Who is responsible for the data processing?
Allianz SE, Koeniginstrasse 28, 80802 Munich
You can contact the Data Protection Officer of Allianz SE by post at the following address:
Allianz SE, Group Data Protection Officer, Koeniginstrasse 28, 80802 Munich
ADEUS Aktienregister-Service-GmbH, Munich has been commissioned with maintaining Allianz SE‘s share register. ADEUS is a subsidiary of Allianz SE.
For what purpose and on what legal basis is your personal data processed? From where does Allianz SE obtain your data?
Allianz SE processes your personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Data Protection Act (Bundesdatenschutzgesetz, BDSG), the German Stock Corporation Act (Aktiengesetz, AktG) and all other relevant statutory provisions.
The shares of Allianz SE are no-par value registered shares. For such registered shares, § 67 AktG stipulates that they shall be recorded in the company’s share register stating the name, date of birth, postal and electronic address of the shareholder, as well as the number of shares. The shareholder is legally required to provide this information to the company. The banks involved in the purchase, custody or disposal of your Allianz SE shares regularly relay this, and other information relevant for maintaining the share register (e.g. nationality, gender and remitting bank) to the share register. This is performed via Clearstream Banking AG, which, as the central securities depository, is responsible for the technical clearing and settlement of securities transactions, as well as the custody of shares on behalf of credit institutions.
Allianz SE uses your personal data for the purposes defined in the German Stock Corporation Act. These particularly include the administration of the share register, the preparation, execution and post-processing of general meetings as well as the communication with you as a shareholder. If you register as a shareholder for the general meeting or authorize a proxy to vote, Allianz SE will collect personal data on you and/or your authorized representative. Allianz SE does so to enable shareholders to exercise their rights at the general meeting. In addition, Allianz SE may use your data for the preparation of statistical analyses.
The legal basis for the processing of your personal data is the German Stock Corporation Act in conjunction with Art. 6 para. 1 lit. c) and para. 4 GDPR. In addition, Allianz SE processes personal data to protect legitimate interests in accordance with Art. 6 para. 1 lit. f) GDPR. This, for example, is the case, if you as a shareholder submit questions ahead of a virtual general meeting, which has been convened on the basis of the Act on Reducing the Effects of the COVID-19 Pandemic in Civil, Insolvency and Criminal Procedure Law dated March 27, 2020, and your name is disclosed when addressing your questions at such meeting. This data processing is necessary to protect legitimate interests of Allianz SE, in order to ensure the proper execution of the virtual general meeting (without physical attendance of the shareholders or their representatives).
Where necessary, Allianz SE may also process your personal data to fulfil other statutory obligations, such as regulatory requirements as well as retention obligations under the stock corporation, commercial or tax laws. For example, when shareholders authorize proxies nominated by Allianz SE to vote on their behalf at the general meeting, it is mandatory for the company to keep a verifiable record of the proxy declaration access protected for three years (§ 134 para. 3 sentence 5 AktG). The legal basis for the data processing in such cases is stipulated by the respective statutory obligations in conjunction with Art. 6 para. 1 lit. c) GDPR.
Should Allianz SE intend to process your personal data for any other purpose, it will notify you in advance in accordance with the statutory regulations.
To what categories of recipients might your data by relayed?
External service providers: Allianz SE engages external service providers for the administration of the share register as well as for the handling of the general meeting. The external service providers only receive such personal data from Allianz SE that is necessary to execute their mandate, and they process personal data solely based on Allianz SE’s instructions.
Other recipients: In addition, it may be necessary to provide your personal data to other recipients due to statutory provisions.
For how long will your data remain stored?
The retention period for data recorded in connection with general meetings usually amounts to up to 10 years. The data stored in the share register will usually be retained for a period of 10 years following the disposal of shares. Beyond that, Allianz SE shall retain personal data only if this is necessary in connection with claims asserted against the company (statutory retention period of up to 30 years). As a rule, your personal data shall be deleted or anonymized once it is no longer needed for the aforementioned purposes, and provided statutory documentation and retention obligations do not require Allianz SE to store such data for a longer period.
What are your rights as the data subject?
Subject to certain statutory conditions, you have a right to information, rectification, restriction, objection and erasure regarding your personal data and its processing, respectively, as well as a right to data portability in accordance with Chapter III GDPR in conjunction with § 67e para. 4 AktG.
As shareholder of Allianz SE, you can also visit www.allianz.com/aktienregister-service to view your core personal data stored in the share register and correct your address, if necessary.
Right to object:
If your data is processed in order to protect legitimate interests pursuant to Art. 6 para. 1 lit. f) GDPR, you may object to these processing activities on grounds relating to your particular situation by sending a notice to the address of the Data Protection Officer mentioned above. Allianz SE will then no longer process your personal data, unless Allianz SE has compelling legitimate interests for the processing which override your interests, or the data is processed for the purpose of asserting, exercising or defending legal claims.
Do you have questions. comments or complaints?
If you have any questions concerning data protection in connection with the general meeting or the share register, please contact our hotline at firstname.lastname@example.org or +49 89 3800 7555.
If you have any comments or complaints, you also have the opportunity to contact the aforementioned Data Protection Officer or a data protection regulatory authority. The data protection regulatory authority competent for Allianz SE is:
Bayerisches Landesamt für Datenschutzaufsicht
Last update: December 2020