Privacy policy

1. Transparency Matters to Us

This privacy policy explains what we do with your data, why we do it, and with which tools and partners. We believe in full transparency: no hidden practices, no surprises.

Here is a short summary of what you should know:

• We are a lead platform for financial products (in particular personal loans). We receive your inquiry and forward it, under an exclusive partnership, to AS Finanz GmbH, which, as an authorized credit broker, carries out the actual brokering to banks and other providers.
• We actively work with your data: we qualify inquiries, build profiles, enrich data with additional information, and run marketing across multiple channels – so that we can serve you better and matching offers can be brokered.
• To do this we use modern tools, including artificial intelligence, as well as services from large providers such as Google, Microsoft, and Meta (WhatsApp Business).
• We store your customer data in a database with a server location in Switzerland; individual services, however, also process data abroad (details in sections 8 and 9).
• You have comprehensive rights (access, deletion, objection, etc., section 13) and can unsubscribe from advertising at any time.

This privacy policy applies to our website, all landing pages and forms, our apps, and all digital and telephone touchpoints. It is governed by the Swiss Federal Act on Data Protection (FADP). For individuals in the European Economic Area, the EU General Data Protection Regulation (GDPR) may additionally apply.

2. Controller

Data protection contact: privacy@privatkredit.ch

privatkredit.ch AG is the controller for the data processing described on this platform. AS Finanz GmbH, Badenerstrasse 676, CH-8048 Zürich (our exclusive brokering partner, hereinafter the "Broker"), processes your data after forwarding as an independent controller under its own privacy policy (available at asfinanz.ch). To the extent that we and the Broker jointly determine the purposes and means of processing, we have contractually regulated the respective responsibilities; the single point of contact for all data protection matters relating to the platform is privatkredit.ch AG at privacy@privatkredit.ch.

This privacy policy is primarily governed by the Swiss Federal Act on Data Protection (FADP). To the extent that we provide services to individuals resident in the EU/EEA (e.g., cross-border commuters working in Switzerland), the GDPR may additionally apply.

3. What We Do (Our Business Model)

So that you can put our data processing into context, here is an open account of our business:

• Lead generation and qualification: We obtain inquiries through our website, landing pages, online advertising, and partners, and review and qualify them.
• Forwarding to the Broker: We forward qualified inquiries exclusively to AS Finanz GmbH. The Broker carries out the actual brokering: it connects customers with banks, credit institutions, and other providers. To the extent that we hold our own authorization to broker consumer credit, we act exclusively as a sub-broker of the Broker; operational processing is, even in that case, carried out by the Broker.
• Data enrichment: We supplement and update your information with data from additional sources (e.g., credit reporting agencies, public registers, publicly accessible sources, partners) in order to correctly assess inquiries and enable matching offers to be brokered.
• Marketing: We run multi-channel marketing – by phone, email/newsletter, SMS, WhatsApp and other messengers, social media, and online advertising.
• Platform development: We continuously develop and operate our digital platforms and analyze their use.

If successful, the Broker receives a commission from the provider; we are compensated by the Broker for referring inquiries and for any sub-brokering.

4. What Data We Process

Master data: name, first name, date of birth, gender, nationality, residence status, marital status, address, phone numbers, email address.

Financial and application data: income, expenses (e.g., rent, health insurance, alimony), employer and employment relationship, existing loans and leases, desired loan amount and term, creditworthiness information, information from submitted documents (e.g., salary statements, copies of identity documents).

Communication data: email, chat, and messenger histories (including WhatsApp), phone notes and – with prior notice – call recordings, your communication and advertising preferences.

Technical data: IP address, device and browser information, cookies and similar identifiers, date/time and duration of use, pages visited, referring page (referrer), approximate location.

Profile and preference data: interests and needs, product-interest scores, segmentations, assessments of financial situation, results of our qualification and enrichment processes.

Data sources: directly from you (forms, conversations, documents); automatically via our website and apps; from the Broker (e.g., processing status, outcome of brokering); from credit reporting agencies and creditworthiness checkers; from the providers contacted (e.g., outcome of the application review); from partners and referrals; from public registers and publicly accessible sources (including the internet and social media).

Please share third-party data (e.g., a household partner) with us only if you have previously informed the individual concerned about this privacy policy.

