C‑568/25 - Universal Versand

The Advocate General opined that an automated credit assessment of customers of a mail order business that can result in the exclusion of payment methods can fall under Article 22 GDPR when the decision can prevent the conclusion of a contract. The exception of Article 22(2)(a) GDPR is applicable when there is an objective link between the decision and the performance of the contract. English Summary. Facts. The controller is a mail order business that handles several ten thousand monthly orders. It offers its customers the option to pay in instalments or payment on open account. Those payment methods amount to 90% of all payments. Before a customer is offered one of these payment methods, the controller is conducting an internal credit assessment for existing customers and a credit assessment via a credit information agency for new customers. In case of a negative result, the payment method is denied. There are alternative payment methods available to all customers regardless of a cre