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Data Protection at MLP

We are delighted that you are interested in our offers and are happy to provide you with information as to how MLP handles your personal data when using our wide range of online and mobile offers, when advising and supporting our clients, as well as when brokering and concluding contracts in the insurance and financial services segments. The following notes on data protection refer to data processing at MLP SE, MLP Finanzberatung SE and MLP Banking AG, all of which are referred to jointly as "MLP" in the following.

General information

Personal data encompasses all information that can be used to identify you as a person. At MLP, we place great emphasis on protecting your personal data. This privacy statement explains what personal data is collected from you, as well as where and for what purposes it is processed by MLP.

Insofar as you make personal data available to MLP online, this is only used to respond to your request or process contracts that have been concluded with you in line with Art. 6 (1b) of the GDPR (EU General Data Protection Regulation), as well as for technical administration purposes, to optimize the website, and place advertising in line with Art. 6 (1f) of the GDPR. Your personal data is only transmitted to third parties if this is necessary for contract processing (for example when drawing up quotations for insurance policies and loans) or if you have given your express consent for such usage in line with Art. 6 (1a) of the GDPR.

External service providers that process data on behalf of MLP are under strict contractual obligation to comply with the provisions of Art. 28 of the GDPR and are not classed as third parties in terms of data protection legislation.

You can find detailed information on how we handle the personal data when providing consulting and support services to existing clients or prospective clients interested in our offers and services here.

As a general rule, your data is processed in the Federal Republic of Germany and complies with the regulations of the GDPR, the BDSG (German Federal Data Protection Act), as well as the TMG (German Telemedia Act). In isolated cases and within the permissible legal framework data is also processed abroad.

Data transfer

Your visit to the websites of the MLP Group is protected from unauthorised access using the SSL (secure socket layer) transport protocol. This also applies to cases in which services are called up while using the MLP internet offer which prompt the user to enter personal data. This data is always encrypted prior to transmission. The SSL (secure socket layer) transport protocol is currently considered secure and complies with the recommendations of the German Federal Office for Information Security (BSI).

Data protection when visiting MLP web pages

Your data is stored on systems of either the MLP Group or order processors that are integrated into the data protection policy of the MLP Group. All IT is subject to a dedicated IT security concept. The latest IT security components are employed to protect servers and networks from unauthorised external access. Processing of the data within the MLP Group is subject to the stipulations of a data protection concept. MLP has appointed an external data protection officer, whose processes are subject to the internal data protection stipulations. This concept substantiates the legal stipulations of the German Federal Data Protection Act (BDSG).

Protection via participation

As a user, you are obliged to treat all personal access data that has been made available to you so that you can take up individual offers from MLP as confidential and not make any of this data available to third parties. MLP does not accept any liability for misuse of passwords, to the extent that we cannot be held responsible for such misuse.

Other security measures

MLP has implemented technical and organisational measures to ensure compliance with both European and German data protection legislation. All persons that collect, process or use data at MLP are obligated to observe confidentiality. This obligation also continues to apply if the employment relationship with MLP of any such persons is terminated. In addition to this, banking secrecy and special secrecy obligations are applied in certain areas.

Your rights

You can receive information regarding the stored data pertaining to your person at any time. Assuming the legally defined prerequisites are met (Art. 17-21 of the GDPR), you also have a right to deletion or correction of your data, as well as to restrict processing or data portability of the data made available. Right of revocation: If data processing is based on consent in line with Art. 6 (1a) of the GDPR, this consent can be revoked at any time with future effect. If you wish to do so, please get in touch with your consultant, your branch office, by e-mail to datenschutz@mlp.de or by post to the Group data protection officer using the address given below.

If data processing is based on a legitimate interest of MLP in line with Art. 6 (1f) of the GDPR, you can object to this processing for reasons resulting from your own specific situation. MLP will then only continue to process your personal data if there are demonstrable and compelling legitimate grounds to protect your interests, rights and freedoms or if such processing serves to assert, exercise or defend legal claims.

To exercise your rights, please get in touch with our Group data protection officer directly. You can reach him in writing at the following address:

MLP Finanzberatung SE
Data protection officer
Alte Heerstr. 40
D – 69168 Wiesloch
Germany
E-mail address:
datenschutz@mlp.de

Please submit your respective request in text form (in writing, via e-mail) using the contact details provided. Complaints can also be submitted to the data protection officer at any time using the contact details provided. You also have a right of appeal at any data protection authority. You can find a list of the supervisory authorities (for the non-public sector) including addresses at the following URL: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html .

