Cayman Islands privacy notice

Effective Date: October 2026

Nuveen, LLC, its subsidiaries, including its affiliated investment advisers, a fund or account managed or advised by them (together, "Nuveen," "us" or "we"), considers your privacy to be a fundamental aspect of our relationship with you. This privacy notice does not apply to Schroders plc or its affiliates (“Schroders”), which maintain their own separate privacy notices governing their websites and other related data transfer and processing activities. Links to Schroders' privacy notices are provided at the end of this Privacy Statement for your convenience.

The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Act, (As Revised) of the Cayman Islands (the "DPA"). This notice also gives information regarding the basis on which we collect, hold, use and disclose your personal data and your data protection rights under the DPA.

Investor data

By virtue of making an investment with Nuveen and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPA ("Investor Data"). We may also obtain Investor Data from other public sources. Investor Data may include, without limitation, the following information relating to you and/or any individuals connected with you as an investor:
 

• 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 our use of Investor Data, Nuveen (e.g., the respective fund) will be characterized as a "data controller" for the purposes of the DPA. Nuveen's affiliates and delegates may act as "data processors" for the purposes of the DPA.

Who this affects

If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, 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 may use your personal data

Nuveen (e.g., the respective fund), as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:
 

• Where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of the fund;
• Where this is necessary for compliance with a legal and regulatory obligation to which the fund or respective entity is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
• Where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Additionally, a Nuveen affiliate or a respective fund’s administrator (the "Administrator"), may use Investor Data, for example to provide its services to the fund or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the fund relies upon the Administrator, but such use of Investor Data by the Administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.

Why we may transfer your personal data

In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Investor Data and other information in possession of Nuveen with the relevant regulatory authorities such as the Cayman Islands Monetary Authority, the competent authority for purposes of the Beneficial Ownership Transparency Act (As Revised) or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.

We anticipate disclosing Investor Data to parties who provide services to Nuveen and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area). Such parties include the following who may either process personal data on our behalf or for their own lawful purposes in connection with services provided to Nuveen.
 

• Nuveen affiliates (e.g., for a respective fund);
• 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 Nuveen, a Nuveen fund and/or a Nuveen 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 also need to provide Investor Data to investment funds into which a relevant fund invests for purposes of their compliance with legal and regulatory obligations (such as compliance with Anti-Money laundering and FATCA/CRS requirements).

The data protection measures we take

Any transfer of Investor Data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPA.

We and our duly authorized affiliates and/or delegates shall apply appropriate technical and organizational information security measures designed to protect against unauthorized or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.

Getting in touch

Should you have any queries or wish to discuss your data protection rights with us, 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 Investor Data.

Notices for Individuals Interacting with Schroders

For information on Schroders' privacy practices, please visit the following link for more information: https://www.schroders.com/en/global/official-institutions/privacy-policy/