Data protection

DATA PROTECTION

INFORMATION ON DATA PROCESSING
Privacy Policy – Sponti-Car GmbH

Privacy Policy of Sponti-Car GmbH

Valid from 04.10.2026 (replaces all previous versions)

1. Controller

Sponti-Car GmbH
Talstrasse 24
8852 Altendorf
Switzerland

Email: info@sponti-car.ch
Phone: 055 264 10 00
Data protection contact: Mark Ritzmann

Sponti-Car is the controller within the meaning of the Swiss Data Protection Act (DSG) and – to the extent applicable – the EU General Data Protection Regulation (GDPR).

2. Scope

This privacy policy applies to all customers, interested parties and users of the website, app and vehicles of Sponti-Car as well as to all other persons whose data is processed within the scope of the service. The German version is authoritative.

3. What personal data we process

  • Master data: Name, date of birth, address, telephone, email
  • Identity and ID data: Driver's license (incl. place of origin, nationality, date of issue, validity); SwissPass number and associated verification results
  • Biometric data: Selfie and ID verification via Stripe Identity (not transmitted to Grok)
  • Payment data: Credit card references hosted via Stripe; no complete card numbers at Sponti-Car
  • Creditworthiness data: Risk score and information from CRIF AG
  • Usage and vehicle data: Bookings, kilometers, GPS/location, sensor and vehicle status, app data
  • Correspondence: Emails, chat, telephone notes, messages created or sent by AI
  • Technical data: IP address, device and log data, cookies

4. Purposes and Legal Bases

PurposeLegal basis
Registration, contract, booking, billing, supportContract (Art. 31 para. 2 lit. a FADP / Art. 6 para. 1 lit. b GDPR)
Identity, driving licence and SwissPass verificationContract and legitimate interest in abuse prevention
Credit check (CRIF) and admission decisionContract and legitimate interest; where required, consent or Art. 21 FADP / Art. 22 GDPR
AI-supported review, decision and email communication (Grok)Contract and legitimate interest in efficient, uniform processing
Website/app analysis (Google Analytics)Consent
Accounting, authorities, statutory obligationsLaw

5. Use of Artificial Intelligence (Grok / xAI)

We use the AI system Grok from xAI LLC, USA, via the business API/Enterprise use.

Grok is used in particular for:

  • the direct drafting and sending of emails to customers (confirmations, notices, inquiries, decisions);
  • the verification of the SwissPass number based on the rules specified by us;
  • the admission decision as to whether a customer may use the offer, including evaluation of our internal criteria and the creditworthiness data from CRIF.

AI phone assistant: Calls to the hotline may be answered, transcribed and processed by an AI (Grok/xAI) for identification (member number, date of birth, phone number), for opening vehicles, for extending bookings and for sending notifications. Call transcripts are stored with the AI or in the system for a maximum of 90 days. You may request transfer to a staff member at any time.

Telephone system: For the hotline, we use the 3CX telephone system. The software provider is 3CX Ltd, headquartered in Nicosia (Cyprus, EU). The telephone system is used to accept, forward and log calls (e.g. telephone number, time and duration of the call). A data processing agreement (Data Processing Addendum) exists for this processing. The data may be processed in the European Economic Area (EEA). For push notifications to the phone apps, services from providers in the USA (e.g. Apple or Google) may be used.

Only the information necessary for the respective process is transmitted to Grok (e.g. name, email, SwissPass number, verification result, CRIF score/relevant creditworthiness characteristics, process data). Not transmitted to Grok are biometric images from Stripe Identity and complete credit card data.

xAI acts as processor. The Data Processing Addendum of xAI applies. According to xAI's Enterprise/API terms, business inputs and outputs are not used for model training . Data may be processed in the USA (data processing agreement and standard contractual clauses; Data Privacy Framework to the extent applicable to xAI).

Documents: xAI DPA, xAI Privacy Policy.

6. Automated Individual Decision (Admission)

The decision as to whether you may become a customer or continue to use the offer can be made exclusively on an automated basis by Grok. The basis for this is our defined admission criteria as well as the credit report from CRIF, supplemented by the SwissPass and identity check.

