Privacy policy for shareholders etc.

Latest update: 13 February 2019.

This Privacy Policy explains how Copenhagen Airports A/S (“CPH”, "we" or "us") processes personal data about shareholders, proxies and advisers in connection with registration in the register of shareholders and convening and holding of general meetings.

Data controller

The legal entity responsible for the processing of your personal data is:
Your personal data are processed by Copenhagen Airports A/S, Box 74, Lufthavnsboulevarden 6, DK-2770 Kastrup, Denmark, as data controller.

Data protection officer

CPH has appointed a data protection officer (DPO), and you are welcome to contact our DPO with any ques-tions or other queries you may have about our processing of personal data.
You can contact our DPO at privacy@cph.dk.

Description of the processing

Registration of shareholders in the register of shareholders and on the shareholder portal
 

Purpose

We process your personal data in order to maintain an updated, statutory register of shareholders.

Categories of personal data

We process the following categories of personal data about you:

Ordinary personal data:

  • name
  • gender
  • email address
  • home address
  • telephone number
  • portfolio of shares
  • voting rights
  • date of acquisition, sale or pledge of shares
  • user name and password
  • account number with VP Securities
  • custodian bank
  • investor ID
  • investor group

Source of the personal data

We collect your personal data from the following sources:

  • Directly from you, including when you provide information via our shareholder portal
  • VP Securities

Legal basis for the processing

We process your personal data on the following legal basis:

  • Article 6.1.c - necessary for us to comply with the legal obligation of Section 50 of the Danish Companies Act
  • Article 6.1.f - necessary for the pursuit of our legitimate interest in being able to respond to your requests and to communicate with you

Recipients

We may share your personal data with:

  • Suppliers, including IT-suppliers
  • The public via publication on the website cph.dk in accordance with the flagging rules regarding major shareholders
  • Nasdaq Copenhagen A/S
  • Public authorities, including the Danish Business Authority

Data retention

We will retain personal data for as long as it is necessary for the purposes mentioned.

  • We retain your personal data for up to 5 years plus the current financial year after you no longer own shares in CPH
Convening and holding of general meetings
 

Purpose

We process your personal data for the purpose of convening you to general meetings and enabling you to exercise your rights at the general meetings as well as issue proxies and vote by post. Furthermore, we use the information to issue ballot papers and admission cards to shareholders and advisers, if any. If you are an advisor to a shareholder, we will process your information in order for you to have access to the general meeting.

Categories of personal data

We process the following categories of personal data about you:

Ordinary personal data:

  • name
  • email address
  • home address
  • attendance at the general meeting
  • advisor's attendance at the general meeting
  • proxies
  • votes cast, including written votes
  • portfolio of shares

Source of the personal data

We collect your personal data from the following sources:

  • Directly from you, including when you provide information via our shareholder portal, see above

Legal basis for the processing

We process your personal data on the following legal basis:

  • Article 6.1.c - necessary for us to comply with the legal obligation of Section 93 of the Danish Companies Act
  • Article 6.1.f - necessary for the pursuit of our legitimate interest in being able to convene shareholders to - and to conduct - general meetings

Recipients

We may share your personal data with:

  • Suppliers, including IT-suppliers
  • Nasdaq Copenhagen A/S
  • Public authorities, including the Danish Business Authority

Data retention

We will retain personal data for as long as it is necessary for the purposes mentioned.

  • We retain your personal data for up to 5 years plus the current financial year after you no longer own shares in CPH
  • A notice to convene the general meeting with agenda and complete proposals as well as registrations, proxies and postal votes are retained for 5 years plus the current financial year after the general meeting has taken place
  • Material that documents the company's history, decisions made, etc. is retained for as long as the company exists
Handling of questions and proposals submitted prior to the general meeting, handling of questions and exercising the right to speak at the general meeting as well as preparation of minutes of the general meeting
 

Purpose

We process your personal data for the purpose of handling questions and proposals submitted prior to the general meeting, questions and the right to speak during the general meeting and the preparation of minutes of the general meeting. If questions are answered in writing prior to the general meeting, we will process your information in order to be able to submit questions, answers and the name of the person who has put forward the question at the general meeting. If proposals are included on the agenda, wewill process your personal data (your name and proposal) provided on the forms for appointment of proxy or written voting as well as on the agenda. Forms, postal votes and agenda, including complete proposals, are published on our website. Finally, we will process your personal data when preparing and issuing the minutes of the general meeting.

