Data privacy

1. An overview of data protection

General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit our website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on our website
Who is the responsible party for the recording of data on this website (i.e. the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information Required by Law” on this website.

How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Our IT systems automatically record other data when you visit our website. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access our website.

What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyse your user patterns.

What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified, blocked or eradicated. Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.

Moreover, under certain circumstances, you have the right to demand the restriction of the processing of your personal data. For details, please consult the Data Protection Declaration under section “Right to Restriction of Data Processing.”

Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analysed when your visit our website. Such analyses are performed primarily with cookies and with what we refer to as analysis programmes. As a rule, the analyses of your browsing patterns are conducted anonymously; i.e. the browsing patterns cannot be traced back to you. You have the option to object to such analyses or you can prevent their performance by not using certain tools. For detailed information about this, please consult our Data Protection Declaration below.

You do have the option to object to such analyses. We will brief you on the objection options in this Data Protection Declaration.

2. General information and mandatory information

Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:

Universal-Investment-Gesellschaft mbH
Theodor-Heuss-Allee 70
60486 Frankfurt am Main Deutschland
P: +49 69 71043-0
info@universal-investment.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Designation of a data protection officer as mandated by law
We have appointed a data protection officer for our company.

Universal-Investment-Gesellschaft mbH
Data Protection Officer
Theodor-Heuss-Allee 70
60486 Frankfurt am Main
P: +49 1752 649267
datenschutzbeauftragter@universal-investment.com

Universal- Beteiligungs- und Servicegesellschaft mbH
Data Protection Officer
Theodor-Heuss-Allee 70
60486 Frankfurt am Main
Markus.Sullivan@universal-investment.com

Universal-Investment-Luxembourg S.A.
Data Protection Officer
15 Rue de Flaxweiler,
6776 Potaschberg Grevenmacher,
Luxembourg
uil@dury-consult.com

UI efa S.A.
Data Protection Officer
2, Rue d'Alsace
L - 1122 Luxembourg
Linda.Tessin@efa.eu


Universal-Investment-Labs GmbH
Data Protection Officer
Theodor-Heuss-Allee 70
D-60486 Frankfurt am Main
datenschutzbeauftragter@uilabs.de

CAPinside GmbH
Data Protection Officer
Postfach 17 05 48
60079 Frankfurt am Main
datenschutz@capinside.com

UI Enlyte-Gesellschaft mbH
Data Protection Officer
Theodor-Heuss-Allee 70
60486 Frankfurt am Main
Germany
datenschutzbeauftragter@enlyte.eu

Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
In the event that data are processed on the basis of Art. 6 Sect. 1 lit. e or f GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this Data Protection Declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to Art. 21 Sect. 1 GDPR).

If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21 Sect. 2 GDPR).

Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme. You can recognise an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Information about, blockage, rectification and eradication of data.

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified, blocked or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in section “Information Required by Law” to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

Whistleblowing system
To implement the whistleblower system requirements, we work together with CLARIUS.LEGAL Rechtsanwaltsaktiengesellschaft, Neuer Wall 77 20354 Hamburg, Germany.

If you send us a message via the whistleblower form or the message function, your entries from the form will be stored by us for the purpose of processing the whistleblowing. You always have the option of submitting the message without providing personal data.

The processing of this data is based on Art. 6 (1) lit. c DSGVO, provided that we are obliged to accept reports via a reporting chanel. In all other cases, the processing is based on our legitimate interest in effective communication and processing of the notices addressed to us (Art. 6 (1) (f) DSGVO).

The data you entered in the form will remain with us until the processing of the notification is completed, the purpose for data storage ceases to apply. After that, the data from the notification and processing will be stored for up to 3 years within the general limitation periods. The basis is the legitimate interest (Art. 6 para. 1 lit. f DSGVO) to defend against claims by third parties. The documentation may be kept longer to fulfill the requirements under this law or other legal provisions, as long as this is necessary and proportionate.

3. Recording of data on our website

Server-Log-Files
When you visit our websites, our web servers temporarily store each access in a log file. The following data is recorded and stored until it is automatically deleted:

• IP address of the requesting computer
• Date and time of access
• Name and URL of the retrieved file
• Transmitted data volume
• Message as to whether the retrieval was successful
• Identification data of the browser and operating system used
• Website (URL) from which the access was made

Your internet browser automatically transmits this data to our web server when you access our website. This data is processed to enable use of the website (building up a connection), ensure system security and the technical administration of the network infrastructure as well as optimise the internet offerings. The IP address is only stored temporarily and in an abbreviated form to enable our web analysis tool to geolocate the site accesses; no evaluation takes place at the individual person level. No personal user profiles are created. The German Telemedia Act (TMG) permits the use of user profiles under a pseudonym in accordance with section 15 (3) TMG provided the user does not object to this. If we make use of this option on our website, we shall refer to your right of objection at the appropriate point.

