Speakup for Reports

Privacy information SpeakUp for parties involved

Privacy information for parties involved in reports of misconduct and/or maladministration that is in conflict with with applicable law and/or our Code of Conduct

We take the protection of your personal data seriously. We treat them confidentially and in accordance with the legal data protection regulations (GDPR).

Purposes of data processing

We process your personal data for the purpose of investigating and clarifying misconduct and/or grievances that are in conflict with applicable law and/or our Code of Conduct, within the INDUS Group of companies. For this purpose, you are currently listed as a party(ies) involved.

Legal basis

We process your personal data to protect our legitimate interests. These consist of investigating suspected cases of misconduct in relation to INDUS and its portfolio companies and clarifying reported incidents.

Source and categories of personal data

The personal data we process about you in this context originates either from a whistleblower (this may be, for example, an employee or business partner of INDUS or an INDUS portfolio company) or from our own research (e.g. by analysing IT system logs).

This involves identifying information (e.g. name, personnel number, IP address) and information describing behaviour during a certain period of time.


We keep information about you confidential; however, we may need to share it with internal and external parties (e.g. experts) for further investigation.

Other recipients may include government agencies/public authorities and other entities to the extent necessary for law enforcement or to protect legal interests.

In addition, service providers who provide or maintain our IT infrastructure may be able to view the data under certain circumstances; however, they are separately sworn to secrecy.

Storage period

Personal data is stored for as long as it is required for the above-mentioned purposes or for as long as legal retention periods require.

Your rights as a participant

As a data subject, you have the following rights, provided that the legal requirements are met:

  • Right to access personal data, Art. 15 GDPR
  • Right to rectification, Art. 16 GDPR
  • Right to erasure, Art. 17 GDPR
  • Right to restriction of processing, Art. 18 GDPR
  • Right to data portability, Art. 20 GDPR
  • Right to object, Art. 21 GDPR

Insofar as the data processing is based on a consideration of legitimate interests, you have the right to object to this processing of the data. For this, there must be legitimate grounds arising from your particular situation.

You also have the right to complain about data processing to the data protection supervisory authority.

Automated decision-making

We assure you that we will carefully examine the case. Decisions are not made automatically, but are carefully weighed.

Person responsible and data protection officer

The operator of the whistleblower system is responsible for data processing:
INDUS Holding AG
Kölner Straße 32
D-51429 Bergisch Gladbach
Phone: +49 (0)2204/40 00-0

The INDUS data protection officer can be contacted via:
fox-on Datenschutz GmbH
Pollerhofstr. 33a
D-51789 Lindlar

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