EDÖB/PFPDT/IFPDT (Switzerland) - Inkasso-Team AG

EDÖB/PFPDT/IFPDT - Inkasso-Team AG
Authority:	EDÖB/PFPDT/IFPDT (Switzerland)
Jurisdiction:	Switzerland
Relevant Law:	Article 6 Federal Act on Data Protection
Type:	Investigation
Outcome:	Violation Found
Started:	03.09.2024
Decided:	28.04.2025
Published:
Fine:	3,200 CHF
Parties:	Inkasso-Team AG
National Case Number/Name:	Inkasso-Team AG
European Case Law Identifier:	n/a
Appeal:	Pending appeal
Original Language(s):	German
Original Source:	FDPIC ruling against Inkasso-Team AG (in DE)
Initial Contributor:	Harkirt Singh Anand

The DPA fined a debt collection agency CHF 3,200 (€3,422) for unlawfully publishing information about debtors on its website.

English Summary

Facts

In 2021, the DPA was first alerted to Inkasso-Team AG’s (the controller) activities after receiving a complaint from a person in Germany. This complaint, forwarded by the Bavarian DPA, indicated that the controller was publishing information on suspected debtors and persons associated with them on its website and was soliciting information on their whereabouts. On 9 September 2021, the Swiss DPA sent an initial notice to the controller, highlighting that such publication of personal data violates data protection regulations. The controller did not respond, later citing postal and email delivery issues during the company’s early operational months.

Two years later, on 23 October 2023, and following the entry into force of the revised Swiss Federal Data Protection Act (FDPA), the Swiss DPA received another complaint via the Bavarian DPA, again raising concerns that the controller continued publishing personal data on its website. The investigation confirmed that the controller operated the website, which featured personal information including names, addresses, and other details of suspected debtors and associated persons, such as place of residence and alleged outstanding debts. In some cases, photos and videos of family members, including children, were also published.

Based on these findings, the Swiss DPA formally opened an ex officio investigation on 3 September 2024.

In its defence, the controller argued that it represented an overriding private interest for creditors or a public interest in combatting fraud. It claimed that all listed debtors were “confirmed” through legal titles or available documentation. The controller also offered to notify debtors in future or restrict website access through some form of user verification.

Holding

The Swiss DPA found that the controller violated the principles of transparency by failing to inform the data subjects that it published their data on its website. The Swiss DPA further held that the controller violated the principle of proportionality because no overriding private or public interest justified the publication of such data. In particular, the DPA clarified that there is no private or public interest in publishing the personal data of debtors to determine their whereabouts or to warn the public about these persons.

On these grounds, the Swiss DPA prohibited the publication of personal data of suspected debtors and associated individuals and ordered the erasure of all already published information. The Swiss DPA also fined the controller CHF 3,200 (€3,422).

The controller appealed the decision to the Swiss Federal Administrative Court.

Comment

Share your comments here!

Further Resources

Share blogs or news articles here!

English Machine Translation of the Decision

The decision below is a machine translation of the German original. Please refer to the German original for more details.

**Order**  
of 28 April 2025  
in the matter of  
Investigation pursuant to Article 49 of the Federal Act on Data Protection (Data Protection Act, FADP;  
SR 235.1)  
against  
Inkasso-Team AG, Innere Margarethenstrasse 5, 4051 Basel  
(Party)  
regarding the Disclosure of Personal Data on the Internet

## A. Facts

### I. Subject of the Investigation

1. The subject of the present investigation is whether Inkasso-Team AG, by disclosing personal data on the Internet, in particular on the website [redacted], together with the request to provide possible information regarding the whereabouts and activities of the listed persons to Inkasso-Team AG, is in violation of federal data protection provisions. The investigation extends to personal data that Inkasso-Team AG discloses or processes on the website within this context.

### II. Background

2. Based on a complaint from a person residing in Germany, which was forwarded to the FDPIC by the Bavarian State Office for Data Protection Supervision (BayLDA) by letter dated 12 March 2021, the FDPIC was made aware for the first time of the websites [redacted] and [redacted].

3. In the same letter, BayLDA informed the FDPIC that Rolf Schmidt Inkasso-Team, or its successor Inkasso-Team AG, publishes information and notices regarding alleged debtors on the website and calls upon visitors to the website to provide information about the whereabouts of the affected person.

