Data Privacy Statement

1. General Information
   1. Objective and Responsibility
   2. Legal Bases
   3. Data Subject Rights
   4. Data Erasure and Duration of Storage
   5. Security of Processing
   6. Transfer of Data to Third Parties, Subcontractors and Third Party Providers
2. Processing within the scope of our online service
   1. Collection of Information on the Use of the Online Service
   2. Borlabs Cookie Management
   3. DoubleClick
   4. Google Analytics
   5. Google Fonts
   6. Google Maps
   7. Google Tag Manager
   8. Links to other websites
   9. Google Hosted Libraries and Google Apis
3. Processing for the purpose of carrying out our business processes
   1. Personnel application
      1. Direct applications
      2. Inclusion in the applicant pool
      3. Careers page
   2. Registration
   3. Contact form and contacting us by e-mail
   4. Direct marketing
   5. Newsletter – Mailjet
   6. Advertising to existing customers
   7. Responding to enquiries about projects
4. Cookie-Policy
   1. General Information
   2. Cookie overview
   3. Objection Options
5. Changes to the Data Privacy Policy

1. General Information

1.1 Objective and Responsibility

1. This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service https://noxcapital.de and the related websites, features and contents (hereinafter collectively referred to as ‘online service’ or ‘website’). Details of these processing activities can be found in section 2.
2. Details of data processing for the purpose of carrying out our business processes are described in section 3.
3. The online service is provided by Nox Capital Holding GmbH (Am Dorfanger 12, 12529 Schönefeld, Germany) – hereinafter referred to as ‘provider’, ‘we’ or ‘us’ – who is also legally responsible under the data protection law.
4. Our online service is hosted by Mittwald CM Service GmbH & Co. KG (Königsberger Straße 4-6, 32339 Espelkamp, Germany). The cloud server is located in Germany.
5. Our Data Protection Officer is Sven Meyzis – IT.DS Beratung (phone: 0049 40-21091514 / e-mail: meyzis@itdsb.de).
6. The term ‘user’ encompasses all customers, interested people, employees and visitors of our online service.

1.2 Legal Bases

In principle, we collect and process personal data based on the following legal grounds:

1. Consent in accordance with Article 6 paragraph 1 (a) General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
2. Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to Article 6 paragraph 1 (b) GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
3. Processing to fulfil a legal obligation in accordance with Article 6 paragraph 1 (c) GDPR, meaning that e.g. the processing of data is required by law or other provisions.
4. Processing in order to protect legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.

The specific legal bases for the individual processing operations are specified in the following sections.

1.3 Data Subject Rights

You have the following rights with regards to the processing of your data through us:

1. The right to lodge a complaint with a supervisory authority in accordance with Article 13 paragraph 2 (d) GDPR and Article 14 paragraph 2 (e) GDPR.
2. Right of access in accordance with Article 15 GDPR
3. Right to rectification in accordance with Article 16 GDPR
4. Right to erasure („right to be forgotten“) in accordance with Article 17 GDPR
5. Right to restriction of processing in accordance with Article 18 GDPR
6. Right to data portability in accordance with Article 20 GDPR
7. Right to objection in accordance with Article 21 GDPR
   Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

1.4 Data Erasure and Duration of Storage

The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.

1.5 Security of Processing

1. We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
2. These security measures include in particular the encrypted transfer of data between your browser and our server.

1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers

1. A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
2. If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
3. If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.

2. Processing within the scope of our online service

2.1 Collection of Information on the Use of the Online Service

1. When using our online-service, information may be transferred automatically from the browser of the user to us; this information includes the name of the accessed website, file, date and time of the access, amount of data transferred, notification about successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
2. The processing of this information takes place based on legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR (e.g. to optimize the online service) as well as to ensure the security of processing in accordance with Article 5 paragraph 1 (f) GDPR (e.g. for the defence and clarification purposes of cyberattacks)
3. This information will be automatically deleted 30 days latest after the termination of the connection, unless any other retention periods require otherwise.
4. The collection of the data and the storage of the data in log files is essential for the provision of the online service. Therefore users are not entitled to the options of erasure, objection or correction.

2.2 Borlabs Cookie Management

1. Our website uses the cookie consent technology of Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser and to document this in accordance with data protection. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (hereinafter Borlabs).
2. When you enter our website, a technically necessary cookie (borlabs-cookie) is stored in your browser, in which the consent you have given or the revocation of this consent is stored. This data is not shared with the provider of borlabs-cookie. The Borlabs Cookie does not process any personal data.
3. The collected data will be stored until you request us to delete it or until you delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://borlabs.io/kb/what-information-does-borlabs-cookie-store.
4. The use of Borlabs Cookie Consent Technology takes place in order to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c GDPR.

