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Privacy and Cookie Policy, Terms of use

The web site located at www.nuveen.com/global ("Web Site") and the mobile software applications ("Mobile Apps") developed, distributed or owned by Nuveen, LLC, or one of its U.S. subsidiaries or affiliates (collectively "Nuveen," "we," "our,", "us") are referred to herein collectively as the "Web Site/Mobile Apps." Please read these terms and conditions of use ("Terms") carefully before using the Web Site/Mobile Apps or any of the information or services provided by Nuveen in connection with the Web Site/Mobile Apps. By using the Web Site/Mobile Apps, you acknowledge that you have read and understood these Terms and accept and agree to be legally bound by them. If you do not accept and agree to these Terms, please do not use this website as you are not an authorized user of the Web Site/Mobile Apps or any of the information or services provided by Nuveen in connection with the Web Site/Mobile Apps and should promptly terminate all use thereof. The term Web Site includes any other web site owned, operated, licensed, or controlled by Nuveen. The term Mobile Apps includes any updates and supplements to the original Mobile App provided to you by Nuveen. The terms "you" and "your" mean you and any entity you may represent in connection with the use of the Web Site/Mobile Apps. These Terms are in addition to any other agreements between you and Nuveen, including any customer or account agreements, and any other agreements that govern your use of information, content, tools, products and services available on and through the Web Site/Mobile Apps. You may use your browser to download or print a copy of these Terms for your records.

These Terms were last updated on 10 December, 2018.

Nuveen reserves the right, in its sole discretion, to change, modify, add, or remove portions of these Terms at any time. We suggest that you check these Terms periodically for changes. The Terms can be accessed from a link at the bottom of the pages of the Web Site/Mobile Apps. Any changes, modifications, additions to, or deletions from these Terms shall be effective immediately upon posting on the Web Site/Mobile Apps. You acknowledge that, by using the Web Site/Mobile Apps after we post changes to these Terms, you accept and agree to be legally bound by these Terms as changed. Nuveen may also from time to time offer other services that are governed by different terms and conditions.

No Offer or Advice

The Web Site/Mobile Apps and their content are provided for informational and educational purposes only. Nothing on the Web Site/Mobile Apps constitutes a recommendation, solicitation or offer by Nuveen to sell or buy any security or investment product or service. The Web Site/Mobile Apps does not, and it is not intended to, provide any financial, investment, retirement planning, insurance, legal, accounting or tax advice. You are solely responsible for determining whether any investment, investment strategy, security or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. The Web Site/Mobile Apps should not be used or relied upon by you as a substitute for independent research or professional tax, financial or legal advice. You should seek such professional tax, financial or legal advice for your specific situation. You acknowledge that your requests for information in connection with the Web Site/Mobile Apps are unsolicited.

Before acquiring the shares of any investment fund by purchase or exchange, it is your responsibility to read the fund's prospectus or offering materials. For more information on any fund, contact your registered representative (financial advisor) or download a prospectus by clicking on the applicable link appearing throughout the Web Site/Mobile Apps. Prospectuses contain more complete information on advisory fees, distribution charges, and other expenses, and should be read carefully before investing or sending money. Past performance does not guarantee future results. Please remember that there is no assurance that the objective of any fund will be achieved. Please also note that investment return and principal value will fluctuate. All investments involve risks and may lose value. An investment in a fund or other investment product is not a bank deposit and is not insured or guaranteed by any government agency.

Jurisdiction

Unless otherwise specified, Nuveen controls, operates and services the Web Site/Mobile Apps from its offices within the United States. The services and products described and information provided through the Web Site/Mobile Apps are directed to and are intended to be made available only to persons outside of the United States and are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Nuveen or any of its investment products or services to any registration requirement within such jurisdiction or country. Persons who access the Web Site/Mobile Apps do so on their own initiative, and are responsible for compliance with applicable local laws and regulations.

