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Privacy Policy - Shareholders

This privacy policy explains how Bavarian Nordic A/S process your personal information in connection with our shareholder administration activities. 

1. DATA CONTROLLER

The legal entity responsible for the processing of your personal information is:

Bavarian Nordic A/S
CVR: 16271187
Hejreskovvej 10A
3490 Kvistgaard
Denmark     

If you have inquiries and/or questions to our processing of your personal information, please contact us at data.request@bavarian-nordic.com 

2. CATEGORIES OF PERSONAL INFORMATION

We may collect and process the following categories of personal information about you:

  • Contact details
  • Custodian bank
  • VP account number
  • Username and password
  • Photos and videos taken on the general meetings
  • Communication preferences
  • Bavarian Nordic stock portfolio information (such as numbers of shares, voting rights, historical transactions, etc.)
  • Annual general meeting information (e.g. meeting invitation, attendance, voting, accompanying persons, proxies etc.)
  • Meeting minutes for general meetings and other meetings with current and potential new shareholders
  • Other information relevant to the shareholding 

3. SOURCES

When we collect personal information from other sources than you, those sources may be:

  • Computershare
  • VP Securities
  • Nasdaq
  • Other group legal entities
  • Banks and other relevant IR actors 

4. USE OF PERSONAL INFORMATION

We may use your personal information for the following purposes:

  • Compliance with the Danish Companies Act (such as the requirement to maintain a shareholder registry, conducting general meetings etc.)
  • Compliance with various tax legislation and other relevant legislation
  • Sharing relevant Bavarian Nordic shareholder news with you as requested by you
  • Other investor relation activities which may be relevant 

5. LEGAL BASIS

We may process your personal information based on the following legal bases:

  • Processing is necessary for compliance with a legal obligation to which Bavarian Nordic is subject (Art. 6 (1) litra c of the GDPR) – The Danish Company Act, Danish tax legislation and other relevant legislation.
  • You have given your consent to the processing of your personal information for one or more specific purposes (Art. 6 (1) litra a of the GDPR) - The informed consent form presented and approved by you upon entry into the Bavarian Nordic’s Shareholder Portal hosted by Computershare.
  • Processing is necessary for the purposes of the legitimate interests pursued by Bavarian Nordic (Art. 6 (1) litra f of the GDPR) – The interest in maintaining a strong IR management 

6. SHARING OF YOUR PERSONAL INFORMATION

We may share your personal data on a strict need-to-know basis with:

  • Computershare
  • Nasdaq
  • VP Securities
  • Other group legal entities
  • Relevant authorities (e.g. the Danish Business Authority) 

7. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

Your personal information will as a main rule not be transferred to countries outside EU/EEA.

If it becomes necessary to transfer all or some of your personal information to countries outside the EU/EEA that are not deemed to provide an adequate level of protection of your personal information compared to the EU/EEA, we will only transfer the personal information after having provided appropriate safeguard, such as the use of EU Standard Contractual Clauses.

You may obtain a copy of any such safeguards by contacting us as provided for in Section 1. 

8. RETENTION OF YOUR PERSONAL INFORMAITON

It is our policy not to keep personal information for longer than necessary.

Where personal data is kept, the period will be determined based on applicable law.  For further information, please contact us as provided for in Section 1. 

9. YOUR RIGHTS

In general, you have the following rights to:

  • Request access to and rectification or erasure of your personal information.
  • Object to the processing of your personal data and have the processing of your personal data restricted.
  • Object to the processing of your personal data for direct marketing purposes (we do not use your personal information for marketing purposes).
  • If processing of your personal information 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.
  • Receive your personal information in a structured, commonly used and machine-readable format (data portability).
  • Not be subject to automated individual decision-making, including profiling (we do not use your personal information for such automated individual decision-making).

Your rights may be subject to statutory limitations and conditions. It is therefore not certain Bavarian Nordic has to comply with your request.    

You also have the right to lodge a complaint with the Danish Data Protection Authority. The Danish Data Protection Authority has the following contact details:

Datatilsynet
Borgergade 28, 5
1300 København K
Telephone number: +45 33 19 32 00
Email: dt@datatilsynet.dk
www.datatilsynet.dk

10. AUTOMATED DECISION-MAKING

Your personal information will not be used for automated decision-making, including profiling. 

11. CHANGES TO THIS PRIVACY POLICY

Changes to this privacy policy will be posted on our webpage here: /about/privacy/shareholders.aspx. We encourage you to visit our webpage regularly to keep yourselves updated on any such changes.