Data protection
Data protection is an important concern for the CA Immo group, and there is no question of compliance with the applicable statutory regulations. We process your data exclusively in accordance with the statutory regulations. Personal data shared with us is treated strictly confidentially and not shared with third parties.
Purpose and legal foundation of the whistleblowing system
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of applicable laws or the values (Code of Conduct) of CA Immobilien Anlagen AG. The processing of personal data within the framework of the BKMS® System is based on the justified interest of CA Immobilien Anlagen AG (CA Immo) in discovering and preventing abuses and thereby serves to avert harm to CA Immo, its employees and its business partners. The legal foundation for the processing of personal data is Article 6 paragraph 1f EU-GDPR.
Responsible authority
The parties responsible for data protection in the whistleblowing system are
- CA Immobilien Anlagen AG, Mechelgasse 1, 1030 Vienna
- CA Immo Deutschland GmbH, Europa-Allee 22, 60327 Frankfurt am Main
each as parties with autonomous responsibility. The whistleblowing system is operated by a specialised company, EQS Group AG, Bayreuther Straße 35, 10789 Berlin, on behalf of the company.
Personal data and information entered into the whistleblowing system are stored in a database of a high security data centre operated by EQS Group AG. Only CA Immo has access to the data. EQS Group AG and other third parties do not have access to the data. This is ensured in the certified procedures through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access to the data is restricted to a very small selection of expressly authorised persons at CA Immo. CA Immo has appointed a data protection officer; inquiries regarding data protection can be sent to dsb@caimmo.com.
Type of personal data collected
Use of the whistleblowing system takes place on a voluntary basis. If you submit a report via the BKMS® System, we collect the following personal data and information:
- Your name and possibly your contact data, if you choose to reveal your identity
- Your relationship to the company
- The names and other personal data of persons whom you list in your report, if applicable, or such as arise in the course of investigating the report.
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance department of CA Immo or, in the event of a report concerning a violation of the data protection regulations, by the data protection officer, and the reports are always handled confidentially. These employees evaluate the matter and carry out any further investigation that may be required by the specific case.
Within the framework of processing a report or within a special investigation, it may be necessary to share reports with additional employees of CA Immo or with group companies (subsidiaries), if the reports refer to incidents in subsidiaries or if it is necessary to involve the Internal Audit department. Furthermore, it may also be necessary to share reports with external consultants hired to carry out a special investigation. This may in some cases include persons based in countries outside the European Union or the European Economic Area, which may have different regulations about the protection of personal data. We always ensure compliance with the applicable data protection regulations when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information about the accused
We are legally obliged to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so.
Retention period
Personal data is retained for as long as necessary to>
Your rights
You have the fundamental rights of access, rectification, erasure, restriction, data portability, revocation and objecting to the processing of your personal data. If you invoke your right to object to the processing of the personal data, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer required will be deleted at once. If you believe that the processing of your data violates data protection law or that your legal data protection rights have been otherwise violated, you can register a complaint with the supervisory authority. In Austria, this is the Data Protection Authority.
Use of the whistleblowing portal
Communication between your computer and the whistleblowing system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the whistleblowing system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that contains only the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
You can set up a secured postbox within the whistleblowing system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the respectively responsible employee of CA Immo either by name or in an anonymous, safe way. This system stores the data exclusively within the whistleblowing system, which makes the data particularly secure. It differs from regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible CA Immo employee. If you wish to submit an anonymous report, please take note of the following security advice: files can contain hidden personal data that could endanger your anonymity. Remove this data before sending. If you are unable to remove this data or are uncertain about how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.