At DWS we recognize the importance of personal information entrusted to us. It is one of our fundamental responsibilities as an asset manager to ensure that we protect the information entrusted to us by our clients and our website visitors. Please find below select security measures we established to protect your privacy.
We collect, process, and use personal information on our websites in order to offer you even better products and services, best adapt our business processes to our clients’ needs, and steer you to the most suitable product information and applications.
In accordance with the requirements of European data protection law, our website visitors are informed separately about any collection of personal data on the websites concerned that goes beyond the use of Mapp Digital. We do not collect, use or process any personal data without your explicit consent, which can also be declared electronically (e.g. when requesting brochures). Once consent has been given, it can be revoked at any time.
Information input collected through this website will be transferred to the responsible DWS division. Banking secrecy as well as confidentiality are maintained. Data will not be transferred to third parties, unless necessary to answer your queries (i.e. leaflets dispatched by vendors). Your information is used to exclusively fulfil the purpose for which it is collected, relating to the website through which it is collected.
Websites through which we collect your information are usually encoded using the encryption module of your browser. These sites are certified by renowned institutions for international encryption technique. Moreover, DWS put in place additional and comprehensive state-of-the-art security measures when both accounts and custody accounts are accessed via the internet. Firewalls prevent unauthorized access.
Diverse encryption and identification layers protect customer information from intrusion or disclosure to third parties during data transfer. Furthermore, DWS internally uses sophisticated encryption methods in order to prevent de-coding by unauthorized persons. Moreover, an electronic identifier is generated during data transfer to safeguard your information.
In view of the importance of data privacy, and our obligations of transparency, we provide information below about cookies, how we use them on our website based on Article 6 GDPR, lawfulness of processing, and what options you have if you want to activate or deactivate these cookies.
Cookies are small text files that are sent to your computer to ensure the technical functionality of the website. DWS uses cookies in some areas of its web pages to make it easier for you to use the pages and to make them more personalized.
Our websites use cookies, which are necessary for the technical functionality of our websites and the detection of errors and security-relevant anomalies or to offer a service or option you have requested.
Functional and preference cookies enable our website to save information that has already been entered (such as username, language selection or location information) and to offer improved, personalized functionalities. Such cookies are also used to enable functionalities such as playing videos.
We strive to continuously improve the website. For this purpose, we use cookies providing us with overall statistics about the number of visitors, which areas of a page are viewed most frequently, information about the city or location of the users and the length of stay, etc. but also as a statistical audience tool to assess the success of digital communication and marketing measures. These can be installed by external analysis providers commissioned by us.
To adapt our website to your interests and needs, as well as for the purpose of market research, we analyze data that is generated when visiting our website in case you have given explicit consent to analysis cookies. We use the Mapp Digital c/o Webtrekk GmbH (Berlin) offers for this purpose.
Mapp Digital collects anonymized usage data on our website visitors' browsing behavior on our behalf. For this purpose, Mapp Digital sets a session cookie through your browser. The session cookie enables us to record your visit across several DWS websites. The session cookie is set anew each time you visit our website and expires after you leave our website. Mapp Digital also sets a temporary cookie that enables us to identify you pseudonymized using the cookie ID as a returning visitor to our website.
Our websites use cookies so that we can measure and optimize the success of our marketing campaigns. To do this, we track the needs of users in order to prevent them from being shown content that is not relevant to them. Based on these cookies, we personalize our marketing campaigns to the needs of the users.
If you have consented to the use of marketing cookies, we use the re-marketing technology of our below listed partners on our website. It enables us to recognize visitors to our websites on the websites of our advertising partners using a pseudonym and to address them with information relating to their interests. During a visit to our website, a temporary cookie from our advertising partners is placed by the browser of your end device as part of the re-marketing. This cookie enables us to carry out the re-marketing in real time.
To display advertisements on the websites of our advertising partners, we use technologies, so-called "remarketing pixels", from third-party providers. The "remarketing pixels" also use cookies to assign a pseudonymized identification number to your browser. The use of cookies enables publishers (based on your visits to our website) to place advertisements on the websites of our advertising partners. The cookies do not contain any information that would allow conclusions to be drawn about you as a natural person.
