Privacy Statement of Miro Kredit AG

Version from 15.03.2024

In this privacy policy, we, Miro Kredit AG (hereinafter referred to as Miro Kredit, we, or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; other data protection declarations or general terms and conditions, conditions of participation, and similar documents may govern specific matters. Personal data refers to all information relating to an identified or identifiable person. If you provide us with personal data of other persons (e.g. family members, data of work colleagues), please ensure that these persons are aware of this privacy policy and only provide us with their personal data if you are permitted to do so and if this personal data is correct. This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DSG”), and the revised Swiss Data Protection Act (“revDSG”). However, whether and to what extent these laws are applicable depends on the individual case.

1. Responsible person/data protection officer/representative

Miro Kredit AG, Solothurnerstrasse 72, 4053 Basel, is responsible for the data processing described here unless otherwise stated in individual cases. If you have any data protection concerns, you can send them to us at the following contact address: Our representative in the EEA according to Art. 27 GDPR (if required) is: Miro Kredit AG 061 520 00 10

2. Collection and processing of personal data

We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other persons involved or that we collect from their users when operating our websites, apps, and other applications. Where permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, internet) or receive such data from other companies, authorities, and other third parties (e.g. credit agencies, address dealers). In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we obtain in connection with official and legal proceedings, information in connection with your professional functions and activities (so that we can, for example, to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, full addresses, etc.). references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as the fight against money laundering and export restrictions, information from banks, insurance companies, sales, and other contractual partners of ours on the use or provision of services by you (e.g. payments made, purchases made)), information from the media and Internet about your person (insofar as this is appropriate in the specific case, e.g. in the context of a job application, press releases, etc.).e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

3. Purposes of data processing and legal basis

We use the personal data we collect primarily to conclude and process contracts with our customers and business partners, as well as to facilitate the conclusion of contracts between our customers and business partners (e.g. financial institutions) as part of our financing solutions brokerage service and to comply with our legal obligations in Switzerland and abroad. If you work for such a client or business partner, your personal data may of course also be affected by this function.
In addition, our financing partners and we process the personal data of you and other persons, to the extent permitted and deemed appropriate, also for the following purposes in which we, our financing partners (and sometimes also third parties) have a legitimate interest corresponding to the purpose:

  • Credit checks to make decisions on financing requests and submit a customized financing offer (in particular also reporting credit applications and obtaining creditworthiness data from the Central Office for Credit Information (ZEK)).
  • Risk management (e.g. calculation of business-relevant credit and market risks)
  • Handling of business processes
  • Services during the term of contracts (e.g. application and contract processing, debt collection, communication with customers)
  • Offer and further develop our products, services and websites, and other platforms on which we are present;
  • Communication with third parties and processing their requests;
  • Examination and optimization of procedures for needs analysis for direct customer contact and collection of personal data from publicly accessible sources for customer acquisition;
  • Advertising and marketing (including the organization of events), provided you have not objected to the use of your data (if we send you advertising from us as an existing customer, you can object to this at any time and we will put you on a blacklist against further advertising mailings).
    We cannot accept any responsibility for the advertising and marketing activities of our partner companies. If you do not wish to receive advertising from these partner companies, you should contact them directly.
  • Market and opinion research, media monitoring;
  • Assertion of legal claims and defense in connection with legal disputes and official proceedings;
  • Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations and data analysis to combat fraud);
  • Ensuring our operations, in particular IT (e.g. IT security and system control), our websites, and other platforms;
  • Video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
  • Purchase and sale of business divisions, companies, or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations and internal regulations of Miro Kredit AG.

If you have given us your consent to process your personal data for specific purposes (e.g. when ordering one of our products or services, registering to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been given can be withdrawn at any time, but this has no effect on data processing that has already taken place.

4. Handling applicant data

At Miro Kredit AG, we attach great importance to the protection and confidential treatment of your personal data. This section of our privacy policy deals specifically with the handling of applicants’ data. We process the data that you provide to us as part of the application process, as well as data that is publicly accessible or can be obtained from third parties. In particular, this includes your contact and master data, CV, diplomas, and references.
Your personal data will be processed exclusively for the application process and the filling of vacancies. We take appropriate security measures to protect your data from unauthorized access and misuse. Your data may be passed on within Miro Kredit AG for the aforementioned purposes. Service providers acting on our behalf are carefully selected and are bound by our data protection standards. Your data may be processed worldwide. We ensure that an appropriate level of data protection is maintained. Application documents that are not considered will be deleted after six months. If consent is given for storage for future job advertisements, the data will be stored for five years.

