Information about the processing of your data within the framework of the Deutsche Bank Alumni Circle

With the following information, we give you an overview of the processing of your personal data and your rights under data protection law.

Who is responsible for data processing and to whom can I contact?

Responsible is the
       Deutsche Bank AG (hereafter referred to as ‘Company’)
       Taunusanlage 12, D-60325 Frankfurt am Main
       Mail: info@db-alumnicircle.com

You can reach our company data protection officer at

       Deutsche Bank AG Data Protection Officer
       Taunusanlage 12, D-60325 Frankfurt am Main
       Mail: data.privacy@db.com

What data do we use and for what purposes?

We process personal data that we collect directly from you via the registration form for the purpose of establishing and conducting a membership of the Deutsche Bank Alumni Circle.
Relevant categories of personal data collected via the registration form include, in particular: master data (e.g. name, optional date of birth), contact data (such as private address, phone number, email address), and other voluntary details regarding previous employment within the Deutsche Bank Group.
In the registration form, you also have the option to subscribe to the newsletter. If you choose this option, you will be informed about events and news via email.
If you are registered as a member on the alumni platform, we additionally capture data generated through interaction with our system. This includes contact data and images you enter or upload into the system. We store comments you make on the alumni platform, groups you join, your tags, and your participation in events.
All this data is collected to facilitate networking among alumni. At a minimum, we need your name and email address to enable email networking among members. If necessary, further details required for providing these additional services may be collected.
You can view the data stored about you in your profile settings; this allows you to oversee the stored data. You also have the option to request the deletion of your data in the settings section. Based on this, we provide your contact data to other alumni in the network portal. In your profile settings, you can control which data is visible to other members.

What do we process your data for (purpose of processing) and on what legal basis?

We process personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).
     a. To fulfill contractual obligations (Article 6 para. 1 b GDPR):

The processing of your personal data takes place primarily for the purpose of establishing, implementing or terminating the membership, which takes place on request. ä We store this data for the execution of this order in accordance with Art. 6 para. 1 S. 1 lit. b GDPR.
     b. Based on your consent (Article 6 para. 1 a GDPR):

If you have given us consent to process personal data for specific purposes (e.g. sending newsletters), this processing is lawful based on your consent. Consent can be withdrawn at any time. This also applies to the withdrawal of consent given before the EU General Data Protection Regulation came into effect, i.e., before May 25, 2018. Please note that withdrawal only applies to future processing.

Who receives your data?

Within the company, only those departments and individuals who require your data to fulfill processing purposes, such as the HR and communications departments, receive access to your data. We have commissioned the service provider Paulbergman GmbH to operate the alumni platform (https://www.alumnii.de) on servers in Germany. This provider is bound by our written data protection instructions and must comply with all legal data protection requirements.

Is your data transferred to a third country?

Data transfer to other subsidiaries of the Deutsche Bank Group or service providers outside the European Union or the European Economic Area (so-called third countries) occurs if it is necessary for the membership. Only HR departments in the relevant geographical region have access to your data.

How long is your data stored?

We delete your personal data as soon as it is no longer required for the aforementioned purposes. After the termination of membership, your personal data is deleted.

What are your data protection rights?

You can request information about the personal data stored concerning you from the entity mentioned under "Responsible entity". Furthermore, you can, under certain conditions, exercise your right to information according to Article 15 GDPR, the right to correction according to Article 16 GDPR, the right to deletion according to Article 17 GDPR, the right to restriction of processing according to Article 18 GDPR, the right to objection according to Article 21 GDPR, and the right to data portability according to Article 20 GDPR. In addition, the restrictions of §§ 34 and 35 BDSG apply to the right to information and the right to deletion. Moreover, you have the right to lodge a complaint with a supervisory data protection authority (Article 77 GDPR i.V.m. § 19 BDSG).
You can withdraw consent to the processing of your data at any time with the responsible entity mentioned above. This also applies to the withdrawal of consent given before the GDPR came into effect, i.e., before May 25, 2018. Please note that withdrawal only applies to future processing and does not affect processing before the withdrawal.

To what extent is automated decision-making used?

We do not use automated decision-making according to Article 22 GDPR for establishing, conducting, and terminating membership.