4. By letter dated 9 September 2021, the FDPIC informed Inkasso-Team AG that the publication of personal data of allegedly defaulting payers on a website or via other channels violates data protection provisions. The FDPIC received no response from Inkasso-Team AG to this letter.

5. Two years later, and after the entry into force of the new Data Protection Act, the FDPIC again received a letter from BayLDA on 23 October 2023, reporting a data subject. BayLDA informed the FDPIC that Inkasso-Team AG was apparently still publishing personal data of alleged debtors and persons associated with them on its website.

6. Based on the notification from BayLDA, the FDPIC again pursued the disclosure of personal data by Inkasso-Team AG. It was established that the website [redacted] is operated by Inkasso-Team AG as the responsible site owner.

7. Under the sections "Inquiries," "Warnings," and "Investigations & Fraud Prevention," the website publishes names and a range of other personal details such as place of residence and information about alleged payment arrears of alleged debtors and persons associated with them.

8. The homepage of Inkasso-Team AG states: "We report – in exceptional cases – about debtors in whom there is either a public interest (warnings) or from whom we expect further clarification from readers regarding a case (experiences, whereabouts, finding debtors, etc.). We thank you in advance for any information."

*1 As of 2025, no longer in operation*

9. Under the "Inquiries" section, Inkasso-Team AG, based on published personal data (first name, last name, and various other details), calls for experiences regarding the persons concerned to be reported to the company and, in particular, for any known whereabouts to be communicated: "Do you know the following companies or persons? What experiences have you had with them? We expressly also ask for positive experiences! Do you possibly also have a claim against the respective debtors? Do you know other creditors? Depending on the case: find the debtor! Can you provide us with information about the whereabouts (address, contact details, etc.) of the persons concerned?" By linking to specific personal details, one is directed to a subpage where, in some cases, very detailed information about the respective person is provided, together with videos and photos of possible family members, such as the children of the person concerned.

10. Similarly, under the "Warnings" section, information about individual persons or companies is provided based on published personal data (first name, last name, and various other details). Inkasso-Team AG points out: "Exercise caution if the following persons wish to borrow money from you or propose a business to you. Based on the facts at hand, there is a risk that you may lose money. Carefully review business dealings or contracts and seek advice from a professional and, if necessary, legal counsel." Here too, by clicking on the name of the alleged debtor, the website visitor is directed to a subpage where further personal information about the respective person is visible (photos with persons and their names, email addresses, as well as their alleged business conduct and debts).

11. Under the "Investigations & Fraud Prevention" section, fraud prevention is carried out in the form of blog posts. These also contain numerous references to alleged fraudulent companies or associated persons, and personal data including photos of affected persons are published.

### III. Investigation by the FDPIC

12. Based on the information received from BayLDA and its own inquiries, the FDPIC, by letter dated 3 September 2024, ex officio opened an investigation pursuant to Article 49 of the Data Protection Act (FADP; SR 235.1). Together with the opening letter, Inkasso-Team AG was requested to submit a written statement regarding the facts provisionally determined by the FDPIC.

13. Inkasso-Team AG submitted its statement within the extended deadline on 17 October 2024, with various comments on the facts presented (see the following paragraph).

### IV. Statement of the Party

14. In its statement, Inkasso-Team AG asserts that it was founded as a company on 19 May 2021 and at that time took over "cases and tools" of the sole proprietorship Rolf Schmidt Inkasso, including the website.

15. Furthermore, Inkasso-Team AG regrets that it left the intervention of the FDPIC dated 9 September 2021 unanswered. In the first months after the company's founding, there were various problems with postal and email delivery. The letter could not be found in the files of Inkasso-Team AG.

16. Inkasso-Team AG states, regarding the purpose of data processing, that the publications on the website are intended to enable the tracing of alleged debtors, as they "conceal their place of residence and/or registration, deregister to false locations, or are no longer reachable by telecommunications." It further states that in around 50% of the publications, valuable informant information was received, which helped to locate or contact debtors or otherwise advance the case. In around 20% of cases, a solution was expressly achieved as a result of the publication, because debtors or their lawyers made contact and negotiations regarding the debt could be initiated.

17. Furthermore, Inkasso-Team AG claims that "the publication may possibly bring perpetrators to justice" and "a case serves as a warning to other potential victims and may possibly prevent further crimes."

