Information on data protection for shareholders of Allianz SE and their representatives
Who is responsible for the data processing?
You can contact the Data Protection Officer of Allianz SE by post and e-mail at the following address:
Group Data Protection Officer
ADEUS Aktienregister-Service-GmbH, Munich, has been commissioned with maintaining Allianz SE‘s share register. ADEUS is a subsidiary of Allianz SE.
From where does Allianz SE obtain your data?
If you become a shareholder of Allianz SE, we process your personal data to run the share register. The shares of Allianz SE are no-par value registered shares. For such registered shares, § 67 of the German Stock Corporation Act (Aktiengesetz) 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. As a shareholder you are 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 submitting 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.
If you register as a shareholder for the General Meeting or exercise shareholder rights, Allianz SE will process personal data of yours. In case of (statutory) authorizations of third parties, we will also process personal data on your representatives.
Furthermore, we process personal data on you if you register for the e-mail dispatch of the invitation to General Meetings.
Finally, if you approach us and make inquiries, we process the personal data provided by you to answer your inquiry.
For what purpose and on what legal basis is your personal data processed?
Allianz SE processes your personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Data Protection Act (Bundesdatenschutzgesetz), the Regulation on the European Company (Verordnung (EG) Nr. 2157/2001 über das Statut der Europäischen Gesellschaft), the German Stock Corporation Act and all other relevant statutory provisions.
First, 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, including the enabling of exercising shareholder rights prior to and during the General Meeting, such as the right to submit video statements prior to the General Meeting and to hold live speeches and submit shareholder proposals during the Meeting, as well as
- the communication with you as a shareholder.
In these cases, the legal basis for the processing of your personal data are the provisions of the Regulation on the European Company and the German Stock Corporation Act in conjunction with Art. 6 para. 1 sub-para .1 lit. c) and para. 4 GDPR, respectively.
In addition, we process your personal data to protect legitimate interests, for example to prepare statistical analyses or to facilitate communication with you as a shareholder, e.g., by storing your gender for the right form of address. In such cases, the legal basis for the processing of your personal data is Art. 6 para. 1 sub-para. 1 lit. f) GDPR.
The legal basis for the processing of your personal data for the purpose of the e-mail dispatch of the invitation to General Meetings subsequent to your registration is Art. 6 para. 1 sub-para. 1 lit. a) GDPR. If you transfer personal data to us in the course of an inquiry, the legal basis for processing such data for the purpose of answering your inquiry is also Art. 6 para. 1 sub-para. 1 lit. a) GDPR.
Lastly, 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 persons appointed by the Company to vote on their behalf at the General Meeting, it is mandatory to keep a verifiable record of the proxy declaration access protected for three years (§ 134 para. 3 sentence 5 German Stock Corporation Act). The legal basis for the data processing in such cases is stipulated by the respective statutory obligations in conjunction with Art. 6 para. 1 sub-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 be relayed?
Next to Allianz SE, external service providers commissioned by Allianz SE to execute the General Meeting, and guests, only shareholders and their representatives that have access to the Online Service have access to the live webcast of the General Meeting. Access to video statements submitted prior to the General Meeting is limited to shareholders and their representatives who have registered for the General Meeting in time.
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.
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 that 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 GPDR in conjunction with § 67e para. 4 German Stock Corporation Act.
Right to object:
If your data is processed in order to protect legitimate interests pursuant to Art. 6 para. 1 sub-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 email@example.com 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: March 2023