Special Notice for persons in EEA

Our privacy commitments

Nuveen and its subsidiaries and affiliates respects the privacy of every person who visits, registers with or subscribes to our websites and online publications ("you"), and are committed to ensuring a safe online experience.

This privacy notice outlines the information we may collect about you in relation to your use of our websites and related publications and services and how we may use that personal data (as defined by the EU’s General Data Protection Regulation (“GDPR”)). It also outlines the methods by which we and our service providers may (subject to necessary consents) monitor your online behaviour in order to deliver customised advertisements and marketing materials and other tailored services. This privacy notice also tells you how you can verify the accuracy of your personal data and how you can request that we delete or update it or (if applicable) to withdraw your consent given to us.

By accessing and using the Sites you are agreeing to the terms of this privacy notice.

Information about us

Our principal business activities:

Provide client solutions through a range of products and structures within commercial asset management globally.
Provide market-leading research for strategic insights across the investment process.
Co-invest across all commercial sectors and manage funds with sector specialisms
Digital marketing including websites, newsletters, electronic information and data
Organisers and attendees of Seminars, Conferences, and Exhibitions for the asset management sector.

Name of the Data Controller

The European Data Controller is Nuveen Administration Limited, with its registered office at 201 Bishopsgate, London EC2M 3BN.

Email: dataprivacy@nuveenglobal.com

Nuveen Administration Limited is registered in the UK with the Information Commissioner's Office.

1. Collection of personal data

Our primary goal in collecting personal data from you is to give you an enjoyable customised experience whilst allowing us to provide services and features that most likely meet your needs.

Please note that we do not intend to collect any personal data from children under sixteen years of age and no child under sixteen should submit any personal data to any of the Sites. Should we discover that any such personal data has been delivered to any of the Sites, we will remove that information as soon as possible.

2. Types of personal data held and its use

2.1 Customer services and administration

We collect certain personal data from you such as your name, job title, work and/or home address, company, company size, job function and/or seniority, industry, qualification levels, and telephone number and email address, in order to register you for access to certain content and subscriptions. This information may be supplemented with demographic information from your use of our Sites such as your location, age, gender, purchasing preferences and interests.
This information is used to administer and deliver to you the products and/or services you have requested, to operate our Sites efficiently and improve our service to you, and to retain records of our business transactions and communications.

By using the Sites and submitting personal information through the registration process you are agreeing and have given us consent that we may collect, hold, process and use your information (including personal information) for the purpose of providing you with the Site services and developing our business, which shall include (without limitation) the purposes described below in and in accordance with the GDPR.
We will endeavour 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 data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

2.2 Monitoring use of our Sites

If, as part of our Site services, we enable you to post information or materials on our Site, we may access and monitor any information which you upload or input, including in any password-protected sections. Subject to any necessary consents, we also monitor and/or record the different Sites you visit and actions taken on those Sites, e.g. content viewed or searched for.

If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your machine. This enables your access to content and services that are not publicly available. Once you are logged on, the actions you take - for example, viewing an article - will be recorded (subject to any necessary consents). We may use technology or a service provider to do this for us. This information may be used for one or more of the following purposes:

to fulfil our obligations to you;
to improve the efficiency, quality and design of our Sites and services;
to see which articles, features and services are most read and used
to track compliance with our terms and conditions of use;
for marketing purposes (subject to your rights to opt-in and opt-out of receiving certain marketing communications) - see paragraph 2.3 below
for advertising purposes, although the information used for these purposes does not identify you personally;
for advertising purposes, although the information used for these purposes does not identify you personally;
to protect or comply with our legal rights and obligations; and
to enable our employees to contact and interact with you online in connection with any content you may have viewed in our Sites.

Please see paragraph 3 below for more information on cookies and similar technologies and a link to a page where you can turn them on or off.

2.3 Marketing

Some of your personal data collected, in accordance with the privacy notice, may be used by us and/or our other group companies 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 our other group companies.

We give you the opportunity to opt-out of receiving marketing communications and will in certain circumstances need to obtain your consent before sending such communications to you. Further detail can be found on the applicable Site and in each marketing communication sent by us, our group companies or service providers.

3. Cookies and email tracking

We use cookies on our Sites. This is to provide you with a better user experience when you browse our Sites. It also enables us to improve our Sites. This section explains how we do that.

What is a cookie? A cookie is a small file of letters and numbers that we store on your 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, recognise your desktop, tablet or smartphone the next time you visit. A cookie can contain Personal Information. We detail what cookies we use, and what information they contain, below.

What types of cookies do we use? We have included a detailed list of the precise cookies used on the Sites below. In summary, we use the following cookies:

Strictly necessary cookies: These are the cookies required to make our Site usable by enabling basic functions like page navigation and access to secure areas of the Site. Our Site cannot function properly without these cookies.
Preference cookies: These cookies enable our Site to remember information that changes the way the Site behaves or looks, like personalising your content, preferred language or region you are located in.
Statistical cookies: These cookies help us to understand how visitors interactive with our Site by collecting and reporting information anonymously. This helps us improve the designs of our Site.
Marketing cookies: These cookies track your visit across the Site. We use this information to provide you and others with characteristics or behaviours similar to yours, with targeted advertising and content we think will be of interest on LinkedIn, Facebook and other websites and apps.

In some cases we may use information from third party cookies (be they analytics, functionality or targeting cookies) to help us with market research or improving the design of our Sites (for example, where traffic to our Sites comes from).

Accepting cookies You will be asked if you would like to consent to non-essential cookies when you land on our Site. If you do not do so, some experiences on the Sites may be limited.

How can I block accepted cookies? 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 (including essential 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.

When do cookies stop? Our cookies expire after up to ten years. Please contact us if you would like further information about the duration of our cookies.

