Effective Date: 1 July 2026

Nuveen, LLC, its subsidiaries including its affiliated investment advisers and funds (together, the “Company”, “us” or “we”) considers your privacy to be a fundamental aspect of our relationship with you.

This privacy notice (the “Notice”) outlines the information we may collect about you and describes the basis on which we process your personal data, as defined by the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”) and other applicable laws, regulations and guidance in Hong Kong SAR. This Notice also gives information regarding the basis on which we process your personal data and your privacy rights under the PDPO. This 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 Hong Kong SAR 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 data the Company collects, controls and processes in the conduct of its business.

Our privacy commitments

We respect the privacy of every person who visits, registers with or subscribes to our websites and online publications, and are committed to ensuring a safe online experience.

This 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 PDPO). 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 customised advertisements and marketing materials and other tailored services. This Notice also tells you how you can access your personal data and how you can request that we amend 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 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. 

Data User

For the purposes of the PDPO, the data user is Nuveen Hong Kong Limited, whose registered office is at Suite 2701-05, 27/F, AIA Central, 1 Connaught Road, Central, Hong Kong SAR. 
Email: privacyoffice@nuveen.com 

1. Collection of Personal Data

Our primary goal in collecting personal data 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. Sharing your personal data with us is voluntary. However, if you do not provide your personal data to us, we may not be able to provide all of our services to you. You may make a data request by emailing our Compliance Officer at: privacyoffice@nuveen.com.

2. Types of Personal Data held and its use

2.1 Customer services and administration

The Company may, in the conduct of our business, obtain personal data 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, Hong Kong Identity Card number, passport 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 data 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 data to fulfill our contractual obligations, our statutory obligations and/or the purposes described in this Notice and other purposes, 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 facilitate a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business;
• To operate our Sites efficiently and improve our service to you.

We may collect, use, disclose and/or process your personal data for other purposes that do not appear above.  However, we will notify you of such other purpose and obtain your consent, unless the processing of your personal data without your consent is permitted by the PDPO or by law.

We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Your personal data will be generally retained by us for a period of two (2) years after you last accessed our Site, or we have last corresponded with you.  However, how long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices including where we are required to retain your information in accordance with the law for income tax and audit purposes. Personal data 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 data 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. 

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 data 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. We cannot use your personal data for direct marketing purposes unless we have received your consent.

Provided we have obtained your consent, we may process your personal data 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. Further details 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.

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 data.

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. 

4. Disclosures/Third Parties 

We may share your personal data with the Company entities including with the Company Funds for any of the purposes set forth in section 2.1 above. For any such business purposes, the Company may share your personal data 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.

Any third-party service providers 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. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. 
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.

5. Transfers outside of Hong Kong SAR 

Where your personal data is transferred to, stored in, or accessed from jurisdiction outside of Hong Kong SAR, we shall take reasonable steps to 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 data is not always limited to one country. We may transfer your personal data, for the purposes listed above, to the Company, service providers or other third parties which may be located in countries outside of Hong Kong SAR. This may include transfers to group companies in the United States and other jurisdictions (who may collect some data directly from you, in relation to the Sites which they 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 and at all times in a manner consistent with legal requirements. 

6. 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. 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 data that we have under our control from: 

• Unauthorized access;
• Improper use or disclosure; 
• Unauthorized modification; and
• Unlawful destruction or accidental loss. 

7. How to access and amend your personal data

Upon request, we can confirm whether we hold personal data about you and will provide you with a readable copy of the personal data which we keep about you. We may require proof of your identity. We may charge a reasonable fee for complying with a data access request, as permitted by the PDPO.

In accordance with applicable laws and policies, you may request to have your personal data amended.

If you would like to make a data request, please contact our Compliance Officer at: 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 data.