Information on Data Protection
The Whistleblower Portal shall serve to identify and avoid considerable risks for the Talanx Group with its brands Ampega, CiV Life, HDI, LifeStyle Protection, neue leben, PB Versicherungen, Posta Biztosító, Talanx, TARGO Versicherungen, TU Europa and WARTA and for the Hannover Rück Group with its brands hannover re and e+s rück. For this reason, information relating to the violation of a law, e.g. in the areas of anti-trust law, insurance supervision law, market abuse law, financial sanctions and embargos, capital investment, or to a serious breach of internal regulations, are received and processed here in a secure and confidential way.
Data processing commissioners
You may access the Whistleblower Portal via the websites of the above-mentioned brands.
1. If accessed via the websites of the Talanx Group, the following company is responsible for data processing:
- Talanx AG
- HDI Platz 1
- 30659 Hannover
- Telephone: +49 511 3747-0
- Telefax: +49 511 3747-2525
- E-Mail: compliance@talanx.com
2. If accessed via the websites of the Hannover Rück Group, the following company is responsible for data processing:
- Hannover Rück SE
- Karl-Wiechert-Allee 50
- 30625 Hannover
- Telephone: +49 511 5604-0
- Telefax: +49 511 5601-1188
The Whistleblower Portal is operated in Germany by EQS Group AG, Bayreuther Str. 35, 10789 Berlin, in the name and on behalf of Talanx AG. Data entered in the Whistleblower Portal are stored in an encrypted and password-protected form in a database in a high-security data centre operated by EQS Group AG. EQS Group AG cannot view the data.
In case of any queries concerning the data protection information, you may refer to the responsible data protection officer:
You may contact the data protection officer of Talanx AG by mail under the officer's above-mentioned address adding – Datenschutzbeauftragter / Group Data Protection Officer – or by e-mail via the Group's data protection mailbox: privacy@talanx.com
You may contact the data protection officer of Hannover Rück by mail under the officer's above-mentioned address adding – Datenschutzbeauftragter / Group Data Protection Officer – or by e-mail via the Group's data protection mailbox: datenschutz@hannover-re.com
The data protection authority responsible for the above-mentioned officers is „Die Landesbeauftragte für den Datenschutz Niedersachsen“ [Data Protection Authority of the State of Lower Saxony], which is also available to you in queries or complaints:
- Die Landesbeauftragte für den Datenschutz Niedersachsen
- Prinzenstraße 5
- 30159 Hannover
- Telephone: +49 (0511) 120 45 00
- Telefax: +49 (0511) 120 45 99
- E-Mail: poststelle@lfd.niedersachsen.de
Use of the Whistleblower Portal
You may set up a protected mailbox in the Whistleblower Portal by using a pseudonym/user name and password of your choice. By this way, you can anonymously and safely exchange information and files with the responsible employee of the Compliance department. With this system, the data are stored in the Whistleblower Portal, exclusively, and are thus especially protected; this is not an ordinary e-mail communication.
Communication between your computer and the Whistleblower Portal takes place via an encrypted connection. The IP address of your computer is not stored while using the Whistleblower Portal. For maintaining the connection between your computer and the Whistleblower Portal, a cookie will be stored on your computer containing merely the session ID (so-called null cookie). This cookie is valid until the end of your session, only, and becomes invalid when closing the browser.
Kind of the personal data collected
Use of the Whistleblower Portal takes place on a voluntary basis. Whenever you make a report via the Whistleblower Portal, the following personal data and information will be collected by us:
- your name, provided you disclose your identity,
- whether you are employed with the Talanx/Hannover Rück Group, and,
- if applicable, the names of the persons or other personal data of the persons named by you in your report.
Legal basis and purpose of processing
We process your personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR), the Bundesdatenschutzgesetz (BDSG) and other relevant legislation (e.g. insurance supervision law).
We use the personal data for the purpose of receiving and processing the above-mentioned reports in a safe and confidential way, exclusively. Whenever your consent is obtained for operations in relation to the processing of personal data, this is done acording to Article 6 (1) lit. a GDPR. In the other cases, the legal basis for processing in the meaning of Article 6 (1) lit. f GDPR consists in the protection of the overriding legitimate interest of the Talanx/Hannover Rück Group, the detection of violations of law and serious contraventions of internal regulations, and in the protection of the Talanx Group/Hannover Rück Group and its employees against any damage which might be caused by this.
Confidential treatment of information
When you provide your name via the Whistleblower Portal, we ensure that your identity as a whistleblower is treated as confidential.
Access to the data entered is restricted to a very narrow circle of expressly authorised persons of the Compliance department. In addition, depending on the contents of the report, individual, expressly authorised persons in other internal departments or individual authorised persons in other companies of the Group are granted access to the data, on a case-by-case basis, where this is necessary for processing a particular report.
The latter may also be domiciled in countries outside the European Union or the European Economic Area, where deviating regulations for the protection of personal data may exist. We always take care that the pertinent data protection regulations are adhered to when forwarding information.
Tracing of a report is done in a strictly confidential manner. The stating of your name or of circumstances which could disclose your identity as a whistleblower will principally not take place. In exceptional cases, mentioning of your name may, however, be imperative (e.g. due to statutory provisions) or be made where you have given us your consent to doing this. Where a confirmed initial suspicion exists, the information may be passed on to another internal department for the initiation of sanctions or to a public criminal prosecution authority.
Information of the person(s) affected by a report
We are obligated by law to inform the persons concerned that we have received a report relating to them. This can only be done after such notification will no longer imperil tracing of the report. In such case, your identity as a whistleblower will, principally, not be disclosed.
Duration of the storing of personal data
Personal data are stored as long as this is required for tracing or as long as there is a legitimate interest of the company (e.g. protection against any possible unjustified claims, claims to recourse) or as long as required by a law (e.g. liability claims, public authorities' right of inspection). Afterwards, these data will be deleted or anonymised in accordance with the statutory provisions.
Data subject rights
Apart from the right to object, you have a right to information and - under certain conditions - to the rectification or deletion of your data, and a right to the restriction of processing. On request, data already provided by you will be made available in a structured, commonly used and machine-readable format. You may at any time revoke the consent granted by you without giving reasons and with effect for the future. For exercising these rights, please contact the above-mentioned address. If you are still communicating with us via the whistleblower system, you may also direct these rights to us via it.
Right to object
If we process your data for the protection of legitimate interests you may object to this processing if there are grounds resulting from your particular situation which are opposed to this data processing. We will then discontinue such processing, unless it serves overriding compelling interests worthy of protection on our part.
Status of this information: May 2019