Data Protection Policy for the European Platform for Shareholder Identification and Information (DPAii)

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1. General information

The

Bundesanzeiger Verlag GmbH
Amsterdamer Str. 192
50735 Cologne 
Phone: +49 (0) 2 21 / 9 76 68-773
Fax: +49 (0) 2 21 / 9 76 68-278
E-Mail: service(at)bundesanzeiger.de 

operates this website to provide services and information. 
We only process your personal data in compliance with the provisions of applicable data protection law. Definitions of the individual data protection terms are provided in a small glossary under the heading “Definitions”. The rules below inform you about the type, scope and purpose of the collection, processing and use of personal data. This data protection policy only applies to our web pages. If you are forwarded to other sites via links on our pages, please read the policy for handling your data in place there.
Wherever possible, your personal data is encrypted by digital security systems and protected by technical and organisational measures from damage, destruction or unauthorised access.

2. Collection and use of personal data

We collect, store and process the personal data you transmit to us (for example: your name, address and telephone number or e-mail address as well as the data required for invoicing) where this is necessary to process enquiries or orders or for the technical administration of the web pages, for purposes where we have an obligation to do so or for which you have given your consent. The legal basis for processing this data is provided under Article 6 (1) a), b), c), e) and f) EU-GDPR. To facilitate this task, your data may be shared with service providers involved in processing data on our behalf and involved in invoicing. Beyond this, we will not pass on your personal data to any third parties unless we are obligated to do so by reason of mandatory regulations, if this is necessary for the collection of fees or if you yourself so decide.

3. Use and erasure of personal data

To the extent that it is required for the establishment, content or amendment of the contractual relationship, your personal data (customer data), will be used solely for the performance of the contract. We expressly reserve the right to make use of legal permissions and legal bases. In principle, there is a legitimate interest in using your data which we have collected in the course of entering into a contractual relationship with you for marketing purposes. The legal basis for this is Article 6 (1) sentence 1 lit. f GDPR. We process the following data for our own marketing purposes and for third-party marketing purposes. If you contact us by e-mail, fax or telephone, we may request some personal information from you. In each case, we will ask for the data we need to be able to process your contact request in a meaningful way, but as a minimum your last name and first name, e-mail address and telephone number, the legal basis for this is the legitimate interest in processing in accordance with Article 6 (1) c), e) and f) GDPR. In addition to this, you may voluntarily provide us with further data as part of your contact request. The data will be stored by us and used for the purpose of responding to your contact request. The voluntary provision of this data constitutes consent to the use of the data in the above sense. We note any consent to the collection and use of data for our records. The legal basis for data processing is also the consent of the data subject in accordance with Article 6 (1) 

a) EU-GDPR.

For instance, in order to invoice services subject to payment, your name and address have to be passed on to our invoicing provider. Your personal data will not be forwarded to third parties not involved in performance of the contract without your express consent or without a legal basis.
If so ordered by the relevant authorities, in individual cases we are permitted to provide information on customer data to the extent that this is necessary for the purposes of criminal prosecution, measures to ward off danger by the police authorities of the federal states, performance of the statutory tasks of the federal and state authorities for the protection of the constitution, the Federal Intelligence Service or the Military Counter-Intelligence Service or for the enforcement of intellectual property rights.
We carefully examine such requests - should they arise – to the extent that we are able and only forward your data if we judge that the legal obligation does indeed extend to us. In these cases, the legal basis for data processing is then compliance with legal obligations to which the controller is subject pursuant to Article 6 (1) c) GDPR, and any applicable special laws.
The personal data of the data subject will be erased or blocked as soon as the purpose for it being stored no longer applies. Data may continue to be stored if this has been provided for by the European or national legislator in Union regulations, laws or other provisions applying to the controller. Data will also be blocked or erased if a storage period prescribed by these legal norms expires, unless there is a need to continue storing the data by reason of another legal basis.

