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Privacy Notice Shareholders

Last update: August 11th, 2020

Since 25th May 2018, new provisions on data protection have been in place with the General Data Protection Basic Regulation (GDPR). Complying with data protection regulations is very important for PAUL HARTMANN AG (hereinafter referred to as "we" or "us"). With the following information we would like to inform you about the processing of your personal data and the rights you are entitled to under data protection law.

For which purposes and on which legal basis is your data processed? From whom do we receive which data?
We process your personal data in compliance with the GDPR, the Federal Data Protection Act (BDSG), the German Stock Corporation Act (AktG) and all other relevant legal regulations.

PAUL HARTMANN AG shares are registered shares without nominal value (unit shares). In the case of registered shares, Section 67 AktG stipulates that these are to be 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 unit shares - the number of units or the share number. In principle, the shareholder is obliged to inform the company of this information.

As a rule, the credit institutions involved in the purchase, sale or custody of your HARTMANN registered shares will forward to us the mandatory data and other information relevant for keeping the share register (e.g. in addition to the aforementioned data, also nationality, gender and remitting bank). This will be done via Clearstream Banking AG, which as the central depository is responsible for the technical settlement of securities transactions and the safekeeping of the shares for the banks.

We use your personal data (e.g. shareholder and contact details, number of shares, class of shares, type of ownership of shares, number of the admission ticket to the Annual General Meeting) and, if applicable, personal data of your shareholder representatives for the purposes provided for in the German Stock Corporation Act, in particular for keeping the share register, communicating with you as a shareholder and handling Annual General Meetings. The processing of personal data for these purposes is legally mandatory. The legal basis for processing your personal data is the German Stock Corporation Act in conjunction with Art. 6 (1) c GDPR.

In the shareholder portal, we use your personal data only for the purpose for which you have provided us with the data, e.g. to enable you to access the AGM services, to register individually and log on to the shareholder portal electronically, to provide the "Forgotten Password" function, to document your online registration for the AGM and order admission tickets, to document your online order, to document your authorization to represent you at the AGM by proxy and any instructions you may have issued, to contact you in connection with contact and service inquiries in connection with the AGM, or to provide you with access to certain information.

In addition, we use your data on the basis of Art. 6 (1) c and (4) GDPR for purposes that are compatible with the aforementioned (in particular for the compilation of statistics, e.g. for the presentation of shareholder development, number of transactions or overviews of the largest shareholders).

In addition, we may also process your personal data to fulfil other legal obligations such as regulatory requirements, stock corporation, commercial and tax law storage obligations. In order to comply with provisions of stock corporation law, for example, when authorizing the proxies nominated by the Company for the Annual General Meeting, we must record the data serving as proof of authorization in a verifiable manner. In this case, the respective legal regulations and Art. 6 (1) c GDPR serve as the legal basis for the processing.

In individual cases we also process your data insofar as this is necessary to safeguard the legitimate interests of PAUL HARTMANN AG (Art. 6 (1) f GDPR), among other things for statistical purposes, for sending you the HARTMANN GROUP annual report if you have requested to receive it, for sending you quarterly information (in particular our shareholder magazine "Inform"), for attending our Annual General Meeting as a guest as well as for photo and video recordings in the context of our Annual General Meeting at which you may possibly be photographed. In the context of virtual general meetings, we also mention your name when answering your questions. Your name can then be noted by the other participants of the Annual General Meeting. This data processing is necessary in order to safeguard our legitimate interest in bringing the course of the virtual Annual General Meeting as close as possible to a physical Annual General Meeting and the legitimate interest of the other participants in the Annual General Meeting in knowing the name of a person asking questions. You can object to the naming of the person in question. In this case we will not mention your name when answering your questions.

If you have given your consent in our shareholder portal to be contacted by electronic communication for sending the invitation to the Annual General Meeting as well as for sending further information from PAUL HARTMANN AG, e.g. the shareholder magazine "Inform", by electronic means, we will process your e-mail address on the basis of the consent given in each case (Art. 6 (1) a GDPR).

Should we wish to process your personal data for a purpose not previously mentioned, we will inform you of this in advance in accordance with the statutory provisions.
Which categories of recipients do we pass on your data to if necessary?
In order to maintain the share register and to process the Annual General Meeting (e.g. for printing and mailing the invitation documents or for holding the Annual General Meeting), we sometimes use external service providers who are given access to your personal data in the course of the tasks assigned to them. Within the scope of data processing on behalf, our partners are carefully selected and are contractually obliged under Art. 28 GDPR to process all personal data exclusively in accordance with our instructions. The service providers contracted by us process your personal data exclusively in accordance with our instructions and only to the extent necessary for the execution of the contracted service. All employees of PAUL HARTMANN AG and the employees of the contracted service providers who have access to and/or process your personal data are obliged to treat this data confidentially.

In addition, we may be required to transfer your personal data to other recipients, such as public authorities in order to comply with legal notification requirements. If you take part in the Annual General Meeting, other PAUL HARTMANN AG shareholders can inspect any personal data recorded in the list of participants in accordance with § 129 AktG.
How long do we store your data?

As a matter of principle, we anonymize or delete your personal data as soon as they are no longer required for the purposes stated above, the personal data are no longer needed for any administrative or legal proceedings and there are no other legal obligations to provide proof or to retain data (e.g. in the German Stock Corporation Act, the German Commercial Code, the German Fiscal Code) or there are no other justifications for storing the data. After the sale of your shares, we must regularly retain the data stored in the share register for another 10 years. In addition, we only retain personal data in individual cases if this is necessary in connection with claims asserted against our company (statutory limitation period of up to thirty years).

What data protection rights do you have?

If you have any questions or complaints regarding data protection, please feel free to contact us. You will find our contact details at the end of this data protection information. This includes the right to access the data stored about you in accordance with Art. 15 GDPR, the right to rectify your data in accordance with Art. 16 GDPR, the right to delete your data in accordance with Art. 17 GDPR and the right to restrict processing in accordance with Art. 18 GDPR. In addition, you have the possibility of contacting the competent supervisory authority.

Right of objection (Art. 21 GDPR): If we process your data in order to safeguard legitimate interests (Art. 6 (1) f GDPR), you may object to this processing if reasons arise from your particular situation which conflict with this data processing. Please send your objection to the address given at the end of this privacy notice.

Right of withdrawal (Art. 7 (3) GDPR): If we process your personal data on the basis of your consent, you can withdraw this consent at any time. Please send your withdrawal to the address given at the end of this privacy notice. Alternatively, you can use the shareholder portal (https://investor.computershare.de/paul-hartmann#/login).

Right to data portability (Art. 20 GDPR): If we process your personal data on the basis of your consent (Art. 6 (1) a GDPR), you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.

According to Article 21 (2) GDPR, you have the right to object to the processing of your personal data for the purposes of direct marketing at any time and without further conditions. This also applies to profiling, insofar as it relates to such direct advertising. If you lodge an objection, your personal data will no longer be processed for these purposes (cf. Art. 21 (3) GDPR).

Responsible party and contact information

Responsible party:
PAUL HARTMANN AG
Paul-Hartmann-Straße 12
89522 Heidenheim
Phone: +49-7321-36-0
Fax: +49-7321-36-3636
E-Mail: info@hartmann.info

Contact Data Protection:
PAUL HARTMANN AG
Department CFO-DPM / DPO
Paul-Hartmann-Straße 12
89522 Heidenheim
E-Mail: datenschutz@hartmann.info