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Data Protection Policy Whistleblower System



The protection of your personal data (all data that may relate to you personally, e.g. name, address, e-mail addresses) is very important to KUKA. If and insofar as we process your personal data, this will be done in accordance with the applicable statutory data protection regulations, in particular the EU General Data Protection Regulation (GDPR), which has been in force since 25 May 2018.
This information is intended to inform you about the nature, scope and purpose of processing your personal data. Furthermore, we want to inform you about your rights with respect to the processing of your personal data.

1. Name and address of the controller
The “controller” as defined in Art. 4(7) of the EU General Data Protection Regulation (GDPR) is:

KUKA Aktiengesellschaft, Zugspitzstrasse 140, 86165 Augsburg, Germany („KUKA“)
Executive Board: Peter Mohnen (Chief Executive Officer), Alexander Tan (Chief Financial Officer), Phone: +49 821 797-50, Fax: +49 821 797-5252, E-mail: kontakt@kuka.com

Our Data Protection Officer can be reached at
Der Datenschutzbeauftragte, c/o KUKA AG, Zugspitzstraße 140, 86165 Augsburg,
E-Mail: data-privacy@kuka.com

KUKA AG and its affiliated group companies pursuant to Section 15 AktG also process some per-sonal data within the framework of the whistleblower system as joint controllers within the mean-ing of Article 26 GDPR.

2. Scope of the data protection information
The whistleblower system enables you to report, in a protected and, if necessary, anonymous manner, information about criminal acts and violations of the law in connection with KUKA Group that have come to your attention or are suspected.

If voluntarily provided by you, KUKA will process the following data:

First name, last name, e-mail address, telephone numbers, details of employment at KUKA Group and any data you may have provided in the report.

3. Purposes and legal bases for processing
Your personal data will be processed for purposes of the employment relationship (Art. 88 GDPR), for compliance with legal obligations (Art. 6 para. 1 lit. c GDPR) or for the purposes of legitimate interests (Art. 6 para. 1 lit. f GDPR).

4. Who receives your personal data?
Any information received is processed by employees of the Compliance Organization of KUKA Group and always treated confidentially. They examine the facts of the case and, if necessary, carry out further clarification of the facts. In the event of a data protection obligation, the ac-cused person is informed of the allegations concerning him or her. The identity of the person providing the information will not be disclosed as far as legally possible.
We always ensure that the relevant data protection regulations are observed when passing on information.
If required by law or data protection legislation, data may be transferred to law enforcement agencies, antitrust authorities and administrative authorities.

Within the KUKA Group, personal data are provided to departments which require the data for the fulfillment of contractual and legal obligations and who are authorized to process such data. In the context of rendering services, we commission processors who contribute to the fulfill-ment of contractual obligations. These processors are contractually obligated by KUKA to com-ply with the data protection regulations in accordance with Art. 28 GDPR to the extent required by law.

5. Is your personal information transmitted to third countries or international or-ganizations?
The transmission of your personal data to a third country with a lower level of data protection (usually outside the EU/EEA) is subject to your express consent or a legal basis. If such transmis-sion takes place, we ensure that this is subject to a data protection level that corresponds to the GDPR through the implementation of measures in accordance with Art. 44 et seq. GDPR, such as through EU standard data protection clauses.

6. Duration of processing (criteria for erasure)
Your personal data will be erased or blocked (restriction of processing according to Art. 18 GDPR) as soon as the purpose of storage no longer applies. Furthermore, the data may be stored if this is provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data, for example for the conclusion or performance of a contract.

7. Your rights
You have the following rights with respect to KUKA regarding the processing of your personal data:

7.1. Right of access according to Art. 15 GDPR.
7.2. Right to rectification according to Art. 16 GDPR.
7.3. Right to erasure (“right to be forgotten”) according to Art. 17 GDPR.
7.4. Right to restriction of processing according to Art. 18 GDPR.
7.5. Right to data portability according to Art. 20 GDPR.
7.6. Right to lodge a complaint with the supervisory authority according to Art. 13(2)(D) and Art. 77 GDPR.
7.7. Withdrawal of consent according to Art. 7(3) GDPR.

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