The supervisory authority responsible for MLP is: Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (Baden-Württemberg State Data Protection and Freedom-of-Information Officer), Königstraße 10a, 70173 Stuttgart, Germany, tel: +49 (0)711 615 54 10, fax: +49 (0)711 615 54 115, e-mail: poststelle@ldi.bwl.de , homepage: http://www.baden-wuerttemberg.datenschutz.de .

Data protection when visiting MLP web pages

When you visit the MLP web pages, we collect data regarding each access to the server on which this service is located on the basis of our legitimate interest in the sense of Art. 6 (1f) of the GDPR. The access data includes the name of the website visited, as well as the file, date and time of access, the data volume transmitted, a message confirming the successful access, the browser type and version, the user's operating system and the referrer URL (the previously visited website, IP address and provider making the request).

For security reasons (for example to clarify any cases of misuse or fraud), log file information is stored for a maximum period of seven days and then deleted. Data whose continued storage is necessary for evidentiary purposes remains stored until final clarification of the respective incident.

In addition, MLP has a legitimate interest in line with Art. 6 (1f) of the GDPR in analysing your usage behaviour in pseudonymised form to determine the correct need for specific content, to improve the overall range of services provided or to offer you interest-based advertising. To this end, MLP employs various usage analysis systems:

Cookies

To make our websites attractive and facilitate usage of certain functions, MLP employs so-called cookies on various pages. These are small text files that are saved on your terminal. Most of the cookies used by us are deleted again at the end of the respective browser session (so-called session cookies, for example JSESSIONID, PHPSESSID, frontend_, opa-redirected, captcha). Other cookies remain on your terminal and allow MLP to recognise your browser the next time you visit the pages (persistent cookies) to present you with interest-based advertising (for example uid, uidp) or offer you the option to update your browser to display our website optimally (for example Browsehappy-decision). You can set up your browser in such a way that you are informed whenever cookies are placed. This then allows you to decide on a case-by-case basis whether you wish to accept cookies or generally refuse them. However, we wish to point out that refusing cookies may prevent you from using all functions of the MLP websites in their full scope.

In the following, we will inform you of the cookies used by MLP:

MLP uses the tracking pixel technology of wiredminds GmbH ( www.wiredminds.de ) to analyse visitor behaviour. Data maybe collected, processed and stored here to generate a usage profile under a pseudonym. Wherever possible and prudent, these usage profiles are completely anonymised. Cookies (CTCNTNM_) can be used for this. The data collected, which can also include personal data, is either sent to WiredMinds or collected directly by wiredminds. Wiredminds may use information left behind following visits to the websites to create anonymised usage profiles. Without the specific consent of the person affected, the data acquired in this process is not used to personally identify the visitor of our website and is not merged with personal data relating to the bearer of the pseudonym. Insofar as IP addresses are recorded, their immediate anonymisation is performed by deleting the last number block. You can refuse usage of the data generated by the respective cookie and referenced to your usage of the website (including your IP address), as well as processing of this data by wiredminds .

MLP uses Google Analytics, a web analysis service of Google Inc. ("Google"). The usage encompasses the "Universal Analytics" mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonym user ID and thereby analyse the activities of a user across multiple devices. Google Analytics uses cookies for this (_dc, _ga, _gid). The information provided by the cookies regarding your use of our websites is generally transferred to a Google server in the US, where it is stored. IP anonymisation is activated on the MLP websites. This means that your IP address is first abridged by Google within member states of the European Union or other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the US and then abridged there. Google uses this information on behalf of MLP with the aim of evaluating your usage of the MLP websites. Reports are then compiled on the website's activity, while other services related to the website's activity and use of the Internet are rendered. Sessions and campaigns are terminated once a certain period of time has elapsed. By default, sessions are terminated after 30 minutes with no activity, while campaigns are terminated after six months. The maximum time limit for campaigns is two years. You can find more information on the terms of use and data protection at the following URL:  https://www.google.com/analytics/terms/de.html or https://policies.google.com/?hl=de .

You can prevent the data generated by the cookie and referenced to your usage of the website (including your IP address) from being sent to and processed by Google by generally refusing to accept cookies or downloading and installing the browser plugin available via the following link. Google Tools

notice: To prevent data capture by Universal Analytics across multiple devices, you will need to perform the opt-out on all systems in use.

MLP uses conversion tracking within the scope of the Google's online advertising program AdWords. This tool allows MLP to measure which of its websites enjoy the greatest advertising success. Conversion tracking also works with a cookie. The cookie remains valid for 30 days and then automatically expires. It is used by Google when a user clicks on an ad posted by Google or its advertising partners. Based on this cookie, MLP and Google can determine how many users have clicked on ads from MLP and which clicks led to an action. MLP does not receive any information that could be used to personally identify a user.

