Dear whistleblower,
We would like to inform you that our whistleblower system is now accessible via the following link:
https://misterspex.integrityline.com
During the use of BKMS® System, a text file (called a “session cookie”) is saved on your computer containing only the number of your session. This is necessary for technical reasons in order to establish the connection to a security-certified server. The “session cookie” does no damage to your computer, it does not access your data and has no relation to the contents of your report. If you close all browser windows after submitting your report, the “session cookie” will expire and be automatically deleted.
Dear whistleblower,
We would like to inform you that our whistleblower system is now accessible via the following link:
https://misterspex.integrityline.com
Hermann-Blankenstein-Straße 24,
10249 Berlin
Dirk Graber
Stephan Schulz-Gohritz
Peter Williams
District Court of Berlin-Charlottenburg
HRB 230317 B
DE814906005
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
The whistleblowing system (BKMS® System) serves for securely and confidentially receiving, processing and managing reports concerning violations of the compliance rules of Mister Spex. The processing of personal data within the framework of BKMS® System is based on the legitimate interest of our company in discovering and preventing abuses and thereby averting damage for Mister Spex, its employees and customers. The legal basis for the processing of personal data is Article 6(1)(f) of the GDPR (General Data Protection Regulation).
The parties responsible for data protection in the whistleblowing system are
as parties with mutually autonomous responsibility (hereafter also: “Mister Spex”). The whistleblowing system is operated by a specialised company, EQS Group GmbH, Karlstraße 47, 80333 Munich in Germany, on behalf of Mister Spex.
Personal data and information entered into the whistleblowing system are stored in a database operated by EQS Group GmbH in a high security data centre. Only Mister Spex employees can see the data. EQS Group GmbH and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection according to a system of permissions so that access is restricted to a very small selection of expressly authorised persons at Mister Spex.
Mister Spex has appointed a data protection officer. Inquiries regarding data protection can be sent to datenschutz@misterspex.de.
Use of the whistleblowing system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the compliance organisation of Mister Spex and are always handled confidentially. The employees of the Mister Spex compliance organisation evaluate the matter and perform any further investigation required by the specific case.
While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of Mister Spex or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area, which may have different regulations about the protection of personal data. We always ensure compliance with the applicable data protection regulations when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
We are legally obligated to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so.
Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure, restriction of processing and right to object to the processing of your personal data. If the right to object to the processing of the personal data is invoked, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer needed will be deleted at once. You also have the right to lodge a complaint with the supervisory authority.
Personal data are retained for as long as necessary to clarify the situation and perform a final assessment or for as long as a legitimate interest exists on the part of the company or retention is required by law. After the report processing is concluded, the data will be deleted in accordance with statutory requirements.
Communication between your computer and the whistleblowing system takes place over an encrypted connection (SSL). Your computer's IP address is not stored during your use of the whistleblowing system. In order to maintain the connection between your computer and BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
You can set up a secured postbox within the whistleblowing system with an individually chosen pseudonym/user name and password. This allows you to send reports to the responsible Mister Spex employee either by name or in an anonymous, safe way. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular email communication.
When submitting a report or an addition, you can simultaneously send attachments to the responsible Mister Spex employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could jeopardise your anonymity. Remove such data before sending anything. If you are unable to remove these data or you are uncertain, copy the text of your attachment to your report text or send the printed document anonymously to the address of the report recipient (see footer) with specification of the reference number that you receive at the end of the report process.
Version: June 2021