5. Cookies/tracking and other technologies in connection with the use of our website

We typically use “cookies” and similar technologies on our websites and apps to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website or install our app. This enables us to recognize you when you return to this website or use our app, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after you visit the website (“session cookies”), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) (“permanent cookies”). However, you can set your browser so that it rejects cookies, only stores them for one session, or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g. language, autologin), so that we can better understand how you use our offers and content, and so that we can show you offers and advertising tailored to you (which can also happen on websites of other companies; however, we will not tell them who you are, if we know this at all, because they will only see that the same user is on their website which was also on a certain page on our website). Some of the cookies are set by us, some are also set by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart, and ordering processes) may no longer work. In some of our newsletters and other marketing e-mails, we also include visible and invisible image elements, where permitted, which we can retrieve from our servers to determine whether and when you have opened the e-mail so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are pre-set to do this. By using our websites, and apps and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, you must set your browser or email program accordingly, or uninstall the app if this cannot be adjusted via the settings.
We use Google Analytics on our website, an analytics service provided by Google LLC (Mountain View, USA) and Google Ireland Ltd (Dublin, Ireland). Google collects certain information about the behavior of users on the website and about the end device used. The IP addresses of visitors are shortened in Europe before being forwarded to the USA. Google provides us with evaluations based on the recorded data but also processes certain data for its own purposes. You can find information on Google Analytics data protection here, and if you have a Google account yourself, you can find more information here.
We also use the Facebook Pixel from Facebook, Dublin, Ireland. We use this technology to display advertisements on Facebook and with partners cooperating with Facebook if they have shown an interest in us. It also allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad. We are jointly responsible with Facebook for displaying advertising information that matches users’ interests, improving ad delivery, and personalizing features and content (but not further processing). We have therefore concluded a corresponding additional agreement with Facebook. Users can therefore address requests for information and other data subject requests in connection with joint responsibility directly to Facebook. We can also transmit user data such as email addresses to Facebook for the purpose of advertising on Facebook. Facebook compares this with the corresponding details of its members in order to be able to display targeted advertising to our users (“Custom Audiences”). You can object to this comparison at any time.

6. Data transfer and data transmission abroad

We and our financing partners may also disclose data to third parties as part of our business activities and for the purposes set out in section 3, insofar as this is permitted and appears appropriate to us, either because they process it for us or our financing partners or because they wish to use it for their own purposes. This applies in particular to the following bodies:
⎯ Service providers and financing partners of ours (e.g. banks, insurance companies), including contract processors (e.g. IT providers and our service provider Perimex d.o.o. in Serbia);
⎯ Dealers, suppliers, subcontractors, and other business partners;
⎯ Customers;
⎯ domestic and foreign authorities, official bodies, or courts;
⎯ Media;
⎯ the public, including visitors to websites and social media;
⎯ Competitors, industry organizations, associations, organizations, and other bodies;
⎯ Acquirers or parties interested in acquiring business divisions, companies, or other parts of Miro Kredit AG;
⎯ other parties in potential or actual legal proceedings;
⎯ Other companies of Miro Kredit AG;
all recipients together.
Some of these recipients are in Germany, but they can be anywhere in the world. In particular, you must expect your data to be transferred to all countries in which Miro Kredit AG is represented by group companies, branches or other offices, as well as to other countries in Europe and the USA where the service providers we use are located (e.g. Microsoft, SAP, Amazon,
If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection (we use the revised standard contractual clauses of the European Commission, which are available here), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have given your consent, or if the data in question has been made generally accessible by you and you have not objected to its processing.

7. Duration of storage of personal data

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, execution to the termination of a contract) as well as beyond that in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

8. Data security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, and checks.

9. Electronic communication

Electronic means of communication are used in the communication between you, us, our financing partners, and other third parties. Data is also transmitted via the Internet. As the Internet is an open network accessible to everyone, Miro Kredit AG, its financing partners, and other third parties cannot guarantee the confidentiality of data transmitted via the Internet. It is therefore possible for third parties to draw conclusions about an existing or forthcoming business relationship (possibly a banking relationship) between you and one of our partners.

10. Obligation to provide personal data

As part of our business relationship, you must provide the personal data that is necessary for the establishment and execution of a business relationship and the fulfillment of the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or execute a contract with you (or the entity or person you represent). The website can also not be used if certain information to secure data traffic (such as IP address) is not disclosed.

11. Profiling and automated decision-making

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research. As a matter of principle, we do not use fully automated decision-making (as regulated in Art. 22 GDPR) to establish and conduct the business relationship or otherwise. Should we use such procedures in individual cases, we will inform you of this separately if this is required by law and inform you of the associated rights.

12. Rights of the data subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to object to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising, and other legitimate interests in processing, as well as to the disclosure of certain personal data for the purpose of transfer to another body (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example, if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in para. 3 above. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated. The exercise of such rights generally requires that you provide clear proof of your identity (e.g. by means of a copy of your ID where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1 Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (

13. Changes

We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.