Nuveen, LLC, its subsidiaries, including Santa Barbara Asset Management, LLC, and other affiliated investment advisers and funds (together, the “Company”, “us” or “we”) consider your privacy our utmost concern.
This privacy notice (the “Notice”) outlines the information we may collect about you and describes the basis on which we process your Personal Information, as defined by the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) and other United Kingdom (“UK”) and European data privacy laws (the “Privacy Laws”). This Notice also provides information regarding the basis on which we process your Personal Information and your privacy rights under applicable Privacy Laws.
This Notice applies to all websites operated by us, as indicated on the relevant website ("Sites"). This Notice is addressed to any natural person who is resident in the European Union and/or the UK who is any of the following: an investor or prospective investor in any fund or account managed or advised by the Company (a “Company Fund”), a member, distributor, sales representative, business affiliate, or other representative of any client or prospective client of the Company, a Site user, a business contact working with service providers and vendors, or an individual on a Company mailing list (“you”) whose Personal Information the Company collects, controls and processes in the conduct of its business.
1. Collection of Personal Information
Our primary goal in collecting Personal Information from you is to effectively conduct business with our business partners and when applicable provide services and features to our clients, investors and potential clients and investors. You may make a data request by emailing email@example.com
2. Types of Personal Information held and its use
2.1 Customer services and administration
The Company may, in the conduct of our business, obtain Personal Information about you that may include, subject to the type of business or service relationship we have with you, without limitation:
In the course of our business, we may collect Personal Information about you from sources including, but not limited to:
We process your Personal Information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of the Company and for other purposes for which the Company has a lawful basis under the Privacy Laws, including:
We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.
2.2 Monitoring use of our Sites
The Company collects certain information that you provide to us when subscribing to a Company mailing list, which may include your name, email address and other contact details. Some of your Personal Information collected, in accordance with this Notice, may be used by us and third party service providers to contact you by email, fax, telephone and/or post for sending information or promotional material on our products and/or services and/or those of the Company.
In addition, we may process your Personal Information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about services, news updates, research or market commentary, conferences, or events offered by or in conjunction with the Company.
We give you the opportunity to opt-out of receiving marketing communications and may in certain circumstances need to obtain your consent before sending such communications to you. Further detail can be found in each marketing communication sent by us.
Email Tracking: So that we can better understand our users' needs, we track responses to our emails - for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages. To do this, we use small image files that are placed within the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs on links within the message.
A cookie is a small text file that we store on the browser or the hard drive of your desktop, tablet or smartphone when you first visit our Sites. The cookie will help our Sites, or another website, recognize your desktop, tablet or smartphone the next time you visit. A cookie can contain Personal Information.
Cookies may be required to operate our Sites, allow us to recognize and count the number of visitors and to see how visitors move around our Sites, which may help us improve the design of our Sites. Cookies may also recognize you when you return to our Sites, enabling us to personalize our content and remember your preferences, and may be used to record your visit to our Sites, the pages you visited and the links you followed. We may use this information to provide you with targeted advertising and content we think you will be interested in. In some cases we may use information from third party cookies to help us with market research or improving the design of our Sites (for example, where traffic to our Sites comes from).
You can block cookies by activating the setting on your browser that allows you to refuse all, or some, cookies. If you block all cookies you may find that parts of our Sites do not work properly, or you may not be able to access our Sites at all.
4. Third Parties
We may pass your Personal Information on to third-party service providers contracted to us in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service that they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures.
We may share your Personal Information with the Company entities including with the Company Funds for any of the purposes set forth above. In any such business purposes set out above, the Company may share your Personal Information with third parties, including:
We may transfer, sell or assign any of the information described in this policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
6. Transfers outside the UK / European Economic Area (EEA)
Where your Personal Information is processed by third parties outside the UK / EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law. Services on the Internet are accessible globally so collection and transmission of Personal Information is not always limited to one country. We may transfer your Personal Information, for the purposes listed above, to the Company, service providers or other third parties which may be located in countries outside the EEA, whose laws may not provide the level of protection to Personal Information as within the EEA. This may include transfers to Companies in the US (who may collect some data directly from you, in relation to the Sites which it operates) and to third parties who provide us with email and marketing services. Where we conduct any transfers we will endeavor to take steps reasonably necessary to ensure that your data is treated securely.
7. Confidentiality and security of your Personal Information
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your Personal Information from loss, misuse or alteration. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access.
We have implemented information security policies, rules and technical measures to protect the Personal Information that we have under our control from:
8. How to access, update and erase your Personal Information
At your request, we can confirm what information we hold about you and how it is processed. If we do hold Personal Information about you, you can request the following information:
Upon request, we will provide you with a readable copy of the Personal Information which we keep about you. We may require proof of your identity.
We will allow you to challenge the data that we hold about you and, where appropriate in accordance with applicable laws and policies, you may request to have your Personal Information:
If you would like to make a data request please contact firstname.lastname@example.org
Changes to this Notice
We will occasionally update this Notice to reflect new legislation or industry practice, Company changes and customer feedback. We encourage you to review this Notice periodically to be informed of how we are protecting your Personal Information.