our website

You can generally visit our website without telling us who you are. We will then only learn:

your IP address,

• the name of the website or file accessed, the time of access
• the amount of data transferred, an
• whether the access was successful.

The data is used exclusively for the administration and optimization of the website.

The IP address can be considered personal data because, under certain conditions, it is possible to determine the identity of the owner of the internet access used by obtaining information from the respective internet provider.

We only evaluate the IP address in the event of attacks on our internet infrastructure. In this case, we have a legitimate interest in processing the IP address within the meaning of Art. 6 (1) (f) GDPR. This legitimate interest arises from the need to ward off the attack on the internet infrastructure, to determine the origin of the attack, to be able to take criminal and civil action against the responsible party, and to effectively prevent further attacks.

The IP address information will be deleted if there is no indication of an attack on our internet infrastructure. This usually happens after 7 days.

We take the protection of your personal data very seriously and treat your personal data in accordance with the statutory data protection regulations, including the General Data Protection Regulation (EU) 2016/679 of April 27, 2016 (the “GDPR”), and this Privacy Policy. Please read this Privacy Policy carefully before browsing our website or using our services via the platform.

With the following Privacy Policy, we inform you about the processing of your personal data in connection with your visit to our website or your use of our platform as part of our credit brokerage activities for commercial platform users.

1. Definitions

Terms not specifically defined in this Privacy Policy have the meanings defined in the GDPR, such as “personal data” and “processing” within the meaning of Art. 4 GDPR:

• Personal data: means any information relating to a natural person that can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, or online identifier.
• Processing: means any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, disclosure, or any other use.

2. Provision of the website and log files

2.1 Purpose of data processing

Data is stored in log files to ensure the functionality of the website and the platform, as well as to offer you a technically effective visit to our website and platform: for example, the temporary storage of the IP address is necessary to enable delivery of the website or platform to the user’s computer; furthermore, the correct display of the website and platform requires adaptation to the needs of your device.

This data is also collected to ensure the security of our information technology systems, in particular to defend against attempted attacks on our servers and the website or platform.

 

2.2 Possibility of objection and removal

 

The collection of data for the provision of the website or platform and the storage of data in log files are essential for the operation of the website or platform. Therefore, there is no possibility of objection.

 

3. Use of cookies and analytics tools

We use cookies, similar technologies (collectively referred to as “cookies”), and analytics tools to store information about your preferred activities, to better tailor our offerings to your interests, to increase the speed of your requests, and for advertising purposes.

 

4. Data processing when providing the platform

4.1 Description and scope of data processing

4.1.1 Registration and/or manual completion of the contact form

To use services on our platform, you must manually complete our contact form on the website and thus register. This requires us to collect and process certain personal data as registration information during the registration process. This data includes the following information:

• Email address
• Telephone number
• User ID such as last name, first name, job/position, or function within the company
• Selection of the reason for the inquiry via the platform
• Circumstances of registration, including the log data (Section III) at the time of registration and confirmation of registration by the platform user.

 

4.1.2 Purpose of data processing

We collect and process your personal data specified in Section V.1. for the following purposes:

• to establish, implement, or terminate the use of the platform with the platform user
• to ensure that you can access and use the platform in the most effective and appealing way possible (e.g., through statistical analysis)
• for the technical implementation of the platform’s functions, in particular to enable the user to access the user data stored in the user area, upload documents, and forward them to the lending partner banks, factoring companies, and leasing companies selected by the user
• to monitor legal and contractual compliance
• to provide you with technical support
• to inform the user about changes to our services.

 

5. Data processing in the brokerage of loans, factoring, leasing, and surety bonds (deposit insurance) – hereinafter referred to as “loans”:

5.1 Description and scope of data processing

As part of the platform user’s application for a loan, as well as the review, support, and administration of the loan agreement, it is necessary for you to provide us with information in this context, and we process data that may, under certain circumstances, also contain personal information. Your personal data is processed as part of the loan brokerage process as explained below:

5.1.1 Credit Check

Obtaining Information from Credit Agencies

We initially conduct a credit check of the platform user based on the data we receive from the credit agencies listed below in order to present the platform user with a suitable financing partner based on the default risks thus determined, as well as the purpose and amount of the intended loan.

