Regulatory Disclosure



PineBridge Global Disclosure

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CCPA Privacy Notice

CCPA Do Not Sell My Personal Information

GDPR

MiFID

PineBridge Investments Europe Limited (“PBIEL”)

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PineBridge Global Disclosure

PineBridge Investments is a group of international companies that provides investment advice and markets asset management products and services to clients around the world. PineBridge Investments is a registered trademark proprietary to PineBridge Investments IP Holding Company Limited.

Readership: This document is intended solely for the addressee(s) and may not be redistributed without the prior permission of PineBridge Investments. Its content may be confidential, proprietary, and/or trade secret information. PineBridge Investments and its subsidiaries are not responsible for any unlawful distribution of this document to any third parties, in whole or in part.

Opinions: Any opinions expressed in this document represent the views of the manager, are valid only as of the date indicated, and are subject to change without notice. There can be no guarantee that any of the opinions expressed in this document or any underlying position will be maintained at the time of this presentation or thereafter. We are not soliciting or recommending any action based on this material.

Risk Warning: All investments involve risk, including possible loss of principal. If applicable, the offering document should be read for further details including the risk factors. Our investment management services relate to a variety of investments, each of which can fluctuate in value. The investment risks vary between different types of instruments. For example, for investments involving exposure to a currency other than that in which the portfolio is denominated, changes in the rate of exchange may cause the value of investments, and consequently the value of the portfolio, to go up or down. In the case of a higher volatility portfolio, the loss on realization or cancellation may be very high (including total loss of investment), as the value of such an investment may fall suddenly and substantially. In making an investment decision, prospective investors must rely on their own examination of the merits and risks involved.

Performance Notes: Past performance is not indicative of future results. There can be no assurance that any investment objective will be met. PineBridge Investments often uses benchmarks for the purpose of comparison of results. Benchmarks are used for illustrative purposes only, and any such references should not be understood to mean there would necessarily be a correlation between investment returns of any investment and any benchmark. Any referenced benchmark does not reflect fees and expenses associated with the active management of an investment. PineBridge Investments may, from time to time, show the efficacy of its strategies or communicate general industry views via modeling. Such methods are intended to show only an expected range of possible investment outcomes, and should not be viewed as a guide to future performance. There is no assurance that any returns can be achieved, that the strategy will be successful or profitable for any investor, or that any industry views will come to pass. Actual investors may experience different results.

Information is unaudited unless otherwise indicated, and any information from third-party sources is believed to be reliable, but PineBridge Investments cannot guarantee its accuracy or completeness.

PineBridge Investments Europe Limited is authorised and regulated by the Financial Conduct Authority (FCA). In the UK this communication is a financial promotion solely intended for professional clients as defined in the FCA Handbook and has been approved by PineBridge Investments Europe Limited. Should you like to request a different classification, please contact your PineBridge representative.

Approved by PineBridge Investments Ireland Limited. This entity is authorised and regulated by the Central Bank of Ireland.

In Australia, PineBridge Investments LLC is exempt from the requirement to hold an Australian financial services license under the Corporations Act 2001 (Cth) in respect of the financial services it provides to wholesale clients, and is not licensed to provide financial services to individual investors or retail clients. Nothing herein constitutes an offer or solicitation to anyone in or outside Australia where such offer or solicitation is not authorised or to whom it is unlawful. This information is not directed to any person to whom its publication or availability is restricted.

In Hong Kong, the issuer of this document is PineBridge Investments Asia Limited, a company incorporated in Bermuda with limited liability, licensed and regulated by the Securities and Futures Commission (SFC). This document has not been reviewed by the SFC.

In Dubai, PineBridge Investments Europe Limited is regulated by the Dubai Financial Services Authority as a Representative Office.

In Germany, PineBridge Investments Deutschland GmbH is authorised and regulated by the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin).

In Switzerland, PineBridge Investments Switzerland GmbH is authorised and regulated by the Swiss Financial Market Supervisory Authority (FINMA).

PineBridge Investments Singapore Limited is licensed and regulated by the Monetary Authority of Singapore (MAS). In Singapore, this material may not be suitable to a retail investor and is not reviewed or endorsed by the MAS.

As of 22 July 2019


GDPR

PRIVACY NOTICE

This Privacy Notice explains how PineBridge (“the Company”) collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.

In this Privacy Notice, “us”, “we” and “our” refers to the Company.

