Privacy Policy

AS USED HEREIN, THE TERMS “YOU” AND “USER” SHALL MEAN ANY VISITOR TO PINEBRIDGE INTERNET WEBSITES.

PineBridge recognizes the importance of protecting your non-public information when you visit https://www.pinebridge.com/ or its regional websites (individually and collectively, the “Website”). This Privacy Policy (“Policy“) applies to the collection, use, disclosure and protection of personal data, relating to customers of PineBridge Investments LLC and its subsidiaries and related entities (collectively, “PineBridge”) through its Website. By visiting the Website, you are accepting the practices described in this Policy. If you do not agree to this Policy, please refrain from using the Website. Additionally, certain terms and conditions applicable to your use of the Website can be found under the Website Terms of Use link. Regional disclosures that may apply per jurisdiction can be found under the privacy policy link on the PineBridge website designed for that region.

“Personal Data” means information pertaining to specific individuals, or by which specific individuals can be identified, including by name, identification number, address, or other personal characteristics or attributes. Personal Data does not include aggregated statistics, compilations, anonymous data, or other derivative data that does not, alone or with other data, identify a specific individual.

“Data Subject” means an individual who is the subject of personal data.

Changes to this Policy

PineBridge reserves the right to change, modify, add or remove portions of this Policy at any time and for any reason. Such changes will become effective upon posting. We suggest that you review this policy periodically for changes. You will be able to determine when this Policy has been revised by checking the Last Revised legend at the top of this Policy. You acknowledge that by accessing our Website after changes have been posted to this Policy, you are agreeing to the terms of the Policy as modified.

Basic Principle

PineBridge will not collect or maintain Personal Data that is not relevant to or required for the conduct of PineBridge business and will take reasonable steps to assure that Personal Data remains accurate.

Personal Data will be treated as confidential and internal procedures and controls will be employed to prevent unauthorized access, disclosure, use, copying, modification, or destruction. Personal Data maintained by PineBridge will not be used for purposes that are incompatible with the purposes for which it was collected. Personal Data will not be transferred to third parties, except as required for the conduct of PineBridge business, and only to third parties who have agreed in writing to protect such Personal Data.

Information Collected

PineBridge may collect personal information about you (such as your name, title, address, email address and telephone number) that you provide voluntarily. For instance, if you choose to contact us through our “contact us“ feature, we will collect your personal information so that we can respond to your inquiry.

Your Rights

You may contact us to:-

• Request that we amend, rectify, delete or update the personal data we hold about you;

• Where possible (e.g., in relation to marketing) amend or update your choices around processing; and

• Request a copy of personal data held by us.

Where you would like to receive a copy of all personal data held, such request should be in writing (email or post), addressed to our Global Privacy Officer at privacyofficer@pinebridge.com and should contain as much information as possible to facilitate our dealing with this request.

Disclosure to Third Parties

Except as provided herein, PineBridge will not intentionally sell, share or rent your personally identifiable information to others in contravention of this Policy. We may share personally identifiable information provided through the Website with companies that are controlled, owned or operated by PineBridge or its subsidiaries and affiliates. Your information will not be disclosed for marketing purposes without your consent.

PineBridge may employ other companies and individuals to perform functions on our behalf including operating certain features of the Website, or hosting/maintaining servers used in connection with the Website. These companies and individuals have agreed, and are not permitted, to use your personally identifiable information for any other purpose.

PineBridge may disclose aggregate data about its Website and its visitors, provided however that PineBridge will not disclose to third parties any information that could be used to identify you personally.

Security of Your Personal Information

No data transmission over the internet can be 100% secure, as such PineBridge cannot ensure or warrant the security of any information you submit to through the Website. However, PineBridge takes measures to prevent unauthorized intrusion to the Website and the alteration, acquisition or misuse of personally identifiable information by unauthorized persons. PineBridge restricts access to non-public information about you to those employees who need to know the information in order to provide products or services to you. PineBridge maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. PineBridge strives to keep its records about you accurate and up-to-date. Please contact us by email or telephone as specified below to update your account information whenever such information ceases to be complete or accurate.

Cookies

When you view the Website, certain information may be stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages in the form of a small text file called a “cookie“. Cookies are used to enable websites to function or to provide information to the owners of a website, or other third parties that receive data obtained from that website. In general, PineBridge uses cookies to help improve your experience with our Website and understand how and when areas of our Website are visited. Cookies are read only by the server that placed them, and are unable to execute any code or virus. For more information about cookies, how the Website uses them, and your options with respect to Cookie generally, please see the PineBridge Cookies Policy.