To optimise our online advertising, we use the remarketing function, the DoubleClick ad server and AdWords Manager from Google Inc. (Google) when placing individual advertising materials. These technologies enable users that have already visited our websites and online services and shown interest in the respective offers to be addressed again through targeted advertising on other websites. Advertising content is displayed using cookies (_gat, IDE, fr), which are saved by Google or third-party providers on the user's computer. Using these text files allows the user behaviour of those visiting the website to be analysed and then used for targeted product recommendations and interest-based advertising. These cookies do not contain any personal information.

You have the option of generally deactivating the use of cookies for advertising purposes. You can also prevent the use of cookies specifically by Google by calling up the URL ? https://policies.google.com/technologies/ads?hl=de and following the instructions provided. If you only wish to deactivate Google's conversion tracking cookie, you can set up your browser in such a way that cookies from the domain 'www.googleadservices.com' are blocked.

Adtelligence Platform

We use the Adtelligence Personalization Platform software from ADTELLIGENCE GmbH on our pages, www.adtelligence.com . This is group-specific targeting, which we use to personalise our online business. For this purpose, data of website visitors is recorded and assigned to specific target groups by means of cookies (adt, _adt) and tracking pixels. The target-group-specific features are recorded by Adtelligence and transferred to the system in anonymised form. On this basis, content or pages that are shown to you are controlled to present you with personalised and relevant website content. We will not pass on this information to third parties.

If you do not wish to have cookies saved on your computer, you can prevent this from happening and also delete any cookies that have already been saved by using a corresponding setting in your browser software. However, you may then not be able to use all functions of the website.

If you wish to opt out of this process, you can do so using the following URL: https://adtelligence.com/de/opt-out/

Data analysis with Matamo (Piwik)

The Adtelligence Personalization Platform software from ADTELLIGENCE GmbH, www.adtelligence.com , uses the Matomo open source web analysis service (formerly "Piwik") as a self-hosted system on our website. Matomo also uses cookies (piwik.php). The information regarding usage of this website that is generated by the cookie is saved on our Matomo server. Your IP address is anonymised prior to saving. The information regarding usage of this website that is generated by the cookie is not passed on to third parties.

If you do not wish to have cookies saved on your device, you can prevent this from happening by using a corresponding setting in your browser software. However, if you choose to do so, you might then not be able to make full use of all the functions on this website.

If you do not consent to the storage and usage of your data, you can deactivate both storage and usage here. In this case, an opt-out cookie is set up in your browser which prevents Matomo from storing usage data. However, if you delete your cookies, the Matomo opt-out cookie will also be deleted. The opt-out then needs to be re-activated when you visit our website again. https://mlp-tracking.adtelligence.de/index.php? module=coreadminhome&action=optout&language=de

MLP uses the Facebook Pixel (IDE, fr) for conversion tracking. The Facebook Pixel is a JavaScript code, which is used to add an empty 1x1 pixel image on the websites of MLP. When visiting the respective website, this pixel reports the visit to Facebook. Facebook Pixel is used to track whether a user has been forwarded to a certain website or a certain activity has taken place (e.g. purchase of a product). Facebook tracks the conversions performed within 28 days after clicking on or viewing an ad. It then expires automatically. MLP does not receive any information that could be used to personally identify a user.

In the Facebook settings, you can control whether you wish to see interest-based online advertising from Facebook. Please be aware that you will still be shown ads even if you deactivate interest-based online advertising on Facebook, but these ads will no longer be tailored to your interests. The setting you select will be applied across all devices and browsers. You can prevent Facebook from using the information captured by Facebook Pixel by deactivating it in your account settings. You can find more information on how the system works and instructions on how to deactivate it at the following URL: https://www.inyour.facebook.com/help/365596123604315 .

We use the Atlas ad serving tool from Facebook (Atlas Solutions, LLC) to optimise and measure the success of our advertising campaign performance. Atlas provides displays on both desktop and mobile devices and measures their success. This works across all channels, including display, search and video. Atlas’ technology is used to draft, deliver, measure and optimise ads. Atlas uses online ad tracker cookies (ATN) to display online advertising content that is relevant to you. This cookie is placed when you come into contact with an Atlas ad. If you then log into Facebook later on, the Atlas cookie is detected and a hashed – encrypted and anonymised – user ID, as well as information on your age, gender and location is sent to Atlas. Individual persons are not identified here. You can find more information on how this works and on data protection when using Atlas at the URL: https://atlassolutions.com/privacy-policy/ . If you do not consent to the use of this cookie, you can deactivate it by clicking on the URL: http://www.networkadvertising.org/choices/ .

