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