Aegon Asset Management

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https://www.aegonam.com/

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IMPORTANT DISCLOSURE: FOR NON-US PROFESSIONAL INVESTORS ONLY

This site is intended only for non-US professional investors or US-based fiduciaries representing non-US investors eligible to invest in Aegon Asset Management’s (the “Company”) UCITS funds. This site, and the funds described herein, are not suitable for individual investors.

The following information regarding the Company’s funds is for informational purposes only and does not constitute an offer for shares, products or services and should not be interpreted as an offer to sell, an invitation to acquire an investment, or a solicitation of an offer to buy for any persons who are prohibited from receiving such information under their domiciled local laws.

Aegon Asset Management Investment Company (Ireland) Plc is structured as an umbrella type open-ended investment company with variable capital consisting of a number of different sub-funds (“Funds”) and is authorized in Ireland pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) UCITS Regulations and the Central Bank UCITS Regulations (“UCITS Regulations"). Aegon Asset Management Europe ICAV is structured as an umbrella type open-ended investment ICAV with variable capital consisting of Funds and is authorized in Ireland as a UCITS pursuant to the UCITS Regulations.

These Funds are registered in Ireland and are available only to residents of those jurisdictions where allowed by law. Investors that do not meet these requirements will be denied access by the Company.

By checking the box, you have read and understand the important legal information above that pertains to Aegon Asset Management's UCITS funds and agree to these terms and conditions.

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This privacy statement applies to the processing by Aegon USA Investment Management, LLC and Aegon USA Realty Advisors, LLC (collectively, “we” or “the Companies”) of personal data of its clients, customers and potential customers, suppliers/vendors, and business partners as well as visitors of our websites.

Protecting your personal data

Our aim is to be transparent about how we deal with personal data. This privacy statement details how the Companies, and other entities in Aegon Asset Management, appointed suppliers and the Aegon group of companies process your personal data.

More information on these processing activities can be found below.

Controller for the processing of your personal data

The Companies are the controller or co-controller of all personal data that fall within the scope of this privacy statement. The Companies, which have their registered office in Cedar Rapids, IA, USA, are part of Aegon Asset Management, the asset management arm of the Aegon group, a global life insurance, pensions and asset management company.

Contact us

If you have any questions about this privacy statement or the information we collect about you, please contact Client Services or our Data Protection Office.

Aegon USA Investment Management, LLC [or] Aegon USA Realty Advisors, LLC

Attn. US Data Protection Officer

6300 C Street SW

Cedar Rapids, IA 52499

Email Data Protection Office

You may contact the Data Privacy Officer directly using this email address.

More information on your rights as a data subject are contained below under ‘Your Rights’.

Purposes for processing personal data

The most common activities we conduct which involve collecting and processing of personal data include:

Conducting checks and assessments prior to doing business
The administration of the service we have agreed to provide.
Servicing our customers and prospective customers.
To develop our products and services
Managing third party and supplier relationships.
Internal management reporting and support functions
Managing relationships with governments and supervisory authorities
Marketing to our customers and prospects
Cookies

More information on these processing activities is contained below.

How and what personal data we obtain about you

You or someone representing you, for example a financial advisor, consultant, an employer or the business you work for, may give us information about you by completing forms (paper versions or through a website), concluding contractual arrangements or by contacting us by phone, post, email or otherwise. We may also receive your personal information from a third party where they have obtained your consent or have another valid legal basis to share such information. Alternatively, you may have provided the information to us directly.

For the processing activities described below, the personal data that is gathered and processed may include:

Full name
Title
Job role/description
Address including zip code
Phone number
E-mail address (personal and/or business)
Website username and password
IP Address
Date of birth
Gender
Driver’s License number
Passport number
Aegon account number or other Aegon identifier, whether for internal or external use
Bank account
Taxpayer identification number
Cookie information collected when you visit one of our websites. Further information is available in our website Cookie Statement and SEISMIC Cookie and Tracking Statement.

Where sensitive personal data is collected and processed as part of any of the activities below, this will be stated in the relevant processing descriptions.

Sensitive personal data processed may include the following:

Copy of identification document (i.e. passport or ID card)
Social security number

When collecting and processing personal data, the Companies strive to process the minimum amount of personal data relevant to the specific purpose it is collected for and to only use the data for the original purpose for which it was collected (stated below) or a further purpose which you have consented to or that is compatible with the original purpose for which it was collected and that is likely to be in line with your expectations regarding the processing of that data.

If certain elements of personal data are not provided, then we may not be able to conduct all relevant processing required (including meeting regulatory requirements) and as such not be able to provide the full range of products and services.

Common purposes for processing

Conducting checks and assessments prior to doing business.

