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Data protection

DZ BANK International S.A. would like to thank you for visiting our website and for your interest in our company. We take the protection of your personal data seriously and want you to feel secure when visiting our web pages. Data protection at DZ BANK International S.A. takes account of the European data protection standard and is based, in particular, on the Luxembourg Act of 2 August 2002 regarding the protection of personal data during data processing (Luxembourg Data Protection Act).

If you provide us with personal data, we shall treat it with due diligence and in accordance with data protection regulations.

This information will not be used for other purposes or passed on to third parties. Please note that for technical reasons, we are still currently unable to offer any secure (encoded) means of transferring your message. For your security, please use the postal service when sending us confidential information. Data which you submit regarding the use of your virtual securities account will only be used in relation to this account and not passed on to third parties. You may alter or delete your virtual securities account data at any time via the Internet.

The collection and processing of personal data
As a rule, you may visit the web pages of DZ BANK International S.A. without having to provide personal information. We only learn the name of your Internet Service Provider, the web page from which you have visited us and the pages you visit on our site. This information is collected and stored in anonymised form for statistical purposes by technology used by etracker GmbH and will be used for marketing and optimisation purposes. User profiles will be compiled from these data under a pseudonym. The data will not be used to ascertain the identity of users of this website and will not be matched to data relating to the holder of the pseudonym.

Personal data is only collected subsequently and processed to this end if you submit it with a view to ordering information materials, for example, or should you wish to open a virtual securities account. This information is transmitted partly encoded so as to prevent misuse by third parties.

In certain areas of the website, DZ BANK International S.A. uses cookies in order to be able to personalise the services we offer to you. Cookies are identifiers which a web server can send to your computer to be able to identify it for the duration of your visit. You may adjust your browser in such a way that you are notified regarding the insertion of cookies.

The use and transmission of personal data and its earmarking for specific purposes
Any personal data obtained or collected within the framework of the services provided by DZ BANK International S.A. is only collected, processed and utilised in accordance with the laws and regulations in force at the time pertaining to the protection of personal data for the purpose of concluding a contract and for protecting DZ BANK's own legitimate business interests with respect to advising and looking after our customers and interested parties and bespoke products. In addition, DZ BANK International S.A. is obligated to observe banking secrecy vis-à-vis its customers.

Data security
DZ BANK International S.A. takes technical and organisational security measures to protect data from accidental or deliberate processing, loss, destruction or access by unauthorised persons. Our security measures are being improved continuously in line with technological development.

Data processing outside Luxembourg wirh regard to transactions
The personal data required with regard to money transactions shall be processed by the bank and other specialist companies such as SWIFT (Society for Worldwide Interbank Financial Tele-communication). This processing of the data shall be carried out at local computer centres in other European countries and in the United States of America in accordance with the applicable laws in these states. US authorities may therefore acquire access to the data held in such computer centres for the purposes of combating terrorism. All customers that commission the bank with the im-plementation of bank transfer or other transaction give their tacit approval to all data required for the proper implementation of the transaction being processed outside Luxembourg.

Right to demand information and the Public Record of Procedures
On request, we shall notify you in writing in accordance with prevailing law whether we store personal information pertaining to you and, if so, which particular information.

Record of Procedures
On the basis of the Luxembourg Data Protection Act (Articles 26 and 28), the following information shall be made available to everyone by the data processor in an appropriate manner:

1. The identity of the party processing the data:

DZ BANK International S.A., 4, rue Thomas Edison, L-1445 Luxembourg-Strassen

2. The earmarking of the data processing: Data is only processed according to Article 4 et seq. of the Luxembourg Data Protection Act, but in particular,
(a) to fulfil the legal obligations incumbent upon the data processor, and
(b) to implement a contract in which the person in question is a participant or to implement precontractual measures taken at their request.

3. Recipients or categories thereof to whom the data can be transmitted: Public bodies, where priority legal regulations exist, third parties acting on customer’s instructions or for implementing/fulfilling the purposes indicated under number 2.

4. Pursuant to Article 28 of the Luxembourg Data Protection Act, the persons in question or their beneficiaries have the right to access the data pertaining to them and, if necessary, the right to have this information corrected; these details are based on Article 28 of the Luxembourg Data Protection Act.

5. Standard periods for storing the data: The obligations and periods under law pertaining to storage are observed and the data then deleted once this period has expired. Data not covered by the abovementioned regulations is deleted if the purposes indicated under number 2 do not apply.

Data protection interests
Data protection interests within DZ BANK International S.A. are the responsibility of the auditing/data protection department. If you have any questions regarding the processing of your personal data, you may contact the appropriate employee directly.

klaus-peter.gerlach@dzi.lu (no unsolicited advertising by e-mail thank you)

or

Klaus-Peter Gerlach
Audit/data protection department
c/o DZ BANK International S.A.
L-1445 Luxembourg-Strassen
Tel.: 00352 44903-2418
Fax: 00352 44903-2401

As at: 09/2007


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