Legal Notices

Here you will find information on the subjects of data protection and disclaimers.

The information on this internet portal is subject to continuous review and updating by Commerzbank AG. However, some details may have changed since first published. We therefore accept no liability or guarantees for the accuracy, completeness or topicality of the information provided on this site or any other site to which hyperlinks are provided. Commerzbank AG is not responsible for the content of any external websites linked to in this way.

The content and structure of this portal are protected by copyright. Any reproduction of information or data, particularly the use of texts, text extracts or images is prohibited without the express prior consent of Commerzbank AG.

Data protection

Principles and sustainability

Your trust in a long-term business relationship is important to us. Commerzbank AG takes the protection of your personal data very seriously and adheres to the rules of data protection, in particular the provisions of the EU General Data Protection Regulation (GDPR) and our Group Data Protection Policy. The purpose of this policy is to ensure a consistently high level of data protection within the Group and to respect the rights and freedoms of the data subjects in the long term.

Personal data will only be processed if the data subject has consented, if this is required for the fulfillment of a contract or if the GDPR or another law permits or prescribes the processing.

The economical, proportionate, necessary and legally permissible handling of personal data and its purposeful processing as well as the guarantee of transparency and information to the data subject are rights under the Charter of Fundamental Rights of the European Union, to which Commerzbank expressly undertakes. In addition, Commerzbank only transmits personal data to third parties if this is lawful and it is not apparent that there is a risk to the rights and freedoms of the data subject. Commerzbank deletes personal data as soon as they are no longer required for business purposes and there are no other legitimate reasons to keep them, such as statutory retention periods. Where required by law, we can demonstrate that we comply with the principles governing the processing of personal data. Commerzbank has implemented technical and organizational measures to guarantee these goals in the long term.

Commerzbank immediately investigates inquiries, complaints, requests for information and violations of the protection of personal data and guarantees immediate information and close communication with the data subject, especially if there are possible risks to their rights and freedoms. In addition, the data subject can contact Commerzbank's data protection officer at any time: datenschutzbeauftragter@commerzbank.com.

With regular data protection impact assessments when processing and transmitting personal data, the risks are evaluated and countermeasures are taken to avert negative consequences for the data subjects. Commerzbank employees are regularly trained in data protection and supported in achieving data protection goals.

Personal data will only be disclosed to authorities if Commerzbank is legally obliged to do so. Insofar as it is obliged to do so, it reports on this and other data protection-related topics via its website.

Data processing on the websites

Personal data is generally collected to the extent that is technically necessary. Under no circumstances is the data forwarded to third parties without a legal basis. The following statements give you an overview of how the Commerzbank AG guarantees this protection and also an overview of the type of data that is collected, processed or used on the websites and to which purpose.

Recording

The Commerzbank AG automatically collects and stores some of the information usually transferred by the browser in their server log files, so far as your browser makes this data available. This data can usually not be connected with specific data subjects by Commerzbank AG. This data is not combined with other data sources.

Cookies

Our websites occasionally use cookies when you visit them. Cookies are text files which are filed on your computer and saved by your browser. The purpose of these is to make our service and offer user-friendly, effective and safe. Passwords are not deposited in cookies. Most of the cookies we use are so-called session cookies. They are automatically reset as soon as you log out. After you have ended the session by closing your browser, the cookie is saved for a certain amount of time and is subsequently overwritten or deleted by the client (e.g. your PC, your Tablet, Smartphone). Our cookies do not cause damage to your computer and contain no viruses.

We use cookies to collect technical data to ensure uninterrupted operation. This helps to identify and resolve functional problems, and continuously improve performance.

We also set cookies after your explicit consent to measure success and optimize our advertising measures.

Processing of personal data

To send you publications or newsletters presented on the website that you ordered, we request your name, your address and your email address by an order form. This data is stored and used solely for the purpose of sending you the desired information based on Art. 6 (1 b) GDPR. It is not forwarded or passed on to third parties. By entering your data (name, address, email address) in the form, you give us your consent to store and to use the data to send you the information. The personal data you enter to receive the newsletter is stored until you cancel the subscription.