Access to Web Site/Mobile Apps and Content

Nuveen reserves the right, in its sole discretion, to withdraw access to or modify any of the information, tools, content or services provided in connection with the Web Site/Mobile Apps (the "Content") at any time without providing notice to you. All Content is presented as of the date published or indicated, and may become inaccurate as a result of subsequent market events or for other reasons. Although Nuveen makes every attempt to provide accurate and timely Content, Nuveen does not guarantee or ensure the accuracy, completeness, currency or authenticity of any Content or functionality, or transmission of any Content from the Web Site/Mobile Apps to you. Furthermore, you are solely responsible for making sure that you are receiving up-to-date Content from the Web Site/Mobile Apps, including, but not limited to, by properly using the "Update Content" function on the Mobile Apps while you are connected to the internet or by appropriately setting cache settings on your web browser. Nuveen may withdraw access to or modify any of the investment products and services described on the Web Site/Mobile Apps at any time without providing notice to you.

Trademarks, Copyrights and other Intellectual Property

All Content is owned or licensed by Nuveen and its third-party information providers and is protected by applicable copyrights, trademarks, service marks and/or other intellectual property rights. All Content is solely for your personal, non-commercial use or that of your clients. Accordingly, you may not copy, reproduce, modify, sell, reuse, republish, post, frame, deep link, transmit, display, distribute or use for any commercial or unlawful purpose any Content, including, without limitation, any text, images, video, audio, code, user interface design or logos on the Web Site/Mobile Apps, without Nuveen's express prior written permission. If permitted by the Web Site/Mobile Apps, you may download Content for your personal use or that of your clients so long as you retain all copyright and other proprietary notices set forth in the Content. Please note that, notwithstanding the foregoing, if you have access to Content that is marked for use by financial advisors only, then you are not permitted to disclose such Content to your clients and your clients are not permitted to use such Content in any way. Any unauthorized use of Content violates the intellectual property rights of Nuveen and may violate copyright laws, trademark laws, the laws of privacy and publicity and communications regulations and statutes.

All trademarks, service marks, trade names, and logos ("Marks") displayed on the Web Site/Mobile Apps are proprietary to Nuveen and/or any respective third-party owners. Nothing contained on the Web Site/Mobile Apps should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Mark displayed on the Web Site/Mobile Apps without the express prior written permission of Nuveen or such other third-party owner. Your use of the Marks displayed on the Web Site/Mobile Apps, except as provided herein, is strictly prohibited.

Limited License and Mobile Apps Access; All Rights Reserved

Nuveen hereby grants you a limited, non-exclusive, non-transferable and revocable license to access and make personal use of the Mobile Apps. Nuveen owns all intellectual property and proprietary rights in and to the Mobile Apps. Your limited, non-exclusive, non-transferable and revocable license to use the Mobile Apps confers no title or ownership in or to the Mobile Apps or any portion of them and shall not be deemed or construed a sale or other conveyance of any right in the Mobile Apps or any portion of them other than the specific rights provided hereby. The Mobile Apps are licensed to you; they are not being sold. You may install, use, access, display, run or otherwise interact with one copy of each Mobile App, or any prior version for the same application, on a single computer, workstation, terminal, handheld PC, "tablet," "smart phone," or other digital electronic device. Your limited, non-exclusive, non-transferable and revocable license to use the Mobile Apps may be suspended or terminated by Nuveen at any time for any reason, without prior notice. Upon any prohibited use of the Mobile Apps by you, including, but not limited to, those described below, your limited, non-exclusive, non-transferable and revocable license to use the Mobile Apps shall be immediately and automatically terminated.

The Mobile Apps are protected by copyright laws, including international copyright treaties, as well as other intellectual property laws and treaties. We (and/or any third party that holds any rights in the Mobile Apps and/or any Content) retain all right, title, and interest in the Mobile Apps and the Content, including any and all intellectual property and proprietary rights therein. To the extent any third party holds any rights in the Mobile Apps and/or any Content, such third party may protect its rights in and to any such Mobile App or Content and may enforce its rights separately from any rights or enforcement of or by Nuveen. We (and/or any third party that holds any rights in the Mobile Apps and/or any Content) reserve all rights not expressly granted herein.