Apart from the cases mentioned above, personal data shall not be collected and processed unless you expressly consent to the further processing of aforesaid data.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Use and disclosure of personal data
Any use of your personal data shall only take place for the stated purposes and to the extent necessary to achieve these purposes. Personal data shall only be passed on to state institutions and authorities within the framework of mandatory national legislation or if such disclosure is necessary for legal and criminal prosecution in the event of attacks on our network infrastructure. No data shall be passed on to third parties for any other purposes.

Consent to further use
The use of certain offerings on our website, such as newsletters, requires prior registration and further processing of personal data such as long-term storage of e-mail addresses, user IDs and passwords. Such data shall only be used if you have transmitted it to us and given your prior consent to its use.

Recruitment of personnel
Universal Investment receives personal data from you in connection with a job application or inquiry, regardless of whether it is made on our website or in any other form, such as a CV. Universal Investment can use this personal data within the company for the purpose of deciding on employment or responding to the inquiry.

In the case of job applications that do not lead to a recruitment, the documents will be deleted maximum within six months after the application procedure has been completed, unless they will have to be stored due to legally justified reasons. Your application documents will only be kept for later selection procedures if you have given us your prior consent. 

The period that we storage your data is regulated by law of the country you apply from or work in. 

After the recruitment process is over you will be provided an anonymous and voluntary questionnaire in order to learn your level of satisfaction after the application procedure. 
By filling in the questionnaire, you give your consent to the processing of your personal data.
The controller of your personal data is Universal- Investment GmbH

If you order information material, we use the address data provided for the sole purpose of processing this order. The data shall not be passed on to third parties.

Security
Universal Investment applies technical and organizational measures (TOMs) to protect your personal data managed by us against accidental or deliberate manipulation, destruction or access by unauthorized persons. We continuously improve our security measures in line with technological developments.

Cookies
Cookies are only used to store technical session control data in your browser’s memory. If, in exceptional cases, we also wish to store personal data in a cookie, such as a user ID, we shall inform you of this separately. You can of course also view our websites without cookies. However, most browsers automatically accept cookies. You can prevent cookies from being saved by setting this in your browser settings. If you do not accept cookies, this can lead to functional restrictions of our offerings. Here you can alter your individual cookie settings.

Universal Investment does not use cookies containing personal data in the fund selector (www.fondsfinder.universal-investment.com) and on the website (www.universal-investment.com). However, the following types of cookies are set on both websites:

Cookies

Cookies are only used to store technical session control data in your browser’s memory. If, in exceptional cases, we also wish to store personal data in a cookie, such as a user ID, we shall inform you of this separately. You can of course also view our websites without cookies. However, most browsers automatically accept cookies. You can prevent cookies from being saved by setting this in your browser settings. If you do not accept cookies, this can lead to functional restrictions of our offerings. Here you can alter your individual cookie settings.

Universal Investment does not use cookies containing personal data in the fund selector (www.fondsfinder.universal-investment.com) and on the website (www.universal-investment.com). However, the following types of cookies are set on both websites:

Functional Cookies

• Technical cookies for distributing requests to various backend servers (the content of the cookies does not vary per user)
• Cookies for measuring and monitoring service by Microsoft. These cookie values vary depending on the user and browser: Universal Investment receives a different value in the cookie for each computer/browser/PC user. These values are clear, but do not allow any conclusions to be drawn about the person.
• Cookies for measuring user behaviour through etracker
• Cookies for measuring user behaviour through Google Analytics

The fund finder also sets cookies:

• depending on the user’s choice, for the selected country of origin
• depending on the user’s choice, for the selected investor type
• a cookie that is identical for all users of the fund finder

The cookies of Google Analytics (web analysis) and Microsoft (technical analysis) are set for a period of up to one year – we are unable to influence the content of these cookies and the length of time for which they are set. The one-year cookies from Microsoft and Google Analytics are already set when the address www.universal-investment.com is requested – i.e. even before a message has been displayed.

When the PowerPortal is requested, an authentication cookie is set (for a period of one day after the user has logged in) and a cookie for storing a date (one year), as well as two session cookies (until the browser is closed).

The cookie data is not linked to your other data. You can find out more about how cookies work by visiting the following website: www.allaboutcookies.org.

Cookie consent with Cookiebot

Our website uses cookie consent technology from Cookiebot to obtain your consent to store certain cookies on your terminal device and to document this consent in accordance with data protection law. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter "Cookiebot").

When you enter our website, a connection is established to Cookiebot's servers to obtain your consents and other declarations regarding cookie use. Subsequently, Cookiebot stores a cookie in your browser in order to be able to assign the consents granted to you or their revocation. The data collected in this way will be stored until you request us to delete it, delete the Cookiebot cookie yourself or the purpose for storing the data no longer applies. Mandatory legal storage obligations remain unaffected. Cookiebot is used 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 DSGVO. You can change your cookie consent at any time and modify your configurations by clicking on the link in the footer. 