Right of access by the data subject

You have the right to receive information on the data

stored about your person, the categories of recipients thereof and the purpose of the processing. Furthermore, we are available to answer your questions about the collection, processing and use of your personal data.

Processing of personal data on the basis of the EU data protection regulation

Commerzbank AG processes personal data on the basis of the EU General Data Protection Regulation (GDPR). With the following information we provide an overview of the processing of this personal data by us and the rights resulting from data protection law: www.commerzbank.de/dataprotection

Further information

If you require information that this data protection declaration cannot provide you with or if you require further information on a specific point, please contact the data protection officer at Commerzbank AG: datenschutzbeauftragter@commerzbank.com

Notices on data protection for using Microsoft Teams

Information on data protection regarding the use of Microsoft Teams can be found here.

Data Protection Notices for use of DocuSign

This information gives you, as the contractual partner, an overview of the processing of your personal data that arises when using the DocuSign software. We inform you about what data we collect from you and how we use it. We will also inform you about your rights under applicable data protection law and tell you who you can contact if you have any questions.

1. Controller

Commerzbank AG, with which you use DocuSign for your request, is responsible for data collection and processing.

2. Data Protection Officer

You can reach our data protection officer at

Commerzbank AG
Data Protection Officer
Kaiserplatz, 60261 Frankfurt am Main
datenschutzbeauftragter@commerzbank.com

3. Scope and Purpose of Processing

We process the following personal data:

• Your email address,
• Your (qualified) digital signature via DocuSign.

4. Legal Basis for Processing

The DocuSign software is used to formally simplify the processes within the controller. It is used where and in the form where the corresponding written form requirements allow this. Likewise, the traceability of the receipt of the necessary feedback can be facilitated.
The legal basis for the processing of personal data is Art. 6 Para. 1 f GDPR (optimization of formal processes). Your e-mail address is used to send the form and to facilitate the process of obtaining these necessary documents. The legal basis for the processing of personal data is therefore Art. 6 Para. 1 f GDPR with the aforementioned legitimate interests.

5. Recipients of the personal data; Data transfer to third countries

Your personal data will be processed internally by the departments of Commerzbank AG with which you are in contact.

In addition, this data is transmitted externally to the responsible supporting service provider for a specific purpose. We use so-called contract processors to process the signatures. Service providers used by us must meet special confidentiality requirements. You will only have access to your data to the extent and for the period required to perform the tasks.

We also use service providers located in third countries outside the European Union to process your data. Countries outside the European Union handle the protection of personal data differently than countries inside the European Union. There is currently no decision by the EU Commission that these third countries must generally offer an adequate level of protection. We have therefore taken special measures to ensure that your data is processed just as securely in the third countries as it is within the European Union. With service providers in third countries, we conclude the data protection contract (standard data protection clauses) provided by the EU Commission for the processing of personal data in third countries. This provides suitable guarantees for the protection of your data from service providers in third countries.

If there is a suspicion of a criminal offence, we can pass on your data to law enforcement authorities (e.g. police, public prosecutor's office).

6. Duration of storage

Your personal data will be stored as long as this is necessary to fulfill the stated purposes and as long as legal and/or contractual storage obligations are relevant.
After the end of the service relationship, the data will also be deleted after the relevant retention periods.

• Tax-relevant data, for example, is stored for a period of 6 or 10 years (§§ 257 HGB, 147 AO).
• The data processed via DocuSign is automatically deleted by the system after 120 days after the document has been completed.

7. Automated Decision Making; profiling

We do not process your data for so-called automated decision-making, including profiling.

8. What data protection rights do I have?

Every data subject has the right to information under Article 15 GDPR, the right to rectification under Article 16 GDPR, the right to erasure under Article 17 GDPR, the right to restriction of processing under Article 18 GDPR, the right to object under Article 21 GDPR and the right to data portability under Article 20 GDPR. The restrictions under §§ 34 and 35 BDSG apply to the right to information and the right to erasure. In addition, there is a right of appeal to a competent data protection supervisory authority (Article 77 GDPR in conjunction with Section 19 BDSG).