This includes anti-money laundering, sanctions and politically exposed persons (‘PEP’) reviews. This processing is conducted to detect and prevent financial crime. and help us meet our legal and regulatory obligations. We conduct these reviews with the assistance of a third-party system provided by FinScan which compares personal data against various official sanctions and PEP lists. For lending activities, your personal data may also be checked with a credit rating company as part of the loan approval process. The results of these reviews will be considered by a member of our staff in determining whether to conduct business with or provide a service to a person or company.

This processing may include collecting (sensitive) personal data including copies of identification documents, and providing or disclosing such data to other entities within Aegon Asset Management, the Aegon group of companies and appointed suppliers. Personal data may also be provided or disclosed to supervisory/regulatory or other governmental authorities in certain circumstances.

The administration of the service we have agreed to provide.

This includes processing your instructions and account transactions, settling those transactions, assessing investments and markets, managing investment portfolios, monitoring investment portfolios and managing risks associated with an account or product, including areas of regulatory compliance. This processing is imperative to us providing the requested service and executing the agreement between us.

Servicing our customers and prospective customers.

This includes managing existing and prospective customer relationships, handling queries and complaints, managing any incidents/issues encountered, providing account reporting, detecting fraud and providing online services including our websites. This processing is required for us to provide the service agreed under our agreement and ensure the integrity of any account you have with us. Customer relationships may be maintained by phone, mail, e-mail, personal contact and fax where appropriate (see the section below titled 'Being in contact with us').

To develop our products and services.

This includes reviewing our existing offering of products and services, making required improvements and launching new products/services. Personal data may also be processed when we develop our appropriate business strategies internally. Where these processes include personal information they are conducted in the legitimate interest of the Companies to ensure we provide the best products and services for our customers. We are committed to ensuring that the impact to the data subjects involved is minimal, the approach adopted is reasonable and that the least intrusive approach is followed. The data may be provided or disclosed to other entities within the Aegon group of companies. More information can be found in the section titled 'Disclosing your personal data’.

Managing third party and supplier relationships.

Personal data may be processed to assess and obtain services provided by a third party company, to manage the relationship between the companies (including where they act as our data processor) and reporting and performance analysis on these relationships. These processes may also require providing or disclosing personal data to other entities within the Aegon group of companies as well as consulting publicly available records. These processes are conducted to ensure appropriate execution of the agreement between the parties and between us and our clients, as well as being in the legitimate interests of the Companies to be able to utilise third party services when providing its products and services to clients in the best way possible.

Where appropriate, these processes may include the use of any sensitive data provided on copies of identification documents.

More information can be found in the section titled 'Disclosing your personal data’

Internal management reporting and support functions.

This includes the provision of legal and regulatory support and advice (both internal and external), internal auditing, strategy development and providing and maintaining IT solutions. Also includes processing required to effectively manage data including scanning, classification and labelling. Most of these processes are conducted to execute activities vital to the internal management of our business and are imperative to the performance of our agreements with clients, customers and suppliers, however some will be conducted in order to meet our legitimate interests as a company. Where this is the case we are committed to ensuring that the impact to the data subjects involved is minimal, the approach adopted is reasonable and that the least intrusive approach is followed. Other processing may be conducted to fulfil a legal or regulatory obligation. Personal data may be provided or disclosed to other entities within the Aegon group of companies, including Aegon Global Technology Services who act as a data processor of personal data handled or processed when providing IT and technology solutions. Personal data may also be provided or disclosed to third parties including external law firms, accountants, technology providers and auditors.

More information can be found in the section titled 'Disclosing your personal data’

Managing relationships with governments and supervisory authorities.

This includes responding to requests and providing regular and ad hoc reporting. These processes are conducted to fulfil a legal and regulatory obligation of the company. Where personal data, including sensitive personal data, needs to be processed in order to fulfil these obligations it will be in line with this privacy statement including when processing involves third parties and entities within Aegon Asset Management, appointed suppliers and the Aegon group of companies.

More information can be found in the section titled 'Disclosing your personal data’.

Marketing to our customers and prospects

This will include the execution and analysis of marketing campaigns, surveys and strategies, promoting products and services provided by the Companies and affiliated Aegon Asset Management companies, running and contributing to promotional events and the use of ad hoc competitions and promotions.

We may use the personal data we have to send you marketing information and news about our products and services that may be of interest to you, unless you have opted out of marketing.

We may conduct marketing with our customers (including business partners) based on our legitimate interest to share product and service information with them for them to take it into account when providing a related service. When doing this we will ensure that the least intrusive method is used and that we feel the recipient would reasonably expect to receive marketing of this type. Business partners will be able to opt out of marketing from us at any point and this will be respected.

Marketing communications will be conducted using various channels such as mail, phone and email.

Please remember that you can withdraw your consent or request to opt-out of marketing communications at any time by contacting us (see section 'Your Rights'). The withdrawal of consent, or your objection to the specific processing of personal data, including for the purposes of marketing, does not affect the processing conducted before the withdrawal. It will also not affect the provision of other products and services unrelated to the process for which you have withdrawn consent.

