DATA PROTECTION DECLARATION (INCLUDING LEGALLY REQUIRED INFORMATION CONTENT)

Data protection information for clients and
prospective clients

Information on data protection concerning our data processing in accordance with Article (Art.) 13, 14 and 21 of the General Data Protection Regulation (GDPR)


We take data protection seriously and hereby inform you about how we process your data and what claims and rights you are entitled to according to the statutory data protection regulations. Valid from 25 May 2018


1. Responsible bodies and contact details for data processing:


Swiss Life Asset Managers Deutschland GmbH
– Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de 		Swiss Life Insurance Asset Management GmbH
– Data Protection –
Zeppelinstrasse 1
85748 Garching near Munich
DSB-SwissLifeAsset@he-c.de


SL AM Development Bergedorf 1 GmbH
– Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de 		SL AM Development Bergedorf 2 GmbH
– Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de


Swiss Life Asset Managers Luxembourg Niederlassung Deutschland
– Data Protection –
Hochstrasse 53
60313 Frankfurt am Main
DataprotectionAM@swisslife.de

SL AM Aurum GmbH & Co. KG
 – Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de


SL AM Development Commercial GmbH
– Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de

SL AM Development Residential GmbH
 – Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de


BEOS AG
– Data Protection –
Kurfürstendamm 188
10707 Berlin
Datenschutz-Beos@he-c.de

BEREM Property Management GmbH
 – Data Protection –
Kurfürstendamm 188
10707 Berlin
Datenschutz-Beos@he-c.de


PE Reiterstaffel GmbH & Co. KG
 – Data Protection –
Clever Str. 36
50668 Cologne
DSB-SwissLifeAssetManagers@he-c.de

Contact details of the data protection officer of Swiss Life Asset Managers Deutschland GmbH, Swiss Life Insurance Asset Managers GmbH, Swiss Life Kapitalverwaltungsgesellschaft GmbH and Swiss Life Asset Managers France:

Harald Eul
HEC Harald Eul Consulting GmbH
Auf der Höhe 34
DE-50321 Brühl

If you have any questions on the subject of data protection, you can contact the relevant data protection responsibles or the data protection officer in confidence at any time.

2. Purposes and legal basis according to which we process your data

We process personal data in accordance with the stipulations of the General Data-Protection Regulation (GDPR), the German Federal Data-Protection Act (Bundesdatenschutzgesetz – BDSG) and other applicable data-protection provisions (details are provided in the following). The details of which data are processed and how they are used depends largely on the services requested or agreed in each case. Further details or additions for the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provided to you (e. g. in the context of the use of our website or our terms and conditions). In addition, this data protection information may be updated from time to time, as you may find out from our website www.swisslife-am.com

2.1 Purposes of contract fulfilment or pre-contractual measures (Art. 6, section 1 b of the GDPR)

The processing of personal data is carried out in order to carry out our contracts with you and the execution of your orders as well as to carry out measures and activities within the framework of pre-contractual relations, e. g. with interested parties. In particular, the processing thus serves to provide real estate related services, in particular marketing, letting, acquisition and sale of real estate according to your orders and wishes and include the necessary services, measures and activities. This essentially includes contract-related communication with you, Credit checks, the verifiability of transactions, orders and other agreements as well as quality control by means of appropriate documentation, goodwill procedures, measures to control and optimize business processes as well as the fulfilment of general duties of care, control and supervision by affiliated companies (e. g. Parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, accounting and tax assessment of operational services, risk management, assertion of legal claims and defence in the event of legal disputes; ensuring IT security ((inter alia system and plausibility tests) and general security, including building and plant security, securing and exercising domestic authority (e. g. by means of access controls); guaranteeing the integrity, authenticity and availability of data, preventing and investigating criminal offences; control by supervisory bodies or supervisory authorities (e. g. auditing).

