Privacy Statement

1. General; Responsible Body As of: May 2018

This data protection statement informs you about the processing of your personal data when using the website (the „Website“).

The body responsible, as defined by the EU-General Data Protection Regulation (EU-GDPR) and other national data protection regulations within the scope of using the website, is creditPass Co.Ltd. (from here on: creditPass), Mehlbeerenstr. 2, 82024 Taufkirchen b.München, Germany, email:, telephone: +49 (=) 89 – 273747-210, Fax: +49 – 273747-250 („creditPass“, „we“, „us“). Further information is available in the masthead.

We take the protection of your personal data very seriously. We deal with your personal data confidentially and according to data protection legislation as well as this data protection statement.

In the following, we inform you which data we collect within the scope of using of our website, to what purpose and how we use this data, and what constitutes your rights.

Please note that the website may offer links to other providers where we have no influence and this data protection statement is not valid.

In so far as we also act on your behalf as a service provider, independent of website use, the appropriate data protection information within the framework of the respective contract agreements is valid.


2. Processing your Data

Basically, we collect and use your personal data only to the extent that is necessary to set up a functioning website, as well as our content and services.


a) Visiting the Website:

aa) As is usual with most websites, our system, with every visit, collects data and information from the system of the visiting computer and stores this temporarily in a “logfile”.

The following data in particular is among the data stored in this manner:

  • IP-address of the visiting computer
  • Name and URL of the data file accessed
  • Date and time of access
  • Time zone difference from Greenwich Mean Time (GMT)
  • Access status/HTTP- status code
  • Actual data volume transmitted
  • Identification data of the browser in use including language and version of browser software, operating system and interface of the visiting computer
  • URL of the referring website, if accessed by a link, and in addition a search term if accessed by a search engine
  • Name of your internet access provider


bb) We are unable to relate the data to any particular person. Also, personalised user profiles will not be generated. Data processing takes place only for the purpose of enabling website use (dial up), for internal system related purposes (technical administration, system security), and for statistical purposes, such as the anonymous evaluation of website user behaviour to better adapt the website to your requirements. Logfiles are stored in order to secure optimal functioning of the website. In addition, the data serves to optimise the website and to safeguard the security of our information technology systems. Evaluation of data in this context is not used for marketing purposes.

If data processing in the course of visiting the website concerns personal data, the processing of this data is based on Art. 6 (1) p.1 lit. f EU-GDPR. This purpose defines our legitimate interest.


b) Contact via Email or Contact Form

aa) A contact form is available on the website which can be used for electronic contact. If you wish to make a query in this manner, the data entered in the input mask will be sent to us and stored. This data is:

  • Firm
  • Name
  • Email address
  • Telephone
  • Type of service and use
  • Content of message

At the point of sending the message, the following data will be saved:

  • Date and time of query

Alternatively, you can make contact with the email address supplied. In this case, the personal data supplied in the user’s email will be stored.

Data will only be used for the purpose of processing the queries made and serve to avoid misuse of the contact form and to safeguard the security of our information technology systems.

The legal basis for the processing of this personal data is Art. 6 (1) p 1 lit. f EU-GDPR (legitimate interests). Legitimate interest here lies in the fact that we can implement the user’s wishes (e.g. answering queries) only through an appropriate processing of the user’s data. If the aim of the contact is to close a contract, the additional legal basis for processing is Art. 6 par. (1) lit. b EU-GDPR.


c) Newsletter

aa) You can subscribe to a newsletter free of cost on our website. Your email address will be sent when registering for the newsletter. Accessing the user’s email address allows the delivery of the newsletter. Data will be stored only as long as the newsletter subscription is active and will then be deleted. You can cancel the subscription at any time. To this purpose, an appropriate link is to be found in each newsletter.

bb) The user’s consent provides the legal basis for processing data after the user’s registration for the newsletter, Art. 6 (1) lit. a EU-GDPR. The legal basis for sending the newsletter due to the product offer is § 7 (3) German Fair Trade Practices Act


d) Disclosure to a third party

Personal data accessed when using the website will not be – except for other cases explicitly described in this data protection statement – disclosed to a third party or transmitted in any other manner without your consent. Exceptions are the transmission of personal data to state institutions and authorities as well as private copyright holders on the basis of legal provisions, judgements or regulatory judgements respectively, as well as the disclosure to state institutions and authorities in the case of attacks on our protected rights for the purpose of legal or criminal prosecution.

The legal basis for this processing of your personal data is Art. 6 (1) p 1 lit. c EU-GDPR (compliance with legal obligation).


e) Use of cookies

aa) Our website uses cookies. Cookies are text files stored in or by the internet browser of the user’s computer system. If the user visits a website, a cookie can be stored on the user’s operating system. This cookie has a distinct character string, which enables a clear identification of the browser when the website is next visited.

We use cookies in order to create a more user-friendly website. Some elements of our website require this so that the visiting browser can still be identified when changing pages. The technically necessary gathering of user data by cookies will not be used to generate user profiles.

bb) The legal basis for processing of personal data with the use of cookies is based on Art. 6 (1) lit. f EU-GDPR (legitimate interest). Legitimate interest is the purpose of facilitating use of the website for the user. Some functions of our website would not be available without the use of cookies. It is necessary for the browser to be recognisable even after a page break.


f) Tools for analysis

aa) The following third-party software solutions are implemented for statistical evaluation of visitor access and to optimise our website:

We can evaluate the use of our website by using these services and, on the basis of this, can collect valuable information about the requirement of our users in order to increase the user friendliness and quality of our online services. To implement the analysis, aggregated and anonymous statistical data is gathered. This data is communication and transaction data without personal references, which when using the browser, makes a connection between the number of page calls and visits, navigation behaviour and the amount of time each visitor spends on the website. In the course of gathering and processing data, sometimes the anonymised IP address of the visitor is viewed.