The tracking of Ad Up, a technology and service provider of Axel Springer Teaser Ad GmbH (Axel-Springer-Straße 65, 10969 Berlin, Germany), is integrated on our websites.

By collecting anonymised and/or pseudonym data, Ad Up can then display interest-based advertising on websites for a certain time.

Ad Up uses cookies (uid, uidp) to be able to offer advertisers so-called conversion tracking, thereby enabling them to determine the effectiveness of their ads and keywords. You can find more information on data protection at Axel Springer Teaser Ad GmbH by navigating to the URL: www.adup-tech.com/datenschutz/ .

You can also use the "Activate opt-out cookie" button on this site to set up an opt-out cookie and thereby deactivate Ad Up in this browser.

Information on how to deactivate the use of cookies by third-party providers can be found on the deactivation site of the Network Advertising Initiative .

Contact forms / newsletters / subscriptions

When you get in touch with us via one of our websites, MLP collects various personal data from you in a contact form. The exact data collected varies depending on requirements. Mandatory fields are marked as such and help ensure that we can contact you reliably. All data provided in fields not marked as mandatory are optional. All information made available by you is saved, yet only processed and used by MLP for the stated purpose on the basis of Art 6 (1b) of the GDPR.

If you subscribe to our free-of-charge IR Service, MLP also collects the data required for this in a contact form. The entries made here are used exclusively to keep you up-to-date with the latest information in and around the MLP Group via e-mail. You can cancel your subscription at any time for the future. A corresponding unsubscribe link is included in all mails.

When subscribing to an MLP newsletter, the data entered by you is used exclusively for the purpose of providing the respective newsletter service. The data defined in the entry mask is collected within the scope of the subscription. Only your e-mail address is required in order to receive the prospective newsletter. All other entries are made on a voluntary basis. In the event that you voluntarily provide us with your telephone number when subscribing to our newsletter, you also give consent for MLP to contact you via telephone as a way of informing you about our offers and services when you submit the form. However, your data will not be passed on to third parties.

You can revoke your consent in line with Art. 6 (1a) of the GDPR for storing your personal data and using it to send out newsletters, as well as your consent to be contacted by MLP by telephone at any time for the future. A corresponding link is included with each newsletter e-mail. You can also revoke your consent at any time by sending a corresponding e-mail to datenschutz@mlp.de . The transfer to MLP is protected. MLP uses the SSL (Secure Socket Layer) protocol for this. This protocol is currently considered secure and complies with the recommendations of the German Federal Office for Information Security (BSI). Your data is therefore protected from unauthorised access at all times.

Making comments in the blog

If you comment on or ask questions relating to individual articles in the MLP Finance blog, we will record your first and last names, as well as your e-mail address, in combination with the content of your comment and an abridged version of the comment you submitted. Your comment, your first name and the first letter of your last name are published, potentially in combination with a response from the online editorial team. By submitting the comment/question, you declare your consent in line with Art. 6 (1a) of the GDPR for publication of the aforementioned personal data, as well as your comment/question. The online editorial team at MLP may use your e-mail address to get in touch with you in order to answer your question. You will always receive an e-mail confirming publication of your comment/question, together with a link to the response page.

Your data will not be used for any other purposes and will not be passed on to third parties. If you wish to delete your e-mail address or the comment/question you have published, please send an e-mail to financify@mlp.de . The online editorial team at MLP will perform the deletion.

We are always delighted to hear your suggestions, contributions and questions. All constructive comments are of great value to us. In this respect an objective, polite and above all respectful dialog is a matter of course for us. We therefore ask you to please follow the netiquette for this site:

Contents, comments or questions with xenophobic, insulting, extremist or racist content are not desired and will be deleted by us without the need to provide any justification. The same applies to illegal, pornographic, libellous or commercially detrimental content. Users who repeatedly fail to comply with these rules may be excluded from further participation.

Social Media

MLP uses social plugins from various social media networks. You can recognise social plugins by their logos, which can be seen on the websites of the online social media networks. When calling up our pages, your browser does not automatically establish a connection to the servers of the respective networks. The connection is only established when you actively click the corresponding buttons on our websites.

If you press the "like" button on Facebook, your browser establishes a connection to the Facebook servers (Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2 Ireland). If you are also logged into Facebook in parallel or save Facebook cookies on your computer, Facebook can assign your visit to the MLP websites to your Facebook account and displays your selection in your Facebook profile. The MLP websites merely enable a connection to Facebook. Please refer to the Facebook data protection information for details on the purpose and scope of data collection and usage by Facebook, as well as your rights and the security options available to you as a Facebook user.

