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
Untermainanlage 1
60329 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.

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

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.

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.

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.

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.

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.