2.3 DoubleClick

1. Doubleclick by Google is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
2. Doubleclick by Google uses cookies to serve ads relevant to you. Your browser is assigned a pseudonymous identification number (ID) to check which ads have been displayed in your browser and which ads have been called. The cookies do not contain any personal information. The use of DoubleClick cookies only allows Google and its partner websites to serve ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. Under no circumstances will Google match your data with other data collected by Google.
3. With your consent in accordance with Article 6 (1) (a) GDPR to the use of Youtube, Doubleclick is automatically reloaded. You consent to the processing of data about you by Google in the manner and for the purposes set out above. By using our website, you consent to the processing of data about you by Google and the manner of data processing described above as well as the named purpose.
4. For more information about DoubleClick by Google and privacy, please visit: https://policies.google.com/technologies/ads?hl=en

2.4 Google Analytics

1. We use Google Analytics, a web analytics service of Google Ireland Limited (Gordon House Barclays Dublin Ireland – hereinafter “Google”), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Article 6 (1) (a) GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by the users is transmitted to a Google server in the USA and processed there.
2. Google acts on our behalf within the framework of order processing in accordance with Article 28 GDPR. We have concluded a data protection agreement with Google that contains the EU standard data protection clauses.
3. We use Google Analytics with IP anonymization enabled.
4. Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you during future website visits. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/¬dlpage/gaoptout?hl=en.
5. The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.
6. For more information on data usage by Google, settings and revocation options, please visit Google’s websites:
   https://policies.google.com/technologies/partner-sites?hl=de (“Data use by Google when you use our partners’ websites or apps”).
   https://policies.google.com/technologies/ads (“Data use for advertising purposes”)
   https://adssettings.google.com/¬authenticated (“Manage information Google uses to serve ads to you”).

2.5 Google Web Fonts

1. In order to display our content correctly and graphically appealing across browsers, we use ‘Google Web Fonts’ from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter ‘Google’) to display fonts on this website.
2. The use is based on our legitimate interests, i.e. interest in an appealing presentation of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.
3. The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy/

2.6 Google Maps

1. By selecting / clicking on the static map that is embedded on our website, Google Maps is reloaded.
2. By using the Google Maps map, you consent to the collection, processing and use of automatically collected data and data entered by you by Google, one of its representatives or third parties.
3. The terms of use for Google Maps can be found at https://policies.google.com/privacy?hl=en&gl=en.
   You can find more details in the data protection centre of google.de at https://policies.google.com/privacy?hl=en&gl=en.

4. Processing is based on your consent in accordance with Article 6 (1) (a) GDPR.

2.7 Google Tag Manager

1. This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. The Google Tool Manager only implements tags, does not set cookies and does not collect any personal data. The Google Tag Manager triggers other tags that may collect personal information. However, the Google Tag Manager does not access this data.
2. If deactivated at domain or cookie level, it will remain valid for all tracking tags implemented with Google Tag Manager.
3. The use of the Google Tag Manager shall be based on our legitimate interests in accordance with Article 6 (1) (f) GDPR. We are interested in an efficient and simple deployment of our services.

2.8 Links to other websites

1. While using some of our services, you will be automatically redirected to other websites.
2. Please note that this privacy policy does not apply there. The privacy policy of the linked website may differ considerably from this one.

2.9 Google Hosted Libraries and Google Apis

1. We use the Google Hosted Libraries service. The provider is Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) – hereinafter referred to as ‘Google’.
2. We use the service to integrate various open source JavaScript libraries provided by Google via a so-called Content Delivery Network (CDN). The libraries are loaded onto our web server so that our website can use the library.
3. The legal basis for the processing of personal data described here is the balancing of interests pursuant to Art. 6 (1) (f) GDPR. Our legitimate interest lies, for example, in the efficient and high-performance provision of the website and in integrating the libraries required for the optimal functioning of the website.
4. The integration of the libraries takes place via an interface (‘API’) to the Google services. By integrating the libraries, Google collects personal data, e.g. the IP address of the website visitor’s end device.
5. Google may store cookies on your end device for the use of the libraries. According to Google, these cookies are used exclusively for security reasons and to prevent misuse.
6. Further information on Google’s services can be found here:
   – https://policies.google.com/privacy
   – https://developers.google.com/speed/libraries
   – https://developers.google.com/speed/libraries/terms

3. Processing for the purpose of carrying out our business processes

3.1 Personnel application

For reasons of better readability, the simultaneous use of masculine and feminine and various forms of language is dispensed with – within the framework of the following explanations. All references to persons apply to all genders: m/f/d.

3.1.1 Direct applications

1. We offer you the opportunity to apply to us (e.g. by e-mail or post). In the following, we inform you about the scope, purpose and use of your personal data collected during the application process. We assure you that the collection, processing and use of your data will be carried out in accordance with applicable data protection law and all other legal provisions and that your data will be treated in strict confidence.
2. Scope and purpose of data collection
   If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.
3. If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship.
4. Storage period of the data
   If we are unable to make you a job offer, if you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted for up to 6 months from the end of the application process (rejection or withdrawal of the application) on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR). The data will then be deleted and the physical application documents destroyed. This storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), the data will only be deleted when the purpose for further storage no longer applies.
   Longer storage may also take place if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if legal storage obligations prevent deletion.

