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?
In respect of leasing
FAO Data Protection
Q-House, Suite 306
Sandyford Business Park
Phone: +353 1 292 3400
In respect of invoice financing:
GC Factoring Ireland Limited
FAO Data Protection
Q-House, Suite 508
Sandyford Business Park
Phone: +353 1 297 1060
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 (e.g. a credit agency). Finally, we process personal data of our shareholders, shareholder representatives, guests of the Annual General Meeting and analysts on the basis of our legal obligations.
Relevant personal data includes:
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 Data Protection Act 2018 (DPA).
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. leasing, factoring) and may include, but are not limited to, needs analysis, consulting and to perform transactions.
b. As part of the legitimate interest (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 e.g. Central Credit Register and Experian to identify credit risk or default risk
For the purposes of examining possible credit risks and default risks as well as preventing criminal offences, we provide Experian (Registered office at Newenham House, Malahide Road, Northern Cross, Dublin 17), Experian with data on the application and the applicant. Experian will make the data safe and available to us through direct electronic mail provided that we have given convincing evidence that our interest in this is legitimate. CRIF Bürgel GmbH will provide us with data stored on your person in the DSPortal (Deutsches Schutz Portal) if we have credibly demonstrated our legitimate interest.
The legal bases of these transfers 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.
Credit agencies process the data obtained and also use it for the purposes of profiling (scoring) in order to provide their contractors in the European Economic Area and in Switzerland and, where applicable, other third-party countries (if there is an adequacy decision by the European Commission) 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:
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., 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), 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., in respect of financial services laws, anti-money laundering legislation or tax laws) as well as banking supervisory requirements (e.g., the European Central Bank, the European Banking Authority, or the Central Bank of Ireland). 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.
Due to legal obligations, under the Companies Act 2014 as well as due to the legitimate interests in the context of the organization and orderly conduct of Annual General Meetings, we also process personal data of shareholders, shareholder representatives and, if applicable, guests at the Annual General Meeting of GRENKE AG (in particular name and contact details). The processing of this data is necessary for the participation of shareholders, shareholder representatives and possible guests in the Annual General Meeting or the holding of analyst events. 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 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 Group, we may only disclose information about you if we are required to do so by law, or is in our legitimate interest or if you have given us your consent to do so. Under these conditions, recipients of personal data may be, for example:
Other data recipients may be those to whom you have given us your consent for your data to be submitted.
We may also share your information within the GRENKE Group and with our parent company, GRENKE AG for our legitimate business interest.
5. Is data transmitted to a third-party country or to an international organisation?
A transfer of data to official bodies in countries outside the European Union (so-called third-party countries) takes place, as far as
6. How is my data processed on the website?
Unless otherwise stated, we process your data on our website either to action 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 used for security purposes respectively to report criminal offences in exceptional circumstances. The data is stored in httpd access logs in the data centers of our service provider Bloomreach and can be accessed in case of a legitimate interest.
A transfer of data to other third parties or any other evaluation does not take place, unless there is a legal obligation to do so. Data will be deleted automatically after 4 weeks retention time.
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
• User's IP address
We do not save your browser history.
The legal basis for data processing is Article 6 (1) (f) GDPR. Our legitimate interest follows from the aforementioned purposes as well as the technical necessity of processing the collected data in order to display our website to you.
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 data processors within the meaning of the GDPR. Further information on joint responsibility can be obtained by sending an e-mail to email@example.com.
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) 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 Limited and GC Factoring Ireland Limited 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 e-mail address and the date of your registration in order to be able to prove your newsletter subscription in case of doubt. The legal basis for this processing is Article 6 (1) (c) GDPR, as we are legally obliged to provide evidence of registrations. 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 to the subscription of our newsletter, 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.
The data provided during registration will only be used by us to enable you to use our website (Article 6 (1) (b) GDPR).
We collect the following data for the registration process:
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 e-mail address and the date of your registration in order to be able to prove the newsletter subscription in case of doubt. The legal basis for this processing is Article 6 (1) (c) GDPR, as we are legally obliged to provide evidence of registrations.
You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the newsletter.
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 recognise your browser on your next visit (so-called persistent cookies).
Cookies cannot access other files on your computer or identify your email address.
cc) Legitimacy of the storage of cookies
The essential, functional cookies are stored for the optimisation and needs-based design of our website.
Statistical cookies and cookies for marketing purposes are stored 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 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.
ee) Overview of the cookies we use
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.
Technical cookie for the load balancer
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 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.
Used to send data about the device and the visitor's behaviour to PIWIK.
30 minutes – 1 year
Session and permanent cookie
These cookies enable behavioural advertising and analysis of Facebook
These cookies enable behavioural advertising and analysis of Instagram.
These cookies enable behavioural advertising and analysis on the Google AdWords platform.
30 days–2 years
These cookies enable behavioural advertising and analysis of LinkedIn
These cookies enable behavioural advertising and analysis of Twitter.
These cookies collect information that is either used to track the interests of our customers' users and to help improve the experience on their websites or to help us understand how our products and services are used.
These cookies enable behavioural advertising and analysis within the context of email marketing and measuring the effectiveness of email advertising. Tracking is done anonymously until a user identifies him or herself by submitting a form.
f. Range analysis using Piwik
Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our website within the meaning of Art. 6 (1) (f) GDPR), we use Piwik, a software for the statistical evaluation of user access.
You can opt-out of 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.
Eloqua uses "cookies", which are text files placed on your computer, to help the website analyze how users utilize the site. 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 have not expressly consented to this use, our legal basis for this is our justified interest in optimizing our offers (Art. 6 Para. 1 S. 1 lit. f DS-GVO).
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.
E-mails sent with the help of Eloqua use tracking technologies. We use this information primarily to determine which topics are of interest to you by tracking whether our emails are opened and which links you click. We then use this information to improve the emails we send you and the services we provide, as well as to link them to existing tracking or profiling information. You will not be able to track emails if you have disabled image viewing by default in your email program. In this case, however, the newsletter will not be displayed in full and you may not be able to use all functions. If you display the images manually, the above tracking will take place.
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 subpage of our website. In addition, the data referred to in section 3 of this declaration will be transmitted, whereby in the case of Facebook and XING, according to the respective providers in Germany, 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.
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:
i) Integration of Google Map
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:
8. Which data protection rights do I have?
Every affected person has with respect to us
Each individual also has the right to complain to the Data Protection Commission at 21 Fitzwilliam Square South, Dublin 2, D02 RD28 (website: www.dataprotection.ie).
The rights set out above are in some circumstances limited under Data Protection Legislation. Where you exercise any of the rights above we will aim to respond to you within one month however where the request is complex this may be extended by a further period of two months.
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 legislation 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:
Information about your right of revocation according to Art. 21 GDPR
1. Case-specific right of objection
You have the right at any time,for reasons arising from your particular situation, to object to the processing of personal data relating to you, which takes place on the basis of Article 6 (1) (e) GDPR (data processing in the public interest) and Article 6 (1) (f) GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 (4) GDPR.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing serves the establishment, exercise or defence of legal claims.
2. Right to object to the processing of data for direct marketing purposes
In individual cases, we process your personal data in order to perform direct marketing. You have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
If you object to the processing for direct advertising purposes, your personal data will no longer be processed for such purposes.
You can exercise your right to object to this by sending a correspondingly worded letter to:
For GRENKE Limited:
Q House, Suite 306
Sandyford Business Park
For GC Factoring Ireland Limited:
Q House, Suite 508
Sandyford Business Park
Or by using the unsubscribe links in any email marketing communications we send to you.