2.2 2.2 Purposes within the framework of a legitimate interest on our part or of third parties (Art. 6, section 1 f of the GDPR)
Above and beyond the actual fulfilment of the (pre-) agreement, we process your data whenever this is necessary to protect legitimate interests of our own or of third parties, in particular for the following purposes:
  • advertising or market and opinion research, as far as you have not objected to the use of your data;
  • obtaining information and exchanging data with credit agencies where this goes beyond our economic risk;
  • the examination and optimization of processes for needs analysis;
  • the further development of services and products as well as existing systems and processes;
  • the disclosure of personal data within the framework of due diligence in the course of company sale negotiations;
  • for comparison with European and international anti-terrorist lists, insofar as this goes beyond the legal obligations;
  • the enrichment of our data, e. g. by using or researching publicly accessible data;
  • statistical evaluations or market analysis;
  • of benchmarking;
  • the assertion of legal claims and defence in legal disputes which are not directly attributable to the contractual relationship;
  • the restricted processing of data, if a deletion is not possible or only possible with disproportionately high effort due to the special type of storage;
  • the development of scoring systems or automated decision-making processes;
  • the prevention and investigation of criminal offences, if not exclusively for the fulfilment of legal requirements;
  • the anonymization of personal data;
  • building and plant security (e. g. by means of access control and video surveillance), insofar as this goes beyond the general duties of care;
  • internal and external investigations, safety reviews;
  • internal fraud prevention in connection with the performance of a contract as well as pre-contractual measures, insofar as not exclusively for the fulfillment of legal requirements
  • any monitoring or recording of telephone conversations for quality control and training purposes;
  • Preservation and maintenance of certifications of a private-law or official government nature;
  • the seizure and exercise of domestic authority by means of appropriate measures as well as video surveillance for the protection of our customers and employees as well as for securing evidence in the event of criminal offences and their prevention.

2.3 Purposes within the framework of your consent (Art. 6, section 1 a of the GDPR)
Your personal data can also be processed for certain purposes (e.g. use of company communication systems for private purposes; photographs/videos of you for publication in the Intranet/Internet) including as a result of your consent. As a rule, you can revoke this consent at any time. This also applies to the revoking of declarations of consent that were issued to us before the GDPR went into effect, i.e. prior to 25 May 2018. You shall be separately informed about the consequences of revocation or refusal to provide consent in the respective text of the consent. Generally speaking, revocation of consent only applies to the future. Processing that takes place prior to consent being issued is not affected by such and remains lawful

2.4. Purposes relating to adherence to statutory requirements (Art. 6, section 1 c of the GDPR) or in the public interest (Art. 6, section 1 e of the GDPR)

Just like any actor which takes part in business life, we are also subject to a large number of legal obligations. These are primarily statutory requirements (e.g. commercial and tax laws), but also if applicable supervisory law or other requirements set out by government authorities. The purposes of processing may also include identity and age checks, prevention of fraud and money laundering (e.g. comparisons with European and international anti-terror lists), compliance with control and notification obligations under tax law as well as the archiving of data for the purposes of data protection and data security as well as for purposes of audits by tax advisors/auditors, fiscal and other government authorities. In addition, it may be necessary to disclose personal data within the framework of official government/court measures for the purposes of collecting evidence, law enforcement and criminal prosecution or the satisfaction of civil law claims.

3. 3. The categories of data that we process as long as we do not receive data directly from you, and its origin

If necessary for the contractual relationship with you and the activities performed by you, we may process data which we lawfully receive from other offices or other third parties (e.g. commercial or address sales agencies). In addition, we process personal data that we have lawfully collected, received or acquired from publicly accessible sources (such as, for example, commercial registers and association registers, civil registers, the press, Internet and other media) if such is necessary and we are allowed to process this data in accordance with statutory provisions.

Relevant personal data categories may in particular be:
  • personal details (name, date of birth, place of birth, nationality, marital status, profession/sector and comparable data)
  • contact details (address, email address, telephone number and comparable data)
  • address data (population register data and comparable data)
  • payment confirmation/confirmation of cover for bank and credit cards
  • information about your financial situation (creditworthiness data including scoring, i. e. data for assessing the economic risk)
  • customer history
  • data about your use of the telemedia offered by us (e. g. time of access to our websites, apps or newsletter, clicked pages/links of us or entries and comparable data)
  • video data

