This Privacy Policy applies to the processing of personal data collected through this landing page, which provides information about the Climate Change Performance Index (CCPI) and facilitates the initiation of commercial licensing enquiries for institutional clients. We process personal data exclusively in accordance with the applicable provisions of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG).

We process the following categories of personal data:

When you submit an enquiry via our Client Information Form, we collect: - Full name - Business email address - Professional role/function - Description of intended use case

When you access this website, the following data may be automatically collected and temporarily stored in log files: - IP address - Date and time of access - Browser type and version - Operating system - Referring URL - Access status/HTTP status code

If you contact us via email or other communication channels, we may process the content of your communication and associated metadata.

We process your personal data on the following legal grounds:

Art. 6(1)(b) GDPR (Pre-contractual measures): Processing of contact form data to respond to your enquiry and initiate potential licensing arrangements for the Climate Change Performance Index (CCPI).

Art. 6(1)(f) GDPR (Legitimate interests): Processing of technical data for the purpose of:

- Ensuring the technical functionality and security of our website - Improving user experience and website optimization - Maintaining business relationships and conducting follow-up communications with qualified leads

Our legitimate interest lies in the effective operation of our business activities, the provision of information about our data licensing services, and the cultivation of commercial relationships with institutional clients in the financial sector.

Art. 6(1)(a) GDPR (Consent): Where you have opted in to receive marketing communications, we process your data based on your explicit consent. You may withdraw this consent at any time with future effect.

We process your personal data for the following purposes:

- Responding to enquiries submitted via the contact form - Providing requested information materials (factsheets, documentation) - Evaluating use case descriptions to determine appropriate licensing models - Facilitating demo access following manual review and approval - Synchronizing data with our customer relationship management (CRM) system - Conducting follow-up communications regarding licensing opportunities - Analyzing website usage to improve content and user experience - Ensuring website security and preventing misuse

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

Contact form submissions: Data submitted via the contact form is retained for the duration of the enquiry process and subsequent business relationship. In the absence of active communication or commercial engagement, data will be deleted after a maximum period of 24 months from the date of last contact.

Technical log data: Server log files are automatically deleted after 30 days.

Communication records: Correspondence related to active or concluded licensing arrangements may be retained for statutory retention periods as required by commercial and tax law (typically 6 to 10 years).

You may request earlier deletion of your data at any time, subject to legal retention obligations.

Your personal data is processed internally by authorized employees of RCLM GmbH who require access to perform their duties related to client services, sales, and data licensing operations.

We engage the following categories of third-party processors to support our operations:

Purpose: Customer relationship management (CRM), form processing, marketing automation, and analytics Location: European Union (Germany) Legal basis: Data Processing Agreement in accordance with Art. 28 GDPR

Purpose: Website hosting and content delivery Location: European Union (Germany) Legal basis: Data Processing Agreement in accordance with Art. 28 GDPR

Purpose: Delivery of web fonts (if applicable) Location: European Union (Ireland); potential processing in the USA under adequate safeguards Legal basis: Art. 6(1)(f) GDPR (legitimate interest in consistent website presentation)

All third-party processors are carefully selected and contractually bound to process data only in accordance with our instructions and applicable data protection law.

Data processing by our service providers takes place primarily within the European Union. Where data is processed in third countries (outside the EU/EEA), we ensure an adequate level of data protection through:

- Standard Contractual Clauses (SCCs) approved by the European Commission (Art. 46(2)(c) GDPR) - Adequacy decisions pursuant to Art. 45 GDPR - Additional technical and organizational measures where necessary

We do not sell or otherwise disclose your personal data to third parties for their own purposes.

This website may use cookies and similar technologies. Cookies are small text files stored on your device that enable certain website functions and usage analysis.

We may use both technically necessary cookies (essential for website operation) and optional cookies for analytics and performance optimization. You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may limit website functionality.

We may use HubSpot Analytics to evaluate website usage and improve our services. This may include analysis of page views, visitor behavior, and form interactions. Analytics data may be processed in aggregated or pseudonymized form wherever possible and stored on servers within the European Union. You can object to analytics tracking at any time.

Under the GDPR, you have the following rights regarding your personal data:

Right of access (Art. 15 GDPR): You may request confirmation as to whether we process your personal data and obtain information about such processing; Right to rectification (Art. 16 GDPR): You may request correction of inaccurate personal data; Right to erasure (Art. 17 GDPR): You may request deletion of your personal data where legally permissible; Right to restriction of processing (Art. 18 GDPR): You may request limitation of processing under certain conditions; Right to data portability (Art. 20 GDPR): You may request to receive your personal data in a structured, commonly used, and machine-readable format; Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests (Art. 6(1)(f) GDPR) on grounds relating to your particular situation; Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw such consent at any time with future effect; and Right to lodge a complaint (Art. 77 GDPR): You have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these rights, please contact us using the contact details provided above.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, or unauthorized disclosure. These measures include:

- Encryption of data transmission (TLS/SSL) - Access controls and authentication mechanisms - Regular security assessments and updates - Employee training on data protection requirements - Contractual safeguards with third-party processors

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

The provision of personal data via the contact form is voluntary. However, without providing the requested information, we may not be able to process your enquiry or provide you with the requested materials regarding the Climate Change Performance Index (CCPI) licensing options.

If you have opted in to receive marketing communications, we may periodically send you information about our data products, services, and related content. You may unsubscribe from such communications at any time by:

- Using the unsubscribe link included in each marketing email - Contacting us directly at inquire [at] rclm-data.com - Adjusting your communication preferences in our system

This website may contain links to external websites operated by third parties. We have no control over the content and data protection practices of such websites. Please review the privacy policies of third-party websites before providing any personal data.

We reserve the right to update this Privacy Policy to reflect changes in our data processing practices or legal requirements. The current version is always available on this website. Material changes will be communicated through appropriate means.

If you have any questions about this Privacy Policy or our data processing practices, please contact us at inquire [at] rclm-data.com.

RCLM GmbH

Last update: 16.11.2025