18. Inkasso-Team AG states that for all debtors, either enforcement titles already exist or these could be obtained without difficulty with the documents available to Inkasso-Team AG, e.g., contracts or acknowledgments of debt. Thus, these are "confirmed" debtors, and Inkasso-Team AG represents, by means of the publication, overriding private interests, in particular creditor interests, or public interests, e.g., to pursue fraudulent activities when state prosecution does not achieve its aim. Any infringements of personality rights by the publication are thereby justified.

19. The statement provides some concrete examples where the approach via the website has shown success. Ultimately, Inkasso-Team AG offers that in the future it would be willing to actively inform debtors about the publication or to restrict access to the website to such an extent that a "declaratory legitimation" by users would be required.

20. The submissions of the party will be addressed in the following considerations, insofar as necessary.

## B. Considerations

### I. Formal Aspects

21. The FADP applies to the processing of personal data of natural persons by private persons and federal bodies (Art. 2 para. 1 FADP). Pursuant to Art. 4 para. 1 FADP, the FDPIC supervises the application of federal data protection provisions. He initiates an investigation ex officio or upon notification against a federal body or a private person if there are sufficient indications that data processing may violate data protection provisions (Art. 49 para. 1 FADP).

22. Inkasso-Team AG constitutes a private person within the meaning of Art. 2 para. 1 lit. a FADP. It processes, by means of the website [redacted], data of natural persons, i.e., information relating to an identified or identifiable natural person (Art. 5 lit. a FADP).

23. There are no grounds for excluding the applicability of the FADP (Art. 2 para. 2 FADP). Thus, the FADP is applicable in both personal and material terms. The data processing to be assessed also falls within the territorial and temporal scope of the FADP.

24. The investigation was initiated ex officio by the FDPIC, as there were sufficient indications that the data processing could violate data protection provisions (Art. 49 para. 1 FADP).

### II. Substantive Aspects

#### 1. Processing of Personal Data

25. The FADP applies to the processing of personal data by private persons (Art. 2 para. 1 lit. a FADP). "Processing" means any handling of personal data, regardless of the means and procedures used, in particular the collection, storage, retention, use, modification, disclosure, archiving, deletion, or destruction of data (Art. 5 lit. d FADP). "Personal data" means all information relating to an identified or identifiable natural person.

26. Inkasso-Team AG publishes on the website [redacted] under the sections "Inquiries," "Warnings," and "Investigations & Fraud Prevention" a multitude of personal data regarding alleged debtors and persons associated with them. Typically, the first and last names of the debtor, address data, origin, place of work or business activity, information on civil and criminal proceedings and judgments, as well as photos are published. The website contains similar data on persons who are related to the debtor by family, friendship, or business.

27. The publication of this data on the website constitutes processing of personal data by Inkasso-Team AG.

#### 2. Compliance with Data Processing Principles

28. The purpose of the FADP is to protect the personality and fundamental rights of natural persons whose personal data is processed (Art. 1 FADP). Pursuant to Art. 30 para. 2 lit. a FADP, a violation of personality rights exists in particular if personal data is processed contrary to the principles of Art. 6 and 8 FADP. If the principles are violated, there is, according to Art. 31 para. 1 FADP, an unlawful violation of personality rights, unless it is justified by one of the grounds for justification under Art. 31 FADP – the consent of the data subject, an overriding private or public interest, or a legal provision.

##### 2.1. Transparency of Data Processing

29. The principle of transparency requires that the collection of personal data and, in particular, the purpose of its processing must be recognizable to the data subject.

30. The principle of transparency is specified by the information obligations when collecting personal data: Pursuant to Art. 19 FADP, the controller shall adequately inform the data subject about the collection of personal data (para. 1) and provide the information necessary for the data subject to assert their rights under this Act (para. 2), in particular the purpose of processing. If the controller does not collect the data from the data subject and discloses it before the expiry of one month from receipt of the data, the controller must inform the data subject at the latest at the time of disclosure (para. 5).

31. The FADP does not specify how the data subjects must be informed. Art. 19 para. 1 FADP only requires that the information be "adequate." However, the information must be provided actively, meaning that the controller must provide this information and ensure that the data subject can actually take note of the complete information in a reasonable manner.

32. Inkasso-Team AG publishes on the website [redacted] and its subpages various personal data about alleged debtors, in some cases also with information about relatives, including the children of a debtor. The website does contain a privacy policy; however, this only provides information on data processing that occurs when visiting the website or using the contact form, as well as data of any applicants. It contains no information on data processing as described above in para. 26.