3.1.2 Inclusion in the applicant pool

1. If we do not make you a job offer, we may be able to include you in our applicant pool. In the event of inclusion, all documents and details from the application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.
2. The inclusion in the applicant pool is based exclusively on your express consent (Art. 6 para. 1 lit. a GDPR). The provision of consent is voluntary and is not related to the current application process. The person concerned can revoke his/her consent at any time. In this case, the data from the applicant pool will be irrevocably deleted, unless there are legal reasons for retention.
3. The data from the applicant pool will be irrevocably deleted no later than two years after consent has been given.

3.1.3 Careers page

1. Our vacancies are offered on the careers page https://noxcapital.de/immobilien-jobs/#jobs. If you select a specific position, further data processing will be carried out by our service provider Kenjo (Kenjo GmbH (Urbanstraße 71, 10967 Berlin, Germany).
2. We have concluded a data protection agreement with Kenjo. The legal basis for processing at Kenjo is the balancing of interests pursuant to Art. 6 para. 1 lit. f GDPR. Our legitimate interest is to provide an effective and secure application process.
3. Details on data protection at Kenjo can be found at https://www.kenjo.io/legal/privacy

3.2 Registration

1. On our website, we offer users the opportunity to register as a potential investor by providing personal data and thus to receive further information. The data is entered into an input mask, transmitted to us and stored. The data is not passed on to third parties. The following data is collected during the registration process:
   • Name and first name (mandatory fields)
   • Title
   • Company (mandatory field), role
   • Postal address
   • Telephone number
   • E-mail address (mandatory field)
   • Password (mandatory field)
   • Consent (mandatory field)
2. At the time of registration the following data will also be stored:
   • the IP address of the user
   • date and time of registration
3. As part of the registration process, the user’s consent to the processing of this data is obtained. The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR. You can revoke this consent at any time with effect for the future.

3.3 Contact form and contacting us by e-mail

1. When contacting us (via online form or email), the data provided by the user will be processed exclusively for the purpose of handling the enquiry and its processing.
2. The data will only be used for other purposes on the basis of the user’s consent.
3. The user’s data is stored in our customer relationship management system (“CRM system”). The statutory retention periods for business letters apply.

3.4 Direct marketing

1. If you have given us your consent, we will inform you regularly by e-mail about new offers. We will use your name and e-mail address for this purpose. The legal basis for data processing is Art. 6 para. 1 UAbs. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future, e.g. via the link at the end of each e-mail.
2. Our newsletter is only sent by e-mail with your prior express consent according to the double opt-in principle: after registering for the newsletter on our website, you will receive an e-mail asking you to confirm your newsletter registration. This ensures that no third party has misused your data.
3. When you register for the newsletter, we also obtain your consent to newsletter tracking for the purpose of personalised advertising and market research by us. With the help of so-called tracking pixels or web beacons and links, each of which is linked to an individual ID, we collect the following personal tracking information in connection with the use of our newsletter:
   • Opening the newsletter, clicking on the links contained therein, submitting a form on our website after clicking on a link contained in the newsletter (along with the time of these actions)
   • Type of terminal device used when you call up images in the newsletter or click on links
   • Behaviour on our website when you access it via a link from our newsletter (along with the time of these actions)
   • Location of access when you access images in the newsletter or click on links (by assigning your IP address, which we do not store).

   We save this data to your user profile, which is assigned to the data entered when you registered for the newsletter. We use this data to evaluate and optimise our e-mail marketing and for the purposes of personalised advertising and market research. This enables us to send you personalised product, service and offer information in our newsletter that is of particular interest to you. You can revoke your consent to this data processing at any time with future effect by unsubscribing from the newsletter. An isolated deactivation of the newsletter tracking is (currently) technically not possible. We delete the tracking data when you unsubscribe from our newsletter. Data that has been stored by us for other purposes remains unaffected by this.

3.5 Newsletter – MailJet

1. The newsletter is sent using the shipping service provider MailJet, 13 Rue de l’Aubrac, 75012 Paris, France.
   You can view the privacy policy of the shipping service provider here: https://www.mailjet.com/security-privacy/.
   The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR and an order processing contract according to Art. 28 para. 3 p. 1 GDPR.
2. The service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes.
   However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

3.6 Advertising to existing customers

1. Insofar as you have already used services from us against payment, we may inform you from time to time by e-mail or letter about similar services from us (in particular new offers) if you have not objected to this.
2. The legal basis for the data processing is Art. 6 para. 1 UAbs. 1 lit. f GDPR. Our legitimate interest lies in direct advertising (recital 47 GDPR). You can object to the use of your e-mail address and postal address for advertising purposes at any time without additional costs with effect for the future.

3.7 Responding to enquiries about projects

In the case of enquiries about projects, we will only pass on the data provided in your enquiry to third parties if this is necessary or conducive to answering your enquiry and/or carrying out contractual or pre-contractual measures.

4. Cookie-Policy

4.1 General Information

1. Cookies are information transmitted by our web server or third-party web servers to the users’ web browsers where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
2. In the case that users do not want that cookies are stored on their computer, they will be asked to disable the corresponding option in their browser’s system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.

4.2 Cookie overview

4.3 Objection Options

These cookies are necessary, in this respect there are no possibilities to object.

5. Changes to the Data Privacy Policy

1. We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
2. If users’ consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
3. Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.

Version: July 2024