4. Recipients or categories of recipients of your data

At our company, your data is received by those internal offices or organisational units that need such to fulfil our contractual and statutory obligations or that require such data within the framework of processing and implementing our legitimate interests. Your data is disclosed/passed on to external offices and persons solely
  • in connection with the execution of the contract
  • for purposes where we are obligated or entitled to give information, notification or forward data (e.g. employer’s liability insurance association, health insurance schemes, fiscal authorities) in order to meet statutory requirements or where the forwarding of data is in the public interest (see number 2.4)
  • to the extent that external service-provider companies commissioned by us process data as contract processors or parties that assume certain functions (e.g. external data centres, support and maintenance of IT applications, archiving, document processing, call centre services, compliance services, controlling, data screening for anti-money laundering purposes, data validation and data protection. plausibility check, data destruction, purchasing/procurement, customer administration, lettershops, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutions, printing plants or companies for data disposal, courier services, logistics)
  • as a result of our legitimate interest or the legitimate interest of the third party within the framework of the purposes cited under number 2.2 (e.g. to government authorities, credit agencies, collection agencies, attorneys, courts of law, appraisers, companies belonging to company groups and bodies and control instances)
  • if you have given us consent to transmit data to third parties.

We shall moreover refrain from transmitting your data to third parties if we have not informed you of such separately.If we commission service providers within the framework of processing an order, your data will be subject there to the security standards stipulated by us in order to adequately protect your data. In all other cases, recipients may only use the data for purposes for which the data has been sent to them.

5. Length of time your data is stored

We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.
Above and beyond this, we are subject to various retention and documentation obligations that emanate inter alia from the German Commercial Code (HGB) and the German Tax Code (AO), as well as the Makler- und Bauträgerverordnung (MaBV) The periods and deadlines for retention and/or documentation stipulated therein are up to ten years beyond the end of the contractual relationship or the pre-contractual legal relationship.
Furthermore, special statutory provisions may require longer retention such as for example the preservation of evidence in connection with statutory time-barring provisions (statute of limitations). Under §§ 195 ff. of the German Civil Code (BGB), the regular time-barred period is three years, but time-barred periods of up to 30 years may also be applicable.
If the data is no longer required to meet contractual or statutory obligations and rights, it is regularly deleted unless its further processing – for a limited period – is necessary to fulfil the purposes listed under number 2.2 due to an overriding legit-imate interest. Such an overriding legitimate interest is deemed to be the case, for example, if it is not possible to delete the data as a result of the special type of storage or such is only possible at an unreasonably great expense and processing for other purposes is excluded by appropriate technical and or-ganisational measures.

6. Processing of your data in a third country or through an international organisation

Data is transmitted to offices in countries outside the European Economic Area EU/EEA (so-called third states) whenever such is necessary to meet a contractual obligation towards you (e.g. if you are despatched to another country), such is required by law (e.g. notification obligations under tax law), such is in the legitimate interest of us or a third party or you have issued us your consent to such.
At the same time, your data may be processed in a third country including in connection with the involvement of service providers within the framework of the processing of the order. If no decision has been issued by the EU Commission regarding the ensurance of an adequate level of data protection for the respective country or for one or more specific sectors within a third country, appropriate contracts (such as EU standard contracts) and additional measures may be used as a basis for the transfer. Information on the appropriate or adequate safe-guards and on the possibility of obtaining a copy from you can be requested from the company data protection officer.

7. Your data-protection rights
If certain conditions are met, you can assert your data-protection rights against us
  • Thus, you have the right to receive information from us on the data stored on you in accordance with the rules of Art. 15 of the GDPR (if applicable with restrictions in accordance with § 34 of the German Federal Data-Protection Act (BDSG))
  • If you so request, we shall correct data stored on you in accordance with Art. 16 of the GDPR if such data is incorrect or flawed.
  • If you so desire, we shall delete your data in accordance with the principles of Art. 17 of the GDPR if such is not prevented by other statutory provisions (e.g. statutory retention obligations or the restrictions laid down in § 35 of the German Federal Data-Protection Act (BDSG)) or an overriding interest on our part (for example, to defend our rights and claims)
  • Taking into account the preconditions laid down in Art. 18 of the GDPR, you can demand that we restrict the processing of your data.
  • Furthermore, you can file an objection to the processing of your data in accordance with Art. 21 of the GDPR, as a result of which we have to stop processing your data. This right of objection only applies, however, if very special circumstances characterise your personal situation, whereby the rights of our company may run counter to your right of objection.
  • You also have the right to receive your data in accordance with the arrangements laid down in Art. 20 of the GDPR in a structured, commonplace and machine-readable format or transmit such data to a third party.
  • You furthermore have the right to revoke consent that has been issued to us to process personal data at any time effective into the future (see number 2.3).
  • You are in addition entitled to file a complaint with a data-protection supervisory authority (Art. 77 of the GDPR). We recommend, however, to first always send a complaint to our data-protection officer.

