Online Privacy Statement

Protecting your personal information is of utmost concern to Universal-Investment-Gesellschaft mbH (Universal). When processing personal information collected during visits to our website, we consistently observe the rules laid down in applicable data protection laws. We will not publicly disclose your personal information nor transfer it to any third parties without your consent. In the following sections, we explain the types of information we collect when you visit our website and outline precisely how we use this information.

1. Recording and processing of information collected during your visit to our website

When you visit our website, our web server temporarily stores access data in a log file. The following data are collected and stored until the point they are automatically deleted:

• Client IP address
• Date and time of access
• Name and URL of the accessed file
• Volume of transmitted data
• Notification that access was successful
• Data identifying the browser software and operating system
• Website from which our site was accessed
• Name of your Internet service provider

Your Internet browser automatically transmits these data to our web server at the point you access our website.

These data are stored for the purposes of facilitating use of the website (establishing a connection), ensuring system security, carrying out the technical administration of the network infrastructure and optimizing our online services. The IP address is resolved only in the event of fraudulent access to Universal’s network infrastructure.

We do not compile users’ personal profiles. Section 15 Paragraph 3 of the German Teleservices Act (Telemediengesetz TMG) permits usage of user profiles subject to the condition that pseudonyms are employed and the user does not withhold consent. Should we make use of this option anywhere on our website, we will notify you on that respective page of your right to withhold consent.

Apart from the specific cases cited above, we do not collect or process personal information without your explicit consent to do so.

2. Use and transfer of personal information

Use of your personal data is limited to the purposes stated above and only to the extent necessary for these purposes.

Personal information will not be transferred to governmental bodies or agencies except to comply with mandatory national laws or in cases where the transfer of such data is necessary in order to take legal action due to fraudulent access to our network infrastructure. Personal data will not be transferred to third parties for any other purpose.

3. Consent for other uses

The use of certain services on our website, such as newsletters or discussion forums, requires prior registration and involves a more extensive processing of personal information, including longer-term storage of e-mail addresses, user IDs and passwords. We use such data only if you have provided us with them and given us your prior consent.

Newsletters

To register for Universal’s newsletters, you need to provide at least an e-mail address to which the newsletter should be sent. All other information is voluntary and will be used to contact you directly as well as to resolve questions concerning your e-mail address. If you request delivery by post, we need your postal address.

As a general rule, we employ the double opt-in method for sending a newsletter. This means that a newsletter will not be sent until after you have first registered for the service and informed us of your email address and have subsequently confirmed your registration by clicking the link contained in an email you receive from us. This procedure is used to ensure that only you personally can register for the newsletter service using the specified email address. You must confirm your registration shortly after receiving our email; otherwise your registration and e-mail address will be deleted from our database. Until we receive your confirmation, our newsletter service will refuse to accept any other registration requests using that e-mail address.

You can cancel your subscription to one of our newsletters at any time. To do this, either send us an email or follow the link at the end of the newsletter.

Guest books and forums

If you would like to sign up for an Internet forum run by Universal, you need to provide at least a user ID, a password and your e-mail address. For your own protection, the registration procedure for this type of service is similar to registering for a newsletter: You must confirm your request by clicking the link contained in the e-mail we send you.

You can cancel your registration for this type of service at any time by sending us an e-mail from the web page offering the service.

In general, the content of guest books and forums is not subject to monitoring by Universal. Nevertheless, we reserve the right to delete posted contributions and to prohibit users from further use of the service, especially in cases where posted content violates the law or is deemed incompatible with the objectives of Universal.

Ordering

If you order material from our website, we will use the address information you provide only for the purpose of processing your order. It will not be transferred to a third party.

4. Security

Universal employs technical and organizational security measures to safeguard the personal information we store against inadvertent or deliberate manipulation, loss or destruction and against access by unauthorized persons. We continuously improve our security measures in line with technological developments.

5. Cookies

We do not generally use cookies on our website, but in certain exceptional cases we may use cookies for technical reasons to place session control data in your browser’s memory. These data are automatically deleted when you close your browser.

Should we store personal data in a cookie for a specific purpose, e.g., user recognition, we would request your permission in advance.

Of course, you can visit our website without the use of cookies. Please note, however, that most browsers accept cookies automatically. You can prevent this by changing the settings of your browser. If you set your browser to refuse all cookies, this may restrict your use of certain functions on our website.

6. Links to websites operated by other providers

Our website may contain links to other providers’ websites. Please note that this privacy statement applies exclusively to Universal’s website. We have no influence on the data protection practices of other providers nor do we ensure they conform to relevant data protection laws.

7. Right to information and contact data

You have a legal right to review all stored information related to you as well as the right to require the correction of inaccurate information, the deletion of information or the blocking of access to information.

If you would like to review your personal information or want us to correct or delete such information or if you have any other questions concerning our use of your personal information, please contact:

Privacy Protection Officer
Universal-Investment-Gesellschaft mbH
Theodor-Heuss-Allee 70
60486 Frankfurt am Main
Germany
Email: Datenschutzbeauftragter@universal-investment.com

8. Acceptance, validity and status of privacy statement

By using our website, you implicitly agree to accept the use of your personal information as specified above. This privacy statement took effect on October 20, 2011.

As our website evolves and new technologies come into use, it may become necessary to amend the privacy statement. Universal reserves the right to update its privacy statement at any time and have this take effect on a future date. For this reason, we recommend you reread the current version from time to time.