Refused without a reason: Alza NEO, Třetinka and a customer's right to know why
I have been shopping at Alza since 2018 and I am satisfied with it. The range is wide, the goods are fine, complaints are handled without trouble, and delivery is fast even by European standards: what I order in the evening I can usually pick up the next day. It is the largest Czech online store, and over the years I have come to understand why.
This text is about two services that any registered customer can apply for, and that Alza turned down for me without giving a reason. I am not writing it as a complaint about one customer-care employee. I want to understand how Alza's terms, Czech law and EU rules treat decisions like this, and what a customer in the same situation can do.
What happened
Alza NEO is electronics for rent (phones, laptops, watches) for a monthly fee, with an extended warranty. On the service page Alza says: "The condition is reaching the age of 18. You also need to be registered at Alza. For every customer interested in renting, we check the ability to pay regularly."
Třetinka ("a third") lets you pay a third of the price on collection and the rest interest-free within three months. The conditions are an account older than three months, two completed orders, purchases of at least 5,000 CZK in the last 12 months, a Czech birth number and permanent residence.
I meet all the published conditions, permanent residence included. I am not a Czech citizen. Whether that played a role in the assessment I don't know, and that is why I am writing this.
Alza turned down my Třetinka purchase several years ago and my Alza NEO application in October 2026. For completeness: my bank granted me a mortgage without difficulty.
What Alza replied
I wrote to customer care that a refusal without explanation looks to me like possible discrimination. Here is the reply in full (translated from Czech):
"I am very sorry that you perceive the result of the assessment of your AlzaNeo application as discrimination against you. Nevertheless, I can assure you that all applications are assessed on the basis of the same criteria, and there is in no case any different assessment on the basis of race or nationality.
Your application has been assessed repeatedly, and unfortunately we must maintain our position that, on the basis of an internal assessment, it is not possible to grant your application for rental. The assessment criteria are internal company information and are not disclosed by us.
Rental within the AlzaNeo programme is not a legal entitlement, and the mere rejection of an application cannot be regarded as a discriminatory attack on you."
So Alza says the criteria are the same for everyone and nationality is not among them. What the criteria are, and which of them decided my case, it won't say.
What the terms say
The Alza NEO terms (in force since 18 May 2025), clause 1.3:
"Nobody is entitled to Membership in the Programme; it is entirely at Alza's discretion whether it accepts the offer in the form of a particular customer's application for membership or not. Alza will evaluate the applications of particular applicants for membership individually, on the basis of firmly set criteria."
The terms from 2021 already contained the same sentence. There was no requirement on the volume of earlier purchases in them then, and there is none now.
The Třetinka terms (in force since 25 March 2025) go further:
"Alza reserves the right not to provide the Třetinka service to a customer and also reserves the right not to disclose to the customer the reasons for not approving the service."
That there is no legal entitlement to the service is fine; a business may choose whom it rents to or lets pay later. The question is different: whether it may keep from the customer what the refusal was based on.
Distinctions by citizenship are, in fact, described openly in Alza's help pages, just for another service. On the page answering frequent questions about instalments, which explains the conditions of loans from Home Credit, a Slovak citizen proves permanent or temporary residence in Czechia, whereas: "If you come from a country other than the Czech or Slovak Republic, you will need to prove permanent residence in the Czech Republic including an assigned birth number", plus a phone number from a Czech operator. By this text, a citizen of another EU country needs more than a Slovak citizen. No such rule is published for Alza NEO or Třetinka, and in its reply about my NEO application Alza says nationality plays no role.
Who assesses the applications
According to its privacy policy, to check the ability to pay for Třetinka and Alza NEO, Alza may pass personal data to Nikita Engine s.r.o. (a software company), GEOAPPLY s.r.o., Intrum Czech, s.r.o., CRIF – Czech Credit Bureau, a.s. and CRIF – Registr platebních informací s.r.o. GEOAPPLY's own description lists, among other things, "customer scoring", "geoscoring", "address scoring" and "address profiling", that is, assessing customers by their address. For Třetinka, Alza's service page says directly: "We evaluate your creditworthiness and determine a so-called score." For Alza NEO it only speaks of checking the ability to pay.
I don't know which of these data and models Alza used in my case. In theory anything could have decided: an error in a register, a namesake's record, a short history in Czech databases, or a model that rates addresses. I am not claiming any of this happened; I am only saying that without information from Alza it can be neither confirmed nor ruled out.
One specific inconsistency, though, I found myself. The standard export of my data from Alza contains three records of identity verification through Bank iD, the Czech banks' identity service. They have the correct date of birth (1983) and age, yet the field IsAdult is false. According to the Bank iD documentation, the adulthood claim belongs to a separate scope, profile.legalstatus, which, judging by the records, Alza did not request from the bank. The fields IsLimitedLegalCapacity and IsPoliticallyExposedPerson belong to the same scope and are also false. So these are most likely empty fields rather than data from the bank. Whether Alza's system reads the IsAdult field in the assessment I don't know. But it is exactly the kind of question a customer should get an answer to: for a service whose first condition is being 18, such a field could be decisive.
Is it discrimination?
I don't have an answer, and Czech case law does not give a clear one.
Section 6 of the Czech Consumer Protection Act says: "When selling products or providing services, the seller must not discriminate against the consumer." The Czech Trade Inspection applies this ban to distinctions by nationality as well. In its report on inspections in 2014, among the proven cases of discrimination by nationality it lists one in which "a credit provider restricted foreigners' access to consumer loans".