If you want to prevent the use of these cookies, you can deactivate the marketing cookies under cookie settings. This also prevents the transmission of data to the above-mentioned publishers.
As part of re-marketing, no personal data will be processed or passed on to Mapp Digital or our advertising partners without your explicit consent.
The following cookies are used if you have given your consent:
|
Cookie-name |
Purpose |
Category |
Lifetime |
Type |
Processing entity |
|
Tealium Collect |
Collects data on user preferences such as language settings or topic preferences |
Functional and preference cookies |
1 Year |
Session-Cookie |
Tealium 11095 Torreyana Road San Diego, CA 92121 |
|
EID Ever ID / Cookie ID |
Collects aggregated data on website usage and functioning |
Essential Cookies |
6 Months |
Session-Cookie |
Mapp Digital Germany GmbH Robert-Koch-Platz 4 10115 Berlin |
|
Google Analytics |
Collects aggregated data on website usage |
Analysis cookies |
2 Years |
Session-Cookie |
Google Ireland Limited Google Building Gordon House 4 Barrow Street Dublin D04 E5W5, Ireland |
|
Google Remarketing |
Enables targeted display advertising |
Marketing Cookies |
30 Days |
Session-Cookie |
Google Ireland Limited Google Building Gordon House 4 Barrow Street Dublin D04 E5W5, Ireland |
|
Facebook Pixel |
Enables targeted Social Media Marketing |
Marketing Cookies |
88 Days |
Session-Cookie |
Facebook Ireland Limited 4 Grand Canal Square Grand Canal Harbour Dublin, D02, Ireland |
|
|
Enables targeted Social Media Marketing |
Marketing Cookies |
2 Years |
Session-Cookie |
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland |
Some cookies allow you to take full advantage of the functionality of our website. In order to offer certain functionalities, certain technically necessary cookies can be used to display these functionalities correctly.
You can set your web browser to disable cookies. Please note that most browsers offer different ways to protect your privacy. If you do not activate or deactivate certain cookies via the browser settings, it is possible that certain functionalities will not be available to you as expected. For example, you can allow first-party cookies, but block third-party cookies, or receive a notification each time a website wants to install a cookie.
Please note that if you disable cookies in this way, you will not be able to set new cookies. However, it will not prevent previously set cookies from continuing to work on your device until you clear all cookies in your browser settings. Instructions for managing cookies on your browser can usually be found under the browser's help function or in the operating instructions for your smartphone.
In addition to the above mentioned website-specific data protection information, the following data protection information under the General Data Protection Regulation also apply.
The following information gives you an overview of the way in which Xtrackers, Xtrackers II and Xtrackers (IE) plc (each a “Company”) and other third parties may process your personal data and your rights under data protection law. The specific types of data processed, and how they are processed, are largely determined by the requested/agreed services in question.
The Company is a data controller in respect of your personal information that we process in connection with our business. In this Notice, reference to "we", "us" or "our" are references to the Company.
This Notice applies to you and to any third parties whose information you provide to us in connection with our relationship with you. Please ensure that a copy of this Notice is provided to any third parties whose personal data you provide to us. We may update this Notice from time to time and we will notify you in writing of any changes we make.
You, as an investor, remain responsible to inform any of your potential authorised representatives or beneficial owners about the existence and content of this Privacy Notice.
Due to our contractual relationship with you, or in order to fulfil our legal obligations, we must collect certain personal information from you. If you do not provide this personal data to us, we may not be able to process your investor application or otherwise maintain a business relationship with you or provide you with our services.
We process some or all of the following types of personal data:
Name, address/other contact details (telephone, email address), date/place of birth, gender, nationality, language, marital status, legal capacity, professional group key/type of partnership (employed/self-employed), identification data (e.g. ID card data), authentication data (e.g. specimen signature), tax ID and information, FATCA status, current occupation or previous occupation if relevant and financial status (assets, liabilities, income from employment/self-employment/trade or business, expenses).
Your personal data will be processed to process, manage and administer your holding(s) and any related accounts, on an ongoing basis. This includes the assessment of your application, the management of your investment, maintaining the register of investors, and the provision of associated services to you (such as account statements or other communications relevant to your application or investment), directly or through the use of service providers.
