In this document, "we", "us" and "our" refers to Nuveen, LLC, its subsidiaries including its affiliated investment advisers, a fund or account managed or advised by them (together, "Nuveen") and its or their affiliates and/or delegates.
- 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 DPL. Nuveen's affiliates and delegates may act as "data processors" for the purposes of the DPL.
Who this AffectsIf 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 DataNuveen (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.
We, as a UK-based data controller, process your data in the UK. 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 or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.
Why We May Transfer Your Personal Data
We may share Investor Data with the following parties (which may be amended from time to time) who provide services to a respective fund and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf:
- 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.
The Data Protection Measures We TakeAny transfer of Investor Data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.
We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.