Privacy

Deutsche Beteiligungs AG assigns the utmost importance to protecting your privacy and your personal data. With this in mind, we are happy to provide the following information on how we process and use your personal data:

This Data Protection Policy governs the process of personal data of visitors to our website, business partners, shareholders, job applicants, investors in DBAG Funds, journalists/media representatives and newsletter subscribers.

Responsible Person

The Responsible Person (as defined by data protection law) is:

Deutsche Beteiligungs AG
Börsenstrasse 1
60313 Frankfurt/Main, Germany

Processing of personal data

We process your personal data in accordance with the provisions set out in the EU General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act (Bundesdatenschutzgesetz – "BDSG") including applicable supplementary legal regulations.

This document provides an overview of the purposes, legal bases and recipients of processing data of visitors to our website, business partners, shareholder, job applicants, investors in DBAG Funds, newsletter subscribers and journalists/media representatives.

Information for visitors to our website

Thank you for your interest in our Company. Protecting your privacy whilst you are using our website is important to us.

  1. Whilst you may use the Deutsche Beteiligungs AG ("DBAG") website without directly disclosing your identity to us, we use Matomo, a statistics tool outlined in more detail below. Using Matomo, all we find out is the name and location of your Internet Service Provider (host name and server location), the website from where you are visiting us, parts of your IP address (only the first half of this numerical address), and the web pages you call up during your visit. This information is generally not personal, and will only be analysed for statistical purposes. Any exceptions to this principle are outlined below.

  2. We use Matomo, an open-source software tool, for statistical analyses. Matomo uses cookies which permit analysis of your use of Deutsche Beteiligungs AG's website. These 'session' cookies will only be temporarily stored on your computer, and will be deleted as soon as you close your internet browser. Information concerning your use of our internet offer generated via the cookies will be stored on a server operated by MPM Corporate Communication Solutions Media Process Management GmbH, a service provider processing data on behalf of DBAG. Data is recorded for the purposes of identifying and enhancing relevant content within our internet offer; such data will not be disclosed to third parties.

    Your IP address will be anonymised immediately after processing, and prior to saving this information. You can set your internet browser so that it will block cookies; please note that you may not be able to access all functions of our website to their full extent in this case.

    The legal basis for the processing of your personal data is our legitimate interest, pursuant to Article 6 (1) f of the GDPR, to improve our offer and to make it more interesting for you as a user.

    For more detailed information, please refer to https://matomo.org.

  3. You are welcome to submit your query using the contact form provided. Submitting your request in this way is voluntary; you are under no obligation to do so. If you enter and transmit your data to us using the contact form, we will use this data exclusively in order to process your query; we will not forward your data to third parties. The legal basis for the processing of your personal data is Article 6 (1) b of the GDPR, provided that your query is necessary in order to make pre-contractual arrangements; in all other cases, it is our legitimate interest, pursuant to Article 6 (1) f of the GDPR, to process our users' queries.

    How long will personal data of visitors to our website be stored?

    We will only store personal data transmitted to us through using the contact form for the period of time required to process your query, or for any retention period that may be required by law. This is without prejudice to your rights as a data subject, including the right to demand erasure.

  4. On our website we offer you the possibility to subscribe to our newsletter.

    The processing of your personal data within the framework of the DBAG newsletter is based exclusively on your consent pursuant to Art. 6 Paragraph 1 lit. a DSGVO.

    Your consent relates to the processing of the following personal data provided voluntarily by you: Title, first name, surname, e-mail address.

    Your consent serves the purpose of using your e-mail address to send the newsletter to the named address.

    The newsletter informs you about company related news and events.

    We analyse your usage behaviour in each newsletter: Deliveries, openings, clicks, country of origin and the medium used to open the newsletter. The analysis tool of the newsletter provider Cleverreach is used for this purpose.

    You can revoke your consent at any time. If you do not wish to receive any more newsletters in future, you can unsubscribe at any time by sending an e-mail to IR(at)dbag.de or via the unsubscription link which you will find in every newsletter.

