Online Privacy Statement for Website Users, Professional Contacts and Applicants

(As of September 2019)

Universal-Investment-Luxembourg S.A. (“Universal-Investment,” “we” or “us”) takes the protection of your personal data very seriously.

This Privacy Statement is applicable to you if you are a website user, a professional contact, or an applicant. By “website user,” we mean any individual visiting our website ( ). If you are currently reading this Privacy Statement on our website, this means that you are a website user. By “professional contacts,” we mean current, prospective, or past business partners and service providers with whom we have interacted in the course of our professional activities. By “applicant,” we mean any person contacting us about job opportunities.

We process your personal data in compliance with applicable data protection law and, in particular, the General Data Protection Regulation. Below we explain which data we collect, for what purposes, how long we store the data, with whom we share the data, and your rights in this respect.

1. Which personal data do we collect?

For website users

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.

For professional contacts

When we interact with you in the course of our business activities, we will usually receive the following personal data from you:

  • Your professional contact details (name, phone number, email address, and professional address)
  • Information about your employer (mainly, your company’s name, location, and activities)
  • Information about your qualifications (mainly, your professional title, and your expertise)
  • Any other relevant information that you or your employer may provide to us, such as your experience, availabilities, professional interests, etc.

We may also collect or consult information about you that you have made publicly available, such as information on your LinkedIn profile.

For applicants

When you apply for a job with us, we will only process the information that you have provided to us, such as your name, contact details, and CV. We may also collect or consult information about you that you have made publicly available, such as information on your LinkedIn profile.

2. Why do we process your personal data and how long will we store the data?

Any use of your personal data shall only take place for the stated purposes and to the extent necessary to achieve these purposes. Apart from the cases mentioned below, personal data shall not be collected and processed for other purposes, unless you have given your consent to the further processing of your personal data, as further explained in section 3 below.

For website users

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 legal basis for the processing of your personal data is our legitimate interest to provide you with a functional website.

For professional contacts

We will mainly process your personal data to interact with you where necessary to conduct our business activities, for example by exchanging emails with you.

We may also process your personal data to promote our professional activities towards you and maintain an effective professional relationship with you, for example by inviting you to events or informing you about relevant professional matters.

We may also need to process your personal data for compliance with our legal obligations, or to protect or defend our professional interests, for example in the context of an audit, the defense of a legal claim, or when cooperating with a regulatory authority.

The legal basis for the processing of your personal data is either (i) the necessity to perform our contractual obligations towards you, (ii) the necessity to comply with our legal obligations, or (iii) our legitimate interests to promote our business activities, to maintain an effective professional relationship with you or to protect or defend our interests.

After termination of our professional relationship with you, we will delete or anonymize your personal data within maximum 1 year. As an exception, if your personal data (such as your name or signature) appear in professional files or documents which are necessary for us to conduct our business activities or to protect our legitimate business interests (for example in the context of a liability claim), we will keep these data for a longer period. We have implemented adequate technical and organisational measures to ensure the security of our archives.

For applicants

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 will only process this personal data for the purpose of deciding on employment or responding to the inquiry.

In the case of a job application that does not lead to a recruitment, your personal data will be deleted within 6 months after the application procedure has been completed. At the end of this 6 month period, we may ask for your permission to keep your application documents for a longer period in view of later selection procedures. If you decide not to give your consent, we will delete your application documents.

3. Consent to further processing

In some specific cases, you may give us your consent in order to allow us to process your data for further purposes.

4. With whom might we share your personal data?

For website users

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. In this event, the processing of your personal data would be based on a legal obligation to which we are subject, or on our legitimate interest to defend our website, assets, and interests.  No data shall be passed on to third parties for any other purposes.

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.

For professional contacts

In the course of our business activities, we may need to put you in contact or share your contact details with our affiliates, business partners, services providers, regulatory authorities, or third parties. We will only do so to the extent necessary for achieving the purposes mentioned in Section 2 above. We will not share your personal data with third parties whose involvement is not necessary for achieving the above-mentioned purposes.

For applicants

We will handle any application that we receive with strict confidentiality. Your personal information will only be reviewed within Universal-Investment by persons taking part in the recruitment process. We will not share your personal data with third parties, unless you have expressly requested us to do so.

5. Security

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

6. Cookies

For website users

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 adjusting this in your browser settings. If you do not accept cookies, this can lead to functional restrictions of our offerings.

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

Functional Cookies

  • Technical cookies for distributing requests to various back-end 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 behavior through etracker

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 etracker (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 or the length of time for which they are set. The one-year cookies from Microsoft and etracker are already set when the address is called up - i.e. even before a message has been displayed.

When the PowerPortal is called up, 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: .

7. Your rights as data subjects

You have a right to know which personal data we process about you, and to have access to your personal data; you are also entitled to have such data corrected or completed if it is incorrect or incomplete, restrict the processing, or ask for your personal data to be deleted in some circumstances.

You have the right to object to processing of your personal data on several grounds. You also have the right to withdraw your consent when such consent is used as a basis for the processing of your personal data.

In the event of privacy violations, you have a right to lodge a complaint with the competent supervisory authority. In Luxembourg, the competent supervisory authorithy is the Commission Nationale pour la Protection des Données (CNPD).

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-Luxembourg S.A.
Gerd Büttner - Data Protection Officer
15, rue de Flaxweiler
6776 Grevenmacher

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

This privacy statement is currently valid and dates from 3 September 2019. 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.