Did you also cite the part where you are being financially supported by Bertelsmann Stiftung who have a competing product (Arvato Infoscore)? Though I am not sure if it is as bad as they claim...
c. "The SCHUFA is the best known credit reporter & market leader. In our project description we ask: The SCHUFA & other credit bureaus must publicly and permanently explain how their score works and which models / assumptions are based on it (traceability)"
They also have a legal arm (Haas & Partner) in the same building (again "independent"), who collect legal fees on top of Infoscore's debt collection fees -- a practice that has been deemed illegal by several federal courts.
The legal arm is largely automated, so the "lawyer" fees are questionable.