Privacy Policy

Athlon Germany GmbH ("Athlon", "we", "us", "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it, with whom we may share it, and the rights you have under applicable data protection law, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG).

1. Data Controller

The data controller responsible for your personal data is:

Athlon Germany GmbH
Am Seestern 24
40547 Düsseldorf
Deutschland
Telephone: +49 211 54017000
Email: support@athlon.ltd

2. Data Protection Officer

We have appointed a Data Protection Officer (Datenschutzbeauftragter) as required by Article 37 GDPR. You may contact our DPO at: datenschutz@athlon.ltd

3. What Personal Data We Collect

Depending on how you interact with us, we may process the following categories of personal data:

• Identity data: name, title, date of birth, passport or identity card details where required for credit assessment
• Contact data: postal address, email address, telephone number
• Professional data: employer name, job title, company registration details
• Financial data: bank account details, credit history (obtained via credit reference agencies), tax identification number
• Contract data: details of leasing or factoring agreements, payment history, vehicle or asset data
• Usage data: IP address, browser type, pages visited on our website, and timestamps, collected via cookies and similar technologies
• Communication data: records of correspondence, telephone calls (where consent is given and calls are recorded), and emails

4. Legal Bases for Processing

We process personal data only when we have a valid legal basis to do so under Article 6 GDPR:

• Contract performance (Art. 6(1)(b)): Processing necessary to enter into or perform a leasing or factoring contract with you or the organisation you represent.
• Legal obligation (Art. 6(1)(c)): Compliance with anti-money-laundering obligations (GwG), tax law (AO), and other applicable German and EU regulations.
• Legitimate interests (Art. 6(1)(f)): Fraud prevention, credit risk management, IT security, and direct marketing to existing clients (where no overriding interests apply).
• Consent (Art. 6(1)(a)): Where we rely on your consent, for example for optional marketing communications or the use of non-essential cookies. You may withdraw consent at any time.

5. How We Use Your Personal Data

• Processing and managing leasing and factoring applications and agreements
• Conducting creditworthiness assessments with the assistance of credit reference agencies
• Administering client accounts and processing payments
• Sending service communications, invoices, and contract-related notices
• Complying with anti-money-laundering and know-your-customer requirements
• Preventing fraud and managing operational risk
• Improving our website and services through aggregated analytics
• Responding to enquiries and providing client support

6. Sharing of Personal Data

We may share your personal data with:

• Credit reference agencies (e.g. SCHUFA Holding AG, Creditreform) for creditworthiness assessments
• Vehicle manufacturers and dealers where necessary to fulfil a leasing order
• Service providers acting as data processors on our behalf (e.g. cloud hosting providers, document management systems), bound by data processing agreements under Art. 28 GDPR
• Regulatory authorities (e.g. BaFin, tax authorities, law enforcement) where required by law
• Group companies within the Athlon corporate group for shared administrative and IT services

We do not sell personal data to third parties for marketing purposes.

7. International Transfers

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission or adequacy decisions applicable to the recipient country.

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy or as required by law. Key retention periods include:

• Contract documentation: 10 years following contract end (§§ 238, 257 HGB; § 147 AO)
• Correspondence related to contractual matters: 6 years
• Credit assessment records: 3 years following the last decision
• Website usage data: up to 26 months (aggregated analytics)

9. Your Rights

Under GDPR, you have the following rights in relation to your personal data:

• Access (Art. 15): Request a copy of the personal data we hold about you
• Rectification (Art. 16): Request correction of inaccurate data
• Erasure (Art. 17): Request deletion of your data where no longer necessary
• Restriction (Art. 18): Request that we restrict processing in certain circumstances
• Portability (Art. 20): Receive your data in a structured, machine-readable format
• Objection (Art. 21): Object to processing based on legitimate interests
• Withdrawal of consent: Where processing is based on consent, withdraw it at any time without affecting prior lawful processing

To exercise any of these rights, please contact us at datenschutz@athlon.ltd. We will respond within one month of receiving your request.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. In Germany, the competent authority for Athlon Germany GmbH is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2–4
40213 Düsseldorf
Website: www.ldi.nrw.de

11. Website Analytics and Cookies

Our website uses cookies and similar technologies. For detailed information on the cookies we use, the data they collect, and how to manage your preferences, please see our Cookie Policy.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law or our practices. The updated version will be published on this page with a revised effective date. For significant changes, we will provide more prominent notice.