You may not download, export, or re-export the Mobile Apps or any part of them (a) into, or to a national or resident of, any country to which the United States has embargoed goods, or (b) to anyone on the United States Treasury Department's list of Specially Designated Nationals or the U.S. Commerce Department's Table of Deny Orders. By downloading or using the Mobile Apps, you are representing and warranting that you are not located in, under the control of, or a national or resident of any such country or on any such list. You further acknowledge and agree that any use by or for you of the Mobile Apps shall comply with all export control laws including without limitation the Export Administration Regulations ("EAR"), International Traffic in Arms Regulations ("ITAR"), and regulations and orders administered by the Treasury Department's Office of Foreign Assets Control.

Prohibited Uses

Any use or attempted use of the Web Site/Mobile Apps (i) for any unlawful, unauthorized, fraudulent or malicious purpose, or (ii) that could damage, disable, overburden, or impair any server, or the network(s) connected to any server, or (iii) that could interfere with any other party's use and enjoyment of the Web Site/Mobile Apps, or (iv) to gain unauthorized access to any other accounts, computer systems or networks connected to any server or systems through hacking, password mining or any other means, or (v) to access systems, data or information not intended by Nuveen to be made accessible to a user by hacking or any other means, or (vi) to obtain or attempt to obtain any materials or information through any means not intentionally made available by Nuveen, or (vii) for any use other than the purpose for which it was intended, is prohibited.

In addition, users and visitors of the Web Site/Mobile Apps may not, without Nuveen's express prior written permission:

copy, reproduce, republish, upload, post, transmit, or distribute in any way Content in any manner inconsistent with the purposes for which it is offered by Nuveen to its customers, prospective customers or members of the general public;
copy, modify, or display Nuveen's name or logo, or any text, graphic images, or other Content; redeliver any of the pages, text, images, or other Content using "framing" technology; use devices (including software) that are designed to provide repeated automated access to the Web Site/Mobile Apps other than those made generally available by Nuveen; deep link or employ software or any automatic device, technology or algorithm, to "crawl," "scrape," search or monitor the Web Site/Mobile Apps, provided that generally available third-party web browsers may be used without Nuveen's authorization; include "Nuveen" or any other Nuveen trademark, the name of any Nuveen personnel, or any variation of any of the foregoing, as a metatag, hidden textual element, or any other indicator that may create a false or misleading impression of affiliation, sponsorship, or endorsement between any user and/or site and Nuveen; collect or store personal data about other users of the Web Site/Mobile Apps; upload, email or otherwise transmit to the Web Site/Mobile Apps any material that contains viruses or any other computer code, files or programs that might interrupt, limit or interfere with the functionality of any computer software or hardware of file communications equipment that is owned, leased or used by Nuveen;
resell or provide commercial use of the Web Site/Mobile Apps or the Content, or create any derivative use of the Web Site/Mobile Apps or the content therein;
make use of any data mining, robots, or similar data gathering and extraction tools; or
reproduce, duplicate, copy, sell, resell, visit, or otherwise exploit for any commercial purpose the Web Site/Mobile Apps.

Nuveen reserves the right to take whatever lawful actions it may deem appropriate in response to actual or suspected violations of the foregoing, including, without limitation, the suspension or termination of the user's access and/or account. Nuveen may cooperate with legal authorities and/or third parties in the investigation of any suspected or alleged crime or civil wrong. Except as may be expressly limited by the Nuveen Privacy Policy as stated herein, Nuveen reserves the right at all times to disclose any information as Nuveen deems necessary to satisfy any applicable law, regulation, legal process or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, in Nuveen's sole discretion.

Links to Nuveen's Website from Other Websites

You shall not display hyperlinks on your websites to any website owned or operated by Nuveen, including the Web Site. If you desire to display on your website a hyperlink to the Web Site, you must enter into a written agreement with Nuveen governing such display. To submit a request to display hyperlinks on your websites to the Web Site, please contact us.