Information for business partners

If you are (or would like to become) a business partner of Deutsche Beteiligungs AG, we must record and use certain information about yourself and/or persons within your organisation in order to fulfil our contractual obligations, or to be able to communicate with you. Without this data, we will generally have to decline entering into a contract or executing an order, or to cease performing obligations under an existing contract and terminate it.

What personal data of our business partners do we process?

To the extent required, we will record the first name and family name, any titles or academic degrees, the company name, job function, address, telephone details, e-mail address, gender and language preference of our business partners.

For which purposes and on which legal basis do we process personal data of our business partners?

We use the data set out above in order to fulfil our contractual obligations and/or to communicate with business partners. The legal basis for processing your personal data is Article 6 (1) b of the GDPR.

To whom will we pass on personal data of our business partners?

Deutsche Beteiligungs AG will exclusively process your personal data itself, and will not forward this to any third parties.

How long will personal data of business partners be stored?

We will delete personal data of our business partners ten (10) years after the last documented communication, or as soon as the respective business partner exercises his/her/its right to demand erasure as set out below. This is without prejudice to your rights as a data subject, including the right to demand erasure.

Information for shareholders

If you are a shareholder of Deutsche Beteiligungs AG, we are under a legal obligation to record and use certain information about yourself.

What personal data of shareholders do we process?

DBAG shares are registered no par-value shares. Section 67 of the German Stock Corporation (Aktiengesetz – "AktG") requires such registered shares to be entered into the Company's share ledger stating the holder’s name, date of birth, address, and the number of shares held. Shareholders are obliged to specify these details to the Company.

For which purposes and on which legal basis do we process personal data of shareholders?

DBAG uses your personal data for the purposes provided for by the AktG – in particular, maintaining the share ledger (as set out in more detail below), carrying out general meetings, as well as for giving notice when share ownership exceeds or falls below certain thresholds. The legal basis for processing your personal data is the German Stock Corporation Act in conjunction with Article 6 (1) c of the GDPR.

If you take part in the General Meeting, we are obliged, pursuant to section 129 (1) sentence 2 of the AktG, to include you in the list of participants, stating your name, domicile, the number of shares held, and the type of ownership. Other shareholders and other participants of the General Meeting will be able to inspect these details during the meeting; shareholders will continue to have access for up to two (2) years afterwards (section 129 (4) of the AktG).

Where a shareholder demands that items be placed on the agenda, the Company will publish these items, provided that the requirements under German company law are met, stating the shareholder's name. Likewise, the Company will make counter-proposals or proposals of candidates for election available on the Company's website, provided that the requirements under German company law are met, stating the shareholder's name (for details, please refer to sections 122 (2), 126 (1) and 127 of the AktG).

In addition, we may process your personal data in order to fulfil further legal obligations such as regulatory requirements as well as to comply with retention periods under company, commercial or tax law. For example, where the Company appoints and instructs proxies for the General Meeting, data evidencing the instruction must be documented in a verifiable manner, and retained as well as protected against unauthorised access for three (3) years (section 134 (3) sentence 5 of the AktG). The legal basis for processing your personal data in this case are the respective legal rules in conjunction with Article 6 (1) c of the GDPR.

In individual cases, DBAG will also process your data in order to protect its own legitimate interests pursuant to Article 6 (1) f of the GDPR. This is the case, for example, in the event of a capital increase where individual shareholders must be excluded from information on offers for subscription on the grounds of their nationality or place of residence in order to comply with the securities laws of the countries concerned, or if shareholders must be excluded from invitations to Investor Relations events. Should we intend to process your personal data for any other purpose, we will inform you in advance, in accordance with applicable law.

To whom will we pass on personal data of shareholders?

Banks involved in the purchase, safekeeping or disposal of your shares in DBAG will regularly communicate related details (including those required for maintenance of the share ledger, i.e. nationality, gender, and the submitting bank) to the share ledger. This takes place via Clearstream Banking AG, the central securities depository which is responsible for the technical settlement of securities transactions, and keeps shares in safe custody on behalf of banks, acting as a data processor. We will not forward your personal data outside of Europe.