33. It is to be assumed that the data about the persons concerned originates, on the one hand, from the clients of Inkasso-Team AG, i.e., the creditors, and, on the other hand, from other sources and research obtained by Inkasso-Team AG through its own investigations. Thus, the data is not collected from the data subject themselves, but from third parties. Unless an exception under Art. 20 FADP applies, the data subjects must, pursuant to Art. 19 para. 5 FADP, receive the necessary information about the data processing from the controller no later than one month after receipt of the data. Inkasso-Team AG states in its submission that the data subjects are not informed about the data processing.

34. By refraining from informing the data subjects without invoking justified exceptions, Inkasso-Team AG's data processing is in violation of the principle of transparency under Art. 19 FADP.

##### 2.2. Proportionality of Data Processing

35. Furthermore, data processing such as the publication of personal data by Inkasso-Team AG must be proportionate (Art. 6 para. 2 FADP). It must therefore be objectively suitable and necessary to achieve the purpose of processing and must be reasonable for the data subjects. Reasonableness exists if there is a reasonable relationship between the purpose of processing and the necessary impairment of personality rights in view thereof (cf. with respect to the former FADP, Message on the Federal Act on Data Protection (FADP), BBl 1988 II 413, 450).

36. It must be examined whether the publication of personal data of alleged debtors and persons associated with them on the website is suitable and necessary to achieve the purposes asserted by Inkasso-Team AG, namely the tracing of debtors and the warning effect for potential further victims, and whether this is reasonable for the data subjects.

37. According to the statement of Inkasso-Team AG, the publications are "highly effective" for its work and help to locate debtors. "In around 50% of the publications," they received valuable information "which, for example, helped us to locate or contact the debtor or otherwise advance the case. In around 20% of cases, a solution was expressly achieved as a result of the publication, either because debtors contacted us and we could enter into negotiations with them, or because they instructed lawyers to issue warnings against the publication with various legal arguments."

38. The "pillory effect" of the publication via the "Warnings" and "Investigations & Fraud Prevention" sections is also, according to Inkasso-Team AG, successful: "As a result of our publication, in recent days we received a report from another injured party with newer and more specific location and personal information. Based on this, we can continue our investigations and pass them on to the authorities." And further: "There is in any case a public interest, not only because the publication may possibly bring perpetrators to justice, but also because the case serves as a warning to other potential victims and may possibly prevent further crimes."

39. Based on the statements of Inkasso-Team AG, it cannot be ruled out that the purpose – tracing alleged debtors by means of publication on the website – can be achieved at least in some cases. Whether this also applies to the warning or pillory function of the publication appears questionable. However, this question can be left open here, as, as set out below in paras. 47 et seq., reasonableness for the data subjects will be denied.

40. In assessing the reasonableness of data processing, it must be examined whether there is an appropriate relationship between the data processing and the associated interference with the privacy of the data subjects (proportionality in the narrower sense; cf. BGE 138 II 346 E. 9.2 p. 362). In the context of a balancing of interests, it must therefore be examined to what extent the interest of Inkasso-Team AG in publishing the data of alleged debtors and persons associated with them outweighs the interest of the data subjects in the least possible interference with their informational self-determination.

41. Since an examination of the mutual interests from the perspective of proportionality in the narrower sense under Art. 6 para. 2 FADP in conjunction with Art. 30 para. 2 lit. a FADP is, in substance, very closely linked to the examination of the justification ground of overriding interest under Art. 31 para. 2 FADP, the decisive aspects of the balancing of interests and the proportionality assessment are examined together at the level of the grounds for justification (BGE 138 II 346 E. 9.3 p. 362 f.; BGE 136 II 508 E. 5.2.5 p. 521). The balancing of interests is therefore carried out in the context of examining the justification ground of overriding private interest (see paras. 47 et seq.).

#### 3. Infringement of Personality Rights and Justification

42. The aforementioned violation of data processing principles constitutes an infringement of personality rights (Art. 30 para. 2 lit. a FADP). Infringements of personality rights are unlawful (Art. 30 para. 1 FADP), unless they are justified by consent, an overriding private or public interest, or by law (Art. 31 para. 1 FADP). According to Federal Supreme Court case law, grounds for justification can only be affirmed with great restraint in the event of a violation of data processing principles (cf. BGE 136 II 508 E. 5.2.4; see also, for example, BGer 6B_68/2023, of 9 October 2023, E. 2.1.2).