Several MLP websites contain quick links to Twitter (Twitter, Inc., 1355 Market Street., Suite 900, San Francisco, CA 94103). Using the Twitter website causes certain data from your browser to be saved automatically on the Twitter server. The data saved can contain certain information, such as your IP address, browser type or user domain, frequently visited websites and frequently entered search words. Other data, such as online ads that you have clicked on in the past, can also be included in the saved data. The MLP websites merely enable a connection to Twitter. Please refer to the Twitter data protection information for details on the purpose and scope of data collection and usage by Twitter, as well as your rights and the protection/security options available to you as a Twitter user.

Plugins from YouTube.de/YouTube.com are used on several of our websites. These are operated by YouTube, LLC, Cherry Ave., USA, represented by Google (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States). If you call up MLP websites that contain a plugin of this kind, a connection to YouTube servers is established and the plugin is shown on the website via a message sent to your browser. This stores cookies on your computer (VISITOR_INFO1_LIVE, PREF, YSC). Information about which of our websites you have visited is also sent to the YouTube server. If you are logged into YouTube while doing so, YouTube will automatically assign this information to your personal user accounts. When using these plugins, for example by clicking on the start button to play a video/audio file or when sending a comment, this information is assigned to your user account (e.g. YouTube). You can prevent this from happening by logging out of your YouTube account before calling up the respective file or sending a comment.

Please refer to the YouTube data protection information for details on the purpose and scope of data collection and usage by Google, as well as your rights and the protection/security options available to you as a YouTube user.

Pressing the Google "+1" button (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States) causes your browser to establish a connection to the Google servers. If you are a Google+ member and use this button, you and other users worldwide will receive personalised content from Google and its partners. Google at least saves your IP address, the activity and content of the page you were viewing when you clicked on the button.

Our websites merely enable a connection to Google+. Please refer to the Google+ data protection information for details on the purpose and scope of data collection and usage by Google+, as well as your rights and the privacy protection/security options available to you in this regard as a Google+ user.

Integration of offers from third-party providers

Content and services of cooperation partners are used to optimise the offering on several of our websites. These offerings are incorporated using iFrame technology. This means that your browser will establish a direct connection to the servers of the respective provider when you call up a website from our internet presence with corresponding content. The content of the offering that has been called up is sent to your browser directly by the respective provider and presented on the corresponding MLP website. So that your browser can display the content, your computer establishes an HTTPS connection to the web servers of the respective providers. Each time a connection is established, log data is transferred that also contains certain information on the person visiting the website, including the IP address, the website from which the data request was sent (so-called referrer), yet potentially also cookies placed by the respective provider for the website executing the activity.

These cookies can offer the provider information regarding your visit of the respective website. You can set up your browser in such a way that you are informed whenever cookies are placed. This then allows you to decide on a case-by-case basis whether you wish to accept cookies or generally refuse them. However, if you refuse to accept any cookies, this can restrict the functionality of the respective web page. The content and services of the pages integrated in this way are operated by third-party providers that are not associated with MLP. These third-party providers use personal data as per their own data protection guidelines. The third-party providers in question are explicitly named, both on the websites on which the corresponding functions are offered and in the following:

The offer of EQS Group AG, Karlstraße 47, D-80333 Munich, Germany is integrated to present the MLP share at the URL: https://mlp-se.de/investoren/mlp-aktie/ . You can find information on how personal data is handled by the EQS Group AG at the URL: https://germany.eqs.com/de/legal . For information and registration in and around the topic of "Secure payments with MasterCard© Secure Code™", the corresponding offering of MasterCard Europe SPRL, Chausée de Tervuren 198A, 1040 Waterloo – Belgium is incorporated. You can read further information on how personal data is handled by MasterCard Europe SPRL at the URL: https://www.mastercard.de/de-de/datenschutz.html .

MLP uses Google Maps (Google LLC, 1600 Amphitheatre Parkway Mountain View in CA 94043, USA) to pinpoint MLP locations. You can find additional terms of use for Google Maps/Google Earth at the URL: https://maps.google.com/help/terms_maps.html Notes on handling of your data when using Google Maps are available at the URL: https://policies.google.com/privacy/update .

MLP is not responsible for the content of third-party providers and therefore does not accept any liability whatsoever for the completeness or correctness of the information made available by said third parties.

Date: 17.05.2018

Data protection notices for the MLP FinancePilot app