Transmissions to and From this Website

Electronic communications can be intercepted by third parties and, accordingly, transmissions to and from the Web Site/Mobile Apps may not be secure or confidential. Nuveen makes no representation whatsoever concerning the security or confidentiality of your electronic communications and specifically makes no representation that any electronic communications transmitted to the Web Site/Mobile Apps will be received by Nuveen. Communications to Nuveen, particularly those containing confidential information, may be sent by mail to: Nuveen, LLC, 333 West Wacker Dr., Chicago, IL 60606, Attn: Webmaster. Subject to our Privacy Policy as stated herein, any electronic communications you transmit to the Web Site/Mobile Apps, including, but not limited to, data, questions, comments or suggestions, will be treated by Nuveen as nonconfidential and nonproprietary. Any such communications, including any ideas, concepts, know-how, or techniques contained therein, may be used by Nuveen for any purpose whatsoever, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. You hereby waive all rights to any claim against Nuveen for any alleged or actual infringements of any proprietary rights, rights of privacy and publicity, moral rights and rights of attribution in connection with electronic communications you transmit to the Web Site/Mobile Apps.

Email and Marketing

Financial advisors who complete the registration process to access information on the Web Site/Mobile Apps that is restricted to financial advisors are at the same time granting Nuveen permission to send them e-mail messages for marketing and general communication purposes at the e-mail address they have provided. This service may be discontinued at any time by responding to the email with "Unsubscribe" in the subject line or by using the Contact Us feature on the Web Site/Mobile Apps to notify us of your desire not to receive such communications.

Copyright Agent

Nuveen respects the intellectual property rights of others, and we ask all those that access the Web Site/Mobile Apps to do the same. Pursuant to Section 512(c)(2) of the Copyright Revision Act, as enacted through the Digital Millennium Copyright Act, Nuveen designates an agent, as described below, to receive notifications of claimed infringement. If you reasonably believe that your work has been copied in a way that constitutes copyright infringement, please provide Nuveen's Copyright Agent the following information:


Nuveen's Legal Department is its Copyright Agent for notice of claims of copyright infringement on its site. Nuveen's Legal Department address is: Nuveen Legal Department – Copyright, 333 W. Wacker Dr., Chicago, IL 60606.

Connection Requirements; Passwords and Security

To ensure a high level of confidentiality and security, Nuveen maintains physical, electronic and procedural safeguards that meet or exceed federal standards. However, you are responsible for providing and maintaining, at your own risk, option and expense, any hardware, software and communication lines required to access and use the Web Site/Mobile Apps, and Nuveen reserves the right to change the access configuration of the Web Site/Mobile Apps at any time without prior notice. The Mobile Apps should be accessible on currently supported iPad® devices. iPad® is a registered trademark of Apple Inc. Please note that wireless networks and Wi-Fi network speeds vary by provider and geographic location. We are not responsible for limitations of such services used to access the Web Site/Mobile Apps.

The Mobile Apps will provide you with general information about Nuveen and its products and services. To access detailed information about certain Nuveen accounts you may be enrolled or subscribe to, an internet link within the Mobile App will direct you to the appropriate login page of the Web Site. From there, you must provide your login credentials to access available account information. To access password-protected content on the Web Site, you must complete the registration process by providing us with current, complete and accurate information as prompted by the applicable registration form, and choose a password and user name. You are entirely responsible for maintaining the confidentiality of your login credentials and for any and all activities that occur while logged in or accessing personal account information through the third-party links provided on the Web Site. You will be logged out of certain secure portions of the Web Site after a period of inactivity, at which time you will be required to re-enter your credentials to access secure information. You agree to (a) immediately notify Nuveen of any unauthorized use of your account or any other breach of security of which you become aware, and (b) exit completely from your account at the end of each online session. NUVEEN WILL NOT BE LIABLE FOR ANY LOSS THAT YOU MAY INCUR AS A RESULT OF SOMEONE ELSE USING YOUR PASSWORD OR ACCOUNT, EITHER WITH OR WITHOUT YOUR KNOWLEDGE. HOWEVER, YOU COULD BE HELD LIABLE FOR LOSSES INCURRED BY NUVEEN OR ANOTHER PARTY DUE TO SOMEONE ELSE USING YOUR ACCOUNT OR PASSWORD. YOU MAY NOT USE ANYONE ELSE'S ACCOUNT AT ANY TIME.

Privacy

Nuveen considers your privacy our utmost concern. In order to provide you with individualized service, we collect certain nonpublic personal information about you from information you provide on applications or other forms (such as your address and social security number), and information about your account transactions with us (such as purchases, sales and account balances). We may also collect such information through your account inquiries by mail, email, telephone, or web site.