If data is collected on the basis of Art. 6 Para. 1 f GDPR (data processing to protect legitimate interests), you have the right to object to the processing of your data for reasons that arise from your particular situation. In the event of an objection

Disclaimer

IMPORTANT NOTICE

No Liability

Users of this website expressly recognise that they use this website at their own risk and sole responsibility.

For Information Purposes Only

The content of this website has been created and published by the Corporates Clients division of Commerzbank AG, Frankfurt/Main or the group companies mentioned in the document ("Commerzbank"). Commerzbank Corporates Clients is the investment banking division of Commerzbank.

The content of this website is a financial promotion/marketing communication (together “communication”). It is not “investment research” or “financial analysis” as these terms are defined in applicable regulations and has not been prepared by a research analyst. The views in this communication may differ from the published views of Commerzbank Corporates Clients Research Department and the communication has been prepared separately of such department. This communication may contain short term trading ideas. Any returns or future expectations referred to are not intended to forecast or predict future events. Any prices provided herein (other than those that are identified as being historical) are indicative only, and do not represent firm quotes as to either size or price. This communication is for information purposes only. The descriptions of the products and ideas featured in this document do not purport to be comprehensive descriptions. The information contained herein does not constitute the provision of investment advice. It is not intended to be nor should it be construed as an offer or solicitation to acquire, or dispose of, any of the financial instruments and/or securities mentioned in this communication and will not form the basis or a part of any contract.

Potential counterparties/distributors should review independently and/or obtain independent professional advice and draw their own conclusions regarding the suitability/appropriateness of any transaction including the economic benefit and risks and the legal, regulatory, credit, tax and accounting aspects in relation to their particular circumstances. Levels, bases and relief from taxation may change from time to time.

Any information in this communication is based on data obtained from sources believed by Commerzbank to be reliable, but no representations, guarantees or warranties are made by Commerzbank with

regard to the accuracy, completeness or suitability of the data. Commerzbank has not performed any independent review or due diligence of publicly available information regarding an unaffiliated referenced asset or index.

The past performance of financial instruments is not indicative of future results. No assurance can be given that any financial instrument or issuer described herein would yield favourable investment results. This communication is intended solely for distribution to professional clients and/or eligible counterparties of Commerzbank. It is not intended to be distributed to retail clients or potential retail clients. Neither Commerzbank nor any of its respective directors, officers or employees accepts any responsibility or liability whatsoever for any expense, loss or damages arising out of or in any way connected with the use of all or any part of this communication.

Commerzbank and/or its principals or employees may have a long or short position or may transact in financial instrument(s) and/or securities referred to herein or may trade in such financial instruments with other customers on a principal basis. The information may have been discussed between various Commerzbank personnel and such personnel may have already acted on the basis of this information (including trading for Commerzbank’s own account or communication of the information to other customers of Commerzbank). Commerzbank may act as a market maker in the financial instruments or companies discussed herein and may also perform or seek to perform investment banking services for those companies. If an actual secondary market does not exist after an offering, you may not be able to sell the security at a price above or below what you paid initially at the offering. Commerzbank is not obligated to provide, can be above or below the offer price based on market factors at that point in time. Debt securities issued by Commerzbank or its affiliates are unsecured obligations and any payment on the security is subject to the credit risk of the issuing entity. Any changes to our credit rating may have a positive or adverse impact on the security. If we were to default on our payment obligations, you may not receive amounts owed to you and or lose your entire investment.

