Privacy Notice

This Privacy Notice describes the types of personal information Loomis, Sayles & Company, L.P., Loomis Sayles Investments Limited, Loomis Sayles Investments Asia, Pte. Ltd., Loomis Sayles Distributors, L.P., Loomis Sayles (Netherlands) B.V. and Loomis Sayles Trust Company LLC (collectively referred to as “Loomis Sayles”) collects, how we may process that information and who we can share it with. This Privacy Notice also describes the measures we take to protect the security of your personal information.

Personal Information

Personal information, also referred to as “Personal Data”, means any information relating to an identified or identifiable natural person); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Types of Information We Collect

Loomis Sayles will only collect personal information that is relevant and not excessive for the purposes for which it is collected.

Please see our Candidate Privacy Notice for additional, detailed information on the personal data we collect during the recruitment process.

What we use your personal information for and why

Loomis Sayles only collects your data to fulfill our contractual obligation(s) to you or your company, to comply with related legal requirements, and/or to further our legitimate business interests, or when we have obtained your consent.

Loomis Sayles may use your personal data collected for a variety of different reasons, which include:

• to serve you or your company as our client(s);
• to communicate with you as our client, our client contact, or employee;
• to manager our business operations (including but not limited to: managing our products and services; collecting money owed to us; and making payments for products and/or services received);
• to improve our products and services;
• to manage privacy and securities;
• to aid in the detection and prevention of financial crimes;
• to comply with our regulatory and legal requirements.

How do we obtain your personal information?

We may collect personal information about you or your company from any of these sources:

Directly by you when:

• You or your company engage our services or buy our products
• Communicate to us as your company's contact person
• When you use our website (please see our Cookie Policy for additional information on how we use cookies)
• When you speak to us on the phone or during meetings
• You apply for employment or become an employee

From outside sources such as:

• Government and law enforcement entities for purposes such as identification verification and the prevention of crime
• Your employer with whom we conduct business
• Our affiliated companies or agents who help us source business or service our employees and clients (such as the transfer agents or administrators of Loomis Sayles’ investment funds, distributors or financial intermediaries, platforms, professional advisers including consultants, lawyers and tax advisers, product providers, event organizers, and other agents and/or representatives)
• Other publicly available sources (including third party agencies such as credit reference agencies and fraud prevention agencies, public databases, corporate registers and records such as UK Companies House and the UK FCA Register, the EU Central Register of Beneficial Owners, and the Singapore Accounting and Corporate Regulatory Authority; and other publicly accessible sources)

Security and confidentiality

Equipment and Information Security

In order to safeguard against unauthorized access to personal information by third parties outside Loomis Sayles, all electronic personal information held by Loomis Sayles is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. Servers holding personal information are “backed up” (e.g. recorded on separate media) on a regular basis in an effort to avoid any inadvertent erasure or destruction of information. The servers are stored in facilities with appropriate security and fire detection and response systems.

Access security

Loomis Sayles limits access to the internal systems that hold personal information to a select group of authorized users who require such personal information for the sole purpose of performing their job duties. Unauthorized use or disclosure of personal data or confidential client information by a Loomis Sayles employee is prohibited and may result in disciplinary measures.

Sharing of Personal Information

Loomis Sayles may share the information you provide among our subsidiaries and affiliates as required and as permitted by law. Loomis Sayles may also share personal information with third party service providers to perform services on our behalf for the benefit of our clients and/or employees as permitted by law or pursuant to their consents.

In addition, Loomis Sayles may disclose personal information (i) if Loomis Sayles is required to do so by law or legal process or to enforce any rights Loomis Sayles may have against you as necessary, (ii) to law enforcement authorities or other government officials, (iii) when Loomis Sayles believes disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity, or (iv) if this is necessary to protect the vital interests of a person. Third party service providers may disclose personal information to other third parties for business purposes such as: governmental authorities for immigration or visa issues, as a matter of law or legal process (e.g. to tax and social security authorities), to protect Loomis Sayles legal rights (e.g. to defend a litigation suit) or as part of litigation involving such third party; or in an emergency where the health or security of an individual or an individual’s personal information is endangered (e.g. a fire or natural disaster); or, for such other purpose required for business operation or by local laws.

Loomis Sayles requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as Loomis Sayles when processing personal information.

Loomis Sayles does not sell or disclose our clients’ personal information to other businesses or third parties for monetary or other valuable consideration. The information we provide to third parties are for the business purposes described in this Privacy Notice.

Information We Transfer, and Storage

Loomis Sayles may transfer your personal information to the United States based on a need to comply with the terms of various contracts, to comply with applicable laws and regulations, or for our legitimate business needs.

Personal Information may be stored on servers located in the United States.