Request by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 (1) a GDPR) and/or on our legitimate interests (Article 6 (1) (f) GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

4. Analysis tools and advertising

Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored.

The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities.

IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyse your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objection to the recording of data
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics
This website uses the function “demographic parameters” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender and interests of website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data.”

Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=de.

Google Analytics Remarketing
Our websites use the functions of Google Analytics Remarketing in combination with the functions of Google AdWords and Google DoubleClick, which work on all devices. The provider of these solutions is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This function makes it possible to connect the advertising target groups generated with Google Analytics Remarketing with the functions of Google AdWords and Google DoubleClick, which work on all devices. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g. cell phone) in a manner tailored to you as well as on any of your devices (e.g. tablet or PC).

If you have given us pertinent consent, Google will connect your web and app browser progressions with your Google account for this purpose. As a result, it is possible to display the same personalized advertising messages on every device you log into with your Google account.

To support this function, Google Analytics records Google authenticated IDs of users that are temporarily connected with our Google Analytics data to define and compile the target groups for the ads to be displayed on all devices.

You have the option to permanently object to remarketing / targeting across all devices by deactivating personalized advertising in your Google account. To do this, please follow this link: https://www.google.com/settings/ads/onweb/.

The consolidation of the recorded data in your Google account shall occur exclusively based on your consent, which you may give to Google and also revoke there (Art. 6 Sect. 1 lit. a GDPR). Data recording processes that are not consolidated in your Google account (for instance because you do not have a Google account or have objected to the consolidation of data), the recording of data is based on Art. 6 Sect. 1 lit. f GDPR. The legitimate interest arises from the fact that the operator of the website has a legitimate interest in the anonymized analysis of website visitor for advertising purposes.

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.

Google AdWords and Google Conversion Tracking
This website uses Google AdWords. AdWords is an online promotional program of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

In conjunction with Google AdWords, we use a tool called Conversion Tracking. If you click on an ad posted by Google, a cookie for Conversion Tracking purposes will be placed. Cookies are small text files the web browser places on the user’s computer. These cookies expire after 30 days and are not used to personally identify users. If the user visits certain pages of this website and the cookie has not yet expired, Google and we will be able to recognise that the user has clicked on an ad and has been linked to this page.

A different cookie is allocated to every Google AdWords customer. These cookies cannot be tracked via websites of AdWords customers. The information obtained with the assistance of the Conversion cookie is used to generate Conversion statistics for AdWords customers who have opted to use Conversion Tracking. The users receive the total number of users that have clicked on their ads and have been linked to a page equipped with a Conversion Tracking tag. However, they do not receive any information that would allow them to personally identify these users. If you do not want to participate in tracking, you have the option to object to this use by easily deactivating the Google Conversion Tracking cookie via your web browser under user settings. If you do this, you will not be included in the Conversion Tracking statistics.

The storage of “Conversion” cookies and the use of this tracking tool are based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising.

To review more detailed information about Google AdWords and Google Conversion Tracking, please consult the Data Privacy Policies of Google at: https://policies.google.com/privacy?hl=en.

You can set up your browser in such a manner that you will be notified anytime cookies are placed and you can permit cookies only in certain cases or exclude the acceptance of cookies in certain instances or in general and you can also activate the automatic deletion of cookies upon closing of the browser. If you deactivate cookies, the functions of this website may be limited.

5. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data you archive with us for the purpose of the newsletter subscription shall be archived by us until you unsubscribe from the newsletter. Once you cancel your subscription to the newsletter, the data shall be deleted. This shall not affect data we have been archiving for other purposes.

6. Right of data subjects and contact data

You have a right to view the information stored about you in your personal data; you are also entitled to have such data corrected if it is incorrect, restrict its processing, have it deleted or permit your personal data to be transferred.

You have the right to object to the consent you might already have given to the processing of your data.

In the event of privacy violations, you have a right of appeal to the competent supervisory authority. The competent supervisory authority for privacy matters is the data protection officer of the federal state in which our company is domiciled.

If you wish to assert your rights in respect of your personal data or have further questions about the use of your data provided to us, please contact us as follows:

Universal-Investment-Gesellschaft mbH
Data Protection Officer
Theodor-Heuss-Allee 70
60486 Frankfurt am Main
datenschutzbeauftragter@universal-investment.com

7. Inclusion, validity and up-to-date status of the privacy statement

By using our website, you consent to the use of data as described above. This privacy statement is currently valid and dates from 27th of January 2021. By further developing our websites or implementing new technologies, it may become necessary to change this privacy statement. Universal Investment reserves the right to update this privacy statement at any time with effect for the future. We therefore recommend that you re-read the current privacy statement from time to time.

Updated in October 2023