A rejecting or restricting decision will be communicated to you. You have the right:

  • to present your point of view;
  • to request a review by a natural person at Sponti-Car;
  • To receive information about the relevant decision-making criteria, insofar as business secrets do not conflict with this.

Contact: info@sponti-car.ch or 055 264 10 00.

Legal bases: Art. 21 DSG and Art. 22 GDPR. Insofar as consent is legally required, we obtain it during registration. Refusal may result in no contract being concluded.

7. Recipients and processors

Data is only disclosed to the extent necessary for the contract, legal requirements, or legitimate interests. The list is not exhaustive. The privacy policies of the named companies apply in each case.

RecipientLocationPurposeNote
ibiola Mobility Solutions GmbHAustriaBooking, opening, telematicsData processing agreement; EU adequacy
Stripe Inc. (Payments / Identity)USAPayment and identity verificationData processing agreement; DPF/SCC
CRIF AGSwitzerlandCreditworthiness and identity informationsee also mycrifdata.ch
xAI LLC (Grok)USAAI: emails, SwissPass verification, admission decisionDPA; no training on business data according to xAI
xAI LLC (Grok), AI phone assistantUSAAI phone assistant: Receiving and transcribing hotline calls, identification (membership number, date of birth, phone number), opening vehicles, extending bookings, sending notificationsDPA; call records for a maximum of 90 days; forwarding to an employee possible at any time
3CX Ltd (3CX phone system)Cyprus (EU)Hotline phone system: accepting, forwarding and logging callsData processing agreement (DPA); processing within the EEA possible; push notifications possibly via services in the USA
Google Ireland/USA (Analytics)Ireland/USAWebsite/app analysisonly with consent
Bexio AGSwitzerlandAccountingData processing agreement
Microsoft (Office 365)USA/EUOffice communicationData processing agreement; DPF/SCC
OpenAI (ChatGPT)USAinternal text and auxiliary work, insofar as usedonly with AVV/API; own regulations of OpenAI
WhatsApp / MetaUSA/EUcommunication, insofar as you use this channelown regulations of Meta

Other possible recipients: authorities (legal obligation), insurance companies (damage cases), payment service providers, IT and support partners. All processors are contractually bound to our instructions and may not use the data for their own purposes, insofar as the respective contract so provides.

Third-party privacy notices (excerpt):
xAI · Stripe · CRIF · Google · Bexio · Microsoft · OpenAI · WhatsApp

8. Disclosure abroad

Some of the processing takes place in the EU/EEA (adequate level of protection) and in the USA (Stripe, xAI, Google, Microsoft, Meta, OpenAI). Depending on the recipient, the basis is the data processing agreement, standard contractual clauses and – insofar as the recipient is certified – the EU-US or Swiss-US Data Privacy Framework. A copy of the guarantees used can be requested.

9. Storage duration

  • Contract and accounting data: contract duration plus statutory retention (usually 10 years)
  • Creditworthiness, identity and approval data: at most 5 years after the end of the contract or earlier upon a justified deletion request, provided no retention obligation prevents this
  • SwissPass verification data: for as long as required for access and abuse prevention
  • AI prompts/outputs at xAI: in accordance with the xAI DPA (typically limited retention for abuse monitoring, no training on business data)
  • Call records of the AI phone assistant: a maximum of 90 days
  • Google Analytics: in accordance with the configuration, usually 14 months
  • Biometric data at Stripe: only for the verification plus a short security period

10. Your rights

You have – within the framework of the FADP and the GDPR – the right to information, rectification, erasure, restriction, data portability, objection to processing based on legitimate interest, as well as the right to human review of automated decisions.

Complaint: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch. Where the GDPR applies, additionally to the competent EU supervisory authority.

Contact: info@sponti-car.ch

11. Cookies and Tracking

Google Analytics only with consent (Consent Mode v2, IP anonymization). Consent can be withdrawn via the cookie banner.

12. Data Security

We take appropriate technical and organizational measures (access restrictions, encryption of transmission, instructions to processors). Only minimized data sets are transmitted to Grok.

13. Changes

We may amend this privacy policy. The current version applies upon publication on the website. We will communicate material changes, in particular regarding the use of AI or automated decisions, in an appropriate manner (website, email or app).

As of: 04.10.2026