Category	Cookie name	Cookie purpose	Expiry
Necessary	__cfduid	Used by the content network, Cloudflare, to identify trustedweb traffic.	1 year
Necessary	asp.net_sessionid	Preserves the visitors’ session state across page requests	Session
Necessary	checkforpermission	Determines whether the visitor has accepted the cookie consent box	1 day
Necessary	rt	This cookie is used to identify the visitor through an application.	6 days
Preferences	lang	Remembers the user’s selected language version of a website	Session
Preferences	land	Set by LinkedIn when a web page contacts an embedded ‘Follow us’ panel	Session
Statistics	_ga	Registers a unique ID that is used to generate statistical data on how the visitors use the website	2 years
Statistics	_gat	Used by Google Analytics to throttle request rate	1 day
Statistics	_gid	Registers a unique ID that is used to generate statistical data on how the visitor uses the website	1 day
Statistics	personalization_id	This cookie is set by Twitter and allows the visitor to share content from the website to their own Twitter profile	2 years
Statistics	sc_analytics_global_cookie	Used by sitecore engagement analytics to identify the visitor on repeat visits to the website	10 years
Marketing	_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	3 months
Marketing	_gcl_au	Used by Google Adsense for experimenting with advertisement efficiency across websites using their services	3 months
Marketing	Ads/ga-audiences	Used by Google Adwords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites	Session
Marketing	bcookie	Used by the social networking service, LinkedIn, for tracking the use of embedded services	2 years
Marketing	bito	Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisements. This pairing service is provided by third party advertisement hubs, which facilities real-time bidding for advertisers	1 year
Marketing	bscookie	Used by the social network service, LinkedIn, for tracking the use of embedded services	2 years
Marketing	fr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	3 months
Marketing	i/adsct	The cookie is used by Twitter to determine the number of visitors accessing the website through Twitter advertisement content	Session
Marketing	ide	Used by Google DoubleClick to register and report the website user’s actions after viewing or click one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user	1 year
Marketing	lidc	Used by the social networking service, LinkedIn, for tracking the use of embedded services	1 day
Marketing	pardot	Used to identify the visitor across visits and devices. This allows the website to present the visitor with relevant advertisement	Session
Marketing	test_cookies	Used to check if the user’s browser supports cookies	1 day
Marketing	tr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	Session
Marketing	tuuid	Collects unidentifiable data, which is sent to an unidentifiable received. The receiver’s identity is kept secret by Perfect Privacy LLC	2 years
Marketing	tuuid_lu	Contacts a unique visitor ID, which allows Bidswitch.com to track the visitor across multiple websites. This allows Bidswitch to optimise advertisement relevance and ensure the visitor does not see the same ad multiple times	2 years
Marketing	usermatchhistory	Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences	29 days
Marketing	visitor_id#	Used by Pardot to track know visitor’s behaviour across the site.	10 years
Marketing	visitor_id#-hash	Used by Pardot to track know visitor’s behaviour across the site.	10 years
Marketing	com.silverpop.ima.page_visit	Used to identify known users site usage	1 day
Marketing	com.silverpop.ima.session	Used to identify visitors site usage per session	Session
Marketing	com.silerpop.imawebcookies	Used to identify site usage	1000 days

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.

Any other purposes for which we wish to use your personal data will be notified to you and your personal data will not be used for any such purpose without obtaining your prior consent.

4. Third Parties

We may pass your personal data 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. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

5. Processing information

By continuing to use the Sites, you acknowledge the information in this policy regarding the processing of your personal information.

6. Disclosures

Information collected may be shared between with any of our group companies for the purposes listed above and as part of the processing activities.
We may also disclose your personal data to other third parties, including, without limitation, professional advisers, or governmental or State institutions or regulatory authorities, where necessary in order to exercise or defend legal rights or where required by law.

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 reorganisation of our business.

7. Public forums, message boards, social media and blogs

Some of our Sites make message boards, blogs or other facilities for user generated content available and users can participate in these facilities. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information.

8. Transfers outside Europe

Services on the Internet are accessible globally so collection and transmission of personal data is not always limited to one country. We may transfer your personal data, for the purposes listed above, to other group companies, service providers or other third parties which may be located in countries outside Europe, whose laws may not give the level of protection to personal data as within Europe. This will include transfers to Nuveen 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 take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. We have executed standard contractual clauses approved by the European Commission with our affiliates and third party entities located outside Europe (unless they have adequate data protection laws or are certified with the EU-US Privacy Shield) in accordance with the GDPR (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915) (http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087).

9. Confidentiality and security of your personal data

We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your personal data from loss, misuse or alteration.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

unauthorised access
improper use or disclosure
unauthorised modification
unlawful destruction or accidental loss

All our employees, contractors and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your personal data, are obliged to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.

10. How to access, update and erase your personal information

You have certain rights to control the processing of your personal data, subject to and in accordance with applicable laws including the GDPR.

At your request, we can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information:

Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU or UK.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of us or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
The duration of storage of your data
In cases you have given your consent to use your personal data you may at any time withdraw a consent granted hereunder at dataprivacy@nuveenglobal.com
If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Upon request, we will provide you with a readable copy of the personal data which we keep about you. We may require proof of your identity before we can send you a copy of your data.

We will allow you to challenge the data that we hold about you and, where appropriate in accordance with applicable laws, you may have your personal information:

Erased;
rectified or amended; and/or
completed

You may also object to the processing of your personal data in accordance with applicable laws.

If you would like to make a data request please use this web form. We will aim to respond within a month of your request. We may need to extend the period of time by a further two months in accordance with our legal entitlements.

Changes to this privacy notice

We will occasionally update this privacy notice to reflect new legislation or industry practice, group company changes and customer feedback. We encourage you to review this privacy notice periodically to be informed of how we are protecting your personal data.