##### 3.1. Statutory Basis and Consent

43. There is no statutory basis for the publication of data of alleged debtors and persons associated with them on the Internet by a private company, nor is one asserted. Nor can it be assumed that consent to publication exists: In its statement of 17 October 2024, Inkasso-Team AG itself proposes that in the future it could actively inform debtors about the publication. This establishes that, as of today, it neither contacts the affected debtors nor seeks their consent to publication. The consent of the data subjects is therefore not a ground for justification for the publication in the present case. The possibility of justification by overriding private or public interests remains.

##### 3.2. Overriding Public Interest

44. Inkasso-Team AG argues that its warnings about debtors are justified by a public interest, because the publication may possibly bring perpetrators to justice, serve as a warning to other potential victims, and may possibly prevent further crimes.

45. An overriding public interest means an interest of the general public. In the case of data processing by private parties, such an interest rarely exists. On the one hand, data processing by private parties naturally involves private individuals who pursue private interests. On the other hand, public interests are often reflected in statutory provisions.

46. In particular, the rule of law provides for the exclusive competence of the criminal prosecution authorities to bring perpetrators to justice. Victims or injured parties may contact the competent police authority to provide information about a perpetrator. Publication by private individuals on the Internet is not necessary for the prosecution of criminal conduct and also lacks a statutory basis.

47. With regard to the collection of outstanding monetary claims, the state provides the instrument of debt enforcement and bankruptcy law, which already takes into account the public interest in the enforcement of claims.

48. In summary, an overriding public interest in the publication of personal data of alleged debtors and persons associated with them on the Internet is to be denied.

##### 3.3. Overriding Private Interest

49. It remains to be examined whether Inkasso-Team AG can assert an overriding private interest in the publication of data of alleged debtors and persons associated with them. It should be noted that, according to case law, data processing that infringes personality rights can only be justified by overriding private interests with restraint (cf. BGE 136 II 508, E. 5.2.4. and 6.3.3).

50. The overriding private interests in processing may primarily be those of the processing party. However, interests of third parties, such as other potential "victims" or business partners of the alleged debtors, may also justify data processing. In principle, all legitimate interests in data processing may be taken into account in the balancing of interests, including purely economic interests.

51. Opposed to this is the interest of the data subject in the protection of their personality. The degree of protection depends, among other things, on the sensitivity of the processed personal data, the potential for harm from the data processing, and the severity of the possible infringement of personality rights resulting from the processing.

52. In the present case, the publication of personal data by Inkasso-Team AG on the website [redacted] essentially pursues two interests: the collection of outstanding claims by determining the whereabouts, and the warning of the public about certain persons.

###### 3.3.1. Determination of Whereabouts

53. With regard to the determination of whereabouts via publication of the data, it should be noted that Inkasso-Team AG does indeed pursue an economic interest for the creditor or for itself, but the publication of personal details of alleged debtors and persons associated with them on the Internet overshoots the mark. The persons concerned are portrayed negatively in public without their knowledge, and their personal situation is negatively assessed.

54. Even if, as stated by Inkasso-Team AG, there is some documentation regarding the asserted claim, the publication of the name is based on a unilateral assessment by the creditor. The interest of the debtor in being able to defend themselves against the claim is prevented by the publication. The mere existence of a potentially outstanding monetary claim does not justify the publication of personal data of alleged debtors and persons associated with them to an indefinite number of persons on the Internet. All the more so as it is not the task of the public to search for defaulting debtors. This function is usually performed by creditors and, in the case of public interest, by the state.

55. Furthermore, once personal data is published on the Internet, it can no longer be controlled. Even if the data is removed from a website itself, it is very likely that the data in question has already been copied by other sites and may be reused in the future.

56. The interests of the alleged debtors and persons associated with them in controlling their data or their right to informational self-determination outweigh the economic interests of Inkasso-Team AG and its clients in the present case. Thus, reasonableness for the data subjects, i.e., proportionality in the narrower sense, is not given here.

###### 3.3.2. Protection of Creditors or Warning of Third Parties

57. As already set out above in para. 3.2., the general warning of the public about fraudsters is not the responsibility of private parties, and a private data processor can assert neither a public nor an overriding private interest in this regard.

