Privacy notice for individuals residing in California

Effective Date: October 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”) does not apply to Schroders plc or its affiliates (“Schroders”), which maintain their own separate privacy notices governing their websites and other touchpoints. Links to Schroders' privacy notices are provided at the end of this privacy notice for your convenience.

This Notice contains information about how the Company collects, uses, and shares Personal Information, as defined by the California Consumer Privacy Act of 2018, as amended (“CCPA”).

1. Purpose and content

1.1 This Notice applies to all websites operated by us, as indicated on the relevant website ("Sites"). This Notice is for California residents only pursuant to the CCPA.

1.2 The CCPA defines Personal Information broadly to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

1.3 Please note that much of the Personal Information we collect about California residents is not covered by this Notice. The CCPA includes certain exemptions that may apply to our use or collection of your Personal Information and it is possible that not all Personal Information that we collect from you or about you is covered by the CCPA or this CCPA Privacy Notice. For example:
 

• Personal Information that is collected, processed or sold pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations is not covered by this Notice. If you seek to or have obtained a financial product or service from us, please read Nuveen’s Privacy Statement (https://www.nuveen.com/privacy), which explains the types of nonpublic personal information we collect from you and how we share it, consistent with federal privacy laws applicable to financial institutions, including the GLBA. This CCPA Privacy Notice and the rights granted hereunder do not apply to the information we collect from or about you pursuant to Nuveen’s Privacy Notice.

2. Categories of Personal Information that we may collect, use, and share

2.1 We may collect, use, or share Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or a member of your household. The categories of Personal Information we may collect, use, or share include, but are not limited to:
 

• Identifiers (e.g., name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
• Categories of Personal Information in California Civil Code Section 1798.80
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement);
• Geolocation data;
• Professional or employment-related information (e.g., job application or resume information, past and current job history, and job performance information);
• Inferences drawn from Personal Information (e.g., consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

3. Sources from which we may collect your Personal Information

3.1 We may obtain your Personal Information:
 

• Directly from you when you contact us via the internet, in person, or subscribe to a company mailing list;
• From third parties such as data aggregators, social media, or companies with which we have business relationships;
• Using online tracking technologies (including cookies, email tracking, and similar technologies), which may be used, among other things, to provide you with advertisements tailored to your interests (also known as targeted or behavioral advertising);

4. How we use your Personal Information

4.1 We use your Personal Information for our business and commercial purposes, including:
 

• To present our Sites and their contents to you;
• To deliver the information, products or services you requested from us;
• To reach out to you about and market our products and services to you;
• To communicate with you;
• To help us improve our Sites and deliver a more personalized experience;
• To deliver interest-based, targeted or behavioral advertising to you;
• To carry out our obligations and enforce our rights;
• In any other way we describe when you provide the information, or otherwise at your direction or with your consent;
• As permitted by law or as we may notify you.

5. How we disclose your Personal Information

5.1 We do not currently sell your Personal Information and have not done so in the past twelve months.

5.2 We may “share” your Personal Information, as such term is defined in the CCPA, for purposes of cross-context behavioral advertising (also referred to as interest-based or targeted advertising).  In the past twelve months, we have ”shared” the following categories of Personal Information with third parties for purposes of cross-context behavioral advertising:
 

• Identifiers;
• Categories of personal information described in Cal. Civ. Code 1798.80(e);
• Internet or other electronic network activity information;
• Geolocation data;
• Inferences drawn from Personal Information.

5.2 We disclose  your Personal Information for business purposes and in the last twelve months we have disclosed the categories of Personal Information listed in Section 2 for a business purpose. For example, we disclose  Personal Information with our affiliates, with entities that provide marketing services to us, and with our business partners, service providers and vendors. We may disclose your Personal Information to third parties and endeavor to ensure that they use it only for those services requested and keep it confidential; however, depending on the nature of the services provider by those third-parties they may, at times, have independent rights to your data.

