Part 1: Information on data protection regarding our processing under Articles 13, 14 and 21 of the General Data Protection Regula-tion (GDPR)

We take data protection very seriously and inform you herein how we process your data and what claims and rights you are entitled to under data protection regulations. 


1. Office responsible for data processing and contact data

Responsible office in the meaning of data-protection law

Swiss Life Asset Managers Deutschland GmbH
Clever Str. 36
50668 Köln



Contact data of our data-protection officer:

HEC Harald Eul Consulting GmbH
Data-protection officer company
Auf der Höhe 34
D-50321 Brühl



2. Purposes and legal foundations upon which we process your data 

We process personal data in accordance with the stipulations of the General Data-Protection Regulation (GDPR), the German Feder-al Data-Protection Act (Bundesdatenschutzgesetz - BDSG) and oth-er applicable data-protection provisions (details are provided in the following). The details of which data are processed and how they are used depends largely on the services requested or agreed in each case. Further details or additions for the purposes of data processing can be found in the respective contract documents, forms, a declaration of consent and/or other information provid-ed to you (e. g. in the context of the use of our website or our terms and conditions). In addition, this data protection infor-mation may be updated from time to time, as you may find out from our website


2.1. Purposes pursuant to fulfilment of an agreement or pre-contractual measures (Art. 6, section 1 b of the GDPR)

The processing of personal data is carried out in order to carry out our contracts with you and the execution of your orders as well as to carry out measures and activities within the frame-work of pre-contractual relations, e. g. with interested parties. In particular, the processing thus serves to provide real estate relat-ed services, in particular marketing, letting, acquisition and sale of real estate according to your orders and wishes and include the necessary services, measures and activities. This essentially includes contract-related communication with you, Credit checks, the verifiability of transactions, orders and other agree-ments as well as quality control by means of appropriate doc-umentation, goodwill procedures, measures to control and op-timize business processes as well as the fulfilment of general duties of care, control and supervision by affiliated companies (e. g. Parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, account-ing and tax assessment of operational services, risk manage-ment, assertion of legal claims and defence in the event of legal disputes; ensuring IT security ((inter alia system and plausibility tests) and general security, including building and plant securi-ty, securing and exercising domestic authority (e. g. by means of access controls); guaranteeing the integrity, authenticity and availability of data, preventing and investigating criminal of-fences; control by supervisory bodies or supervisory authorities (e. g. auditing). 


2.2. Purposes within the framework of a legitimate interest on our part or of third parties (Art. 6, section 1 f of the GDPR)

Above and beyond the actual fulfilment of the (pre-) agree-ment, we process your data whenever this is necessary to protect legitimate interests of our own or of third parties, in particular for the following purposes:

  • advertising or market and opinion research, as far as you have not objected to the use of your data;
  • obtaining information and exchanging data with cred-it agencies where this goes beyond our economic risk;
  • the examination and optimization of processes for needs analysis;
  • the further development of services and products as well as existing systems and processes;
  • the disclosure of personal data within the frame-work of due diligence in the course of company sale negotiations;
  • for comparison with European and international an-ti-terrorist lists, insofar as this goes beyond the legal obligations;
  • the enrichment of our data, e. g. by using or re-searching publicly accessible data;
  • statistical evaluations or market analysis;
  • of benchmarking;
  • the assertion of legal claims and defence in legal disputes which are not directly attributable to the contractual relationship;
  • the restricted processing of data, if a deletion is not possible or only possible with disproportionately high effort due to the special type of storage; 
  • he development of scoring systems or automated decision-making processes;
  • the prevention and investigation of criminal offenc-es, if not exclusively for the fulfilment of legal re-quirements;
  • the anonymization of personal data;
  • building and plant security (e. g. by means of ac-cess control and video surveillance), insofar as this goes beyond the general duties of care;
  • internal and external investigations, safety reviews;
  • internal fraud prevention in connection with the performance of a contract as well as pre-contractual measures, insofar as not exclusively for the fulfill-ment of legal requirements
  • any monitoring or recording of telephone conversa-tions for quality control and training purposes;
  • Preservation and maintenance of certifications of a private-law or official government nature;
  • the seizure and exercise of domestic authority by means of appropriate measures as well as video surveillance for the protection of our customers and employees as well as for securing evidence in the event of criminal offences and their prevention. 


2.3.  Purposes within the framework of your consent (Art. 6, section 1 a of the GDPR)

Your personal data can also be processed for certain purpos-es (e.g. use of company communication systems for private purposes; photographs/videos of you for publication in the Intranet/Internet) including as a result of your consent. As a rule, you can revoke this consent at any time. This also ap-plies to the revoking of declarations of consent that were is-sued to us before the GDPR went into effect, i.e. prior to 25 May 2018. You shall be separately informed about the con-sequences of revocation or refusal to provide consent in the respective text of the consent.
Generally speaking, revocation of consent only applies to the future. Processing that takes place prior to consent being is-sued is not affected by such and remains lawful.