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Specifically, so that we may continue to offer you Nuveen products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, or printers and mailers that assist us in the distribution of investor materials. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.

If you decide at some point either to close your account(s) or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

Nuveen will gather personal information when you complete the Web Site registration form, subscribe to weekly commentary or other marketing collateral or order literature from the Web Site. We also collect general tracking information through our Web Site/Mobile Apps, such as which pages are viewed at which times, automatically through our web server software. The tracking information is used to give us a summary view of how our Web Site/Mobile Apps are used. Currently, we track IP addresses and Mobile App installation IDs of our users on the Web Site and within the Mobile Apps in order to provide us with information that will improve our services and help us analyze the data to determine customer interest.

We may conduct surveys regarding our products and services, including the operation of our Web Site/Mobile Apps. The information you provide is used only on an aggregated basis and is analyzed only to help improve our products and services and for company management and planning purposes. You will not receive communications as a result of your participation in one of our surveys if you notify us not to contact you.

Our Use of Cookies and Other Automatic Data Collection Tools

As you navigate through and interact with the Web Site/Mobile Apps, we may automatically collect certain information through cookies, web beacons and other tracking technologies, including information about your equipment and usage. This information may include details of your visit to the Web Site/Mobile Apps, including traffic data, location data, logs and other communication data and the resources that you access and use on the Web Site/Mobile Apps, the websites that you access immediately before and after your visit to the Web Site/Mobile Apps, and information about your computer or other device and internet connection, including but not limited to your IP address, operating system and browser type. We do not collect personal information automatically, but we may tie information that we do collect automatically to personal information about you that we collect from other sources or that you provide to us.

The technologies we use for automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or use the Web Site/Mobile Apps. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Please note that if you refuse to accept browser cookies, your access to or use of certain portions of the Web Site/Mobile Apps may be limited.

Flash Cookies. Certain features of the Web Site/Mobile Apps may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Web Site/Mobile Apps. Flash cookies are not managed by the same browser settings used for browser cookies. Please note that your access to or use of certain portions of the Web Site/Mobile Apps may be limited as a result of any change to such settings.

Web Beacons. Pages of the Web Site/Mobile Apps may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use the information we collect automatically to operate and improve the Web Site/Mobile Apps. For example, such information enables us to estimate our audience size and usage patterns, customize the Web Site/Mobile Apps according to your individual preferences and recognize you when you return to the Web Site/Mobile Apps. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose the presence of a cookie to third parties in order to advertise our services. For example, we may ask advertisers to display ads promoting our services on other websites based on the presence of a cookie. We may also contract with third-party advertising networks that use cookies, web beacons or other tracking technologies to collect certain non-personal information about your activities on the Web Site/Mobile Apps and on third-party websites to provide you with targeted advertising based upon your interests. We may also use cookies delivered by third parties to track the performance of our advertisements.

Anti-Money Laundering

The USA PATRIOT Act, signed by President Bush, is designed to detect, deter, and punish terrorists in the United States and abroad. The Act imposes new anti-money laundering requirements on all financial institutions – from check-cashing and currency exchange stores to the largest banks, brokerage firms and mutual fund companies – including Nuveen (and its affiliated investment advisers and funds).

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person or company that opens an account. When you open an account, you will be required to provide your name, address, date of birth, and other information that will allow us to identify you and any other persons listed on your account that have trading authority.

For questions about our policy, or for additional copies of this notice, please contact Nuveen, LLC at 333 W. Wacker Drive, Chicago, IL 60606, or (800) 257-8787.

Contents of the Web Site/Mobile Apps — DISCLAIMER

THE MATERIALS IN AND ON THE WEB SITE/MOBILE APPS (INCLUDING ANY GRAPHICS) AND ANY MATERIALS MADE AVAILABLE THROUGH THE WEB SITE/MOBILE APPS ARE SUBJECT TO APPLICABLE STATUTES AND REGULATIONS, AND ARE PROVIDED "AS IS" AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, NUVEEN DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, WITH RESPECT TO ANY MATTER WHATSOEVER RELATING TO OR REFERENCED BY THE WEB SITE/MOBILE APPS, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTY OF NON-INFRINGEMENT OF THIRD-PARTY RIGHTS AND ANY IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. NUVEEN DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE CONTENT IN TERMS OF ITS CORRECTNESS, ACCURACY, RELIABILITY, OR OTHERWISE. THE CONTENT COULD INCLUDE TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS. THE CONTENT COULD BECOME INACCURATE AS A RESULT OF DEVELOPMENTS OCCURRING AFTER ITS RESPECTIVE DATE. NUVEEN UNDERTAKES NO OBLIGATION TO MAINTAIN THE CURRENCY OF SUCH INFORMATION.