Evaluation of this data serves in particular to measure the attractiveness of certain parts of the website as well as measuring the reach of our services.

bb) Opt-out You can prevent the use of the above mentioned tools by setting appropriate adjustments to your browser software; but please note that by doing so you might not be able to use the full range of our website functions.

cc) Google Analytics

The website uses Google Analytics, a web analysis service of Google Inc. (Google). Google Analytics uses so called “cookies”, text files which are stored on your computer and facilitate your website use. The information generated by using the website is usually transmitted to a Google server in the USA and stored there. If an IP anonymisation is activated on the website, your IP address will be shortened beforehand by Google within the member states of the European Union or in other signatory states to the EEA Treaty. In exceptional circumstances, the full IP address will be transmitted to a Google server in the USA and shortened there. Acting under the authority of the website provider, Google will use this information to evaluate your use of the website, to collate reports about website activity and further, to provide other website and internet related services to the provider of the website. The IP address transmitted to Google Analytics by your browser, will not be combined with other data by Google.

This website uses the IP anonymisation as defined above.

You can prevent the storage of cookies by setting an appropriate adjustment to your browser software; but please note that by doing so you might not be able to use the full range of our website functions. Moreover, you can prevent the collection of data generated by the cookie and obtained by your using the website (incl. your IP address), as well as the processing of data by Google, if you download and install the browser plugin available under the following link:

As an alternative to the browser plugin or within the browsers of portable devices, please click on the following link to set an opt-out cookie which will prevent future collection by Google Analytics within the website (this opt-out cookie will only function in this browser and on this website. If you delete your cookies in your browser, you must click on the link again):

Further information on Google Analytics is available here:,,

dd) Google reCAPTCHA

To protect input forms on our page, we use the Google service “reCAPTCHA” of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter “Google”. By using this service, it can be noticed whether a particular entry is of human origin or is an improper use by automated machine processing.

To the best of our knowledge the referrer-URL, IP address, website visitor behaviour, information on your operating system, browser and visiting time spent, cookies, display statement and script, user input performance, as well as mouse movement in the “reCAPTCHA”-Checkbox will be transmitted to “Google”.

“Google” uses the information obtained this way to digitise books and other printed matter as well as to optimise services such as Google Street View and Google Maps (e.g. house number and street name recognition).

The” reCAPTCHA “reported IP address will not be combined with other data by Google, except when you are registered with your Google account at the time of using the “reCAPTCHA”-plug-ins. If you want to prevent the transmission and storage of your data and your website behaviour by “Google”, you must log out of “Google” before you visit our page or use the reCAPTCHA plug in.

Use of the information obtained by the service “reCAPTCHA” is in accordance with the Google terms of use:

ee) The legal basis for the described processing of your personal data using the above defined analysis tools is legitimised by Art. 6 (1)p. 1 lit. f EU-GDPR (legitimate interest). The legitimate interest here is that it is important for the operation of our website to understand if and how often it is used.


3. Subcontractor services concerning the website

For the operation of the website and the services offered on the website (for example sending the newsletter) external agents are contracted who process your personal data for us. These service providers process the data exclusively under our orders. The legal bases of this data processing are Art. 6 (1)p. 1 lit. b) EU-GDPR (contractual performance and pre-contractual measures) and Art.28 EU-GDPR (job processing).


4. Time limit for storing your personal data

As long as there is no shorter storage time specified under the rules of this data protection statement, we store your personal data, obtained in connection with the use of the website, only as long as is necessary to process your queries, and after that only to the extent that we are bound to a mandatory legal retention period. As soon as we no longer need your data for the above mentioned purposes, it will be stored for the legal retention period and not processed for other purposes.


5. Your rights

You have the right to ask for information about your personal data stored by us at any time. As long as the legal requirements are met, you have rights to demand from us the correction, deletion or limitations to processing of the said data. If you have made a declaration of consent to the use of personal data, you may revoke this at any time.

In as much as you want to exercise these rights, or if you want to revoke the declaration of consent for the processing and use of your personal data entirely or partially, please write to us at our email address or our postal address creditPass Co.Ltd, Mehlbeerenstr. 2, 82024 Taufkirchen b. München, Germany.

If you would like to contact us per email, please note that the content of unencrypted emails can be seen by third parties. We therefore advise that you send confidential information either encrypted or by post. If you are of the opinion that our processing of the relevant personal data contravenes the applicable data protection law, you may make a complaint to the competent supervisory authority for data protection.


6. Data security

CreditPass employs current technical measures to guarantee data security, in particular to protect your personal data from the dangers of data transmission as well as preventing a third party from obtaining knowledge. These measures conform to the current technical status.


7.  Amendment of the data protection statement

Sometimes it will be necessary to amend the data protection statement because of new developments on the website or legal changes. We exercise the right therefore to amend the data protection statement at any time with effect for the future. We advise you therefore to re-read this data protection statement periodically.