4. Logging in with a user profile

After the conclusion of the contract, you have the possibility of logging in to our website with your user profile. When you log in on our website, in addition to the data automatically transmitted to us by your Internet browser, we use the following data, which is marked as mandatory or voluntary depending on the purpose of processing:

• your e-mail address
• your user password

Your user profile allows you to use additional parts of our website and to log in for the services you have purchased. The login is necessary for the performance of the contract. Your data will not be passed on to third parties without your consent.
The legal basis for data processing is your consent pursuant to Article 6 (1) sentence 1 lit. a GDPR. If the registration serves the performance of a contract to which you are party or the implementation of steps prior to entering into a contract, the additional legal basis for processing the data is Article 6 (1) sentence 1 lit. b GDPR.
The data will be erased as soon as it is no longer required to achieve the purpose for which it was collected. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.

5. Provision of the website and creation of log files

a. Browser data

For technical reasons and in order to maintain and improve functionality, information your Internet browser transmits to us is automatically collected, stored and, to the extent necessary, forwarded to third parties. The legal basis for processing is Article 6 (1) sentence 1 lit. f GDPR. Our legitimate interest in processing pursuant to Article 6 (1) sentence 1 lit. f GDPR is the operational reliability of the website.
This data is:

• Browser type and version
• Operating system used
• Website you are visiting us from (referrer URL)
• Website you are visiting
• Date and time of your visit
• Your internet protocol data (IP address)
• Volume of data transferred
• Access status (files transferred, file not found, etc.)

This anonymous data is stored separately from any personal data you may have provided and so does not allow us to link it to a specific person. It may be analysed for statistical purposes in order to optimise our website and our products and services.
After analysis, we and our service providers erase this data.
Where data is collected to the extent described, this is essential for the security and operation of the website. For this reason, there is no possibility to object.

b. Anonymised use profiles

Using our website does not require you to provide personal data, unless otherwise stated in this policy. Each time a user accesses the aforementioned web pages and each time a file is accessed, data on this process is stored in a log file. We use this data to make it technically possible for you to visit our site. We also use this data for statistical purposes to improve the design and layout of our website. This data is not used in relation to a specific person. Our legitimate interest in processing pursuant to Article 6 (1) f) GDPR is the operational reliability and functionality of the website.
The following details are stored in the data record each time you access the site or a file:

• Name of the retrieved file
• Date and time of retrieval
• Volume of data transmitted
• Message as to whether retrieval was successful
• Description of the type of web browser used
• Requesting domain
• Country of origin of the domain

After analysis, we and our service providers erase this data.
The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. For this reason, there is no possibility for you to object.

6. Use of cookies and analytics tools

a. Cookies

We use what are known as “cookies” on our website. These are small text files that are sent from our web server to your computer in order to store certain pieces of information (e.g. identification characteristics).
If you use our website anonymously, cookies are used for statistical analysis of the use of this site, including to record new and returning visitors. We also use cookies to measure the extent to which free content is used. To calculate this, our website sends what is called a unit ID to your browser. This is an anonymous code whose sole purpose is to record what content has already been used free of charge.
If you use our website through your user profile, cookies are used to identify your browser for the duration of the visit, including which pages you visit. Our website can also be viewed without cookies being stored. You can deactivate the storage of cookies in your browser settings or set your browser to inform you of a website’s intention to store cookies. In this case, you decide whether to accept the cookie. To be able to use all the functions on our website, though, for technical reasons it is necessary to fully enable temporary cookies. Even if cookies are disabled, our website sends the aforementioned unit ID to your browser to measure the use of free content. The legal basis is our legitimate interest in accordance with Article 6 (1) sentence 1 lit. f GDPR.
We use cookies for proper operation of the website, to provide basic functionalities and to tailor our websites to your preferred areas of interest. This also constitutes our legitimate interest in data processing within the meaning of Article 6 (1) sentence 1 lit. f GDPR.
You can delete cookies already stored on your terminal device at any time. If you wish to block the use of cookies, you can block acceptance of cookies in your browser settings. Please refer to the instructions of your browser provider for the specifics of how this works. For example, for Windows Internet Explorer go to windows.microsoft.com and for Firefox go to support.mozilla.com.
Technically necessary cookies:

