During the use of BKMS® System, a text file (called a “session cookie”) is saved on your computer containing only the number of your session. This is necessary for technical reasons in order to establish the connection to a security-certified server. The “session cookie” does no damage to your computer, it does not access your data and has no relation to the contents of your report. If you close all browser windows after submitting your report, the “session cookie” will expire and be automatically deleted.
Dear Whistleblower,
We would like to inform you that our whistleblowing system can now be accessed via the link
Fürther Straße 252
90429 Nuremberg
Germany
Phone: +49 911 3600-0
Fax: +49 911 3600-358
E-Mail: mail(at)eschenbach-optik.com
Internet: www.eschenbach-optik.com/en
Eschenbach Optik GmbH
Registered office and registration court Nürnberg, HRB No. 16786
VAT Reg. No.:: DE204877739
Dr. Peter Braunhofer
Matthias Anke
Dr. Peter Braunhofer
Eschenbach Optik GmbH
Fürther Straße 252
90429 Nuremberg
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data privacy regulations. Please read this data privacy information carefully before submitting a report.
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of the Eschenbach Group. The processing of personal data in the BKMS® System is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to the Eschenbach Group, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
The party responsible for data privacy in the whistleblowing system is
Eschenbach Optik GmbH, Fürther Straße 252, 90429 Nuremberg, Germany
as parties with mutually autonomous responsibility (hereafter also: „Eschenbach Group“). The reporting system is operated by a specialised company, EQS Group GmbH, Karlstraße 47, 80333 Munich in Germany, on behalf of Eschenbach Optik GmbH.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group GmbH in a high-security data centre. Only Eschenbach Optik GmbH has access to the data. EQS Group GmbH and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at Eschenbach Optik GmbH.
Eschenbach Optik GmbH has appointed a data protection officer:
Attorney Thomas P. Costard
Law office Costard
Lawyer for IT law and data protection
Businesspark EUROCOM
Lina-Ammon-Straße 9
90471 Nuremberg
Questions on data protection and privacy can be sent to Eschenbach Optik GmbH, Fürther Straße 252, 90429 Nuremberg, Deutschland, e-mail address datenschutz@eschenbach-optik.com.
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance department of Eschenbach Optik GmbH and are always handled confidentially. The employees of the Compliance department of Eschenbach Optik GmbH will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of Eschenbach Optik GmbH or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the privacy of personal data. We always ensure that the applicable data privacy regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
If we are processing your personal data, you have extensive rights as a data subject, which are listed in detail below:
You can at any time obtain information about your data processed by us according to Article 15 GDPR.
You may especially obtain information about the purposes of the processing, the categories of personal data concerned, the categories of possible recipients and the envisaged period for which the personal data will be stored.
Please submit information requests to Eschenbach Optik GmbH, Fürther Straße 252, 90429 Nuremberg, Germany, e-mail address datenschutz@eschenbach-optik.com.
In accordance with Article 16 GDPR you are entitled, in case of inaccurate data, to demand recification or completion of your personal data stored with us.
You may exercise your right under the contact detail listed above.
Under Art. 17 of the General Data Protection Regulation, you have the right to obtain erasure of personal data concerning you if storage of the data is no longer required and if there is no other legal ground for its processing. You may also obtain erasure if you object to the processing and there are no overriding legitimate grounds for the processing and if your data was processed unlawfully or if the personal data must be erased for compliance with a legal obligation under EU or national law.
You may exercise your right under the contact detail listed above.
Under Art. 18 of the General Data Protection Regulation, you have the right to obtain the restriction of processing if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of your personal data; if the processing is unlawful, but you oppose the erasure of your personal data; the purposes for the processing cease to apply, but the data is required for the establishment, exercise or defense of legal claims or if you objected in accordance with Art. 21 of the General Data Protection Regulation and if whether the legitimate grounds of the controller outweigh your interests has not yet been determined.
You may exercise your right under the contact detail listed above.
Under Art. 20 of the General Data Protection Regulation, you have the right to receive your personal data in a structured, commonly used and machine-readable format (data portability). In addition, under certain circumstances, you may also receive your data directly from a controller if technically possible.
You may exercise your right under the contact detail listed above.
You have the right to object to use of your data for the above-stated purposes at any time (Art. 21 of the General Data Protection Regulation). This is possible for objections to direct marketing or on grounds relating to your particular personal situation. If you object to direct marketing, we will implement your general objection right without information about your particular personal situation.
To exercise your right to object, please write us at Eschenbach Optik GmbH, Fürther Straße 252, 90429 Nuremberg, Germany or email us at datenschutz@eschenbach-optik.com.
Please also note that, irrespective of other administrative or legal remedies, you have the right to submit complaints to supervisory authorities, especially in the Member state of your habitual residence, place of work or place of the alleged infringement if you believe that the processing of your personal data infringes on the GDPR.
A list of (non-public sector) supervisory authorities and their addresses is provided (in German) at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists, or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym/ user name and password. This allows you to send reports to the responsible employee at Eschenbach Optik GmbH either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of Eschenbach Optik GmbH. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure 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.
We reserve the right to make changes to our security and data protection measures if required due to technical developments. In such cases, we will also adjust our Data Privacy Policy. Therefore, please note the respectively current version of our Data Privacy Policy.