NUVEEN MAY ESTABLISH HYPERTEXT LINKS BETWEEN THE WEB SITE/MOBILE APPS AND ONE OR MORE WEBSITES OPERATED BY UNAFFILIATED THIRD PARTIES. NUVEEN HAS NO CONTROL OVER ANY SUCH LINKED WEBSITES AND IS NOT RESPONSIBLE FOR THE CONTENTS THEREOF OR THE PRODUCTS AND SERVICES DESCRIBED THEREIN. NUVEEN IS NOT RESPONSIBLE FOR WEBCASTING OR ANY OTHER FORM OF TRANSMISSION RECEIVED FROM ANY LINKED SITE. NUVEEN PROVIDES THESE LINKS TO YOU ONLY AS A CONVENIENCE. THE EXISTENCE OF ANY SUCH LINKS SHALL NOT CONSTITUTE AN ENDORSEMENT OF, OR REPRESENTATION OR WARRANTY BY NUVEEN REGARDING, SUCH LINKED WEBSITES, THE CONTENTS THEREOF, THE PRODUCTS AND SERVICES DESCRIBED THEREIN OR THE OPERATORS THEREOF. NUVEEN SHALL HAVE NO LIABILITY FOR ANY LOSS OR DAMAGE INCURRED BY YOU IN CONNECTION WITH YOUR ACCESS TO OR USE OF SUCH LINKED WEBSITES, INCLUDING, WITHOUT LIMITATION, ANY SUCH LOSS OR DAMAGE RESULTING FROM ANY HARMFUL COMPONENTS OF OR INACCURACIES IN THE CONTENT OF SUCH LINKED WEBSITES. YOUR ACCESS TO AND USE OF SUCH LINKED WEBSITES IS GOVERNED BY THE TERMS AND CONDITIONS OF USE AND PRIVACY POLICIES APPLICABLE TO SUCH LINKED WEBSITES, AND SHALL BE AT YOUR OWN RISK. NUVEEN DISCLAIMS ALL RESPONSIBILITY FOR THE PRIVACY POLICIES AND CUSTOMER INFORMATION PRACTICES OF SUCH LINKED WEBSITES.

Operation of the Web Site/Mobile Apps — DISCLAIMER

NUVEEN ENDEAVORS TO MAINTAIN THE WEB SITE/MOBILE APPS AND THEIR OPERATION, BUT IS NOT, AND CANNOT BE, RESPONSIBLE FOR THE RESULTS OF ANY DEFECTS THAT MAY EXIST IN THE WEB SITE/MOBILE APPS OR ITS OPERATION. AS TO THE OPERATION OF THE WEB SITE/MOBILE APPS, NUVEEN EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. NUVEEN MAKES NO WARRANTY THAT (I) THE OPERATION OF THE WEB SITE/MOBILE APPS WILL MEET THE USER'S REQUIREMENTS; (II) ACCESS TO THE WEB SITE/MOBILE APPS WILL BE UNINTERRUPTED, TIMELY, SECURE, FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR FREE OF ERRORS; (III) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE WEB SITE/MOBILE APPS WILL BE ACCURATE OR RELIABLE; OR (IV) DEFECTS WILL BE CORRECTED. YOU ASSUME THE ENTIRE COST OF ALL SERVICING, REPAIR, OR CORRECTION THAT MAY BE NECESSARY FOR YOUR COMPUTER EQUIPMENT AND SOFTWARE AS A RESULT OF ANY VIRUSES, ERRORS OR OTHER PROBLEMS YOU MAY HAVE AS A RESULT OF USING OR VISITING THE WEB SITE/MOBILE APPS.