Compliance with Laws

PineBridge does not automatically collect personally identifiable information from visitors to our Website, except to the extent required to do so by statute or regulation applicable to us. We will not provide any personally identifiable information to any other persons, except (a) if we are required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation, similar proceedings or regulatory examination, (b) to comply with applicable laws or regulations, (c) to enforce the Terms of Use, (d) to our legal advisors, (e) when PineBridge, in its sole discretion, believe it reasonably necessary to protect the rights, property, safety or security of PineBridge, Website visitors, or the public, or (f) to share information with our affiliates or service providers in connection with providing services to you. We can (and you authorize us to) disclose any such information in those circumstances.

Business Transfers

PineBridge may provide your personally identifiable information concerning Website visitors to a purchaser or successor entity in connection with the sale of PineBridge, a PineBridge subsidiary or line of business.

Third Party Websites

PineBridge may establish links between the Website and websites operated by third parties. PineBridge has no control over any such other websites, the contents therein or the products/services offered. Your access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. PineBridge disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website. Links on the Website are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site.

Offline vs. Online Practices

This Policy applies solely to online information collection and use practices in connection with the Website.

Children’s Privacy

Although this Website is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. Consistent with the Children’s Online Privacy Protection Act of 1998, we will never knowingly request or collect personally identifiable information from anyone under 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with personally identifiable information without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without verifiable parental consent, please contact our Global Privacy Officer at privacyofficer@pinebridge.com.

Contact Us

If you have questions or concerns about this Policy or our privacy related practices, collection or use of your information, please contact our Global Privacy Officer at privacyofficer@pinebridge.com.

Last Revised: February 20, 2018

General Data Protection Regulation (GDPR)

& UK GDPR

Last Updated: March 2024

Privacy Notice

This Privacy Notice explains how PineBridge collects, uses, discloses and otherwise processes your personal data (i.e., information which directly or indirectly identifies you), and your rights in relation to such personal data.

In this Privacy Notice, “us”, “we” and “our” refers to the following PineBridge entities: PineBridge Investments Ireland Limited (and the Dutch and Swedish branch offices), PineBridge Benson Elliot LLP, PineBridge Investments Europe Limited, and PineBridge Investments Deutschland GmbH (together for purposes of this Privacy Notice, the “Company”).

The PineBridge group includes the Company as well as its affiliates (for purposes of this Privacy Notice, the “Group”).

Scope of Privacy Notice

This Privacy Notice applies to personal data we collect about individuals:

• who visit our websites;

• who visit our offices;

• who are employed or otherwise engaged by our service providers / professional advisors;

• with whom we have a contact for business-related purposes; and

• with whom we deal with in connection with (potential) transactions.

This Privacy Notice does not apply to personal data we collect about job applicants or our employees and/or personal data collected by any third party, including through any application or content (including advertising) that may link to or be available from our websites.

If you are an individual, this will affect you directly. If you are an institution that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

This Privacy Notice should be read together with any additional notice that we may provide to you when we collect or otherwise process your personal data.

Your Rights

You have the following rights in relation to the personal data we process about you, which may be subject to limitations or restrictions:

• To obtain access to, and copies of, the personal data that we hold about you;

• To object to the processing of your personal data;

• To require us to erase your personal data;

• To require us to restrict our data processing activities;

• To request the transfer of your personal data you provided to us, in a structured, commonly used and machine-readable format, to another controller; and

• To require us to correct the personal data we hold about you if it is incorrect.

If you wish to exercise any of the rights set out above, please contact our privacy officer via email: privacyofficer@pinebridge.com.

You also have the right to lodge a complaint with the competent data protection authority in your jurisdiction.

The Categories of Personal Data We Collect and Why

Individuals who visit our websites:

• Personal data processed: name, contact details, other personal data voluntarily disclosed to us in your communications with us. Please see also the Cookies Policy.

• Legal Basis for processing: it is in our legitimate interest to process such data in order to respond to your queries, complaints or other communications.

• Sources of personal data: we will collect the above personal data directly from you. We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals who visit our offices:

• Personal data processed: name, contact details, company information, video images from CCTV, other personal data voluntarily disclosed to us in your communications with us.

• Legal Basis for processing: it is in our legitimate interest to process such data in order to keep our offices secure.

• Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals who are employed or engaged by our service providers or professional advisors:

• Personal data processed: name, contact details, job title, company information, ID, other personal data voluntarily disclosed to us in your communications with us.

• Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) manage our relationships with service providers and professional advisors (e.g., record-keeping). The processing may also be necessary to perform, or to enter into, contracts with you.

• Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals with whom we have contact for business-related purposes:

• Personal data processed: name, contact details, job title, company information, ID, photographs, other personal data voluntarily disclosed to us in your communications with us.

• Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) maintain a directory of contacts.

• Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Individuals we deal with in connection with (potential) transactions:

• Personal data processed: name, contact details, job title, company information, ID, photographs, log-in information (e.g., for virtual data rooms), results of due diligence undertaken, professional opinions, information relating to financial status and dealings, results of anti-money laundering or KYC checks, other personal data voluntarily disclosed to us in your communications with us. We may also process data concerning your criminal convictions or offences if this is revealed to us when we perform anti-money laundering or KYC.

• Legal Basis for processing: it is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) evaluate, complete and administer transactions – including, seeking advice from professional advisors; (iv) undertake statistical analysis, transaction reporting and market research; and (v) maintain records of investments. Additional processing may be necessary to comply with our legal obligations, including anti-money laundering and KYC.

• Sources of personal data: we will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer). With respect to data concerning your criminal convictions or offences, we may obtain this data from third party sources (for example, disclosure and barring check databases). We may also process your personal data for other purposes as detailed in the sub-section titled “Other Processing” below.

Other Processing: For what other Purposes do we Process your Personal Data?

All of the abovementioned personal data may be processed in reliance on our legitimate interests or otherwise to comply with our legal and regulatory obligations for the following purposes:

• identify and prevent fraud and other unlawful activity

• keep our information and systems secure, and other IT support and development

• train our personnel

• seek and obtain advice from professional advisors

• prepare for, respond to, and obtain advice in connection with, enquiries, investigations, disputes or claims / proceedings

• organising events and meetings

• financial and statistical research

• maintaining records and accounts

• prepare for, and participate in, transactions

• internal reporting

• responding to data subject requests

Consequences of not Providing Personal Data and Right to Object

Where we require your personal data to comply our legal or contractual requirements, failure to provide this information means we may not be able to provide services to you and/or interact with you.

You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.

With Whom Do We Share Personal Data?

We only transfer your personal data or make it accessible to third parties insofar as these third parties need said personal data to carry out their tasks.

Your personal data may be shared with other companies within our Group.

In certain circumstances, we may also disclose and/or make your personal data(including, where applicable, certain sensitive data such as your biometric data) available tothe following categories of third parties:

• service providers, for example IT companies that provide or have access to our IT systems, external storage space providers or outsourcing partners, as well as providers of security devices

• business associates (for example, investors, lenders or financial intermediaries) who are involved in, or considering becoming involved in, transactions in which we are involved

• professional advisors (e.g., accountants, auditors, lawyers or other consultants)

• regulators, courts and other governmental agencies

• third parties that are considering acquiring or that acquire all or part of our assets or stock, or that succeed us in carrying on all or part of our business or services provided to or by us

International Transfers of Personal Data

In principle, the Company processes and stores personal data in countries located within the EEA, UK and Switzerland. However, in sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to recipients located in countries outside of the EEA, UK and Switzerland, including the United States of America, Hong Kong, Japan and India, whose legal framework does not guarantee a level of protection equivalent to that of the jurisdictions in which the Company is incorporated.

Your personal data will only be transferred from the EEA, Switzerland or the UK to a recipient in a country that is not considered to provide an adequate level of data protection if the transfer is in compliance with applicable data protection and privacy laws. In such cases, we ensure adequate protection by using sufficient safeguards, for example by entering into standard contractual clauses (“SCCs”) with the recipient or by relying on the recipient’s Binding Corporate Rules. We may also rely on exceptional legal authorisations in certain cases, for example by obtaining your express consent to a specific communication, notably where the transfer is necessary for performance of a contract or the establishment or defence of legal claims. For intra-Group transfers, we rely on our Group-wide data sharing arrangements, which offer a common level of protection across the Group.

You can request further information in relation to international transfers and/or request a copy of SCCs entered into by us as well as of our Group's data sharing arrangements by contacting our privacy officer at any time via email: privacyofficer@pinebridge.com.

Retention of Your Data

We may retain your personal data only for so long as is necessary for the purposes for which the personal data is collected and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy, which is available upon request from our privacy officer (privacyofficer@pinebridge.com). To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider the applicable legal requirements and the extent to which it is necessary to process the personal data. In exceptional cases (e.g., in pending litigation matters or where the law requires us to) your personal data may need to be kept for longer periods of time.

Changes to the Privacy Notice

We will review and update this Privacy Notice as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on our websites or update the “last updated” date of the Privacy Notice. If we make a material change to this Privacy Notice, you will be provided with appropriate notice in accordance with applicable legal requirements. Only the latest version currently published on our websites is binding.

Contact us

For any privacy issues, questions or complaints concerning the application of this Privacy Notice or to exercise your rights as described above, you may contact our privacy officer via email: privacyofficer@pinebridge.com.