Information on data protection for shareholders of LEONI AG
New rules on data protection have applied under the EU’s General Data Protection Regulation (GDPR) since 25 May 2018. Observance of requirements under data protection legislation is very important to LEONI AG (hereinafter ‘we’ or ‘us’). With the information provided below, we would like to inform you about the processing of your personal data and the rights to which you are entitled under data protection law.
The party responsible for processing personal data is LEONI AG. You can contact LEONI AG at:
Corporate Investor Relations
Phone: +49 911 2023-0
Fax: +49 911 2023-455
If you have any comments or questions concerning the processing of personal data, you can contact the Data Protection Officer of LEONI AG at:
Corporate Data Protection, Data Protection Officer
Phone: +49 911 2023-0
Fax: +49 (911) 2023-455
Purposes of and legal bases for processing:
We process your personal data based on observing the GDPR, the German Federal Data Protection Act (BDSG), the German Stock Corporation Act (AktG) and all other pertinent legal requirements.
Shares in LEONI AG are registered shares. For registered shares, Section 67 of the German Stock Corporation Act (AktG) requires that these are entered in the Company's share register stating the name, date of birth and address of the shareholder as well as – in the case of no-par-value shares – the number held and the share number. The shareholder is as a matter of principle obliged to give the Company these details.
Normally, the credit institutions / custodian banks involved in the purchase, disposal or keeping of registered shares will pass on to us the mandatory information and other details (e.g., along with the aforementioned data, also the citizenship, gender, occupational group and remitting bank) relevant to keeping the share register.
We use your personal data (e.g. name and contact details, number of shares, class of shares, type of share ownership, number of the admission ticket to the Annual General Meeting) as well as, where applicable, the personal data on your shareholder representatives for the purposes stipulated in the German Stock Corporation Act; especially for keeping the share register, communicating with you as a shareholder and holding annual general meetings. The processing of personal data is legally required for these purposes. The legal basis for processing your personal data is the German Stock Corporation Act in conjunction with Article 6 (1) sentence 1 (c) of the General Data Protection Regulation (GDPR).
We also use your data based on Article 6 (1) sentence1 (c) and (4) of the GDPR for purposes that are consistent with the aforementioned ones (especially for generating statistics, e.g. for presenting shareholder trends, number of transactions and for overviews of the largest shareholders).
We also process your personal data to fulfil such other legal requirements as regulatory stipulations as well as record-keeping obligations under stock corporation, commercial and tax law. To conform to requirements under stock-corporation law we must, when authorising the proxies appointed by the Company for the Annual General Meeting, for example, verifiably retain the data that serves to prove the authorisation. The respective requirements under Article 6 (1) sentence 1 (c) of the GDPR serve as the legal basis for processing in this case.
In some cases, we will also process your data so far as required to safeguard the legitimate interests of LEONI AG (Section 6 (1) sentence 1 (f) of the GDPR), among other reasons for statistical purposes, to process contact and service enquiries, sending annual reports or participation in the Annual General Meeting as a guest.
On our AGM shareholder portal and as a matter of principle, we use your personal data only for the purpose for which you have provided us with the data; for example, to give you access to services related to the Annual General Meeting, for individual and electronic registration on the shareholder portal, to document your online registration to the Annual General Meeting and entrance ticket order, to document the online order, to document your authorised proxy at the Annual General Meeting and any instructions you may have issued, to contact you in reply to any enquiries concerning the Annual General Meeting or to give you access to certain information.
If you consented on our AGM shareholder portal to being contacted electronically for mailing of the invitation to the Annual General Meeting, for participation in a shareholders’ prize draw or for mailing of other LEONI AG information, we will process your e-mail address based on the respectively issued consent (Article 6 (1) sentence 1 (a) of the GDPR).
Should we wish to process your personal data for a purpose not previously stated, we would notify you in advance and in line with the legal requirements.
Recipients of your data:
To some extent, we use third-party service providers as well as affiliated companies, who will be given access to your personal data as part of the tasks assigned to them, to keep the share register as well as hold the Annual General Meeting (e.g. for printing and sending the invitation documents and for carrying out the Annual General Meeting). As part of such task processing, our partners are carefully selected and are obliged under Article 28 of the GDPR to observe LEONI AG’s data protection standards. The service providers and affiliated companies that we commission will process your personal data exclusively in accordance with our instruction and only to the extent required to perform the commissioned service. All employees of LEONI AG, its affiliated companies and the staff of the commissioned service providers who have access to and/or process your personal data are obliged to treat this data confidentially.
We might furthermore be obliged to pass your personal data to such other recipients as authorities to fulfil legal reporting obligations.
If you participate in the Annual General Meeting, other shareholders of LEONI AG can, in accordance with Section 129 of the German Stock Corporation Act (AktG), view your personal data as recorded in the register of participants for up to two years after the Annual General Meeting. If you wish to submit an application for an addition to the agenda, countermotions or election nominations, we may under certain circumstances be obliged to publish your name.
Transfers to third countries:
If we were to pass on your personal data to service providers outside the European Economic Area (EEA), this would occur only to the extent that the EU Commission has confirmed the third country has an appropriate level of data protection or other appropriate data protection guarantees (e.g. binding data protection regulations within entities or an agreement on the EU Commission’s standard contractual clauses).
Detailed information in this regard as well as on the data protection level of service providers in third countries can be requested from us via the contact details stated above.
As a matter of principle, we anonymise or erase your personal data as soon as it is no longer required for the stated purposes, your personal data is no longer needed for possible administrative and court proceedings and there are no other legal proofing and record-keeping obligations (e.g. under the German Stock Corporation Act, the German Commercial Code or tax code) or justifications for storage.
The period for storing data recorded in connection with the Annual General Meeting is normally up to three years.
We are normally obliged to keep the data stored in the share register for another ten years after the shares are sold. Beyond that, we keep your personal data only in individual cases as required, for example, in connection with claims.
Your rights as a data subject:
Under the legal provisions and via the contact details stated above, you have the right to access (Article 15, GDPR) to your processed personal data as well as to rectification (Article 16, GDPR) or erasure (Article 17, GDPR) or to restriction of processing (Article 18, GDPR).
You furthermore have the option of contacting the responsible regulatory authority.
Right to object (Article 21, GDPR): If we process your data to safeguard legitimate interests (Article 6 (1) sentence 1 (f) of the GDPR), you may object where there are reasons due to your particular situation that override such data processing. Please submit your objection via the contact details stated above.
Right to withdraw consent (Article 7 (3), GDPR): If we process your personal data based on consent you have issued (Article 6 (1) sentence 1 (a) of the GDPR), you may withdraw this consent at any time. Please submit your withdrawal of consent via the contact details stated above.
Right to data portability (Article 20, GDPR): If we process your personal data based on consent you have issued (Article 6 (1) sentence 1 (a) of the GDPR), you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.
Our general notes on data protection, especially concerning use of LEONI’s website, can be found at https://www.leoni.com/en/data-protection/.