• cc 
  • Publisher: Bundesanzeiger Verlag GmbH
  • Description: This is a technically necessary cookie.
  • Lifespan: 1 to 90 days
  • What data is collected: This is a technically necessary cookie.
  • Purpose of data collection: This cookie stores your cookie consent settings.
  • Legal basis: Article 6 | 1 GDPR.
  • Place of processing: Cologne

b. Matomo

With your consent, this website collects and stores data for optimisation purposes using Matomo, an open-source web analytics tool (https://matomo.org). This data allows use profiles to be created using a pseudonym. Cookies may be used for this purpose. The cookies enable recognition of the Internet browser. The data collected using Matomo will not be used to personally identify visitors to this website without the data subject separately granting his or her consent, nor will it be linked to personal data about the bearer of the pseudonym. The software runs solely on the servers of Bundesanzeiger Verlag GmbH. The information generated by the cookie about your use of this website will not be passed on to third parties either. The legal basis for processing is your consent in accordance with Article 6 (1) lit. a GDPR. 
The following cookies are used:

• _pk_id 
  • Type: statistics
  • Lifespan: 13 months
  • Data: visitorID.cookieCreationTimestamp, visitsCount.currentVisitTimestamp, lastVisitTimestamp.­lastEcommerceOrderTimestamp
  • Purpose: stores user details, e.g. the unique visitor ID.
  • Legal basis: Article 6 (1) lit a GDPR
• _pk_ref 
  • Type: statistics
  • Lifespan: 6 months
  • Data: referrer URL
  • Purpose: stores referrer information from the first time you access the website.
  • Legal basis: Article 6 (1) lit a GDPR
• _pk_ses, _pk_cvar, _pk_hsr 
  • Type: statistics
  • Lifespan: 30 minutes
  • Data: Matomo sessionId, if not set on visit, the visitCount is incremented in _pk_id, page specific variable keys and values, Matomo heatmap session recording data.
  • Purpose: stores short-term data relating to visits to the website
  • Legal basis: Article 6 (1) lit a GDPR
• _pk_testcookie 
  • Type: statistics
  • Lifespan: short term (< 1 second)
  • Data: test data
  • Purpose: created and immediately deleted to test whether the user’s browser supports cookies.
  • Legal basis: Article 6 (1) lit a GDPR

Web analytics are disabled in the default settings. You can decide whether a unique web analytics cookie is allowed to be stored in your browser to enable the website operator to collect and analyse different statistical data. If you want to opt out of this at a later date, please select the corresponding option at the following link “Revoke cookie settings” to store the Matomo deactivation cookie in your browser. 

c. Google Ads & Google Ads conversion tracking

We use Google Ads to advertise our products, offers and services online with a view to making more people aware of the high-quality products and services we offer online. In the scope of our advertising activities using Google Ads, we use the conversion tracking tool from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") on our website. Conversion tracking helps us tailor our products and services to your interests and needs far better. Below we provide further details about why we use conversion tracking, what data is stored in the process and how you can stop this data storage. The legal basis for using Google Ads conversion tracking is Article 6 (1) a (consent).

What is Google Ads?

The in-house Google Ads platform makes it possible to create online ads to inform interested people about our products and services. 

What is a conversion?

A conversion occurs when website visitors become active visitors. This happens whenever you click on our ad and then perform another action, such as visiting our website. Google's conversion tracking tool allows us to record what happens after a user clicks on our Google Ads advertisement. For instance, we can see whether products are purchased, services are used or whether visitors have signed up for our newsletter.

Why have we opted to use Google Ads conversion tracking?

We use Google Ads to publicize our products and services on other websites as well, with the aim of ensuring that our advertising campaigns only target those people who are interested in our products and services. The conversion tracking tool allows us to see which keywords, ads, ad groups and campaigns generate the desired customer actions. We see how many customers interact with our ads on a device or in a browser and then make a conversion. This data allows us to calculate our cost-benefit factor, measure the success of individual advertising activities and subsequently optimize our online marketing activities and make our website more attractive. 

What data is stored during Google Ads conversion tracking?

We have incorporated a conversion tracking tag into our website to better analyze certain visitor actions. If you then click on one of our Google Ads advertisements, the "conversion" cookie is stored on your computer (usually in the browser) or mobile device by a Google domain. Cookies are small text files that store information on your computer. The following cookie is set during conversion tracking:

• Name: conversion
• Value: EhMI_aySuoyv4gIVled3Ch0llweVGAEgt-mr6aXd7dYlSAGQ331656656213-3
• Purpose: This cookie stores every conversion you make on our site after visiting us via a Google Ad.
• Expiry date: after 3 months

As soon as you complete an action on our website, Google recognizes the cookie and saves your action as what is known as a conversion. If you surf our website whilst the cookie is still active, we and Google recognize that you found us via our Google Ads advertisement. The cookie is read and sent back to Google Ads with the conversion data.