58. By contrast, prevention in the sense of credit information in relation to a specific contractual relationship constitutes an overriding private interest. The protection consists in the fact that a business participant checks the creditworthiness of a person before entering into a contract with them. In this case, the legislator has already carried out a balancing of interests and, in Art. 31 para. 2 lit. c FADP, has set limits for the justification of data processing for the purpose of checking the creditworthiness of a person.

59. According to this provision, an overriding interest of the controller may be considered if the data processing is carried out to check the creditworthiness of another person. The law provides for the following requirements: The data does not concern particularly sensitive personal data nor profiling with a high risk; data is disclosed to third parties only if they need the data for the conclusion or execution of a contract with the data subject; the data is not older than ten years; and the data subject whose data is processed is of legal age.

60. Inkasso-Team AG is free to restructure its offering as a credit information service that complies with the legal requirements of Art. 31 para. 2 lit. c FADP. The measures proposed by Inkasso-Team AG in its statement of 17 October 2024 have remained too vague in this respect. It should be noted that the publication of personal data as currently carried out by Inkasso-Team AG does not constitute permitted credit information within the meaning of the law and must therefore be discontinued.

#### 4. Conclusion and Measures

61. The publication of personal data of alleged debtors and persons associated with them on the Internet, in particular on the website [redacted], violates the data processing principles of Art. 6 FADP, in particular the principles of transparency and proportionality.

62. There is no overriding private or public interest in determining the whereabouts of debtors or publishing a warning to the public regarding these persons by means of the publication of personal data.

63. For these reasons, Inkasso-Team AG is prohibited from publishing personal data of alleged debtors and persons associated with them – as found on its website – on the Internet.

64. The personal data of alleged debtors and persons associated with them already published on the website constitutes an unlawful infringement of personality rights and must be deleted.

#### 5. Reference to Penal Provisions

65. Pursuant to Art. 63 FADP, private persons who intentionally fail to comply with an order of the FDPIC issued with reference to the penal provision of this Article shall be punished. The present order is issued with reference to the penal provision of Art. 63 FADP. Liability arises, pursuant to Art. 29 of the Criminal Code (CC; SR 311.0), for the natural person(s) responsible within the company, i.e., the person(s) who must ensure within the company that the order of the Commissioner is complied with (cf. Message on the revised FADP, BBl 2017 6941 et seq., 7103 and 6974).

#### 6. Fees

66. Pursuant to Art. 59 para. 1 lit. d FADP, the FDPIC charges private persons fees for measures under Art. 51 FADP. In the present case, an administrative measure under Art. 51 FADP is ordered against Inkasso-Team AG, which is subject to a fee.

67. Pursuant to Art. 44 of the Data Protection Ordinance (DPO; SR 235.11), the fees charged by the FDPIC are calculated based on time spent. An hourly rate of CHF 150 to 250 applies, depending on the function of the personnel involved (cf. Art. 44 paras. 1 and 2 DPO).

68. The time spent in the present case amounts to a total of 16 hours. This results in a total fee of CHF 3,200.

69. The fees are therefore set in total at CHF 3,200 and imposed on the party for payment. The fee becomes due upon the order becoming legally binding; the payment period is generally 30 days from the due date (cf. Art. 44 para. 5 DPO in conjunction with Art. 12 para. 1 lit. a and para. 2 of the General Fees Ordinance (GenFO; SR 172.041.1).

## Therefore, it is hereby ordered:

1. Inkasso-Team AG shall refrain from publishing personal data of alleged debtors and persons associated with them – as found on its website – on the Internet.

2. Inkasso-Team AG shall delete the personal data of alleged debtors and persons associated with them already published on the website.

3. Inkasso-Team AG is obliged to notify the FDPIC of the implementation of the deletion within 10 days after this order becomes legally binding.

4. Inkasso-Team AG is advised that any violation of items 1 to 3 is subject to a monetary penalty pursuant to Art. 63 FADP:  
Private persons who intentionally fail to comply with an order of the FDPIC issued with reference to the penal provision of this Article shall be punished with a fine of up to CHF 250,000.

5. Inkasso-Team AG is imposed a fee in the total amount of CHF 3,200.

To be served to:  
Inkasso-Team AG, Innere Margarethenstrasse 5, 4051 Basel (Party)

### Right to Appeal

An appeal against this order may be lodged with the Federal Administrative Court (P.O. Box, CH-9023 St. Gallen) within 30 days. The appeal must be substantiated and submitted in two signed copies. The order and the documents invoked as evidence must be enclosed.