Information for shareholders, the shareholder representatives and other participants in the General Shareholders' Meeting of Porsche Automobil Holding SE on the processing of their personal data
Compliance with the provisions of data protection law is very important to Porsche Automobil Holding SE („Porsche SE“ – hereinafter „we“ or „us“).
In the following, we would like to inform you about the processing of your personal data and about your rights under data protection law.
The controller of the processing of personal data is Porsche SE. You may reach Porsche SE at:
Porsche Automobil Holding SE
Telephone: +49 711 911 24420
Telefax: +49 711 911 11819
You may address your questions or comments on the processing of personal data to the data protection officer of Porsche SE:
Porsche Automobil Holding SE
Der Datenschutzbeauftragte (The Data Protection Officer)
We process your personal data in full compliance with the provisions of the European Data Protection Regulation („GDPR“), the German Federal Data Protection Act (Bundesdatenschutzgesetz, „BDSG“), the German Telecommunications and Telemedia Data Protection and Privacy Act (Telekommunikation-Telemedien-Datenschutz-Gesetz, „TTDSG“) and all other relevant data protection regulations.
Generally, Porsche SE will receive the shareholders personal data via the registration office from the ultimate intermediary that the shareholders have appointed to hold their bearer shares in custody. In some cases, Porsche SE may receive personal data directly from the shareholders and, if applicable, their representatives.
We process your personal data (e.g. last name and first name, address, e-mail address, telephone number, number of shares held, class of shares, authorizations/instructions, registration confirmation number and login data for the shareholders’ portal) as well as personal data of your shareholder representatives, if any, to the extent that this is necessary for the fulfilment of legal obligations and for the intended processing purposes, in particular for the performance of virtual General Shareholders' Meetings. This includes in particular
Porsche SE transmits the General Shareholders' Meeting for these purposes on the shareholders` portal and to the back office for shorthand recording.
The legal basis for the aforementioned data processing is Art. 6 para. 1 sentence 1 lit. c GDPR in conjunction with §§ 67e, 118 et seq. German Stock Corporation Act (AktG)1.
When you use the shareholders’ portal as part of the virtual General Shareholders' Meeting, we also process via server log files, the following personal data which your browser automatically transmits to us for technical reasons:
This data is not merged with other data sources. The legal basis for this is Art. 6 para. 1 sentence 1 lit. c GDPR.
In addition, Porsche SE processes personal data of shareholders on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR as necessary to protect the overriding legitimate interests pursued by Porsche SE in certain individual cases. This occurs, inter alia,
In addition, Porsche SE is subject to various other legal obligations that may require the processing of your personal data. Such legal obligations may follow, for example, from regulatory requirements, sanctions laws as well as commercial and taxation laws. In this case, the legal basis for the processing are the respective legal regulations in conjunction with Art. 6 para. 1 sentence 1 lit. c GDPR.
Within Porsche SE, only authorised staff with relevant competencies will have access to your personal data.
For the organization of the General Shareholders' Meeting (e. g. for performing the service of the registration office for the General Shareholders' Meeting, for the video and audio broadcast, the electronic communication and the operation of the shareholders’ portal at a virtual General Shareholders' Meeting), we commission, to some extent, third-party service providers that will also be granted access to your personal data in the context of the tasks assigned to them. In the context of commissioned data processing, our partners are carefully selected and are obligated pursuant to Art. 28 GDPR to observe the data protection standards of Porsche SE. The data processors commissioned by us will process your personal data exclusively as instructed by us and only to the extent that is necessary for the performance of the services commissioned. Furthermore, we use legal advisors, management consultants, auditors and notaries for the execution and processing of the General Shareholders' Meeting and disclose personal data to them - limited to the scope required in each case.
All employees of Porsche SE and the employees of the commissioned service providers who have access to and/or process personal data of the shareholders or representatives are obliged to treat this data confidentially.
In addition, your personal data will be made available to other shareholders and their representatives within the framework of the statutory provisions, in particular regarding the list of participants (§ 129 AktG) and when exercising shareholder rights. This applies, for example, to statements you have submitted in advance (§ 130a para. 1 to para. 4 AktG). In this context, personal data contained in motions for additions to the agenda, counter-motions, election proposals, speeches and questions or corresponding answers will also be published or made accessible or available to other shareholders and shareholder representatives.
Furthermore, we may be obligated to transmit your personal data to further recipients such as, for instance, public authorities in order to comply with statutory reporting obligations.
In these cases, the legal basis is Art. 6 para. 1 sentence 1 lit. c GDPR or, if there is no legal obligation to publish the personal data, Art. 6 para. 1 sentence 1 lit. f GDPR.
We will anonymize or erase your personal data as soon as they are no longer required for the aforementioned purposes, the personal data is no longer required for any administrative or court proceedings, if any, and no other statutory obligations to furnish evidence or record retention requirements (e. g. under the AktG, the German Commercial Code (Handelsgesetzbuch) or the German Tax Code (Abgabenordnung)) apply or any reasons justifying the storage exist.
Subject to the statutory requirements, you have the right to access information (Art. 15 GDPR) about your processed personal data and to require rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR) of your personal data or the restriction of processing (Art. 18 GDPR) as well as to request the portability of your personal data (Art. 20 GDPR) under using the contact information indicated above.
Right to object (Art. 21 GDPR):If we process your data for the purposes of the legitimate interests pursued by us (Art. 6 para. 1 sentence 1 lit. f GDPR), you may object to such processing at any time with effect for the future on grounds relating to your particular situation that oppose such data processing. Please submit your objection to the contact address indicated above.
We would also like to draw your attention to your right of appeal to a supervisory authority. The supervisory authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg, Lautenschlagerstraße 20, 70173 Stuttgart.
1 The provisions of the German Stock Corporation Act apply to the company pursuant to Art. 9 para. 1 lit. c) (ii) of Council Regulation (EC) No 2157/2001 of 8 October 2001 on the Statute for a European company (SE) (the SE Regulation).