Whenever possible, your applications for the exercise of your rights should be sent in writing to the address stated above or addressed directly to our data-protection officer.

8. Scope of your obligations to provide us your data

You only need to provide data that is necessary for the commencement and performance of the business relationship or for a pre-contractual relationship with us or the collection of which we are required by law. Without this data, we are generally not able to conclude the agreement or continue to perform such. This may also relate to data that is required later within the framework of the contractual relationship. If we request data from you above and beyond this, you shall be informed about the voluntary nature of the information separately.

9. 9. Presence of an automated decision made in individual cases (including profiling)

We do not use any purely automated decision-making procedure as set out in Article 22 of the GDPR. If we do institute such a procedure in individual cases in the future, we shall inform you pursuant hereto separately if this is required by law

Under certain circumstances, we may process your data in part with the aim of evaluating certain personal aspects (profiling). In order to provide you with targeted information and advice on products, we may use evaluation tools. These enable a needs-oriented product design, communication and advertising including market and opinion research.

Such procedures can also be used to assess your solvency and creditworthiness as well as to combat money laundering and fraud. “Score values” can be used to assess your creditworthiness and creditworthiness. In the case of scoring, the probability is calculated using mathematical methods with which a customer will meet his payment obligations in accordance with the contract.

Such score values thus support us, for example, in assessing our creditworthiness, decision-making in the context of product deals and are incorporated into our risk management. The calculation is based on mathematically and statistically recognised and proven methods and is based on your data, in particular income, expenditure, existing liabilities, profession, employer, length of service, experience from the previous business relationship, repayment of previous loans in accordance with the contract and information from credit agencies.

Information on nationality and special categories of personal data according to Art. 9 GDPR are not processed.
Information about your right to object Art. 21 GDPR
1. 1. You have the right to file an objection at any time against processing of your data which is performed on the basis of Art. 6, section 1 f of the GDPR (data-processing on the basis of a weighing out of interests) or Art. 6, section 1 e of the GDPR (data-processing in the public interest). The precondition for this, however, is that there are grounds for your objection emanating from your special personal situation. This also applies to profiling that is based on this purpose in the meaning of Art. 4, no. 4 of the GDPR.
If you file an objection, we shall no longer process your personal data unless we can demonstrate compelling reasons warranting protection for the processing that outweigh your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
2. 2. We will also use your personal data in order to perform direct advertising. If you do not want to receive any advertising, you have the right to file an objection to such at any time. This also applies to the profiling to the extent that it is connected with such direct advertising. We shall respect this objection with effect into the future. .

We shall no longer process your data for the purpose of direct advertising if you object to processing for this purpose.

The objection can be filed without adhering to any form requirements and should if possible be sent to

Swiss Life Asset Managers Deutschland GmbH
z. Hd. Rechtsabteilung
Clever Str. 36
50668 Köln

Status of the data protection information 28.11.2023



PART 2: SUPPLEMENTARY DATA PROTECTION INFORMATION FOR OUR WEBSITE

With the following data protection information, we would like to explain to you in more detail how your data is handled when you use our Websites.

1. Visiting the website Each time you visit our website, our systems automatically collect data and information from the computer system of the calling computer (personal data that your browser transmits to our server). This also occurs if you do not register or otherwise transmit information to us, for example by actively entering it. The following data is collected in any case when visiting our websites:
  • IP address of the user
  • Date and time of the request or access
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request originates (from which the user’s system accesses our website)
  • Website accessed by the user’s system via our website
  • Information about the browser type and version used
  • Operating system and its interfaceLanguage and version of the browser software

The storage of the aforementioned data is generally only temporary for the duration of the session and is necessary to enable the proper operation and display of the website. This processing of your data also serves the purpose of evaluating and ensuring system security and stability as well as other administrative purposes. If your data is stored in our log files, this is also only done to ensure the functionality of our websites. In addition, we use the data to optimize and ensure the security of our information technology systems. The legal basis for the processing and storage of your personal data is Art. 6 para. 1 sentence 1 lit. f GDPR. Your data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If your data is stored in log files, this is the case after five days at the latest. Data is only stored beyond this period in exceptional cases, for example if this is necessary for technical reasons or to improve our systems. In this case, the IP addresses of the users are deleted or anonymized so that they can no longer be assigned.