Information about your right to object under Article 21 GDPR

Individual right to objection

You have the right to object at any time to the processing of your personal data, which occurs based on Article 6 (1) e GDPR (data processing in public interest) and Article 6 (1) f GDPR (data processing based on balancing interests) for reasons arising from your particular situation; this also applies to profiling based on these provisions according to Article 4 No. 4 GDPR.
If you object, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms, or the processing serves the assertion, exercise, or defense of legal claims.

Recipient of an objection

The objection can be made informally with the subject "Objection according to Article 21 GDPR" including your name, address, and date of birth, and should be directed to:

       Deutsche Bank Alumni Circle
       Taunusanlage 12, D-60325 Frankfurt am Main
       info.db-alumnicircle@db.com

(1) Operators and users

These terms of use apply between the operator Deutsche Bank AG – (hereinafter: operator) and the registered users (hereinafter: users). Users are all members invited by the operator and activated as a member after completion of the registration process.

(2) Subject matter of the contract

DB Alumni Circle is a platform of the operator at the URL db-alumnicircle.com, through which registered users can exchange information and communicate via messages and comments (‘the platform’). The use of the platform is only permitted on condition that the users accept these terms of use.

(3) Rights and obligations of the user

3.1 Registration for DB Alumni Circle is only possible upon invitation by the operator, i.e. only persons who have been selected by the operator and have received a corresponding notification can register. There is no general right of access to the platform (even in the case of an invitation). The operator reserves the right to refuse registration in individual cases without giving reasons.

3.2 Users undertake to provide only correct information (in particular name and email address) during registration. The password for the personal login must be kept secret from third parties. If users have reason to believe that third parties are aware of their password, they are obliged to change it immediately. The change of the password can be made in the personal profile area.

3.3 Users are responsible for their activities within the entire platform. Only those contents and statements of the users may be published that do not infringe any rights of third parties (in particular personal rights, copyrights and ancillary copyright), criminal regulations or other mandatory law. If users become aware of any violations in the context of the use of the platform, they are obliged to report them to the operator.

Users are expressly prohibited from publishing, transmitting or disseminating content and/or statements that are illegal, in particular those with offensive, violent, discriminatory or pornographic content or with other content that violates accepted principles of morality. This also includes content that can be reached via links set by the users. Furthermore, the use of offensive content and descriptions as well as other representations is prohibited, the illegality of which is suspected, but cannot be conclusively determined.

Unauthorized activities, content and/or statements include, but are not limited to:

• Content that violates human dignity,
• extreme religious or political content, as well as racist, inflammatory or war-glorifying content,
• Content that is harmful to minors,
• any depiction and incitement to violence against people, institutions and animals,
• the agreement on criminal and terrorist acts,
• Use of offensive or defamatory content, whether that content concerns other users, employees, or any other person or entity,
• Use of content protected by law (e.g. copyright, trademark, patent, design or utility model law) without being entitled to do so, or advertising, offering and/or distributing goods or services protected by law without being entitled to do so,
• any use of the Platform for commercial purposes, including any form of advertising, in particular by sending content that the recipients receive unsolicited, such as chain letters, games of chance and fund-raising calls, or any other advertising address of the users.

3.4 Acts designed to impede the functionality of the Platform or render the Platform inoperable are inadmissible and may be subject to civil and criminal prosecution by the Operator or the competent public authorities. In particular, measures that may influence the physical and logical structure of the platform are prohibited.

3.5 Data and content on the platform may not be read, stored, processed, changed, forwarded, commercially used or otherwise misused manually or automatically for the purpose of data acquisition without the consent of the operator. No technical attacks may be undertaken to alter, misuse, delete or otherwise damage data of individual users in whole or in part.

(4) Tasks, rights and obligations of the operator

4.1 The operator provides users with a platform on which they can contact other users. The offer only includes the provision of the technical applications, without any claims arising from this offer for the establishment of contacts. The operator shall endeavor, but not be obliged, to ensure the smooth operation of the platform. For example, system availability may be affected by maintenance and other influences. Users are not entitled to compensation.

4.2 The operator does not systematically check the content and statements of users distributed on the platform before they are disseminated, transmitted or published.

The operator reserves the right to remove prohibited content and/or statements or references according to section 3.2 without prior notice or explanation.

In the event of non-compliance with the terms of use or the reasonable suspicion of a violation by users, the user receives a warning from the operator with a deadline for a statement or to adjust the misconduct accordingly. If the user fails to set a deadline or the violation is so serious that a continuation of the user relationship is not reasonable, the operator is entitled to immediately exclude the users concerned or to terminate the user extraordinarily; the termination must be in writing.