5.3 We may disclose any of the Personal Information described in this CCPA Notice with third parties as part of or in connection with a sale, merger, consolidation, change of control, transfer of assets or reorganization of all or part of our business.

5.4 We may additionally disclose Personal Information 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, or as otherwise required by law.

5.5 We do not have actual knowledge that we sell or share the personal information of minors under the age of 16.

6. Your rights under the CCPA

6.1 As a California resident, you have the right to know how we have collected, used, and disclosed your Personal Information in the last twelve months. Specifically, you have the right to request to know:
 

• The categories and specific pieces of your Personal Information we have collected about you in the twelve months prior to your request, the categories of sources from which we have collected it, the business or commercial purpose for its collection and the categories of third parties to whom we have disclosed it;
• The categories of your Personal Information we disclose for a business purpose, the categories of the third parties to whom it is disclosed, and the purpose for such disclosures;
• The categories of your Personal Information sold and the categories of third parties to whom it was sold; and
• The categories of your Personal Information “shared” for purposes of cross-context behavioral advertising and the categories of third parties with whom it was “shared” for such purposes.

6.2 In addition, you have the right to request that we delete your Personal Information.

6.3 You have the right to request that we correct any inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

6.4 If we were to sell your Personal Information, you would have the right to request to opt-out of sales of your Personal Information.

6.5 You have the right to request to opt-out of our “sharing” your Personal Information for purposes of cross-context behavioral advertising.

6.6 You have the right to limit the use or disclosure of your sensitive Personal Information; however we do not use or disclose your sensitive Personal Information in a way that gives rise to this right.

6.7 You have a right to not be discriminated against for exercising these rights.

7. Verification of requests to know or delete your Personal Information

7.1 When you make a request that (i) we disclose to you the categories and/or specific pieces of Personal Information that we have collected about you, (ii) we delete your Personal Information; or (iii) we correct inaccurate Personal Information about you, we will first take steps to verify your identity.

7.2We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the authorized agent acting on your behalf that is reasonable in light of the nature of the personal information requested. We may need additional information from you to verify your request.

7.3 In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know if we need more information from you to verify your request. Please reply to our requests promptly.

7.4 If we cannot verify your request, we will let you know. Please note, we may decline your request if we are unable to verify your identity

7.5 Please note that with respect to requests to delete your Personal Information, once we have verified your identity, we will delete your Personal Information from our records unless an exception to your deletion request applies. We may deny your request to delete Personal Information in whole or in part if, for example, retaining the information is necessary for us or our service providers to:
 

• Complete a transaction for which the Personal Information was collected, provide a good or service requested by you, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract(s) with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

8. Submitting requests

8.1 To submit a request to know, a request to delete, or a request to correct inaccurate Personal Information we have about you, as described above, please call 866.887.1975 or email privacyoffice@nuveen.com.

8.2 To make a request to opt-out of the “sharing” of your Personal Information for purposes of cross-context behavioral advertising, please visit 
Do Not Sell or Share My Personal Information and opt-out of all cookies and tracking technologies other than those that are strictly necessary.

9. Information for Authorized Agents

In certain circumstances, you can authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights and submit requests on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. Any Authorized Agent can make a request on your behalf by:

To submit a request as an Authorized Agent, please call 866.887.1975 or email privacyoffice@nuveen.com.

10. Responding To Your Requests

We aim to promptly verify and respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccuracies in your personal information within 45 days of receipt, but may require a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so if your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

11. Do Not Track and Global Privacy Control (“GPC”) Signals

We rely on a third-party service provider to implement a tool in an effort to recognize and honor “do not track” and Global Privacy Control signals as requests to opt-out of “sharing” your personal information for cross-context behavioral advertising purposes (as such term is defined in the CCPA).

12. Changes to this notice

We will occasionally update this Notice to reflect new legislation or industry practice and Company changes. We encourage you to review this Notice periodically to be informed of how we collect, use and disclose your Personal Information.

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-us/us/intermediary/footer/privacy-policy/