We may conduct marketing related analytics which includes the processing of personal data based on our legitimate interest to ensure we provide customers with appropriate marketing information that is relevant to them. When doing this we will ensure that aggregated information is used where possible and where personal data is processed the least intrusive method is used and that we feel the recipient would reasonably expect this type of processing. Data subjects may object to this at any time by contacting us. These analytics may include additional (personal) information obtained from third parties where we consider the use of this data fair and legal.

Cookies

We also collect information using cookies and related website tracking technology. Cookies are small files which save and retrieve information about your visit to this website – for example, how you entered our site, how you navigated through the site, and what information was of interest of you.

Read more about how we use cookies in our website Cookie Statement and SEISMIC Cookie and Tracking Statement.

Communicating with us

Disclosing your personal data

Disclosing your personal data within the Aegon group

As a global organization, personal data we collect may be transferred internationally throughout Aegon’s worldwide organization. Your personal data may be exchanged between each of the Companies as well as within the Aegon group of companies (meaning all subsidiaries and affiliates of Aegon Ltd.), including the other companies in Aegon Asset Management group (the entities within the Aegon group that are responsible for asset management activities) including Aegon Asset Management UK plc, Aegon Investment Management B.V., Aegon Asset Management (Asia) Limited, Aegon Privacy Fund Management (Shanghai) Co. Ltd and Aegon Asset Management Hungary B.V.

We provide or disclose your personal data to others for the purposes mentioned above and to have a complete overview of our contacts and contracts within the Aegon group. We may also provide or disclose your personal data to others to offer you a complete package of services and products. This will be handled in line with the description above on how we provide marketing to customers and prospects. Providing or disclosing personal data within the Aegon group of companies is done in line with applicable regulatory requirements, including appropriate technical and organizational measures.

Our employees are authorized to access personal data only to the extent necessary to serve the mentioned above and to perform their job.

Disclosing your personal data to third parties

We work with carefully selected service providers that carry out certain functions on our behalf and we cooperate with relevant authorities. The following types of third parties have or could be granted access to your personal data where relevant for the processing described above.

Governments
Supervisory authorities – including the US Securities & Exchange Commission (SEC), Commodity Futures Trading Commission and various state regulators
Administrative bodies
Banks
Affiliated and unaffiliated technology suppliers – including Aegon Global Technology Services (GTS), Microsoft, Amazon Web Services, Snowflake, OneTrust and SEISMIC
Client Relationship Management (CRM) tool providers – including SalesForce
Accountants
Auditors
Consultants
Advisors
Third party service providers
External legal counsel
Judicial bodies

When third parties are given access to your personal data, we will implement such contractual, technical and organizational measures as may be legally required to ensure that your personal data is only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

In other cases, your personal data will not be supplied to third parties, except:

to the extent that we are required to do so by law, by a government body or by a law enforcement agency, or for crime prevention purposes (including financial crime protection and credit risk reduction);
when protecting your interests or the interests of other individuals or for reasons of substantial public interest;
in connection with any legal proceedings (including prospective legal proceedings);
in order to establish or defend our legal rights;
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and for the purposes of effecting any sale or purchase; or
if we, or substantially all of our assets, are acquired by a third party, we may disclose your personal data to that third party in connection with the acquisition.

The use of your personal data by data processors

When a third party processes your personal data solely following our instructions, it acts as a data processor. We enter into an agreement with such a data processor concerning the processing of personal data. In this agreement we include obligations to safeguard that your personal data is solely provided to the data processor to provide specific services to us and the data is afforded a sufficient level of protection.

Retention of personal data

Security

Your Rights

You have a number of rights with respect to personal data about you that we collect and process, including:

the right to request a copy of the personal data we hold on you. (Requesting this information is known as making a Data Subject Access Request (DSAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee);
the right to have inaccurate personal data corrected;
the right to have out of date personal data deleted once there is no business need or legal requirement for us to hold it;
the right to object to or restrict some processing, in limited circumstances and only when we do not have legitimate grounds to continue processing your personal data;
the right to object to your personal data being used to send you marketing material. As mentioned above, generally we will only send you marketing material where you have given us your consent to do so or where we believe there is a legitimate reason for doing so. You can withdraw your consent at any time;
the right to have personal data that you provided us with transferred to another service provider in electronic form in certain scenarios; and
the right to ask for a decision to be made manually, where a decision is made by automated means and this adversely impacts you.

To exercise any of these rights, please contact our Data Protection Office.

While we will strive to honor requests you may make to exercise your rights, in considering each request we must take into account other conflicting obligations we may have as well as the rights of other data subjects. As a result, there is a chance that your request may be only partially fulfilled or in limited circumstances it may be rejected completely. If this happens, an explanation will be provided to you.

If you wish to exercise your rights in relation to the processing of your personal data conducted by one of our processors or associated co-controllers then please contact us in the first instance.

Your California Privacy Rights

Children

Making a complaint

Changes to this privacy statement

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