We process your personal data for the purposes above to the extent necessary to perform our contractual obligations to you.
In addition, we are subject to various Luxembourg and international legal and regulatory obligations or statutory requirements (e.g. Luxembourg company law, UCITS Law, laws and regulations relating to anti-money laundering, tax laws) as well as supervisory requirements (e.g. of the Luxembourg Commission de Surveillance du Secteur Financier). We will process your personal data to the extent necessary to comply with our legal and regulatory obligations, including identity verification, prevention of fraud and money laundering, prevention and detection of crime and compliance with monitoring and reporting duties required by tax law such as reporting to the tax authorities under Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS) or any other tax identification legislation to prevent tax evasion and fraud as applicable.
We may be obliged to collect and report any relevant information in relation to you and your investments (including but not limited to name and address, date of birth and U.S. tax identification number (TIN), account number, balance on account) to the Luxembourg tax authorities (Administration des contributions directes) which will exchange this information (including personal data, financial and tax data) on an automatic basis with the competent authorities in the United States or other permitted jurisdictions (including the U.S. Internal Revenue Service (IRS) or other US competent authority and foreign tax authorities located outside the European Economic Area) only for the purposes provided for in FATCA and CRS at OECD and European levels or equivalent Luxembourg legislation.
It is mandatory that you answer questions and requests with respect to your identification and investment and, as applicable, FATCA and/or CRS. We reserve the right to reject any application for investment if you do not provide the requested information and/or documentation and/or if you do not comply with the applicable requirements. You acknowledge that failure to provide relevant information may result in incorrect or double reporting, prevent you from acquiring or maintaining your investment and may be reported by us to the relevant Luxembourg authorities.
We may also ask for your specific consent to the processing of your personal data for other specific purposes (e.g. to provide marketing or more general information about our services to you). You will have the right to withdraw such consent at any time.
We may also process your personal data in furtherance of our legitimate business interests, which include:
In assessing our legitimate interests listed above, we consider that the processing of your personal data in furtherance of these objectives does not prejudice your interests, fundamental rights or freedoms as a data subject. If you wish to obtain additional information in relation to this, please get in contact with us ('Questions and Concerns').
Where processing is based on the furtherance of our legitimate interest, you have the right to object to this processing of your personal data.
Your personal data will be disclosed to, and processed by, State Street Bank International GmbH, Luxembourg Branch which will be the administrator of your investment(s) for the purposes of this Notice, and is acting as depositary, administrative agent, paying agent, domiciliary agent as well as registrar and transfer agent for the Company.
To the extent necessary to perform our services and fulfil our contractual obligations to you and/or our legal or regulatory obligations, we will disclose your personal data to:
We take all reasonable steps to ensure the safety and integrity of your personal information and may, as appropriate, enter into contracts with such third parties to protect the privacy and integrity of any personal data supplied to us.
Your personal data will be disclosed to, and processed by, State Street Fund Services (Ireland) Limited, which will be the administrator of your investment(s) for the purposes of this Notice, and is acting as registrar and transfer agent for the Company.
To the extent necessary to perform our services and fulfil our contractual obligations to you, we will disclose your personal data to:
We take all reasonable steps to ensure the safety and integrity of your personal information and may, as appropriate, enter into contracts with such third parties to protect the privacy and integrity of any personal data supplied to us.
We take all reasonable steps to ensure the safety, privacy and integrity of your personal data. We ensure that we have appropriate technical, organisational and security measures, appropriate to the sensitivity of your information to ensure it is secure.
We will transfer your personal data to countries outside the European Economic Area if this is necessary for the performance of our contractual obligations to you, or to the extent that this is required by law. Transfers to countries outside the European Economic Area will, to the extent required, be made to Australia, Canada, Japan, Hong Kong, India, Singapore, Thailand and the United States.
For any transfers of your personal data outside the European Economic Area, we will ensure that appropriate safeguards are in place, which might include one or more of the following:
We may also transfer your personal data to countries outside the European Economic Area where we have obtained your consent to do so. You will be entitled to withdraw such consent at any time.
