1. Introduction

Kredo SA, whose registered office is at Avenue Charles-Ferdinand-Ramuz 60, 1009 Pully (hereinafter “Kredo SA”, “we”, “us”, “our”) provides credit brokerage services and, to this end, operates a credit brokerage platform (hereinafter: the “Platform”) accessible via the website www.kredo.swiss (hereinafter: the “Site”), which also offers content relating to Kredo SA’s services.

In order to provide our services and operate our Site, we collect, use and disclose certain personal data about you. When we talk about personal data, we are referring to personal data within the meaning of the Swiss Federal Act on Data Protection (FADP). This is any information that enables us to identify you immediately or by combining it with other information. In this respect, we are the party responsible for processing personal data.

This privacy policy (hereinafter referred to as the “Policy”) sets out the conditions under which we process data about you, as well as the choices available to you regarding the collection, use and disclosure of such personal data in accordance with the FADP.

By using our services and/or accessing the Site, you acknowledge that you have read, understood and agree to be bound by all the terms of this Policy.

2. Processing of personal data

2.1  Navigation on the Site

2.1.1 Data that may be processed

When you browse and interact with the Site, we collect data about your actions (e.g. which links were clicked, which pages were viewed), as well as other similar data and statistics (e.g. content response times, download errors, length of time spent on certain pages, type of browser used or location of connection). To collect this information, we use automated data collection technologies such as cookies or web beacons.

Cookies take the form of text files capable of identifying people browsing a site and storing their personal preferences (e.g. their choice of language) as well as technical information (e.g. click and clickstream data).
Web beacons, or clear GIFs, are very small transparent images (1 pixel by 1 pixel) integrated into a website. They enable us to collect information on the activity of visitors to the site, such as the operating system used, the browser used, the IP address and the time spent on the site.

To operate the Site, we may collaborate with third-party companies that place cookies or web beacons on the Site (notably Google Analytics). These companies help us manage the Site and offer additional products and services. The use of these technologies by these third parties is then subject to their own personal data processing conditions and is not covered by the Policy.
The various categories of cookies used on the Site are listed in our cookie manager, which can be consulted by clicking on the icon at the bottom left of your screen .

2.1.2 Purpose of processing

We use cookies and web beacons to provide the basic functions of the Site, to perform certain other features of the Site, to understand how visitors interact with the Site, to understand and analyze key performance indices of the Site in order to provide a better experience to visitors and to provide personalized advertising and analyze the effectiveness of advertising campaigns.

2.1.3 Choices concerning cookies

You can set your cookie preferences at any time using our cookie manager by clicking on the icon at the bottom left of your screen .

2.2 Creating an account

2.2.1 Data that may be processed

When you create an account on our Site in order to use the Platform, we ask you to provide a valid e-mail address and a password.

2.2.2 Purpose of processing

We use your e-mail address and password to provide you with an account, to identify you and to communicate with you.

2.3 Credit brokerage services

2.3.1 Data that may be processed

When you use our brokerage services to obtain credit for a business, we collect the following information about you:

  • Amount of loan requested ;
  • Desired loan term;
  • Company purpose and industry;
  • Intended use of the loan amount ;
  • Account details (bank and IBAN of main business account);
  • Details of company directors and beneficial owners:
  • First name and surname ;
  • Gender ;
  • Address ;
  • Telephone number ;
  • E-mail address ;
  • Date of birth ;
  • Nationality ;
  • Signature rights.

We also collect the following information about the company for which the credit is requested:

  • Company name, address and registered office;
  • Legal form ( public limited company, limited liability company or sole proprietorship) ;
  • Number of employees;
  • Company existence ;
  • Business sector;
  • Representative authority;
  • Company registration number;
  • Information on economic ownership, turnover, balance sheets and profit and loss account, all for the last two years;
  • Information on the company’s situation and shareholdings;
  • Information on board members.

2.3.2 Purpose of processing

We use the data referred to in section 2.3.1 for the purposes of :

  • check the solvency of the company for which the credit is requested ;
  • fulfill our legal and due diligence obligations, in particular by verifying the identity of individuals and their status (sanctions lists, politically exposed person status, blacklists or watchlists, etc.);
  • assess whether a credit recommendation can be made;
  • negotiate, monitor and manage the credit contract;
  • enable the conclusion and execution of the contract with the fund granting the credit.

3. Collection of personal data from third parties

When you provide us with personal data concerning a third party (for example, a director of the company for which credit is requested), you confirm and guarantee that you are acting in compliance with applicable law and that the person concerned has been informed in accordance with this Policy.

4. Communication of personal data

4.1 Subcontracting

We may have recourse to external service providers acting as subcontractors, in particular providers of administrative and IT services and solvency checks.

Personal data is only disclosed to subcontractors to the extent necessary to perform the tasks entrusted to them.

4.2 Disclosure to third parties

We may pass on your personal data to companies and organizations involved in granting credit, in particular Teylor AG, Kredo Debt Fund I, New Debt Sàrl and AIFM RSM Fund Management Luxembourg.

We may also pass on your data to other third parties (i) if this is necessary for the purposes for which you have voluntarily provided it to us (in particular identity or solvency checks), (ii) if you have given your prior consent or (iii) if we are permitted or obliged to do so by law (e.g. at the request of a judicial authority, to enforce our legal rights or to collect a debt with the help of a debt collection service).

4.3 Transfer abroad

Personal data is processed in Switzerland and in the following countries: Luxembourg, Germany and Belgium.

Where appropriate, data may also be transferred to other countries. In such cases, we will comply with the applicable rules and adopt the necessary measures prior to the transfer of personal data abroad.

5. Security and confidentiality of personal data

Although total security does not exist, state-of-the-art technical and organizational security measures have been put in place, taking into account the risks involved, to protect your personal data against accidental or intentional manipulation, loss, destruction, disclosure or unauthorized access.

6. Jurisdiction and applicable law

The Policy and all matters arising therefrom or in connection therewith, as well as the use of our Site or reliance on our services, are governed by Swiss law, to the exclusion of conflict of law rules.

You agree to submit to the exclusive jurisdiction of the courts of Lausanne, Switzerland.

7. Updating our policy

We may update this Policy from time to time without notice to you.

We will seek to bring any significant changes to your attention. If you have provided us with your e-mail address, you will be notified of the new Policy by e-mail. The new Policy will also be available on the Site.

Use of our services following a change to the Policy constitutes explicit acceptance of the changes, as does continued use of our Site.

8. Contact

If you have any questions about this Privacy Policy, you can contact us by sending an e-mail to sos@kredo.swiss or by writing to us at Avenue Charles-Ferdinand-Ramuz 60, 1009 Pully.