We use Creditreform Düsseldorf / Neuss Waterkamp, ​​Zirbes & Coll. KG, Heesenstr. 65, 40549 Düsseldorf (the “Creditreform”) for this purpose. We transmit the following data to Creditreform:

• Company name
• Company address
• Legal form.

Creditreform then calculates and transmits a risk score for the platform user to us. Based on the risk score and taking into account the purpose and amount of the intended loan, we search for one or more suitable financing partners from our cooperating partner banks and present suitable products to you.

Determination of the platform user’s individual score according to the specifications of the partner bank, factoring company, leasing company, or insurance company:

Further referral to some of our partners requires a more detailed assessment of the platform user’s credit risk based on additional criteria and processing additional platform user-related data. If the platform user decides to make a loan offer to such a partner bank, we calculate the potential default risk of the platform user according to the individual specifications of this partner bank based on the information from the credit agencies, the company data of the platform user, the previous history of borrowing via our platform, the purposes and the amount of the intended financing and transmit this score value to the corresponding partner bank that bears the default risk.

 

5.1.2 As part of the application process

When applying for a loan from a partner bank suitable for the platform user, we collect and process the following information:

• Requested loan amount;
• Desired loan term;
• Company purpose and industry;
• Intended use of the loan amount;
• Account details (bank and IBAN of the main business account);
• Data relating to the signatory of the loan agreement: first and last name; gender; address; telephone number; tax identification number; date of birth; nationality; signatory authority;

Circumstances of communication with you related to the offer, insofar as this relates to the brokered offer.

We also require information regarding your company (the “Company Data”). This includes, among other things:

• Name, address, and registered office of the company;
• Email address;
• Company type (AG, GmbH, etc.);
• Number of employees;
• Duration of the company’s existence;
• Industry;
• Authority of representation (information on the authorized natural person(s) (e.g., managing director/board member);
• Commercial register number;
• Tax information (e.g., tax identification number);
• Information on beneficial ownership, sales, balance sheets, and depreciation;
• Account statements;

Information on the company’s financial relationships and shareholdings.

For the purpose of executing the platform usage and brokerage agreement between you and us, as well as for carrying out pre-contractual measures, we will transmit the aforementioned data to the financing partners and also receive data from them for transmission to you.

 

5.1.3 Obtaining Guarantees

In the future, we will provide functionality on our platform for the automated creation of personal guarantees. If you wish to act as a guarantor for a platform user’s loan application, you can use this function to enter your data as a guarantor or upload the guarantee you signed. In this case, we will collect, process, and transmit the data required to create the guarantee to the lending bank. Furthermore, our platform allows platform users to upload and download written guarantees for transmission to the lending bank, factoring company, or leasing company.

5.2 Purpose of data processing

The purpose of processing your data, as stated in Section VI. 1, is to communicate our partners’ offers to the platform user. Specifically, we use your data:

• To identify offers from our partners that are suitable for you
• To initiate a loan agreement with the partner at your request, in particular to avoid duplicate entries and to conduct preliminary checks
• To process brokerage-related queries if the contract with the partner bank has not yet been concluded. This does not preclude us from later providing support during the contract term on behalf of some of our partner banks
• To provide documents and information that our partners need to decide on a loan application, e.g., commercial register extracts, information on shareholdings, or the applicant’s individual credit score.

5.3 Legal basis for data processing

To the extent that we process your data listed in Section VI. 1.1. (with the exception of Section 1.1.3) and 1.2 in order to present and connect you, as a platform user, with a suitable partner bank based on the information provided by credit agencies, we process this data on the basis of Art. 6 (1) Sentence 1 (b) GDPR, as this processing is necessary for the fulfillment of our platform usage and brokerage agreement, and the initiation of a loan agreement with the lending bank occurs at the request of the platform user.