(5) Termination / deletion of the user profile

This License Agreement shall commence upon the completion of the Member’s registration with the Platform.

The usage agreement can be terminated by both parties at any time and without giving reasons.

A Member's request to cancel his or her account or profile shall be considered a termination. The request for deletion must be sent to info@db-alumnicircle.com. In case of termination, the registration of the member including the profile of the member will be deactivated. All personal data of the user will then be irrevocably deleted.

In particular, in the event of violations of these Terms of Use, including, but not limited to, the User’s obligations set forth in Section 3, we may temporarily or permanently suspend and/or revoke the User’s access without giving any reason and terminate the User Agreement. This applies in particular if the member

• (a) provides false information during registration; and/or
• (b) discloses access data, in particular the password, to third parties without our consent.

(6) Liability

6.1 The content placed on the platform by the operator shall be compiled by the operator with the greatest possible care. However, no liability is assumed for the accuracy, accuracy and correctness of the information on the part of the operator.

6.2 The operator accepts no liability for the content published by the users. The users guarantee that the content published by them (including statements and contributions) can be used free of third-party rights. Users shall indemnify the Operator against all claims, including claims for damages, which other users or other third parties assert against the Operator due to a violation of their rights by the content published by users on the Platform or due to a violation of the aforementioned obligations and / or damaging actions of the users.

Users shall bear all reasonable costs incurred by the Operator as a result of a breach of third party rights, including reasonable costs incurred for the legal defense. These obligations of the users do not apply if the users are not responsible for the respective infringement.

6.3 Despite careful control of the content, the operator accepts no liability for the content of external links. The operators of the linked pages are solely responsible for the content of the linked pages.

6.4 Users shall be liable for any damage they cause to the Operator in accordance with the statutory provisions. Item 6.2 remains unaffected.

6.5 The operator, its legal representatives and vicarious agents shall be liable for any breach of essential contractual obligations, i.e. obligations which enable the proper execution of the contract in the first place and on the compliance with which the users may regularly rely, for intent and any negligence, but in the case of simple negligence limited to the foreseeable damage typical of the contract.

In addition, the operator, its legal representatives and vicarious agents are only liable for damages caused by intent or gross negligence. In the case of gross negligence, liability is limited to the foreseeable damage typical for the contract.

The liability of the operator for indirect and consequential damages is excluded in the case of gross negligence.

The above limitations and exclusions of liability shall not apply in the event of injury to life, limb or health or in the event of claims under the Product Liability Act.

(7) Further development of the services and changes to the terms of use

Content and functions within the platform are constantly being developed and improved. The operator is entitled to make changes to its service at any time, insofar as this is reasonable for the user, taking into account the interests of the operator. Accordingly, the terms of use are adapted and updated. Registered users are informed of changes. The current version can be viewed at https://db-alumnicircle.com/terms_of_use/ and printed using a print version.

(8) Termination of services

The operator is entitled to terminate the service at any time, subject to a notice period, and in the event of termination of the service, irrevocably delete the contents of the users and block the access of the users.

(9) Copyright / usage rights

All copyrights, trademarks and other intellectual property rights on the Website and its contents (in particular the design of the Website, texts, graphics and all software and source codes related to the Website) are either the property of the Operator, licensed to the Operator or used in any other legally permissible manner by the Operator. With regard to the content provided by the operator, the user receives a non-exclusive, non-transferable right to use this content to the extent necessary to display and use the platform in a web browser, and to use it for personal non-commercial purposes.

By uploading content, the user grants the operator the permanent, irrevocable, transferable right to store, copy, make available for retrieval, make accessible and delete the content permanently on the platform.

(10) Other

10.1 There are no side oral agreements. The legal invalidity of individual parts and provisions of these General Terms and Conditions of Business and Terms of Use does not affect their validity otherwise. Rather, the ineffective provision is to be replaced retroactively by a provision which is legally permissible and comes closest to the meaning and purpose of the original provision.

10.2 The law of the Federal Republic of Germany, excluding the UN Convention on Contracts for the International Sale of Goods, shall apply exclusively to this contract. Place of jurisdiction is Frankfurt am Main.

10.3 The German version of the Terms of Use shall be deemed to be legally binding

15 November 2019