How long will personal data of shareholders be stored?

We will generally delete or anonymise your personal data as soon as this is no longer required for the purposes set out above, unless we are obliged to maintain the data under a legal obligation to provide evidence, or mandatory retention period. Such obligations to provide evidence or retain data arise under the German Commercial Code (Handelsgesetzbuch – "HGB"), the German Fiscal Code (Abgabenordnung – "AO"), or the German Money Laundering Act (Geldwäschegesetz – "GwG").

Data recorded in connection with General Meetings must generally be retained for three (3) years. Data stored in the share ledger is generally retained for a period of ten (10) years following disposal of the shares. Beyond this, DBAG only retains personal data if this is necessary in connection with claims asserted against DBAG (subject to statutory periods of limitation of up to 30 years). This is without prejudice to your rights as a data subject, including the right to demand erasure.

Information for job applicants

You can submit your application to Deutsche Beteiligungs AG via our website – using the application form provided – or by post. We may not be able to process your application if you do not provide the required data.

What personal data of applicants do we process?

We will record the first name and family name, any titles or academic degrees, address, date of birth, nationality, telephone details and e-mail address of applicants.

For which purposes and on which legal basis do we process personal data of job applicants?

Providing personal data requested in connection with an application is voluntary. The legal basis for the processing of your personal data is the necessity for such processing in order to take a decision on entering into an employment relationship, pursuant to section 26 (1) of the BDSG.

To whom will we pass on personal data of job applicants?

If you use the application form on our website, we will record and compile your personal information separately from other personal data, and will then pass it on to the department responsible within DBAG for carrying out the application proceedings. Your application will be transmitted using HTTPS encryption, whilst the respective data will be stored in our database in unencrypted form. The files (PDF, JPG, GIF, PNG) will be stored within a password-protected area blocked against external access. We will use the details provided with your application exclusively for this purpose. It goes without saying that we will not pass on these details to third parties without your consent.

How long will personal data of job applicants be stored?

We will store personal data of job applicants for a maximum of six (6) months. Once we have rejected an application, we will delete application data, observing statutory retention periods. This is without prejudice to your rights as a data subject, including the right to demand erasure.

Information for investors in DBAG funds

If you have invested in a fund advised by Deutsche Beteiligungs AG, we must record and use certain information about yourself and/or persons within your organisation in order to fulfil our contractual obligations, or to be able to communicate with you. Without this data, we will generally have to decline entering into a contract, or may have to cease performing obligations under an existing contract and terminate it.

What personal data of investors in DBAG Funds do we process?

To the extent required, we will record the first name and family name, any titles or academic degrees, the company name, job function, address, telephone details, e-mail address, gender and language preference of investors in DBAG Funds.

For which purposes and on which legal basis do we process personal data of our investors in DBAG Funds?

We process your personal data exclusively in order to fulfil our contractual obligations, or to be able to communicate with you. The legal basis for processing your personal data is Article 6 (1) b of the GDPR.

To whom will we pass on personal data of investors in DBAG Funds?

Deutsche Beteiligungs AG will exclusively process your personal data itself, and will not forward this to any third parties.

How long will personal data of investors in DBAG Funds be stored?

We will generally delete or anonymise your personal data as soon as this is no longer required for the purposes set out above, unless we are obliged to maintain the data under a legal obligation to provide evidence, or mandatory retention period. This is without prejudice to your rights as a data subject, including the right to demand erasure.

Information for journalists/media representatives

We process specific personal data in order to be able to provide relevant information to journalists and other media representatives, as well as for compliance with legal obligations (such as ad-hoc disclosure).

What personal data of journalists/media representatives do we process?

To the extent required, we will record the first name and family name, any titles or academic degrees, the company name, job function, address, telephone details, e-mail address, gender and language preference of journalists/media representatives.

