Privacy Information for Whistleblowers

The protection of your personal rights in the processing of personal data is an important concern for the Hirschvogel Group. Hirschvogel processes personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and national statutory provisions.


Employees of the Hirschvogel Group and external parties can use the whistleblower system to inform the Hirschvogel Group about possible violations of statutory provisions or internal regulations and thus contribute to the investigation of the violation and prosecution.


We would like to inform you about the processing of your personal data as a whistleblower in the following:

1. Who is responsible for the processing of your personal data?

The responsible body for the processing of your data is the company,


Hirschvogel Holding GmbH

Dr.-Manfred-Hirschvogel-Str. 6

86920 Denklingen



You can reach our data protection officer at the above address or at:

2. The Hirschvogel Group will process your data for the following purposes within the scope of the applicable laws:

To review and process your report and, if necessary, for the associated investigations against the accused person(s), if necessary, to communicate with authorities and courts in connection with your report and to communicate with commissioned law firms and auditing firms or other investigating parties as well as other companies of the Hirschvogel Group.

In detail, this refers to the following specific purposes:


  • Checking the plausibility of reports
  • Investigation of misconduct
  • Implementation of statutory obligations
  • Prevention of future misconduct
  • Exercise of rights
  • Relief for employees
  • Review of the relevance for other companies of the Hirschvogel Group
  • Implementation of duties to cooperate

3. No obligation to provide your personal data

You can also submit reports without providing your personal data (anonymous report). You are not obliged to provide your personal data.

4. Which data or data categories are affected by this data processing?

When you submit a report, we collect the following personal data and information:


  • Your name or private contact and identification data, if you disclose your identity (non-anonymous report),
  • Your professional contact and (work) organization data, if you provide it (non-anonymous report) and,
  • If applicable, names of persons and other personal data of the persons you mention in your report.

5. On what legal basis will the data be processed?

The Hirschvogel Group will only process your personal data if at least one applicable data protection regulation permits this.


In this case, the Hirschvogel Group relies on the following legal bases:


  • Processing within the scope of the employment relationship (Section 26(1) Sentence 1 of the German Federal Data Protection Act (BDSG))
  • Investigation of criminal offenses (Section 26(1) Sentence 2 BDSG)
  • Implementation of statutory obligations (Article 6(1)(c) GDPR)
  • Protection of legitimate interests (Article 6(1)(f) GDPR)
    • Legal defence
    • Improvement of compliance structures
    • Support for data subjects
    • Implementation of foreign legislation

6. How long will we store your data?

We will only store your personal data as long as necessary for investigation and final assessment and, to the extent that country-specific statutory, contractual or statutory retention periods exist, beyond that


After the report has been processed, the data will be deleted or anonymized in accordance with the country-specific statutory requirements. In the case of anonymization, the reference to your identity as the person providing the information will be permanently and irreversibly removed.

7. Who will we share the data with?

In the course of processing reports or during an internal investigation, it may be necessary to pass on information to other employees of the Hirschvogel Group in justified individual cases . If necessary for an investigation, data may be transmitted to companies of the Hirschvogel Group in a country outside the European Union or the European Economic Area on the basis of suitable legal data protection guarantees for the protection of data subjects (e.g. EU standard data protection clauses, for employee data, Article 46 GDPR, or exceptional circumstances pursuant to Article 46 GDPR). We always ensure that the relevant data protection regulations are observed when passing on information.


In the case of a corresponding statutory obligation or in the case of a legitimate interest of the Hirschvogel Group or a third party in the investigation of the report, law enforcement agencies, antitrust authorities, other administrative authorities, courts as well as international law firms and auditing companies commissioned by the Hirschvogel Group shall also come into consideration as recipients.


In certain cases, the Hirschvogel Group has an obligation under data protection law to inform the accused person of the allegations made against them. This is required by law if it is objectively established that the provision of information to the accused can no longer affect the concrete investigation of the report. If you have provided us with your name or other personal data (non-anonymous report), your identity as the person providing the report will not be disclosed - as far as legally possible, - and we will also ensure that no conclusions can be drawn about the identity of you as the person providing the report.

8. Your rights as a data subject

As a data subject of the data processing, you may assert certain rights with us according to GDPR as well as according to other relevant data protection provisions. In particular, you are entitled to the following rights as a data subject vis-à-vis the Hirschvogel Group according to GDPR:


  • The right to information (Article 15 GDPR)
  • The right to rectification (Article 16 GDPR)
  • The right to erasure (Article 17 GDPR)
  • The right to restriction of processing (Article 18 GDPR)
  • The right to lodge a complaint with a data protection supervisory authority


You can contact us by using the contact details provided under section 1 in order to exercise your rights. 


The Hirschvogel Group takes your concerns and rights very seriously. However, if you feel that we have not adequately addressed your complaints or concerns, you have the right to file a complaint with your local data protection supervisory authority.