International Transfers of Personal Data

Loomis Sayles is a global business and as a result we or our external service providers collect and transfer personal data globally and may transfer your personal data to locations outside of your country or jurisdiction. Your personal data also may be processed by individuals operating outside of your country or jurisdiction who work for Loomis Sayles or for one of our external service providers. Loomis Sayles shall ensure that in case of transfer and processing of personal data outside the European Economic Area (“EEA”), Switzerland and the UK (in respect of which the laws of those jurisdictions apply), such processing is carried out only where allowed by an adequacy decision of the European Commission, Switzerland and/ or the UK Information Commissioner’s Office (“ICO”) and/or Loomis Sayles has provided for appropriate safeguards which provide you with enforceable data subject rights and effective legal remedies. This can be done in various ways, for instance:

• the country to which we send the personal information may be approved by the EU Commission, Switzerland or the UK Government, or;
• the recipient might have signed up to a contract based on standard contractual clauses, such as “model contractual clauses” approved by the European Commission, Switzerland or the ICO (as appropriate), obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA, Switzerland and/or UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the UK, Switzerland and/or EEA (including a sample copy of the standard contractual clauses) by contacting us in accordance with the relevant contact details provided below.

For transfer of personal data outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements. You can obtain more details of the protection given to your personal data by contacting us in the manner described in the section entitled “Rights with Respect to Personal Data".

Retention of Personal Data

We hold Personal Data on our systems (or those of our service providers) for the duration needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine retention periods include:

• The duration of our contractual relationship with our client and the provision of related services;
• The legal obligations to which we are subject – laws or regulation may set a minimum period for which we have to keep your personal data.

Rights with Respect to Personal Data

Where permitted by applicable law and regulation, you have a number of legal rights in relation to the personal data that we hold about you. These rights may include:

• Obtain access to your Personal Data
• Obtain information regarding the processing of your personal data and access to your personal data which we process at the time of your request;
• Rectify, update and delete your Personal Data for legitimate reasons
• Subject to the conditions set out in relevant local legislation, such as sec. 35 of the German Federal Data Protection Act (“BDSG”), the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it
• Object to the processing of your Personal Data for legitimate reasons and object to the processing of your Personal Data for direct marketing purposes without giving any reason
• Request the portability of your Personal Data for processing that required your consent
• Demand the limitation of processing of your Personal Data
• Withdraw your consent of the processing of your Personal Data
• Lodge a complaint with a regulatory authority regarding the processing of your Personal Data.

To seek to exercise these rights, please contact Loomis Sayles at 800-343-2029 or via email at privacyinquiries@loomissayles.com.

In the UK, you may also report a concern by contacting the Information Commissioner’s Office at 0303 123 1113 or through their website at ico.org.uk/concerns.

In the Netherlands, you may report a concern by contacting the Dutch Data Protection Authority at (+31)-(0)70-888 85 00.

Loomis Sayles Investments Limited Data Protection Representatives

Loomis Sayles Investments Limited, located at 77 Coleman Street, 6th Floor, London EC2R 5BJ, United Kingdom shall operate as the Data Protection Representative in the United Kingdom. Privacy inquiries can be directed to privacyinquiries@loomissayles.com.

Loomis Sayles (Netherlands) B.V.—Netherlands Data Protection Representative

Loomis Sayles (Netherlands) B.V. located at Stadsplateau 7, 3521 AZ Utrecht, The Netherlands, shall serve as the Data Protection Representative of Loomis Sayles (Netherlands) B.V. Privacy inquiries can be directed to privacyinquiries@loomissayles.com.

Updates to our Privacy Notice

Loomis Sayles reserves the right to modify this Privacy Statement, and this Privacy Notice may be updated periodically to reflect changes in our information practices or as may be required by law.

California Residents

Please click here for our Privacy Statement for California Residents.

Canadian Residents

If you are a resident of Canada, Loomis, Sayles & Company L.P. controls the personal data collected in accordance with this Privacy Notice. Personal data is maintained on Loomis Sayles servers or those of its service providers and is accessible by its authorized employees, representatives, and service providers as necessary for the purposes described in this Privacy Notice. Loomis Sayles collects personal data with consent except as otherwise permitted or required by law.

If you wish to exercise any of your rights or have any questions in relation to how your personal data is processed by Loomis, Sayles & Company L.P., please contact via email at privacyinquiries@loomissayles.com.

Japanese Residents

For those whose personal data is collected and handled by Loomis, Sayles & Company L.P., if you wish to exercise any of your rights as a Principal under Act on the Protection of Personal Information of Japan or have any questions in relation to how your personal data is processed by Loomis, Sayles & Company L.P., please email: privacyinquiries@loomissayles.com.

Singapore Residents

To the extent permitted by law, if you wish to exercise any of your rights or any questions in relation to how your personal data is processed by Loomis Sayles Investments Asia Pte. Ltd., please email: privacyinquiries@loomissayles.com, with the phrase “Data Subject Rights” in the subject line. This would assist us in attending to your matter speedily by passing it on to the relevant staff in our organisation to handle. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

We will strive to deal with any issue you may raise speedily and fairly.