Limitation of Liability

UNDER NO CIRCUMSTANCES WILL NUVEEN OR ITS DIRECTORS, OFFICERS, EMPLOYEES OR AGENTS BE LIABLE TO YOU FOR ANY LOSSES OR DAMAGES ARISING FROM YOUR USE OR ATTEMPTED USE OF, OR INABILITY TO USE, THE WEB SITE/MOBILE APPS OR THE CONTENT, INCLUDING, BUT NOT LIMITED TO, ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL, OR INCIDENTAL DAMAGES (INCLUDING, BUT NOT LIMITED TO, LOST PROFITS OR TRADING LOSSES), EVEN IF SUCH DAMAGES ARE REASONABLY FORESEEABLE OR NUVEEN OR ANY OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH LOSSES OR DAMAGES. FOR THE AVOIDANCE OF DOUBT, NUVEEN AND ITS DIRECTORS, OFFICERS, EMPLOYEES AND AGENTS SHALL NOT BE LIABLE OR HAVE ANY RESPONSIBILITY OF ANY KIND FOR ANY LOSS OR DAMAGE THAT YOU INCUR ARISING FROM OR IN CONNECTION WITH:

ANY ERROR OR OMISSION IN THE WEB SITE/MOBILE APPS OR THE CONTENT AND FOR THE USE OR INTERPRETATION THEREOF BY OTHERS;
ANY DELAY, TERMINATION, FAILURE, DEFECT, OR INTERRUPTION IN THE TRANSMISSION OF THE WEB SITE/MOBILE APPS OR ANY CONTENT;
ANY TERMINATION OR INTERRUPTION OF YOUR ACCESS TO THE WEB SITE/MOBILE APPS OR ANY CONTENT;
YOUR RELIANCE ON OR USE OF THE WEB SITE/MOBILE APPS OR ANY CONTENT;
ANY ELECTRONIC REQUESTS, ORDERS, OR INSTRUCTIONS YOU SEND, OR THE INTERCEPTION BY THIRD PARTIES OF ANY ELECTRONIC REQUESTS, ORDERS, OR INSTRUCTIONS YOU SEND;
ANY HARM CAUSED BY THE TRANSMISSION, THROUGH ACCESS OF THE WEB SITE/MOBILE APPS, OF A COMPUTER VIRUS, OR OTHER COMPUTER CODE OR PROGRAMMING DEVICE THAT MIGHT BE USED TO ACCESS, DELETE, DAMAGE, DISABLE, DISRUPT OR OTHERWISE IMPEDE THE OPERATION OF THE WEB SITE/MOBILE APPS OR OF YOUR SOFTWARE, HARDWARE, DATA OR OTHER PROPERTY;
ANY ACT OR OMISSION OF NUVEEN IN MAKING THE WEB SITE/MOBILE APPS OR ANY CONTENT AVAILABLE TO YOU; ORANY OTHER CAUSE RELATING TO YOUR ACCESS TO, INABILITY TO ACCESS, OR USE OF THE WEB SITE/MOBILE APPS OR ANY OF THE CONTENT, WHETHER OR NOT THE CIRCUMSTANCES GIVING RISE TO SUCH CAUSE MAY HAVE BEEN WITHIN THE CONTROL OF NUVEEN OR WITHIN THE CONTROL OF ANY OTHER PARTY PROVIDING SOFTWARE OR SERVICES SUPPORT FOR THE WEB SITE/MOBILE APPS.

Limitations

APPLICABLE LAW MAY NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU. HOWEVER, IN NO EVENT SHALL NUVEEN'S TOTAL LIABILITY TO YOU FOR DAMAGES, LOSSES, AND CAUSES OF ACTION (WHETHER IN CONTRACT, TORT (INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE), OR OTHERWISE) EXCEED THE GREATER OF THE AMOUNT PAID BY YOU FOR ACCESSING THE WEB SITE/MOBILE APPS AND $50.00 USD.