The offer price of our securities will exceed the estimated value when the value was provided, as determined by Commerzbank’s pricing models, which incorporates numerous factors that may include our creditworthiness, market conditions as well as other applicable factors. These pricing models are proprietary and predicated partly on certain assumptions about future events that can be correct or not. The difference between the estimated value and offer price is based on factors that can include underwriter discount, commission and expenses involving marketing. No part of this communication may be reproduced, distributed or transmitted in any manner without prior written permission of Commerzbank. This communication or the manner of its distribution may be restricted by law or regulation in certain countries. Persons into whose possession this document may come are required to inform themselves about, and to observe, any such restriction. By accepting this communication, a recipient hereof agrees to be bound by the foregoing limitations.

United Kingdom:

The content of this website is intended solely for professional customers and/or eligible counterparties of Commerzbank. It is not intended to be distributed to retail clients or potential retail clients.

Commerzbank AG is authorised by the German Federal Financial Supervisory Authority and the European Central Bank. Commerzbank AG, London Branch is authorised and regulated by Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) and the European Central Bank. Authorised by the Prudential Regulation Authority. Subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are available from us on request. (Financial Services Register number: 124920)

US:

To the extent this communication is distributed in the United States, it must solely be sent to “institutional investors” and “major U.S. institutional investors,” as defined in Rule 15a-6 under the Securities Exchange Act of 1934. Any securities transaction by U.S. persons must be effected with Commerz Markets LLC (“CMLLC”), a wholly owned subsidiary of Commerzbank AG and a US registered broker-dealer. CMLLC is a member of FINRA and SIPC. Under applicable US law, information regarding clients of CMLLC may be distributed to other companies within Commerzbank. Banking services in the U.S. will be provided by Commerzbank AG, New York Branch. Any derivatives transaction with U.S. persons must be effected with Commerzbank AG, in accordance with the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Commerzbank AG is not a member of SIPC and is a provisionally registered swap dealer with the CFTC. Some products or services may be unavailable in the United States.

Canada: The information contained herein is not, and under no circumstances is to be construed as, a prospectus, an advertisement, a public offering, an offer to sell securities described herein, solicitation of an offer to buy securities described herein, in Canada or any province or territory thereof. Any offer or sale of the securities described herein in Canada will be made only under an exemption from the requirements to file a prospectus with the relevant Canadian securities regulators and only by a dealer properly registered under applicable securities laws or, alternatively, pursuant to an exemption from the dealer registration requirement in the relevant province or territory of Canada in which such offer or sale is made. Under no circumstances is the information contained herein to be construed as investment advice in any province or territory of Canada and is not tailored to the needs of the recipient. In Canada, the information contained herein is intended solely for distribution to Permitted Clients (as such term is defined in National Instrument 31-103) with whom Commerz Markets LLC deals pursuant to the international dealer exemption. To the extent that the information contained herein references securities of an issuer incorporated, formed or created under the laws of Canada or a province or territory of Canada, any trades in such securities may not be conducted through Commerz Markets LLC. No securities commission or similar regulatory authority in Canada has reviewed or in any way passed upon these materials, the information contained herein or the merits of the securities described herein and any representation to the contrary is an offence.

Dubai (DIFC): The content on this website has been approved for distribution in or from the DIFC, Dubai, United Arab Emirates (the U.A.E) under the applicable Regulatory Law 2004 and the DFSA Rules by Commerzbank AG, DIFC Branch. This content may only be received in or from the DIFC, Dubai U.A.E by Market Counterparties and Professional Clients as defined in the DFSA Rulebook Conduct of Business Module Section 2.3. Commerzbank AG, DIFC Branch is regulated by The Dubai Financial Services Authority (The DFSA). Commerzbank AG, DIFC Branch Suite 11-15, Gate Village 05, 4th Floor, Dubai International Financial Centre PO Box 506596, Dubai, United Arab Emirates, Tel.: +971 4 428 4999.