You can obtain more information about data transfers, appropriate safeguards and standard contractual clauses by contacting us ('Questions and Concerns').
Personal Data will be retained by Company and/or its processors until investors cease to hold shares and a subsequent period of 10 years thereafter to the extent necessary to comply with laws and regulations applicable to them or to establish, exercise or defend actual or potential legal claims, subject to the applicable statutes of limitation, unless a longer period is required by laws and regulations applicable to them. In any case, your personal data will not be retained for longer than necessary with regard to the purposes and legal and regulatory obligations or statutory requirements contemplated hereunder (or any other information notice provided by the Company from time to time), subject always to applicable legal minimum retention periods. If you have any questions, please contact us ('Questions and Concerns').
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing ('Questions and Concerns').
There is no need to take any action as a result of receiving this letter. If you have any questions or concerns about how we handle your personal data, further information can be obtained from State Street Bank International GmbH, Luxembourg Branch (49, Avenue J.F. Kennedy, L-1855 Luxembourg, Grand Duchy of Luxembourg), acting in its capacity as administrator and transfer agent of the Company (ssbquerydesk@statestreet.com).
If you are unhappy with how we are handling your personal data, or how we respond to a query/complaint about the processing of your personal data, you have the right to make a complaint to the relevant data protection supervisory authority.
If you are have any questions or concerns about how we handle your personal data, further information can be obtained from State Street Fund Services (Ireland) Limited (78 Sir John Rogerson's Quay, Dublin 2, Ireland), acting in its capacity as administrator and transfer agent of the Company (by emailing taregistration.eb@statestreet.com or ETF_Servicing@statestreet.com).
If you are unhappy with how we are handling your personal data, or how we respond to a query/complaint about the processing of your personal data, you have the right to make a complaint to the Irish Data Protection Commissioner, or any other relevant privacy regulator.
This privacy notice explains the manner in which Xtrackers ETC plc (the Company) collects, processes and maintains personal data about you pursuant to the Data Protection Law.
You should review this notice carefully as it contains information about the treatment of your personal data and your rights under Data Protection Law.
For the purposes of this privacy notice: (i) Data Protection Law means the General Data Protection Regulation (EU) 2016/679 and the Irish Data Protection Acts 1988 to 2018, as amended from time to time (ii) controller, processor, data subject, personal data, and processing shall have the meanings given to them under Data Protection Law, (iii) we, us or our means the Company in its capacity as controller of the personal data, and (iv) you or your means the securityholder under the Secured Xtrackers ETC Precious Metal Linked Securities Programme (the Programme) (the investor) and includes any person owning or controlling the investor, having a beneficial interest in the investor, or for whom the investor is acting as agent or nominee. For the avoidance of doubt, Processor (as defined below) shall include State Street Fund Services (Ireland) Limited (and its affiliates) acting as determination agent, issuing agent and paying agent in relation to the Programme in its capacity as processor of the personal data.
Personal data includes identifiers such as: name, date of birth, gender, address and proof of address, email address, nationality, copy of official identification, tax identification number (TIN), financial and investment qualification, shareholder reference number, national identification number, telephone/mobile number, fax number, bank details, and power of attorney details.
The Company collects personal data about investors mainly through the following sources:
The storage, processing and use of personal data will take place for the following purposes:
Where the processing is necessary for compliance with a legal obligation to which the Company is subject
Where the processing is necessary for the Company to perform a contract to which you are a party or for taking pre-contract steps at your request
Where the processing is necessary in order to pursue the Company’s legitimate interests
Where you consent to the processing of personal data
As a controller, we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We do not envisage that any decisions producing legal or other significant effects will be taken about you using fully automated means, however we will notify you in writing if this position changes.
Any disclosure of personal data shall be in accordance with the obligations of the disclosing party under the Data Protection Law. Further:
You have the right to:
Further, you may at your discretion refuse to communicate personal data to the Company or object to some processing of your personal data. There are situations where the Company may not be able to comply with a request, for example, where it is subject to a legal obligation to retain or process the data, or where the data is required to perform the investment services. If you refuse to provider certain information to the Company (e.g. contact information), then the Company may not be able to provide investment services to you.