The Constitutional Court, however, in ruling II. ÚS 3212/18 of 17 April 2019, in the case of a hotel in Ostrava that accommodated Russian citizens only after they signed a statement condemning the annexation of Crimea, said that neither the Czech Charter of Rights, nor the Anti-Discrimination Act, nor the EU anti-discrimination directive lists citizenship among the prohibited grounds, "with the exception of different treatment of citizens of other member states of the European Union". What is prohibited, the court said, is a distinction without rational justification. It also stressed that the hotel had not refused Russian citizens in advance: "this was not a restriction of the 'we don't serve Americans' kind". Judge Ludvík David dissented, and the Supreme Administrative Court then in August 2019 cancelled the Trade Inspection's decision.
It follows that a distinction by citizenship is not automatically unlawful in Czechia, but it must be rationally justified, and for EU citizens it is prohibited. Whether a business's conduct is justified, however, cannot be judged when the business does not give its reasons.
What the GDPR says
Here "we don't disclose the criteria" is a weaker answer than it may seem.
- Article 22 GDPR gives the right not to be subject to a decision based solely on automated processing that produces legal effects for a person or similarly significantly affects them. Where such a decision is allowed (for example on the basis of explicit consent or as necessary for entering into a contract), the person has the right to human intervention, to express their point of view and to contest the decision. In its SCHUFA judgment (C-634/21) of 7 December 2023, the EU Court of Justice held that a credit agency's score can itself be such a decision if whoever decides on the contract draws on it decisively.
- Article 15(1)(h) GDPR gives the right to know whether automated decision-making exists and to "meaningful information about the logic involved". In its Dun & Bradstreet Austria judgment (C-203/22) of 27 February 2025, the EU Court of Justice clarified that the controller must explain intelligibly the procedure and principles actually applied, that is, which personal data were used and how they affected the result, so that it can be understood and contested. It need not publish a formula or source code. Invoking trade secrets is not enough: protected information must be submitted to the supervisory authority or the court, which decides how much access to give. The case concerned the refusal of a mobile phone contract for ten euros a month.
The sentence "Your application has been assessed repeatedly" does not tell whether a person or the system assessed it again. European regulators state in their guidelines on automated decision-making that human involvement must be meaningful, not a token gesture: if an employee merely confirms a model's output without being able to change it, the decision is still based solely on automated processing. The right to know which personal data Alza processed about me and where it got them applies in any case.
What is about to change
The EU Directive 2023/2225 on credit agreements for consumers (CCD2) changes the rules in exactly this area:
- Article 6 requires that the conditions for being granted credit do not discriminate against consumers legally resident in the EU on grounds of their nationality or place of residence. Different conditions are possible only where duly justified by objective criteria.
- Article 18(8) gives the consumer, where the creditworthiness assessment involves automated processing, the right to a clear and comprehensible explanation of the assessment including the logic and risks involved, to express their point of view, and to request a review of the assessment and of the decision.
- Article 2(2)(h) excludes interest-free deferred payment offered by the seller itself, but for large online sellers only where the whole amount is due within 14 days of delivery. Třetinka gives three months, so by the text of the directive it should fall within its scope. Hire without an obligation or option to purchase (Article 2(2)(g)) is not covered, so these rules may not apply to Alza NEO.
The directive is to apply from 20 November 2026. The Czech amendment to the Consumer Credit Act that transposes it was passed by the Chamber of Deputies in August and by the Senate on 21 October 2026; it now awaits the President's signature. According to the Ministry of Finance it is planned to take effect on 1 February 2027; how exactly it takes over these provisions will be clear from its final text.
Not an isolated phenomenon
Decisions of this kind without an explanation are most visible today in banks. According to Reuters (14 February 2025), since 2022 thousands of Russian citizens living in the EU have struggled to open a bank account or had one closed, even though they are not under sanctions themselves; one of the lawyers it spoke to said banks' legal departments are overly worried about sanctions. The European Commission told the agency it had received few complaints but had followed them up with national authorities. EU rules give everyone legally resident in the Union the right to a basic payment account. In Czechia, Seznam Zprávy described in September 2023 cases in which Raiffeisenbank closed accounts without giving a reason; the bank said it must check clients from countries listed as high-risk very thoroughly.
These cases prove nothing about Alza. They do show that decisions the customer cannot see into are not exceptional, and that EU regulation is moving towards more transparency.
What a customer can do
I'm not a lawyer and this isn't legal advice, but this is the sequence I consider sensible:
- Ask Alza for access to your personal data under Article 15 GDPR, preferably through the contact form (Ostatní → Osobní údaje → Přístup k osobním údajům), where you can write your own questions. The "Žádost o zaslání mých údajů" button in your account sends only a standard export: in my case it contained the profile data, a list of documents and records of Bank iD verification, but no score and no result of the assessment. So ask specifically: which data Alza used to assess the application and where it got them; whether a score was used, who computed it and with what result; whether the decision was made by automated processing and what procedure and principles were applied; whether the employee could have decided otherwise. Alza must reply within a month; in complex cases it can extend this by at most two more months and must tell you in time.
- If automated processing decided, ask for human review under Article 22(3) GDPR and state your point of view.
- Request your records from the databases Alza passes data to, for example CRIF (REPI) and Intrum, and have any errors corrected under Article 16 GDPR. Check the data in your own Alza profile too.
- If no answer comes or it is insufficient, complain to the Czech Office for Personal Data Protection. A suspicion of consumer discrimination can be reported to the Czech Trade Inspection. The Public Defender of Rights can advise within its remit, but the Anti-Discrimination Act does not cover citizenship.
Conclusion
Alza remains a shop where I buy, and I value its service. I am not claiming that it refused me because of my citizenship; I am saying I have no way to find out. A business has the right to choose its customers for rentals and deferred payment. But a customer it turns down should be able to learn on what basis: at least which data and which main factors decided. For automated assessments the GDPR already requires this, and for consumer credit the new directive will soon require it explicitly.