5. Purposes

• Receiving, qualifying, and forwarding your inquiry: initial review, selection, and transmission to the Broker for brokering to suitable providers, support through to contract conclusion.
• Customer profiling and data enrichment: to understand your needs and match you with suitable products and providers.
• Marketing and personalized communication: advertising of our own offers and partner offers, by post, phone, email, SMS, WhatsApp/messenger, and online channels; formation of target audiences (including for online advertising, e.g., custom audiences). You can unsubscribe from advertising at any time (section 13).
• Analysis and improvement: evaluation of the use of our platforms, market and product development, quality assurance, and training.
• Legal purposes: fulfillment of statutory obligations (e.g., retention, anti-money-laundering and fraud prevention, CCA requirements applicable to providers), assertion and defense of legal claims.
• Security: IT security, prevention of misuse and fraud.

6. Use of Artificial Intelligence

We use AI, and we disclose this openly:

• Inquiry qualification: AI systems support us in categorizing, prioritizing, and pre-screening inquiries.
• Document processing: automated reading and review of submitted documents.
• Data enrichment and quality assurance: matching, supplementing, and plausibility-checking of data.
• Communication: AI-assisted chat assistants and drafting of responses and marketing content; our staff remain responsible.

AI features are now integrated into nearly all professional software products. We therefore use dedicated AI services on the one hand, and AI features included in our standard tools on the other. Currently these include in particular: Anthropic (Claude; https://www.anthropic.com/privacy), OpenAI (ChatGPT; https://openai.com/privacy), Google (Gemini in Google Workspace; https://policies.google.com/privacy), Microsoft (Copilot in Microsoft 365; https://privacy.microsoft.com), Meta AI (in WhatsApp; https://www.facebook.com/privacy/policy), as well as AI features in our marketing and communication tools (e.g., Brevo). We may also use AI-assisted voice and telephony assistants; in such calls, we will notify you accordingly. This list may change as the tools we use evolve; the providers' respective current privacy notices govern.

Where available, we use business versions with data processing agreements; under their terms, your data is not used to train the AI models. Neither we nor the Broker make credit decisions; these are made by the respective financing institution under its own review process. See section 11 regarding profiling and automated individual decisions.

7. Who We Share Data With

• AS Finanz GmbH (Broker): To process and broker your inquiry, we transmit your application data and documents to AS Finanz GmbH, Badenerstrasse 676, CH-8048 Zürich, our exclusive brokering partner. The Broker processes your data as an independent controller under its own privacy policy (asfinanz.ch) and exchanges information with us on the status and outcome of processing (e.g., for your support and for billing).
• Banks and credit institutions / providers: The Broker transmits your application data and documents – directly, or indirectly as a sub-broker via cooperation partners (e.g., comparison and brokering platforms) – to one or more suitable financing institutions, in particular Cembra Money Bank AG, BANK-now AG, Cornèr Banca SA, and other financial institutions or providers. These are subject to Swiss banking client confidentiality or their own confidentiality obligations and their own privacy policies. Within the scope of the authorization you have granted (see Terms of Use, section 5), the providers exchange data with the Broker and with reporting agencies; for this purpose, you have released the providers from banking client confidentiality.
• ZEK / IKO / credit reporting agencies: The providers report application and contract data to the Central Office for Credit Information (ZEK, www.zek.ch) and the Consumer Credit Information Office (IKO, www.iko.ch). We, the Broker, and the providers may obtain creditworthiness reports from credit reporting agencies (e.g., CRIF, Intrum).
• Partner companies: companies with a direct or indirect connection to credit products, provided a legitimate interest exists.
• Service providers (processors): hosting, databases, communication, marketing, analytics, and AI services (details in section 8), customer service and call center providers, debt collection, advisory services (lawyers, fiduciaries) – domestically and abroad (see section 9).
• Authorities: where we are legally required to do so.

All processors are contractually bound to confidentiality and to compliance with data protection requirements (data processing agreements).

8. Services and Tools We Use

We disclose which categories of services we use and where your data is processed in the process:

Hosting and infrastructure

• Customer database: your core customer data (application, financial, and communication data) is stored in a data center with a server location in Switzerland (Zürich region).
• Website and applications: we operate our website and web applications with specialized cloud providers. When the website is delivered via a global content delivery network, technical data (including IP address, log data) may also be processed in the USA. Data processing agreements and appropriate safeguards are in place with all infrastructure providers (section 9).

Communication

• WhatsApp Business (Meta Platforms Ireland Ltd., Ireland / Meta Platforms Inc., USA): customer communication via WhatsApp, where you contact us via WhatsApp or consent to this channel. In this process, metadata (e.g., phone number, timestamp) is also processed by Meta in the USA. Details: www.whatsapp.com/legal.
• Google Workspace (Google Ireland Ltd., Ireland / Google LLC, USA): email and collaboration, including integrated AI features (Gemini).
• Microsoft 365 / Outlook (Microsoft Ireland Operations Ltd., Ireland / Microsoft Corp., USA): email and office applications, including integrated AI features (Copilot).
• Brevo (Brevo GmbH / Sendinblue SAS, Germany/France, EU): newsletter and email marketing, including AI features. Every newsletter includes an unsubscribe link.
• NFON (NFON AG, Germany, EU): cloud telephony, including possible call recording with prior notice.