Where the processing is based on your consent, you may withdraw your consent at any time. However, the withdrawal of consent shall not affect the lawfulness of processing based on such consent before the consent is withdrawn, nor will it affect the lawfulness of processing based on other grounds.
You also have the right to lodge a complaint with a supervisory authority under the GDPR. For further information, see the “Complaints” section below.
You may exercise your rights by writing to the Company at the following e-mail address: privacy@dws.com.
Should you have any unresolved complaints in relation to the retention or processing of personal data, you may lodge a complaint with the Irish Data Protection Commission at www.dataprotection.ie. Alternatively, you may submit a complaint to your local supervisory authority, the details of which are available at www.edpb.europa.eu/about-edpb/about-edpb/members_en.
We keep your personal data only as long as necessary to fulfil: (a) the specific purpose for which the data is processed; (b) the Company’s legitimate business and operational needs; and (c) in order to comply with the legal obligations to which the Company is subject. The retention period is determined on a case-by-case basis and depends on several factors, including:
Generally speaking, the Company retains personal data for at least the duration of the relevant statute of limitations, in order to ensure that it is able to established and defend legal claims relating to the Programme.
For further information on the Company’s retention practices, please contact us at privacy@dws.com.
The Company reserves the right to update this Privacy Notice at any time, and will ensure that any update to this privacy notice is made available on its website www.etf.dws.com. We encourage you to regularly review this and any updated Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed. We may also notify you in other ways from time to time about the processing of your personal data.
This privacy notice explains the manner in which DB ETC plc (the Company) collects, processes and maintains personal data about you pursuant to the Data Protection Law.
You should review this notice carefully as it contains information about the treatment of your personal data and your rights under the Data Protection Law.
For the purposes of this privacy notice: (i) Data Protection Law means the Data Protection (Jersey) Law 2018, as amended from time to time (ii) data controller, data processor, data subject, personal data, and processing shall have the meanings given to them under the Data Protection Law, (iii) we, us or our means the Company in its capacity as data controller of the personal data, and (iv) you or your means the securityholder under the Secured ETC Precious Metal Linked Securities Programme (the Programme) (the investor) and includes any person owning or controlling the investor, having a beneficial interest in the investor, or for whom the investor is acting as agent or nominee. For the avoidance of doubt, Processor (as defined below) shall include Deutsche Bank AG, London Branch (and its affiliates) acting as arranger and distributor in relation to the Programme in its capacity as processor of the personal data, and Computershare Investor Services (Jersey) Limited (Computershare) acting as registrar of the Company in its capacity as processor of the personal data.
Personal data includes identifiers such as: name, date of birth, gender, address, email address, nationality, tax identification number (TIN), financial and investment qualification, shareholder reference number, national identification number, telephone/mobile number, fax number, bank details, and power of attorney details.
The Company collects personal data about investors mainly through the following sources:
The storage, processing and use of personal data will take place for the following purposes:
Where the processing is necessary for compliance with a legal obligation to which the Company is subject
Where the processing is necessary for the Company to perform a contract to which you are a party or for taking pre-contract steps at your request
Where the processing is necessary in order to pursue the Company's legitimate interests
Where you consent to the processing of personal data
As a data controller, we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
You have the right to:
There are situations where the Company can refuse to comply with such a request, for example, where it is subject to a legal obligation to process the data. The Company may also reject your investment or withhold payments until such time as the requisite data has been provided.
Where the processing is based on your consent, the withdrawal of consent shall not affect the lawfulness of processing for other reasons and based on other grounds where this is permitted under applicable law.
You may exercise your rights by writing to the Company at the following email address: privacy@dws.com.
Should you have any unresolved complaints in relation to the retention or processing of personal data, you may lodge a complaint with the Data Protection Authority in Jersey: Tel +44 (0)1534 716530 or at www.OICJersey.org.
The personal data shall not be held by the Company for longer than necessary with regard to the purposes of the data processing, subject to any limitation periods provided by law.
The Company reserves the right to update this Privacy Notice at any time, and will ensure that any update to this privacy notice is made available on its website www.etf.dws.com. We encourage you to regularly review this and any updated Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed. We may also notify you in other ways from time to time about the processing of your personal data.