Indemnification

As a condition of, and in exchange for, using the Web Site/Mobile Apps, you agree to defend, indemnify and hold Nuveen and its directors, officers, employees, affiliates and agents harmless from and against any and all claims, actions, losses, liabilities, damages, costs and expenses (including but not limited to reasonable attorneys' fees) that may, at any time, arise out of or relate to your authorized, unauthorized, lawful or unlawful use of the Web Site/Mobile Apps and/or the Content, your breach of the Terms, as may be modified from time to time in Nuveen's sole discretion, your inability to access the Web Site/Mobile Apps and/or any Content, the use of any linked web sites, your reliance on any errors or omissions in the Web Site/Mobile Apps and/or the Content, or the propagation and/or contraction of any computer virus in connection with your use of the Web Site/Mobile Apps and/or the Content.

Notices

Any notices to you from Nuveen regarding the Web Site/Mobile Apps or these Terms will be posted on the Web Site/Mobile Apps or made by e-mail or regular mail. When you visit the Web Site/Mobile Apps or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on the Web Site/Mobile Apps. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. You further agree that any notices provided by us electronically are deemed to be given and received on the date we transmit any such electronic communication as described in these Terms.

Governing Law

These Terms shall be governed and construed under the laws of the State of New York without regard to its conflict of law principles, regardless of whether you reside in New York or transact business with Nuveen in New York or elsewhere. If you take legal action relating to these Terms or your use of the Web Site/Mobile Apps or the Content, you agree to file such action only in the New York State Supreme Court located in New York, NY, or the United States District Court for the Southern District of New York, and you consent and submit to the personal jurisdiction of those courts for the purpose of litigating any action relating to these Terms or your use of the Web Site/Mobile Apps or the Content.

Waiver

No waiver by Nuveen of any right under or term or provision of these Terms will be deemed a waiver of any other right, term, or provision of these Terms at that time or a waiver of that or any other right, term, or provision of these Terms at any other time.

Severability

Whenever possible, each provision of these Terms will be interpreted in such manner as to be effective and valid under applicable law, but if any provision of these Terms is held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability will not affect any other provision of these Terms in any manner or the effectiveness, validity and enforceability of such provision in any other jurisdiction.

Entire Agreement

These Terms represent the entire agreement between you and Nuveen relating to the subject matter hereof.

No Partnership or Agency

Neither these Terms, nor any content, materials or features of the Web Site/Mobile Apps create any partnership, joint venture, employment, or other agency relationship between us. You may not enter into any contract on our behalf or bind us in any way.

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.
This privacy notice applies to all websites operated by us (as indicated on the relevant website) ("Sites"). For the purpose of this privacy notice "company" shall mean any company which forms part of the Nuveen group. By accessing and using the Sites you are agreeing to the terms of this privacy notice.

Information about us

Our principal business activities:


Name of the Data Controller

The 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 thirteen years of age and no child under thirteen 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: 


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. See also "Consents and opt-outs" section below.
 

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 use the following cookies:


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).

How can I block 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 two years.

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. Consents and opt-outs

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for us to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by emailing dataprivacy@nuveenglobal.com

For turning cookies off, see the information in paragraph 3 above.
 

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 the EEA

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 the European Economic Area, whose laws may not give the level of protection to personal data as within the UK. 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 
 

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:


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

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: 


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.
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:

If you would like to make a data request please use this web form. 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.   Issue 1 April 2018

Special Notice for persons in the UK

UK Stewardship Code

Nuveen is an institutional asset management firm that advises on and manages physical properties on behalf of our clients and does not manage any listed equities, therefore the Financial Reporting Council’s Stewardship Code which relates to equity holdings in UK listed companies is not relevant.


 

Viruses

We do not guarantee that this website will be secure or free from Viruses. You are responsible for using your own virus protection software.

We will not be liable for any loss or damage caused by a Virus due to your use of this website or to your downloading of any content on it, or on any website linked to it.

You must not misuse or attack this website by knowingly introducing Viruses or attempt to gain unauthorised access to this website, the server on which this website is stored or any server or computer connected to this website. By breaching this provision, you may commit a criminal offence under the Computer Misuse Act 1990. Any such breach may be reported to the relevant law enforcement authorities and we may co-operate with those authorities by disclosing your identity to them. 

"Viruses" means any viruses, Trojan horses, worms or any other computer code which is designed to infect computer hardware, software or any data