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.

YOUR RIGHTS

Under the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and if you are a European data subject you have the following rights including:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Privacy Coordinator via email: privacyofficer@pinebridge.com.

HOW WE COLLECT YOUR DATA

We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you;
  • When we enter into a contract and during the provision of services;
  • From third parties.

THE CATEGORIES OF THE DATA WE COLLECT

We may collect the following categories of data about you:

  • Personal Data (including but not limited to name and contact information); and
  • Sensitive Personal Data (where you volunteer to provide such information to us)

THE BASIS FOR PROCESSING YOUR DATA, HOW WE USE THAT DATA AND WHOM WE SHARE IT WITH

1. We may process your personal data because it is necessary for our legitimate interests.

  • This may include sharing your personal data with the following:
    • other companies in our Group; and
    • third party service providers as may be necessary.
  • This may also include carrying out marketing activities, which are in our or our affiliates’ legitimate business interest.

2. We may also process your data for our compliance with a legal obligation which we are under.

3. To perform our contractual obligations to you. This may also entail sharing your personal data with companies, which assist us in performing our contractual obligations.

4. We may use your personal data to meet our regulatory obligations, with regard to conducting due diligence. In this respect, we may share your personal data with the following:

  • Our auditors where it is necessary as part of their auditing functions;
  • With relevant regulators where we are required to do so; and
  • third party service providers as may be necessary.

In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies located in the European Economic Area as well as Switzerland, which are countries, which provide the same or a similarly adequate level of protection for your personal data as is provided within the jurisdiction in which the Company is incorporated. We may also share your personal data with Group companies located in locations including the United States of America, Hong Kong, and Japan, which do not have laws which provide the same level of protection to your personal data as are provided within the jurisdiction in which the Company is incorporated. However, these companies are subject to our Group-wide data sharing arrangements which offer a common level of protection across the Group.

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 in collected and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy.


MiFID

Annual Best Execution Disclosure 2018


CCPA PRIVACY NOTICE

Last Revised: January 17, 2020

This CCPA Privacy Notice for California Residents supplements the information contained in the Privacy Policy of PineBridge (“us”, “we” and “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumer” or “you”). We have adopted this disclosure to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

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.

HOW WE COLLECT YOUR DATA
We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you;
  • When we enter into a contract and during the provision of services; and
  • From third parties.

THE CATEGORIES OF THE DATA WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
  • Information in Customer Records: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, and financial information.
  • Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
  • Enquiry Data: Information contained in any enquiry you submit to us regarding our services.
  • Correspondence Data: Information contained in or relating to any communication that you send to us.
  • Sensory data: Audio and visual data recorded at our physical offices and locations.
  • Professional or employment-related information.
  • Education information.

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope.

USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information and to perform our contractual obligations to you. This may also entail sharing your personal information with companies, which assist us in performing our contractual obligations.
  • Processing for our compliance with a legal obligation which we are under, including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To meet our regulatory obligations, with regard to conducting due diligence (including complying with anti-money laundering or know your customer laws and regulations). In this respect, we may share your personal data with the following:
    • Our auditors where it is necessary as part of their auditing functions;
    • with relevant regulators where we are required to do so; and
    • third party service providers as may be necessary.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

These uses may include sharing your personal data with the following:

  • Other companies in our Group (our affiliates)
  • Third party service providers as may be necessary which may include carrying out marketing activities, which are in our or our affiliates’ legitimate business interest

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Information in Customer Records
  • Internet or other similar network activity
  • Enquiry Data
  • Correspondence Data
  • Professional or employment-related information
  • Education information

We disclose personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

In the preceding twelve (12) months, we have not sold any personal information. Likewise, we do not have any future plans to sell personal information. However, we respect and understand that you may still want to ensure your personal information is not sold. Therefore, you may make a “do not sell my data” request on our DO NOT SELL MY DATA page.

YOUR RIGHTS AND CHOICES
The CCPA provides Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists:
    • Personal Information Sold: identifying the personal information categories that each category of recipient purchased; and
    • Personal Information Disclosed for a Business Purpose: identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by visiting pinebridge.com/ccpa-request

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website.

CONTACT INFORMATION
If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: privacyofficer@pinebridge.com

Postal Address:

Privacy Officer
PineBridge Investments
65 East 55th Street, 6th Floor
New York, NY 10022