To the extent that we transmit the individually determined score of the platform user to the lending bank as the separately responsible party in accordance with Section VI. 1.1.2, the legal basis for the transmission is Art. 6 (1) Sentence 1 (f) GDPR. The legitimate interest of the financing partners lies in assessing your contractual default risk. You have the right to object to this processing of your personal data by the financing partner or us. The legal consequences of the objection can be found in Section XVII.6 of this Privacy Policy.

5.4 Duration of Storage

We will store your data as defined in Section VI. 1.1.1 and 1.1.2, insofar as it relates to a natural person whom we process for the purpose of credit assessment, until the corresponding credit brokerage is completed.

Section V.4 and Section XII apply accordingly to the duration of processing of the data described in Section VI. 1.2.

We will store your data for the purpose described in Section VI. 1.3, only until this is necessary for the creation or transmission of your guarantee.

Regarding the storage and timely deletion of personal data by the respective partner bank or the creditor, we refer to the data protection regulations of the respective partners, which can be accessed via the link in Section XIII.1.

 

6. Processing on behalf of a third party

If we also collect and process personal data in the context of brokering and processing loan agreements on behalf of and in accordance with the instructions of one of our partners (for example, the lending banks in the context of fulfilling their identification obligations under the Money Laundering Act, the creditor in the context of processing disbursed loans in the case of factoring, or the payment service providers), you will find information on this on the respective partner’s website or under Section XIII.1. In this case, the third party alone determines the type, scope, and use of the information.

 

7. Newsletter and promotional emails

7.1 Interested parties

Interested parties who have not yet registered with us will only receive our newsletter if they have consented to receive such promotional emails. In such a case, we will use the interested party’s email address to send the requested information.

The legal basis for using the email address to send our newsletter is the consent given (Article 6 (1) (a) GDPR). The interested party can revoke this consent at any time, for example, via the unsubscribe link in the newsletter. The legality of any data processing already carried out on the basis of the consent remains unaffected by the revocation.

 

8. Evaluation of your activities in connection with the newsletter

If you receive direct email advertising from us and have given us your consent for this purpose, we may also use the data we collect to tailor such advertising messages to you. We also collect technical information such as information about your browser and system, as well as your IP address and the time of retrieval. Furthermore, it can be determined whether the newsletter was opened and when and which links were clicked.

The legal basis for the processing is your consent given for this purpose, Art. 6 (1) (a) GDPR. You can revoke your consent at any time, for example, via the unsubscribe link in the newsletter. The legality of data processing already carried out on the basis of your consent remains unaffected by the revocation.

 

9. Processing of inquiries / customer support

If you contact us with an inquiry, for example via our service hotline or by email, we process your contact details, such as your name, email address, or telephone number, as well as the time and duration of the telephone call and other personal data evident from your inquiry. This data processing serves to process and answer your inquiry and to ensure effective customer relationship management.

Telephone conversations are not recorded.

The legal basis for this processing to process your inquiry is the fulfillment of a contract or the implementation of pre-contractual measures (Article 6 (1) (b) GDPR).

 

10. General information on storage periods

Our goal is to process your personal data only to the minimum extent possible. Specific requirements regarding the storage period are included in the above descriptions of the respective processing operations. If no precise storage periods are specified in this statement, we will only store your personal data for as long as necessary to achieve the purposes for which it was collected, or – if there are longer statutory retention periods – for the duration of the statutory retention period. After that, your personal data will be deleted.

Retention obligations arise in particular from commercial and tax law, as well as from banking supervisory and administrative law regulations.

If you revoke your consent on which the processing of your personal data is based, or if you exercise your right of objection in the case of processing based on our legitimate interest, we will delete your personal data immediately, provided that the collection and processing of your personal data was based on the revoked consent and there is no longer any legal basis for the processing.

 

11. Sharing your personal data and transferring to third countries

Our partners
As described in more detail in Section VI.1.2. of this Privacy Policy, we will transfer your personal data to the relevant lending bank for the purpose of carrying out our brokerage activities if you submit a loan application to this partner bank.

