Nuveen, LLC, its subsidiaries including its 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 “Abu Dhabi Global Market’s Data Protection Regulations”. This Notice also gives information regarding the basis on which we process your Personal Information and your privacy rights under applicable Privacy Laws. This privacy notice should not be construed as establishing a contractual relationship.
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 ADGM 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.
Our privacy commitments
Nuveen and its subsidiaries and affiliates respect 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 “Abu Dhabi Global Market’s Data Protection Regulations”). It also outlines the methods by which we and our service providers may (subject to necessary consents, where applicable) monitor your online behavior in order to deliver customized 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.
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 privacyoffice@nuveen.com.
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 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:
- Contact information (e.g., your full name, business and/or home mailing address, telephone number, business and/or personal email address, job title);
- Identification information (e.g., date of birth, social security number, tax or other identification numbers and documents);
- Financial Information (e.g., documents and information about your income, account transactions and holdings with us);
- Browsing Information (e.g., Internet Protocol (or IP) address, browser language and type, domain name, operating system, location data, resources that you access).
In the course of our business, we may collect Personal Information about you from sources including, but not limited to:
- Information we receive from you, your application, subscription or other forms or material completed or supplied by an actual or prospective client of the Company or a third party;
- Other written, electronic or verbal correspondence which relate to the business activities by or on behalf of an actual or prospective client of the Company;
- Information we receive from you when subscribing to a Company mailing list;
- Information we receive from you from recorded calls;
- Information we receive from security footage recorded for safety and security purposes when visiting Company premises; and
- Information we automatically collect from Company Sites by using cookies and other online tracking technologies.
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:
- To administer and deliver to you the products and/or services you have requested;
- For purposes of reporting to, or communicating with, actual or prospective clients of the Company or third parties or the appointment or engagement of the Company consistent with our obligations to such Company clients;
- To retain records of our business transactions and communications;
- For compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or other “Know your Client” requirements;
- To verify the status and/or eligibility of an actual or prospective client of the Company for services offered by the Company and for compliance with tax reporting requirements;
- Due diligence or monitoring activities of counter-parties;
- In connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Company or the clients of the Company;
- To enable us to respond to certain requests by you such as access requests, scheduling of meetings or similar requirements;
- To operate our Sites efficiently and improve our service to you; and
- For other legitimate business interests.
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
We collect, process, and use Personal Information on our Sites through the use of cookies in order to offer a better, more tailored overall client experience, better adapt our business processes to our clients’ needs, and provide access to relevant product information and online applications. Please see Section 3 below for more information on cookies and similar technologies.
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
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-through's on links within the message.
3. Cookies
We use cookies on our Sites to provide Site visitors with a better user experience when they browse our Sites. It also enables us to improve our Sites. If you use one of our Sites, and through your consent to the pop up that appeared on your first visit to such Site, you agree to the use of cookies in accordance with this Notice.
What is a cookie?
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.
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.
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.
5. Disclosures
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:
- Service providers e.g., attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers or other agent, adviser or service provider of the Company, a Company Fund and/or the Company client;
- Other counter-parties e.g., managers, general partners or investment advisers or administrators or any of their respective agents or representatives; and
- Regulatory authorities (including tax authorities), courts and bodies as required by law or requested for internal investigations and reporting.
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.
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.
6. Transfers outside the ADGM
Where your Personal Information is processed by third parties outside the ADGM , 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 ADGM , whose laws may not give the level of protection to Personal Information as within the ADGM . 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:
- Unauthorized access;
- Improper use or disclosure;
- Unauthorized modification; and
- 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.
8. 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 “Abu Dhabi Global Market’s Data Protection Regulations”.
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:
- Contact details of the data protection officer, where applicable.
- Identity and the contact details of the person or organization that has determined how and why to process your data. 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 Information collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the Personal Information to a third country or international organization, information about how we ensure this is done securely.
- How long the data will be stored.
- In cases you have given your consent to use your personal data you may at any time withdraw a consent granted hereunder at privacyoffice@nuveen.com.
- Details of your rights to correct, erase, restrict or object to such processing.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of Personal Information 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 Information and the possible consequences of failing to provide such data.
- The source of Personal Information 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 Information 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 and policies, you may request to have your Personal Information:
- Erased;
- Rectified or amended; and/or
- Incomplete information 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 contact privacyoffice@nuveen.com.
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.