For more information on how Google uses conversion data and Google's privacy policy see: support.google.com/adwords/answer/93148http://www.google.de/policies/privacy/

d. Google Analytics 4

If you have given your consent, this website uses Google Analytics 4, a web analytics service provided by Google LLC. The controller for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

Nature and purpose of the processing
Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there.

In Google Analytics 4, the anonymization of IP addresses is activated by default. Due to IP anonymization, your IP address will be truncated by Google within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

During your website visit, your user behavior is recorded in the form of "events". Events can be:

• page views
• first visit to the website
• start of session
• web pages visited
• your "click path", interaction with the website
• scrolls (whenever a user scrolls to the end of the page (90%))
• clicks on external links
• internal search queries
• Interaction with videos
• file downloads
• seen / clicked ads
• language settings

Also recorded:

• your approximate location (region)
• date and time of your visit
• your IP address (in shortened form)
• technical information about your browser and the terminal devices you use (e.g. language setting, screen resolution)
• your internet service provider
• the referrer URL (via which website/ via which advertising medium you came to this website)

Purposes of the processing
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website and the success of our marketing campaigns].

Recipients
Recipients of the data are/may be
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor according to Art. 28 DSGVO).
- Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
- Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Third country transfer
For the USA, the European Commission adopted its adequacy decision on July 10, 2023. Google LLC is certified under the EU-US Privacy Framework. Since Google servers are distributed worldwide and a transfer to third countries (for example, Singapore) cannot be completely ruled out, we have also concluded the EU standard contractual clauses with the provider.

Storage period
The data sent by us and linked to cookies are automatically deleted after 14 months. The maximum lifespan of Google Analytics cookies is 2 years. The deletion of data whose retention period has been reached takes place automatically once a month.

Legal basis
The legal basis for this data processing is your consent pursuant to Art.6 para.1 p.1 lit.a DSGVO and § 25 para. 1 p.1 TTDSG.

Revocation
You can revoke your consent at any time with effect for the future by calling up the cookie settings for our products at the bottom left of the screen and changing your selection there. The legality of the processing carried out on the basis of the consent until the revocation remains unaffected.

You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may result in a restriction of functionalities on this and other websites. In addition, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google, by
a. Not giving your consent to the setting of the cookie or
b. downloading and installing the browser add-on to disable Google Analytics HERE.
For more information on Google Analytics' terms of use and Google's privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.

e. Microsoft Ads

Microsoft Ads is an online advertising service provided by Microsoft that enables advertisers to deliver their ads on Microsoft sites and services such as Bing, MSN, Outlook.com, and others. Microsoft Ads uses various technologies and data collection methods to display and optimize personalized ads. This privacy statement explains what personal data is collected in connection with the use of Microsoft Ads and how Microsoft uses that data.
1. responsible party
The data controller for Microsoft Ads within the meaning of data protection law is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA. If you have any questions about Microsoft's privacy practices, you can contact Microsoft's Privacy Officer at: Microsoft Privacy, Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA.
2. What data is collected?
Microsoft Ads collects several types of data to deliver and optimize personalized ads:

• Device and Usage Data: Microsoft Ads collects information about the device you use to access Microsoft services, such as device type, IP address, browser type and version, device settings and configurations, and usage data, such as pages visited and search queries.
• Location Data: If you allow access to location services, Microsoft Ads collects your location to display ads that are relevant to your location.
• Demographic Data: Microsoft Ads may collect information about your age, gender, and other demographic data to provide personalized ads.
• Interest-Based Data: Microsoft Ads may collect data about what ads you have clicked on, what searches you have performed, and what pages you have visited in order to understand your interest in certain topics and deliver personalized ads.
• Cookies and similar technologies: Microsoft Ads uses cookies and similar technologies to collect and store information about your activities on Microsoft services. For more information, please see Microsoft's Cookie Policy.