2.4. Purposes relating to adherence to statutory requirements (Art. 6, section 1 c of the GDPR) or in the public interest (Art. 6, section 1 e of the GDPR)

Just like any actor which takes part in business life, we are also subject to a large number of legal obligations. These are primarily statutory requirements (e.g. commercial and tax laws), but also if applicable supervisory law or other requirements set out by government authorities. The purposes of processing may also include identity and age checks, prevention of fraud and money laundering (e.g. comparisons with European and international anti-terror lists),  compliance with control and notification obligations under tax law as well as the archiving of data for the purposes of data protection and data security as well as for purposes of audits by tax advisors/auditors, fiscal and other government authorities. In addition, it may be necessary to disclose personal data within the framework of official government/court measures for the purposes of collecting evidence, law enforcement and criminal prosecution or the satisfaction of civil law claims.


3. The categories of data that we process as long as we do not receive data directly from you, and its origin

If necessary for the contractual relationship with you and the activities performed by you, we may process data which we lawfully receive from other offices or other third parties (e.g. commercial or address sales agencies). In addition, we pro-cess personal data that we have lawfully collected, received or acquired from publicly accessible sources (such as, for exam-ple, commercial registers and association registers, civil regis-ters, the press, Internet and other media) if such is necessary and we are allowed to process this data in accordance with statutory provisions. 

Relevant categories of personal data include in particular:

  • ­    personal data (name, date of birth, place of birth, na-tionality, marital status, occupation/trade and com-parable data)
  • ­    contact data (address, e-mail address, telephone number and similar data)
  • ­    Address data (population register data and compara-ble data)
  • ­    payment confirmation/confirmation of cover for bank and credit cards
  • ­    information about your financial situation (creditwor-thiness data including scoring, i. e. data for assessing the economic risk)
  • ­    customer history
  • ­    data about your use of the telemedia offered by us (e. g. time of access to our websites, apps or newsletter, clicked pages/links of us or entries and comparable data)
  • ­    Video data


4. Recipients or categories of recipients of your data

At our company, your data is received by those internal offices or organisational units that need such to fulfil our contractual and statutory obligations or that require such data within the frame-work of processing and implementing our legitimate interests. 
Your data is disclosed/passed on to external offices and persons solely

  • in connection with the execution of the contract;
  • for purposes where we are obligated or entitled to give information, notification or forward data (e.g. employer's liability insurance association, health insurance schemes, fiscal authorities) in order to meet statutory requirements or where the forwarding of data is in the public interest (see number 2.4); 
  • to the extent that external service-provider companies commissioned by us process data as contract proces-sors or parties that assume certain functions (e.g. ex-ternal data centres, support and maintenance of IT applications, archiving, document processing, call centre services, compliance services, controlling, data screening for anti-money laundering purposes, data validation and data protection. plausibility check, da-ta destruction, purchasing/procurement, customer administration, lettershops, marketing, media tech-nology, research, risk controlling, billing, telephony, website management, auditing services, credit institu-tions, printing plants or companies for data disposal, courier services, logistics);
  • as a result of our legitimate interest or the legitimate in-terest of the third party within the framework of the pur-poses cited under number 2.2 (e.g. to government au-thorities, credit agencies, collection agencies, attorneys, courts of law, appraisers, companies belonging to com-pany groups and bodies and control instances) ;
  • if you have given us consent to transmit data to third par-ties.

We shall moreover refrain from transmitting your data to third parties if we have not informed you of such separately. If we commission service providers within the framework of pro-cessing an order, your data will be subject there to the security standards stipulated by us in order to adequately protect your da-ta. In all other cases, recipients may only use the data for pur-poses for which the data has been sent to them.


5. Length of time your data is stored 

We process and store your data for the duration of our busi-ness relationship. This also includes the initiation of a con-tract (pre-contractual legal relationship) and the execution of a contract.

Above and beyond this, we are subject to various retention and documentation obligations that emanate inter alia from the German Commercial Code (HGB) and the German Tax Code (AO), as well as the Makler- und Bauträgerverordnung (MaBV) The periods and deadlines for retention and/or documenta-tion stipulated therein are up to ten years beyond the end of the contractual relationship or the pre-contractual legal rela-tionship.

Furthermore, special statutory provisions may require longer retention such as for example the preservation of evidence in connection with statutory time-barring provisions (statute of limitations). Under §§ 195 ff. of the German Civil Code (BGB), the regular time-barred period is three years, but time-barred periods of up to 30 years may also be applicable.