Categories of personal data

We process the following categories of personal data about you:

Ordinary personal data:

  • name
  • documentation of your status as a shareholder or proxy
  • the content of your question
  • the content of your proposal
  • the content of your opinions expressed at the general meeting

Source of the personal data

We collect your personal data from the following sources:

  • Directly from you, including when you provide information via our shareholder portal, see above

Legal basis for the processing

We process your personal data on the following legal basis:

  • Article 6.1.c - necessary for us to comply with the legal obligations of Sections 78, 90 and 101 of the Danish Companies Act
  • Article 6.1.f - necessary for the pursuit of our legitimate interest in being able to identify you as a shareholder or proxy so that you able to exercise your rights during the general meeting

Recipients

We may share your personal data with:

  • Suppliers, including IT-suppliers
  • The public via publication on the website cph.dk in accordance with the flagging rules regarding major shareholders
  • Nasdaq Copenhagen A/S
  • Public authorities, including the Danish Business Authority

Data retention

We will retain personal data for as long as it is necessary for the purposes mentioned.

  • We retain your personal data for up to 5 years plus the current financial year after you no longer own shares in CPH
  • A notice to convene the general meeting with agenda and complete proposals as well as registrations, proxies and postal votes are retained for 5 years plus the current financial year after the general meeting has taken place
  • Material that documents the company's history, decisions made, etc. is retained for as long as the company exists
Visual and audio recordings to be used for webcast and the preparation of minutes
 

Purpose

Visual and audio recordings may be made during general meetings. The recordings include the general meeting podium and rostrum. If you are identifiable on the recording, your personal data will be processed by us. We use the recordings to webcast the general meeting and to prepare the minutes.

Categories of personal data

We process the following categories of personal data about you:

Ordinary personal data:

  • Visual and audio recordings, including the information included therein

Source of the personal data

We collect your personal data from the following sources:

  • Recordings made during the general meeting

Legal basis for the processing

We process your personal data on the following legal basis:

  • Article 6.1.f - necessary for the pursuit of our legitimate interest in being able to webcast the general meeting and to maintain what was stated at the general meeting for the purpose of preparing the minutes

Recipients

We may share your personal data with:

  • Suppliers, including professional photographers etc. who was hired to make such recordings
  • The public

Data retention

We will retain personal data for as long as it is necessary for the purposes mentioned.

  • We retain visual and audio recordings for 2 years after the general meeting has taken place

Personal data about other parties

If you provide personal data about other people – e.g. name and contact information for advisors and proxies – you must make sure that they agree to it, and that you have permission to provide us with such data. In addition, you must refer them to this privacy policy when you provide us with their data.

Your rights

You have the following rights:

  • You have the right to request access to, rectification or erasure of your personal data.
  • You also have the right to have the processing of your personal data restricted.
  • If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent and exercise your rights as stated below.
  • You have the right to receive the personal data that you have provided yourself in a structured, commonly used and machine-readable format (data portability).
  • You may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency.

Furthermore, you have the right to object to our processing of your personal data in the following circumstances:

  • If our processing of your personal data is based on article 6(1)(e) (the public interest) or article 6(1)(f) (balancing of interests), see above regarding legal basis, you have the right to object, on grounds relating to your particular situation, at any time, to the processing of your personal data.

You can take steps to exercise your rights by contacting our DPO at privacy@cph.dk.

There may be conditions or limitations on these rights. It is therefore not certain that you, for example, have the right to have your personal data erased in the specific case - this depends on the specific circumstances of the processing activities.

If you wish to contact CPH regarding our processing of your personal data, please do not hesitate to contact us via the contact details above.