3. How is the data used?
Microsoft Ads uses the data it collects to deliver and optimize personalized ads. In doing so, the data may also be linked to other Microsoft services and products, such as Microsoft Advertising, Microsoft Analytics, and Microsoft Dynamics 365. Microsoft Ads also uses the data for analytics purposes to measure and improve the effectiveness of ads and to generate reports.
4. How is the data shared?
Microsoft may share personal data within Microsoft Ads with third parties to deliver and optimize personalized ads. These third parties may include advertising networks, marketers

We have chosen to use Microsoft Ads conversion tracking to target our ads to potential customers on other websites. Using the conversion tracking tool, we can see which keywords, ads, ad groups, and campaigns lead to desired customer actions. We can measure how many customers interact with our ads on a device or in a browser and subsequently make a conversion. Based on this data, we can evaluate the success of individual advertising efforts and optimize our online marketing efforts as well as make our website more appealing to achieve a higher return on investment (ROI).
We have included a conversion tracking tag on our website to better analyze specific visitor actions. Now, when you click on one of our Bing ads, a UET tag from a Bing domain is stored on your computer or mobile device. UET tags are small snippets of code that store information on your computer or mobile device.

Once you complete an action on our website, Bing recognizes the UET tag and saves your action as a so-called conversion. As long as you are browsing our website and the UET tag has not expired, we and Bing recognize that you found us through our Bing ad. The UET tag is read and sent back to Bing Ads with the conversion data.

For more information about how Microsoft Ads uses conversion data and Microsoft's privacy policy, please visit: https://advertise.bingads.microsoft.com/en-us/resources/policies/privacy-and-data-protection-policies

7. YouTube

We have incorporated YouTube videos into our website, which are stored on www.YouTube.com and can be played directly from our website. These are all incorporated in “extended data protection mode”, i.e. no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos is the data cited in paragraph 2 transmitted. We have no influence over this data transmission.
When you visit the website, YouTube is informed that you have accessed the relevant subpage of our website. In addition to this, the data listed in the passage “Provision of the website and creation of log files” is transmitted. This happens regardless of whether you have a YouTube account via which you are logged in or whether no user account exists. If you are logged into Google, your data will be directly linked to your account. If you do not wish to have your data associated with your YouTube profile, you need to log out before activating the button. YouTube stores your data as use profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its website. Analysis of this kind is carried out in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, though you will need to contact YouTube to exercise this right.
For more information on the purpose and scope of data collection and processing by YouTube, please refer to its privacy policy. This also provides further information on your rights and setting options to protect your privacy: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the US using Standard Contractual Clauses as the legal basis. 

8. Your rights / contact details / objection

Objection and revocation
You can object to the use of your data without prior consent at any time with effect for the future.
Please note you can revoke any consent you may have granted at any time, including in part, with effect for the future. To do so, it is best to contact the data protection officer by e-mail at:
dsb(at)bundesanzeiger.de
or by post at:
Data Protection Officer
Bundesanzeiger Verlag GmbH,
Amsterdamer Strasse 192, 50735 Cologne
Please note that if you revoke your consent this will only apply from that point onwards and not affect the lawfulness of past processing. In some cases, in spite of your revocation, we will be entitled to further process your personal data on another legal basis - such as for the performance of a contract.
You also have the following rights:

• Articles 13, 14 GDPR - Right to information
• Article 15 GDPR - Right to access: Upon request, we will be happy to inform you about the data stored on you. The information will be provided in text form. Contact see above.
• Article 16 GDPR - Right of rectification
• Article 17 GDPR - Right to erasure with its restrictions, in particular of Article 17(3)(b)
• Article 18 GDPR - Right to restriction of processing
• Article 19 GDPR - Notification
• Article 20 GDPR - Right to data portability
• Article 21 GDPR - Right to object
• Article 22 GDPR - Automated individual decision-making, including profiling
• Article 23 GDPR - Restrictions
• Article 77 GDPR - Right to lodge a complaint

9. Scope of application

This data protection policy applies to the domain www.dpaii.de.

10. Changes and validity of this data protection policy

Any changes to this data protection policy will be announced here on this website and will take effect from the date of publication.

11. Out-of-court online dispute resolution

The European Commission provides a platform for out-of-court online dispute resolution (known as the ODR platform) at ec.europa.eu/consumers/odr/. Please note that we do not participate in dispute resolution procedures before a consumer dispute resolution body.