For which purposes and on which legal basis do we process personal data of journalists/media representatives?

We process your personal data to protect our legitimate interests to provide journalists/media representatives with relevant information and news about the Company. The legal basis for processing your personal data is Article 6 (1) f of the GDPR.

To whom will we pass on personal data of journalists/media representatives?

We will pass on personal data of journalists/media representatives to external service providers only to the extent required to support Deutsche Beteiligungs AG in forwarding invitations to events.

How long will personal data of journalists/media representatives be stored?

We will store personal data of journalists/media representatives only for as long as is required for the purposes set out above. This is without prejudice to your rights as a data subject, including the right to demand erasure.

Information for newsletter subscribers

On our website we offer you the possibility to subscribe to our newsletter.

The processing of your personal data within the framework of the DBAG newsletter is based exclusively on your consent pursuant to Art. 6 Paragraph 1 lit. a DSGVO.

Your consent relates to the processing of the following personal data provided voluntarily by you: E-mail address, surname, first name, title. It serves the purpose of using your e-mail address to send the newsletter to the named address.

The newsletter informs you about company related news and events.

We analyse your usage behaviour in each newsletter. Deliveries, openings, clicks, country of origin and the medium used to open the newsletter are analysed. The systems and technologies of the external provider Cleverreach are used to send the newsletter and analyse user behaviour.

You can revoke your consent at any time. If you no longer wish to receive the newsletter in the future, you can unsubscribe at any time by sending an e-mail to IR(at)dbag.de (or directly via the unsubscription link that you will find in every newsletter). Personal data for the newsletter dispatch will be deleted after withdrawal of your consent.

Your rights as a data subject

Subject to certain requirements, you have the following rights in relation to the processing of your personal data:

Access

Pursuant to Article 15 of the GDPR, you have the right to obtain information concerning your personal data processed by ourselves, and to request a copy of personal data stored about yourself.

Rectification or erasure of data, or restriction of processing

Pursuant to Article 16 of the GDPR, you have the right to have personal data rectified if this is not (or no longer) accurate, or to have it completed should it be incomplete.

You may demand erasure of your personal data, subject to the conditions set out in Article 17 of the GDPR. Your right to erasure is conditional, for example, upon whether we require the data concerning yourself for compliance with a legal obligation. Subject to the conditions stipulated in Article 18 of the GDPR, you have the right to demand a restriction of the processing of data concerning yourself.

Data portability

Pursuant to Article 20 of the GDPR, you have the right to receive the personal data concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format, and to have this data transmitted to another controller without hindrance from ourselves. In exercising this right, you also have the right to have the personal data concerning yourself transmitted directly to another data controller, where technically feasible.

Refusal and withdrawal of consent

You have the right to refuse consent to the processing of your personal data, or to withdraw such consent at any time.

Right to object to processing
Pursuant to Article 21 of the GDPR, you have the right to object, on grounds relating to your particular situation, to processing of personal data concerning yourself – provided that data processing takes place in the public interest, or based on a balancing of interests. To the extent that we process your personal data on the grounds of a balancing of interests, whilst we generally believe that we are able to provide evidence of compelling and legitimate grounds, we will of course examine the merits of each individual case.

Right to complain

You have the right to communicate with the responsible data protection supervisory authority, and to lodge a complaint with that authority if appropriate.

To exercise your rights, please contact our Data Protection Officer:

Deutsche Beteiligungs AG
Data Protection Officer
Untermainanlage 1
60329 Frankfurt/Main, Germany
Phone: +49 69 95787-01
Fax: +49 69 95787-199
E-mail: datenschutz(at)dbag.de

Notwithstanding this, you may contact a data protection supervisory authority. The supervisory authority responsible for DBAG is:

The Data Protection Officer for the State of Hessen
Gustav-Stresemann-Ring 1
65189 Wiesbaden, Germany
PO Box 31 63
65021 Wiesbaden, Germany
https://datenschutz.hessen.de/%C3%BCber-uns/kontakt