If the data is no longer required to meet contractual or statuto-ry obligations and rights, it is regularly deleted unless its fur-ther processing - for a limited period - is necessary to fulfil the purposes listed under number 2.2 due to an overriding legit-imate interest. Such an overriding legitimate interest is deemed to be the case, for example, if it is not possible to delete the data as a result of the special type of storage or such is only possible at an unreasonably great expense and processing for other purposes is excluded by appropriate technical and or-ganisational measures.


6. Processing of your data in a third country or through an international organisation 

Data is transmitted to offices in countries outside the Europe-an Economic Area EU/EEA (so-called third states) whenever such is necessary to meet a contractual obligation towards you (e.g. if you are despatched to another country), such is re-quired by law (e.g. notification obligations under tax law), such is in the legitimate interest of us or a third party or you have issued us your consent to such.
At the same time, your data may be processed in a third coun-try including in connection with the involvement of service providers within the framework of the processing of the order. If no decision has been issued by the EU Commission regard-ing the ensurance of an adequate level of data protection for the respective country or for one or more specific sectors with-in a third country, appropriate contracts (such as EU standard contracts) and additional measures may be used as a basis for the transfer. Information on the appropriate or adequate safe-guards and on the possibility of obtaining a copy from you can be requested from the company data protection officer.


7. Your data-protection rights 
If certain conditions are met, you can assert your data-protection rights against us

  • Thus, you have the right to receive information from us on the data stored on you in accordance with the rules of Art. 15 of the GDPR (if applicable with restrictions in accordance with § 34 of the German Federal Data-Protection Act (BDSG))
  • If you so request, we shall correct data stored on you in accordance with Art. 16 of the GDPR if such data is incorrect or flawed.
  • If you so desire, we shall delete your data in ac-cordance with the principles of Art. 17 of the GDPR if such is not prevented by other statutory provisions (e.g. statutory retention obligations or the restrictions laid down in § 35 of the German Federal Data-Protection Act (BDSG)) or an overriding interest on our part (for example, to defend our rights and claims) 
  • Taking into account the preconditions laid down in Art. 18 of the GDPR, you can demand that we restrict the processing of your data .
  • Furthermore, you can file an objection to the pro-cessing of your data in accordance with Art. 21 of the GDPR, as a result of which we have to stop processing your data. This right of objection only applies, how-ever, if very special circumstances characterise your personal situation, whereby the rights of our compa-ny may run counter to your right of objection. 
  • You also have the right to receive your data in accord-ance with the arrangements laid down in Art. 20 of the GDPR in a structured, commonplace and ma-chine-readable format or transmit such data to a third party. 
  • You furthermore have the right to revoke consent that has been issued to us to process personal data at any time effective into the future (see number 2.3). 
  • You are in addition entitled to file a complaint with a data-protection supervisory authority (Art. 77 of the GDPR). We recommend, however, to first always send a complaint to our data-protection officer.

Whenever possible, your applications for the exercise of your rights should be sent in writing to the address stated above or addressed directly to our data-protection officer.


8. Scope of your obligations to provide us your data

You only need to provide data that is necessary for the com-mencement and performance of the business relationship or for a pre-contractual relationship with us or the collection of which we are required by law. Without this data, we are generally not able to conclude the agreement or continue to perform such. This may also relate to data that is required later within the framework of the contractual relationship. If we request data from you above and beyond this, you shall be informed about the voluntary nature of the information separately.


9. Presence of an automated decision made in individual cases (including profiling)

We do not use any purely automated decision-making proce-dure as set out in Article 22 of the GDPR. If we do institute such a procedure in individual cases in the future, we shall inform you pursuant hereto separately if this is required by law.

Under certain circumstances, we may process your data in part with the aim of evaluating certain personal aspects (profiling). 
In order to provide you with targeted information and advice on products, we may use evaluation tools. These enable a needs-oriented product design, communication and advertis-ing including market and opinion research.

Such procedures can also be used to assess your solvency and creditworthiness as well as to combat money laundering and fraud. "Score values" can be used to assess your creditworthi-ness and creditworthiness. In the case of scoring, the probabil-ity is calculated using mathematical methods with which a customer will meet his payment obligations in accordance with the contract. Such score values thus support us, for ex-ample, in assessing our creditworthiness, decision-making in the context of product deals and are incorporated into our risk management. The calculation is based on mathematically and statistically recognised and proven methods and is based on your data, in particular income, expenditure, existing liabilities, profession, employer, length of service, experience from the previous business relationship, repayment of previous loans in accordance with the contract and information from credit agen-cies.

Information on nationality and special categories of personal data according to Art. 9 GDPR are not processed.

Information on your right of objection under Art. 21 of the GDPR

1. You have the right to file an objection at any time against processing of your data which is performed on the basis of Art. 6, section 1 f of the GDPR (data-processing on the basis of a weighing out of interests) or Art. 6, section 1 e of the GDPR (data-processing in the public interest). The precondition for this, however, is that there are grounds for your objection emanating from your special personal situation. This also applies to profiling that is based on this purpose in the meaning of Art. 4, no. 4 of the GDPR.