Japan: The information contained in this website does not constitute and should not be construed as a "solicitation" under the Japanese Financial Instrument Exchange Act (FIEA) of Japan and the Commodity Derivative Act (hereinafter, "CDA") of Japan. This information is provided solely to "professional investors" as defined in Section 2(31) of the FIEA and Section 23 of the Cabinet Ordinance Regarding Definition of Section 2 of the FIEA and "Persons, etc. with high ability on OTC Commodity Derivative Transaction" as defined in Article 1 of the Ordinance for Enforcement of the CDA. Note that Commerzbank AG, Tokyo Branch has not participated in its preparation. Not all financial / commodity or other instruments referred to in this document are available from the Tokyo Branch. You should contact the Corporate Clients Division of Commerzbank AG in the respective countries for inquiries on the availability of such instruments.

Hong Kong: The content on this website is furnished in Hong Kong by Commerzbank AG, Hong Kong Branch, and may be received in Hong Kong only by "professional investors" within the meaning of the Securities and Futures Ordinance (Cap.571) of Hong Kong and any rules made there under, and persons whose ordinary business is to buy or sell shares or debentures.

Italy: You should contact Commerzbank AG, London Branch if you wish to use our services to effect a transaction in any of the financial or other instruments mentioned in this communication.

People’s Republic of China (PRC): The content of this website is furnished by Commerzbank AG and is intended only for institutions that are eligible for financial transactions. No one else may rely on any information contained within this website. Unless otherwise regulated, any derivative transactions by PRC entities may be entered into only by enterprises for hedging purposes, or PRC financial institutions which are permitted to conduct derivatives business in the PRC and have obtained all necessary regulatory approvals in the PRC.

Singapore: The communication and/or information contained in this website should be read or received only by an institutional investor or an accredited investor as respectively defined in section 4A of the Securities and Futures Act, Chapter 289 of Singapore ("SFA") pursuant to section 274 or section 275 (as applicable) of the SFA. Nothing in this website constitutes accounting, legal, regulatory, tax, financial or other advice and/or recommendations to the recipient of this communication/information. Further, the communication/information contained herein does not constitute a "financial advisory service" within the meaning of the Financial Advisers Act, Chapter 110 of Singapore ("FAA") and therefore, the regulatory requirements and duties that may be owed to a client pursuant to or in connection with the FAA are not applicable to the recipient in connection with this communication/information on this website. Recipients are advised to seek independent advice from their own professional advisors about the information contained herein.

Information about credit transfers

Payment data of cross border credit transfers and other urgent payments are transferred to the beneficiary’s bank via SWIFT (Society for Worldwide Interbank Financial Telecommunication), the only worldwide acting provider of financial messaging services and which is based in Belgium. For data security reasons, SWIFT stores the transaction data temporarily in their data processing centres in the Netherlands and in Switzerland.

The occasion of this information is the resolution of the EU-Council in November 2009 to grant US-authorities access to credit transfer data from February 1st, 2010 until October 31st, 2010 in the data processing centre in Switzerland in order to fight international terrorism.

Dow Jones

Dow Jones’ content is the intellectual property of Dow Jones & Company, Inc. The data is protected by copyright and other intellectual laws and all ownership rights remain with Dow Jones. Any copying, republication or redistribution of Dow Jones’ content, including by caching, framing or similar means, is expressly prohibited without the prior written consent of Dow Jones. Dow Jones’ shall not be liable for any errors or delays in content, or for any actions taken in reliance thereon.

Copyright

All information contained herein shall be used only by the user for their own personal reference. Commerzbank owns all copyrights in this website. Downloading, copying and saving of all or parts of this website is allowed only for private reasons. Any other use, including any disclosure or distribution of any information to any third party, the creation of links to this internet portal or the display of COSOPIA webpages in a frame requires the express written permission of Commerzbank.

Copyright © Commerzbank 2022. All rights reserved.

Arbitration/Ombudsman

The Bundesverband deutscher Banken (German Association of Banks) is the arbitration board for complaints and grievances in connection with transfer transactions or with payment transaction cards. Furthermore, consumers can address their general complaints about the German Association to the ombudsman of the private banks (www.bankenombudsmann.de). More details, especially on the legitimacy and on the procedure itself can be found on the website of the German Association of Banks (www.bankenverband.de).