Marketing and analytics

• Google (Google Ireland Ltd., Ireland / Google LLC, USA): Google Analytics (usage analysis), Google Ads including conversion tracking and remarketing, Google Tag Manager. Used only with your consent via the cookie banner. Objection/settings: https://adssettings.google.com.
• Meta (Facebook/Instagram): Meta Pixel and custom audiences for online advertising, only with consent.
• TikTok (TikTok Technology Ltd., Ireland): pixel and advertising campaigns, only with consent.
• Snapchat (Snap Group Ltd., UK / Snap Inc., USA): pixel and advertising campaigns, only with consent.
• Microsoft Advertising / Bing (Microsoft Ireland Operations Ltd., Ireland / Microsoft Corp., USA): conversion tracking and advertising campaigns, only with consent.
• We may use comparable advertising and analytics platforms from other providers; the current listing in our cookie banner (section 10) governs.

Artificial intelligence

• AI services and AI features integrated into tools as described in section 6.

9. Disclosure Abroad

We store your core customer data in Switzerland (section 8). The service providers we engage are generally located in Switzerland, the EU/EEA, or the USA, but may in principle be based anywhere in the world.

For countries without an adequate level of data protection (from a Swiss perspective), we base the transfer on appropriate safeguards, in particular the Standard Contractual Clauses (SCC) approved by the EU Commission and adapted to Swiss law, or on adequacy decisions (e.g., the Swiss-U.S. Data Privacy Framework for certified US providers).

10. Cookies and Tracking

We use cookies and similar technologies:

• Necessary cookies: for basic functions and security (always active).
• Analytics cookies: to understand how our website is used.
• Marketing cookies: to make advertising more relevant and to measure campaign performance.
• Preference cookies: to save settings such as language.

We use non-necessary cookies only with your consent via our cookie banner (consent management: Usercentrics). The complete list of all cookies and services used, and your settings, can be found at any time at privatkredit.ch/cookies. You can adjust or withdraw your consent there at any time, and you can delete or block cookies in your browser.

11. Profiling and Automated Individual Decisions

We evaluate your data on a partially automated basis to build profiles of your needs, financial situation, and interests ("profiling"). We use these profiles to qualify your inquiry, forward it to the Broker, and for personalized marketing.

Decisions that entail legal effects for you or significantly affect you (in particular the credit decision) are not made solely on an automated basis by us. The credit decision is made by the respective provider under its own procedure (including the statutory creditworthiness assessment under the CCA). Should we exceptionally make an automated individual decision within the meaning of Art. 21 FADP, we will inform you of this, and you may request that the decision be reviewed by a human.

12. Retention

We retain personal data only for as long as necessary for the purpose or as required by statutory obligations:

After this, data is deleted or anonymized unless a statutory basis requires longer retention.

13. Your Rights

Under the FADP – and, where applicable, the GDPR – you have the following rights:

• Access to the data we process about you (Art. 25 FADP / Art. 15 GDPR)
• Rectification of inaccurate data (Art. 32 FADP / Art. 16 GDPR)
• Deletion under certain conditions (Art. 32 FADP / Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability in a common format (Art. 28 FADP / Art. 20 GDPR)
• Objection to processing, in particular to direct marketing – you can unsubscribe from advertising at any time and free of charge (unsubscribe link in every newsletter, "STOP" via WhatsApp/SMS, or notice to us)
• Withdrawal of consent given, with effect for the future

To exercise these rights, an email to privacy@privatkredit.ch is sufficient; we may request proof of identity and generally respond within 30 days. If your request concerns data processing by the Broker (AS Finanz GmbH) or a financing institution, we will forward your request on request or provide you with the responsible point of contact.

Supervisory authority: you may contact the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Bern, www.edoeb.admin.ch. Individuals in the EEA may additionally contact their national data protection authority.

14. Data Security

We protect your data through technical and organizational measures, including: encryption of transmission (TLS) and of stored data, access controls with multi-factor authentication, permissions based on the need-to-know principle, logging, regular backups, security updates, and contractual obligations and training for our staff and service providers.

15. Changes

We may amend this privacy policy at any time. The version published on the website at any given time applies. In the event of material changes, we will inform registered users proactively where possible.

privatkredit.ch AG · Roosstrasse 53 · CH-8832 Wollerau · privacy@privatkredit.ch