Privacy Policy - California

This section (“CCPA Section”) of our Privacy Policy supplements the policy but pertains to the California Consumer Privacy Act, the California Privacy Rights Act, any related regulations, and any amendments to the foregoing (collectively, the “CCPA”). This CCPA Section supplements the information contained in any other Privacy Statement or Notice provided by Schroders Investment Management North America Inc. and its affiliates (“Schroders”, the “company”, “we”, “our” or “us”). This CCPA Section applies solely to individuals who are residents of the State of California (“consumers” or “you”) as required under the CCPA. This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Schroders website (the “Website”), or through other channels including but not limited to visiting one of our locations, phone and email conversations, attending our events, in-person interactions, interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized service providers.

Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. All other terms shall have the meaning set forth in the Schroders’ US Privacy Policy (our “Privacy Policy”) or Important Information sections of the Website, as applicable. The other provisions of our Privacy Policy continue to apply except as modified in this CCPA Section.

Please read this CCPA Section carefully before using the Website or submitting personal information to us. BY ACCESSING OR USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS CCPA SECTION AND THE TERMS OF USE. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this CCPA Section, please do not provide us with such information.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).

We may have collected the following categories of personal information from consumers within the last twelve (12) months. Under the CCPA, personal information does not include certain categories of personal information, including without limitation: (i) publicly available information from government records; (ii) deidentified or aggregated consumer information; (iii) personal information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code), or protected health information that is collected, processed, sold, or disclosed pursuant to the federal Health Insurance Portability and Accountability Act, and implementing regulations.

Category	Examples	Collected
A. 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.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A 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, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES

I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive personal information	Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.	YES

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected and in accordance with applicable laws and regulations, including record retention requirements under the Investment Advisers Act of 1940, as amended, and the Company’s internal data retention policies, unless we have or deidentified or deleted your personal information (for example, in response to a request to delete). We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, and enforce our policies, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we may consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.

Use of Personal Information

We may collect or use the personal information for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment and facilitate delivery.
To contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and service offerings relevant to your interests.
To help maintain the safety, security, and integrity of our Website, services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
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 manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.
As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.

Sources of Personal Information We Collect

You. We may collect personal information that you provide during your interactions with us, such as through our Website, by email, or when you communicate with our professionals online, by phone, at one of our locations, or through social media. We may also collect information when you attend an event, or participate in a program we sponsor. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons, as well as through our advertising activities.
Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures (if any).
Social media and related services. We may collect information about your from social media and related services.
Service providers and contractors. When you obtain products and services from us, we may collect your personal information from service provider and contractors who collected information about you that is needed to provide those products and services.
News outlets, social media, surveys, and certain third parties. In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of personal information about you.
Information Collected Automatically. As you navigate through and interact with our Website, we may compile statistical information concerning your usage of the Website through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to our Website, such as traffic data, location data and data about the resources that you used to access the Website
Information about your computer and internet connection, including your operating system and browser type.
Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Website.
Information about your preferences to make your use of the Website more productive, via the use of cookies. For more information on cookies, please see Schroders’ Cookie Policy. While all of this information can be associated with the IP address your computer had while you visited the Website, it will not be associated with you as an individual or with any other information you may submit through the Website or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Website. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

Disclosures of Personal Information for a Business Purpose

We do not sell your personal information or share your personal information for cross-context behavioral advertising to third parties. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services and are reasonably expected by an average consumer requesting those goods and services. We also do not have actual knowledge that we have sold or shared personal information of minors under age 16.

We may, however, disclose your personal information with service providers and contractors who help us provide the products and services, such as, payment processing, marketing and advertising, email, text and other communications, applications, business support, and website, software, platform, cloud, data storage and other technical services.

We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.

During the past 12 months, we have not sold, shared or disclosed personal information for business purposes to “third parties” as that term is defined in the CCPA. We have disclosed personal information for business purposes to “service providers” and “contractors” as those terms are defined in the CCPA.

Your Rights and Choices

Subject to certain exceptions, the CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know. 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 that personal information.
The categories of third parties with whom we disclose that personal information.
The categories of personal information we sold or disclosed for a business purpose.
The specific pieces of personal information we collected about you (also called a data portability request).

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests. Any disclosures we provide will typically only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.

Right to Delete. 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 and contractors, as applicable, 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 provider(s) to:

Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.
Comply with a legal obligation.
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to correct. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and where required by the CCPA, we will provide a response to such requests.

Exercising the Rights to Know, Delete, and Correct. To exercise the know, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

Toll-free number: 1-866-745-2414
Emailing us at americasprivacy@schroders.com

When leaving a voicemail on our toll-free number or emailing us your request, please provide sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative, and a sufficient description of your request, including:

Your name.
Your address.
Your email address.
Your phone number.
Your relationship with Schroders (for example, customer, former customer, prospective customer, applicant, employee, former employee, prospective vendor, current vendor, former vendor, etc.).
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you are acting as an authorized representative or as a parent on behalf of someone else, please clarify that you are acting as such and provide the information above for the person you are acting on behalf of, and please provide written evidence that shows you are that you permitted to act for such other person.

Once we receive your request, we may need to seek further information to understand and respond to your request and may need to take further steps to verify your identity as a security precaution. 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.

Only you, or someone legally authorized 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. We will verify your identity before responding to your request.

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 Time and Format. We endeavor to respond to a verifiable consumer request within forty-five (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.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will typically only cover the 12-month period preceding the verifiable consumer request’s receipt, except as provided above or as required under the CCPA. 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 usable and should allow you to transmit the information from one entity to another entity without hindrance. Data portability request format will be determined upon request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this CCPA Section. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. The right to nondiscrimination also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

Changes to Our Privacy Notice

We reserve the right to amend this CCPA Section at our discretion and at any time. When we make changes to this CCPA Section, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, 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: americasprivacy@schroders.com

Toll-free number: 1-866-745-2414

Postal Address: Schroders Privacy Officer

7 Bryant Park,

New York, NY 10018 USA