Maintaining the privacy of your data is a top priority at CrossLend. CrossLend considers it essential to establish high standards of data privacy protection for all users of the CrossLend Platform and to continually improve these standards. We therefore adhere and comply with the applicable statutory requirements of the Federal Republic of Germany and the European Union in all data processing procedures. One of our main concerns in this regard, is allowing you to determine to what extent CrossLend processes your data and to decide the way in which you will share your personal data with us.
In order to provide you with our services, it is necessary for us to collect, process and use your personal data as specified below.
Personal data shall mean any information concerning the personal or material circumstances of an identified or identifiable natural person. This includes, in particular, information which can be traced back to your identity, such as your name, telephone number, mailing address or email address. Statistical data collected when users visit our website and which cannot be directly linked to your identity is, for instance, not considered/classified as personal data.
Maintaining the privacy of your data is one of our top priorities. Therefore, we strictly adhere to the statutory provisions when collecting, processing and using your personal data. We collect, store and process your data for the purposes of offering you a better user experience on our website, and in order to provide you with technical services, such as the administration of loans or investment in Notes. We may additionally use your data for the purpose of keeping you informed via engaging, relevant newsletters which you may opt to receive, for our own marketing purposes, and for fraud prevention. We also collect, process and use your personal data for purposes of verifying your identity.
If you visit our website (the “CrossLend Platform”) without registering, we will only collect the information necessary to display the website you have requested. If you wish to access CrossLend’s Platform as a registered user, you will be asked to provide the following information:
This personal data is stored in order to set up your user account and enable you to gain access to the CrossLend Platform. You agree to treat your log in information as confidential and not to share this information with unauthorised third parties. You may alter your log in details at any time in your user profile.
For these purposes, CrossLend collects basic data and loan application data as well as data for the assessment of your creditworthiness, both from you, as well as on your behalf, from publicly accessible sources and other sources, which you make available to CrossLend for these purposes. For the preparation, application, performance and termination of loans, CrossLend will, on your behalf, and within the scope of the technical services of the CrossLend Platform:
For these purposes, CrossLend collects basic data and subscription application data about you. For the purposes of allowing the subscription of securities and access to the cash and securities account, CrossLend will, on your behalf, within the scope of the technical services of the CrossLend Platform:
Obliged entities under German Anti Money Laundering legislation (e.g. credit institutions) and under comparable national regulations are required to obtain information about the identity and address of their customers. This process contributes to prevent the misuse of their services for unlawful activities such as identity theft, identity fraud or money laundering. Verifying the identity of a customer (or “knowing your customer” –“KYC”) is a legal requirement and an essential aspect of risk management practices.
Part of the process of a borrower’s or investor's identity verification is performed by CrossLend on behalf of the credit entity granting the loans to borrowers and providing the cash and security accounts to investors. CrossLend uses a video transmission system which enables simultaneous verbal contact between a Crosslend’s trained operator and the person whose identity is being identified. This procedure has been considered by the German Federal Ministry of Finance as establishing “personal presence” for purposes of verifying identities, thereby overcoming the higher risk presented by the nonphysical presence of such person being verified. Still, other identity verification methods may also be used. The information regarding the verification of your bank account will also be used as part of your identity verification process, if so required by applicable law.
To protect your privacy, the video session will not start until you have expressly agreed to its recording. If you consent to the recording, you will start a video session with a CrossLend’s trained operator that will guide you through the identity verification process.
The process requires the collection of your personal data and biometric information, including screenshots of your face and identity document (front and reverse), and the comparison thereof with the information previously provided by you.
After finalizing the video session, CrossLend creates a report evidencing the results thereof. Both the report, the data collected during the video session and the audio recording of the video session will be transmitted to the referred credit institution.
Please bear in mind that the verification process requires the recording of the video session. Accordingly, the images in front of your video recording device and the sounds in range of your audio recording device will be recorded. Please make sure that no unwanted images or sounds are recorded and that no persons except for yourself appear in front of the recording devices.
To complete the identity verification process, you will also be required to electronically enter a valid sequence of numbers (TAN) previously sent to you either by SMS or email to the respective mobile phone number or email address provided by you.
In addition to processing your data to enable registration and application for a loan or to process an investment, we will use your data to send you information via email, SMS or letter about products, services and marketing campaigns that may be of interest to you. You may partially or fully opt out of the use of your personal data for marketing purposes at any time without incurring any costs other than the transmission costs at standard rates. Sending a written message to our postal or email address, indicated in section 1 above, is sufficient for this purpose.
