Risk-based authentication (RBA) extends authentication mechanisms to make them more robust against account takeover attacks, such as those using stolen passwords. RBA is recommended by NIST and NCSC to strengthen password-based authentication, and is already used by major online services. Also, users consider RBA to be more usable than two-factor authentication and just as secure. However, users currently obtain RBA's high security and usability benefits at the cost of exposing potentially sensitive personal data (e.g., IP address or browser information). This conflicts with user privacy and requires to consider user rights regarding the processing of personal data. We outline potential privacy challenges regarding different attacker models...