If you file an objection, we shall no longer process your personal data unless we can demonstrate compelling reasons warranting protection for the processing that outweigh your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

2. We will also use your personal data in order to perform direct advertising. If you do not want to receive any advertising, you have the right to file an objection to such at any time. This also applies to the profiling to the extent that it is connected with such direct advertis-ing. We shall respect this objection with ef-fect into the future. 

We shall no longer process your data for the purpose of direct advertising if you object to processing for this purpose.

The objection can be filed without adhering to any form requirements and should if possible be sent to

Swiss Life Asset Managers Deutschland GmbH
Attn: Legal Department
Clever Str. 36
50668 Köln


Data protection information effective from 9th April 2018
Part 2: Supplementary privacy notice for our website
CORPUS SIREO takes the protection of personal data very seriously. We want you to know what data we store and when, and how we use it. We have taken technical and organisational measures to ensure that the rules on data protection are complied with.

Anonymous data collection
You can always visit CORPUS SIREO's non-personalised website pages without telling us who you are. Essentially we are informed only of the name of your internet service provider (your IP address), the website from which you are visiting us, the date and time and the pages that you visit on our website. This information is evaluated for statistical purposes. As an individual user, you remain anonymous.

Personal data
Personal data is information that relates to you. It includes information such as your name, address, postal address and telephone number. It does not include information that cannot be directly related to your true identity (such as time spent on the site or the number of users of the site). Personal data is collected by CORPUS SIREO only if you provide it to us yourself, for example when registering for personalised services. Data that you enter in the form will be saved only for the purpose in question. For example, we need your full address in order to send you our annual report. Your data is not passed to third parties outside the CORPUS SIREO Group if to do so is not legally permitted or required.

Email information
We are happy to send you information, reports, studies or similar by email. If you provide us with your email address for this purpose, it will be used only for the purpose in question.

Use of cookies
Cookies are small data sets that your browser stores on your local hard drive. Cookies may be used on our internet pages at The cookies on our website do not contain any personal data about you. Cookies save you having to enter data more than once, facilitate the transmission of specific content and help us to identify particularly popular parts of our online service. For example, we are able to tailor the content of our website pages to users’ needs. If you wish, you can disable the use of cookies at any time by using your browser’s settings. Please use your browser window’s help functions to learn how to change these settings. However, this may mean that you will no longer be able to use individual areas of our website.

Links to other websites
Our internet pages may contain links to other websites. We have no control over whether their operators comply with the data protection rules. Nor do we have any control over the legality of the contents of these websites. We therefore decline any responsibility for the content of other websites.

Questions and comments
If you have questions, suggestions or comments about data protection, please email info[at] The rapid development of new Internet technologies means that we have to change our privacy policy from time to time. You will be informed of the changes here.

Use of web fonts
We use so-called Google Web Fonts on our website. These are external fonts. Google Fonts is a service provided by Google Inc. (“Google”). These Web Fonts are integrated by accessing a server, usually a Google server in the USA. This will tell the server which of our internet pages you have visited. The IP address of the browser of the terminal used by the person visiting these internet pages is also stored by Google. For more information, see Google’s privacy policy, available here:

Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics also uses cookies. The information on your use of this website generated by the Google cookie (including your IP address) is normally transferred to a Google server in the USA and stored there. Google will use this information in order to evaluate your use of the website, to compile reports on activity on the website for us and to provide further services in relation to the use of the website and the internet. Google may also transfer this information to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will Google link your IP address with other data held by Google. By using this website, you agree to the processing of the data collected about you by Google in the manner described above and for the purpose stated above.

We wish to inform you that, in order to improve your privacy, our website uses Google Analytics with the IP Truncation extension. That means that your IP address is first truncated by Google within European Union member states or other states which are party to the European Economic Area Treaty. Only in exceptional cases will the whole of your IP address be transferred to a Google server in the USA, where it will be truncated. This means that it cannot be linked directly to an individual when the use of our website is analysed.

You can prevent the Google Analytics cookies from being set by way of an extension to your browser. This allows you to exercise your right to object to the future collection, processing and use of data by Google Analytics. To do this, you can install the Google Analytics opt-out browser add-on. This prevents Google Analytics from storing information about your website visits.

You can find more information and instructions on how to download and install this deactivation add-on here.

As an alternative to the browser plug-in or within browsers on mobile devices, please click on the following link to set an opt-out cookie that will prevent Google Analytics from collecting data from this website in future (this opt-out cookie works only in this browser and only for this domain; if you delete your cookies in this browser you will need to click on this link again):

Opt out from Google Analytics