2 Contact form

A contact form is integrated on our website, which you can use to contact us or the broker commissioned by us and named in the input mask. When using the contact form, the data entered in the input mask is collected and, if necessary, transmitted to the broker for the purpose of establishing contact. In addition, your IP address and the date and time of the inquiry are stored. The legal basis for the processing of your data when using the contact form is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. The processing of personal data from the input mask is only used to process your contact with us or the broker.


3 Electronic newsletter

When sending our electronic newsletter to which you can subscribe, we collect and process the personal data you enter in the input screen. We process your e-mail address in order to contact you for the purpose of sending you our electronic newsletter and for information on other products, services or other activities. The legal basis is your consent Art. 6 para. 1 sentence 1 lit. a) GDPR. You can revoke your consent at any time with effect for the future and thus unsubscribe from receiving information about current and future products, services or other information about us. You can declare your revocation by clicking on the link provided in every newsletter e-mail or by sending a message to our contact details. If you object to the use of your data, we will no longer send you promotional communications.

4

General information on the use of cookies
Cookies are stored on your computer when you visit and use our website. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. Some cookies are absolutely necessary for the operation of our website. Other cookies are used for statistical purposes or to analyze access to our website or for marketing purposes or to be able to offer you the use of external media. Both temporary/session cookies and longer-stored/permanent cookies are used. Temporary cookies are deleted as soon as you close your browser. Permanent cookies are retained for a longer period of time, but can be deleted manually at any time. Some of the cookies are set by third parties. The legal basis for data processing when using strictly necessary cookies is § 25 para. 2 no. 2 TTDSG, Art. 6 para. 1 sentence 1 lit. f GDPR, when using all other cookies your consent according to § 25 para. 1 TTDSG, Art. 6 para. 1 sentence 1 lit. a GDPR. If we do not process your data on the basis of your explicit consent, your personal data will only be processed to the extent necessary to protect our legitimate interests or the legitimate interests of a third party and not outweigh your interests or fundamental rights and freedoms that require the protection of personal data. Detailed information about the use of the respective cookies, in particular about their purpose, their legal basis, the respective duration of their function and the extent to which they are set by third parties or third parties have access to the data collected via the cookies, can be found in addition to the information in our privacy policy in our cookie banner on our website. You can call this up again at any time by clicking on the icon at the bottom left of the screen. You can consent to the use of the respective categories of cookies individually. You can change or revoke your consent at any time in the cookie banner.

5 Request by e-mail, telephone or fax

If you contact us by email, telephone or fax, we will store and process your request, including all resulting personal data, for the purpose of processing your request. This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested. You can withdraw your consent at any time with effect for the future.


6 Links to other websites

Our website may contain links to other websites. We have no influence on whether their operators comply with data protection regulations. We also have no influence on the legality of the content of these websites. We therefore reject any responsibility for the content of other websites.

7 Questions and comments

If you have any questions, suggestions or comments on the subject of data protection, please contact:
Swiss Life Asset Managers Deutschland GmbH
Attn: Legal Department
Clever Str. 36
50668 Köln

Our supplementary privacy policy for the website and the information on data protection regarding our data processing in accordance with Articles (Art.) 13, 14 and 21 GDPR PART 1 and PART 2 may change from time to time. We will publish all changes on our website. We will make older versions available to you on request at the address given under Part 2 questions and comments.

Contact us:

REANOVO
Insterburger Straße 16
60487 Frankfurt am Main

E-mail: sgoerner@optima-gmbh.de

OPTIMA, a company of Reanovo Germany.

Legal notice

© 2023 SWISS LIFE ASSET MANAGERS

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