You may register for our newsletter, regardless of whether you register as a user of the Platform or not. We use MailChimp, an email service provided by MailChimp, 512 Means Street, Suite 404, Atlanta, GA 30318, USA, to deliver our newsletter. We gather statistics on email openings and clicks, using industry-standard technologies – for example web beacons – to help us monitor and make our newsletter more interesting for our subscribers. You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of the newsletter. You can also send written messages to our postal or email address, indicated in section 1, to update your email address or to unsubscribe from the newsletter. For more information about MailChimp please visit: http://mailchimp.com/legal/privacy/.
In order to complete your registration as user of the Platform and keep you updated with the status of your loan application or investment, we will communicate with you via email, SMS or letter, using the addresses and phone number provided. Users are hereby expressly informed that, in principle, the possibility of unauthorised third parties being able to view, read, manipulate and/or delete electronically transmitted data cannot be excluded.
To improve our services, we will also use your data for general market and opinion research. We will, of course, use your data only for statistical purposes and in an anonymised form. Your responses to survey questions will not be published or disclosed to third parties without your consent. We will not store your responses to our surveys in combination with your email address or other personal data.
You may partially or fully opt out of your data being used for market and opinion research at any time by sending a written message to our postal address or email address, indicated in section 1 above. All survey emails automatically include a link to unsubscribe from further mailings.
With your consent, we will also process and use your data for statistical research. You will be asked to consent as follows: “I want to support CrossLend GmbH ("CrossLend") to further improve its product offering with statistical research and hereby agree that CrossLend may process and use my data to that end. CrossLend may pseudonymise my data, including the data used for risk assessment and loan management purposes, and transfer such pseudonymised data to a trusted third party within the European Economic Area to carry out statistical research. Without my consent, CrossLend will only use anonymised data for statistical research.”
Most cookies used by us are automatically deleted from your hard drive once you end your browser session (hence session cookies). Once you log in to the site using your user name and password, CrossLend uses session cookies, which allow us to identify you on the website. Session cookies automatically expire at the end of your session.
No personal data is stored in the cookies used. Therefore, the cookies used by us cannot be traced back to any specific person and, accordingly, cannot be linked to you. Cookies are assigned unique identifiers when they are activated. It is impossible to link your personal data to these identifiers, and this is never done. Your name, IP address and similar data by which a cookie could be linked to you are not stored. Cookies provide us with merely anonymised and pseudonymised information, on topics such as which sites you have visited.
You can change your browser settings to prevent cookies from being accepted, unless you have approved them. In most cases, the help function in the menu bar of your web browser will explain how to reject new cookies and how to disable cookies you have already received. We recommend always logging out fully after you have used a computer which has multiple users and is set up to accept cookies.
In order to provide you with interesting and customised offers, this website uses interest-based online advertising. For this purpose, we use so-called retargeting technology that is based on cookies. This allows us to address visitors to our platform who showed interest in our products on websites of our partners. We will only collect anonymised and pseudonymised data and will not merge usage profiles with personal data. In the event that you should not wish to receive interest-based advertising, you may prevent this by selecting the respective settings under the hyperlink http://preferences-mgr.truste.com/
This site offers an opt-out mechanism for internet-based advertising in a bundled way. The website of TRUSTe, Inc, 835 Market Street, San Francisco, CA 94103-1905, USA ("TRUSTe") allows you to either deactivate all advertisements across-the-board, or alternatively, block individual advertisement providers. Please note that after deletion of all of your browser’s cookies or usage of another browser at a later stage, the opt-out cookie must be reset.
For more information about interest-based advertising and opt-out options, please visit www.truste.com/consumer-privacy/about-oba/.
Google will use the gathered information for the purpose of evaluating your use of the website and compiling reports on website activity. The IP address transmitted by your browser will not be combined with other data held by Google. Google may only transfer this information to third parties, where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your data with any other data held by Google.
For more information about Google Analytics please visit: https://support.google.com/analytics/answer/6004245?hl
Please note that the subsequently created opt-out cookie will be deleted if you delete your browser’s cookies and will not automatically be activated on other browsers or devices.
For more information about Piwik, please visit: http://piwik.org/privacy/
Each time you access CrossLend’s platform, your web browser sends us information, which is then stored in server log files. The stored files contain the following information:
We will analyse such log files data in anonymised form, in order to continually improve our services and make them more user-friendly, to identify and correct errors more quickly and to manage server capacity. We will analyse such log files in an unanonymised form only to prevent fraudulent use of our platform.
You should never provide third parties with your password for accessing our website and you should change this password regularly. Every time you leave CrossLend’s website, you should log out and close your browser window to prevent unauthorised users from accessing to your CrossLend user account.
As set forth in the German Federal Data Protection Act (Bundesdatenschutzgesetz, "BDSG"), you are entitled to receive information about your stored data free of charge, as well as to rectify, block and delete your data.