The legal basis for this data transfer is the performance of our contract with you (Article 6 (1) (b) GDPR).

Furthermore, as described in more detail in Section VIII of this Privacy Policy, we will also transmit your data on behalf of and in accordance with the instructions of the partner bank to which you submit a loan application, if the partner bank has commissioned us to process this data as its processor based on a data processing agreement pursuant to Art. 28 GDPR, e.g.,

if the partner bank must comply with its anti-money laundering obligations (transmission of data relevant to the KYC (“Know Your Customer”) check to the partner bank’s identification service provider using the video identification process) or

as part of the credit check pursuant to Section VI. 1.1.3 or

when transmitting data to the partner bank’s corresponding service providers for the purpose of digitally signing loan agreements.

In addition, we process your personal data on the basis of the respective order processing agreement pursuant to Art. 28 GDPR for the purposes and in accordance with the instructions of the creditor if the lending bank assigns its rights and obligations arising from the loan agreement concluded with the platform user to a third party after the loan has been disbursed (e.g., setting up a loan after loan disbursement and contract takeover, updating the master data of the risk parameters; monitoring the contractually agreed conditions), as well as as a technical service provider for the payment service providers during the repayment of the loan.

 

12. Transfer of personal data to third countries

If A³ Trading Partner transfers your personal data to a recipient outside the European Union or the European Economic Area, the recipients are either located in a third country for which the European Commission has decided that this country ensures an adequate level of data protection, or an adequate level of data protection is ensured, for example, by standard contractual clauses adopted by the European Commission and concluded between A³ Trading Partner and the recipient. Further information on third-country transfers and the aforementioned safeguards can be found in the list under Section XIII. 2. above. You can obtain further details on the safeguards listed in the list by contacting us or our data protection officer using the contact details provided under Section II. of this Privacy Policy.

 

13. Provision of personal data

The provision of personal data is partly necessary for technical reasons (see Section III); in other cases, we require the data for user registration (Section V. 1.1) and to provide our brokerage services. If you do not provide us with this personal data, we will not be able to provide you with the platform’s services.

 

14. Your Rights Under the GDPR

You have the following rights, depending on the specific circumstances of the case:

Right to Information: The right to (i) receive information about whether we store personal data about you, and (ii) request access to your personal data and/or copies of that data. This includes information about the purpose of use, the category of data used, the recipients and those authorized to access it, and the planned duration of data storage.

Right to Rectification: When we process your personal data, we endeavor to take appropriate measures to ensure that your personal data is accurate and up-to-date for the purposes for which it was collected. In the event that your personal data is inaccurate or incomplete, you can request that it be rectified.

Right to Erasure or Restriction of Processing: You may have the right to request the erasure of your personal data or the restriction of its processing.

Right to data portability: The right to (i) receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and (ii) transmit those data to another controller without hindrance from us. You also have the right to request that we transmit the personal data directly to another controller, where technically feasible.

The right to refuse consent or – without affecting the legality of data processing carried out before the withdrawal – to withdraw your consent to the processing of your personal data at any time. Unless otherwise stated elsewhere in this privacy policy, you can contact one of the contact options specified under Section II to exercise your right of withdrawal.

Right of objection: The right to object to the processing of your personal data at any time for reasons arising from your personal situation, provided that the data processing is based on a legitimate interest of ours or a third party. The controller will no longer process the personal data concerning you unless they can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims. In this case, please provide us with information about your personal situation. After reviewing the information you have provided, we will either stop processing your personal data or inform you of compelling legitimate grounds for continuing the processing.

Right to object to direct marketing: The right to object at any time to the processing of personal data concerning you for direct marketing purposes. This also applies to profiling insofar as it is related to direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority within the European Union.

You can (i) exercise the above-mentioned rights, (ii) ask questions, or (iii) complain about our data processing by contacting us or our data protection officer using the contact details provided in Section II of this Privacy Policy.

 

15. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy in accordance with our website updates. Please always review the most current Privacy Policy when visiting our website.

This Privacy Policy was last updated on December 22, 2024.

 

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