Privacy and Data Protection Statement

(Information on collecting, processing and using personal data on the Pepper GmbH website)

Status: August 01, 2008

1) Introduction

The protection of personal data is a matter of the highest priority to Pepper. At Pepper's website, personal data is only collected and used when absolutely necessary. Collected data is never used for commercial purposes or passed to third parties.

Pepper assures all parties that it complies with the regulations of the German Federal Data Protection Act (Bundesdatenschutzgesetz (BDSG)), and other relevant regulations in the collection, processing and usage of users' personal data.

The following statement provides an overview of the way in which Pepper guarantees the protection of individuals with regard to the collection, processing and purpose of use of personal data.


2) Definitions

'Personal data means any information concerning the personal or material circumstances of an identified or identifiable individual (the data subject) ' (§3 para 1 BDSG).

'Personal data' defines information about an identified or identifiable natural person, e.g. name, age,
e-mail address or house address.

'Website' means the website of Pepper GmbH.

'Pepper' describes Pepper GmbH. Pepper is a wholly owned subsidiary of Computershare Ltd. In Germany all Pepper web services are exclusively offered by Computershare Deutschland GmbH & Co KG.


3) Collecting, processing and using of personal data

We only collect, process or use personal data if you voluntarily provide this data to us and if the use of the data is legitimate or that you have given your consent.

On this website, personal data is exclusively collected, processed and used for the following purposes:

1) "Send to friend" function: the following data is collected and processed, but not further used by Pepper:

• Recipient's e-mail address
• Recipient's name
• Your e-mail address
• Your name

2) Pepper application form: the following data is exclusively collected for human resources purposes, i.e. for filling vacant positions at Pepper:

1. First name
2. Surname
3. Street / no.
4. ZIP code / city
5. Phone number
6. Mobile phone number
7. E-mail address
8. URL

Pepper collects processes and uses personal data only within the Computershare Group Germany (Pepper GmbH, Computershare Deutschland GmbH &
Co. KG, Computershare HV Services GmbH, Computershare Document Services GmbH).

Your data is not forwarded to 3rd parties through sale, lease or exchange. If data is passed on to external service providers (commissioned data processing), they are bound to the laws of the Federal Data Protection Act, to other data protection regulations, and to this data protection statement.

We will pass on your data to an authorised government or private body in the case that we are obliged to by law or by court decision. Furthermore, we reserve the right to pass on your personal data to third parties if this should be necessary to counter attacks that constitute a criminal offence, or are able to prevent or affect the functional capability of our Internet sites or networks.


4) Anonymous Information

When the website is used, other non-personal data also arises. The user can mostly not be identified from this data. Every time the user enters a page of the website, and every time particular data is retrieved, the data is stored in a protocol. The storage of this data is necessary for the system and for statistical reasons. Each time the user accesses the data, the following records are saved:

1. Name of retrieved data,
2. Date and time of retrieval,
3. Amount of data transmitted,
4. Report re. success of retrieval,
5. Description of type of web browser used,
6. Referrer URL (of previously visited page),
7. Host name of computer being used (IP address).

It is not possible to identify the person from this data.

This data will not be collated with other data sources, and the data will be deleted after the statistical analysis.


5) Cookies

The website uses so-called 'cookies' in several places, although it is not always possible for us to indicate this to you. Cookies are small text files that are saved on the user's hard drive.

Cookies do not damage your computer or contain viruses.


6) Links and Hyperlinks

The following applies to anyone using the Application and links to other web pages:

Pepper states categorically that at the time of creating the links, the linked pages contained no illegal content. Pepper has no influence whatsoever over further and future restructuring of the linked or integrated pages. Pepper distances itself herewith completely and categorically from all content of all linked pages which were or are changed after the creation of the links. This statement applies to all links and references within the website. Only the creator of the page can be held responsible for all illegal, erroneous or incomplete content, and in particular for any damage which may arise as a result of using or not using such information. Anyone simply referring to the publicised page cannot be held responsible.


7) Data Security

We accept responsibility for your data's security. In order to avoid the possibility of unauthorised access and to guarantee the accuracy of data and its correct use, we have set up a relevant technical and organisational procedure to save and protect all the data we obtain online.


8) Provision of Information to Data Subject

According to §34 BDSG, you have unlimited rights, free of charge, to information about the personal data referring to yourself which we have saved, as well as the right (according to §35 BDSG) to delete or block inaccurate data. If you request it, we will be pleased to let you know in writing whether we have any saved personal data about you and if so, which data. As far as possible, we will use all available methods to update or amend your personal data at short notice. In this case, please contact our Data Protection Commissioner directly.


9) Further information

We value your trust and want to be able to justify ourselves at all times regarding the use of your personal data.

If you have any queries which this statement does not answer, or if you would like more information about anything written here, please feel free to contact our Data Protection Commissioner any time.


10) Data Protection Commissioner

Data Protection Commissioner
c/o Pepper GmbH

Prannerstr. 8
80333 Müchen

Email: privacy@pepperglobal.com


11) Final Clause

Pepper reserves the right to alter this data protection statement at any time without sending notice of updates.

The most up-to-date version of this data security statement can be accessed at any time by clicking the 'Privacy' link in the lower left-hand corner of the website. Dating from its legally valid date, the newest version replaces without exception all previous versions of this data security statement.