We may collect and use personal data and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (collectively, "Personal Information"). Our Privacy Statement lists many of the types of Personal Information about you that we may collect (from you or from others) and use (see "How and why we obtain personal information about you").

The list below includes additional detail about the categories of Personal Information about you that we may collect and use, to the extent not otherwise prohibited by law.  (Some of these categories of Personal Information, or specific types of Personal Information included within these categories, relate only to our current, former and prospective employees and contractors.  Those are noted by an asterisk (*).)

Of the various types of Personal Information that we may collect and use, the following are considered “sensitive” under California law:

• social security number, driver’s license number, state identification card number and passport number
• racial/ethnic origin*
• health condition*
• sexual orientation*
• contents of mail, email and text messages that we receive where we are not an intended recipient

Personal Information also includes inferences drawn from your non-sensitive Personal Information (whether by us or by others) about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Information is not considered Personal Information, even if it is the kind described above, if:

• the information is publicly available (i.e., it is lawfully made available by federal, state, or local governments; we reasonably believe it has been made available by you to the public or widely distributed media; or you have disclosed it to another person and have not restricted it to a specific audience);
• the information is lawfully obtained, truthful and a matter of public concern; and
• the information is deidentified or aggregated.

We collect and receive Personal Information directly and indirectly from you and from others ("Information Sources"). Our Privacy Statement lists many of the sources from which we may collect or receive of Personal Information (see "How and why we obtain personal information about you" and "Cookies"). Additionally, we may collect Personal Information

• via electronic technologies through which you interact with us, such as our external-facing public and private websites (including cookies), intranet sites, internal computer and communications networks, email messages and systems, voicemail messages and systems, text messages and systems, instant messages and systems, and third party services like LinkedIn and Facebook;
• from third parties such as social media providers, advertising networks, data brokers, and other companies with which we have relationships in connection with the conduct of our business;
• via other electronic means, such as physical access control systems (e.g., door entry and other access control technologies, reception logs, closed circuit TV); and
• public records.

We collect and use Personal Information for a variety of business and commercial purposes, as explained in our Privacy Statement (see "How and why we obtain personal information about you" and "Disclosing your personal data").

Additionally, we collect and use Personal Information in connection with:

• personnel matters, such as employee and contractor hiring, management and other human resources functions; benefits administration; and life safety; and
• facilities management and operations, including physical access control.

Except as further explained below regarding our employees, at this time, we do not sell (i.e., transfer in exchange for payment of money or other valuable compensation) or share (i.e., transfer for cross-context behavioral advertising), and during the past 12 months have not sold or shared, Personal Information (including sensitive Personal Information) to third parties, including Personal Information of California residents under 16 years of age. However, you have the right to opt out of the sale and/or sharing of your Personal Information that might occur in the future. For more information about your right to opt out of the sale or sharing of Personal Information, or to submit a request to opt out of the sale and/or sharing of your Personal Information by us, please click here or click the link at the bottom of this page entitled "Do Not Sell or Share my Personal Information."

Please note that at this time, we do not recognize “opt-out preference signals” or other types of Global Privacy Controls.

For Aegon AM Employees Only:  We occasionally provide certain Personal Information (primarily certain Professional, Employment and Education information) of some of our employees (primarily senior leaders, regulated functions, portfolio managers and investment teams) to companies known as RFP database providers.  These companies aggregate information about investment managers, including information about their portfolio managers and senior leadership, and their investment strategies, platforms and funds.  These companies then provide this information to prospective investors and their advisers and consultants, which use the information to assist their due diligence processes. 

Because Aegon AM benefits from using these companies, but because these companies typically do not enter into written contracts with us with respect to the services they perform and the data we provide to them, these companies are considered “third parties” under the CCPA. As a result, when we provide employee Personal Information to these companies, it is technically considered a “sale” of Personal Information to them even though we do not receive any money from these companies in exchange for the Personal Information we provide to them.

Aegon AM employees who are California residents may opt out of these data disclosures by clicking here or clicking the link at the bottom of this page entitled "Do Not Sell or Share my Personal Information" and following the described process. While not required, we encourage employees to discuss opting out of these data disclosures with their managers prior to submitting opt-out requests.

We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about California residents or for any other purpose not permitted under Section 7027(m), Title 11, Code of California Regulations.  Because of this, you do not have the right to request that we limit our use of sensitive Personal Information to only those purposes specified in the CCPA. 

Although at this time we do not sell or share Personal Information except as described above, we do disclose Personal Information to others for certain business purposes (as defined in the CCPA). Our Privacy Statement explains how, when and with whom we disclose Personal Information (see "Sharing your personal data").

The categories of Personal Information we have disclosed for these purposes during the past 12 months are listed below (although not every category of information may have been disclosed about every California resident).  (Some of these categories of Personal Information, or specific types of Personal Information included within these categories, relate only to our current, former and prospective employees and contractors.  Those are noted by an asterisk (*). See “Categories of Personal Information (Including Sensitive Personal Information) We May Collect and Use” above for more information).

Please see our Privacy Statement for information about our how long we retain your Personal Information (see “Retention of personal data”).

You have the right to request that we delete Personal Information about you that we have collected from you. Upon receipt from you of a Verified Request (as defined below) asking that we delete Personal Information about you that we have collected from you, we shall delete all such information unless you request deletion of only certain items of information (in which case, we will only delete the items you request), and shall direct our Service Providers and Contractors to do the same, except for Personal Information that that we or our Service Providers or Contractors have a legal right or obligation to retain.

If we do not delete certain items of Personal Information because we have a legal right or obligation to retain that information, we shall notify you of that.

Further, if we do not delete certain items of Personal Information because we have a legal right or obligation to retain that data, we shall delete that information at such later time that we no longer have a legal right or obligation to retain that information.

You have the right to request that we correct inaccuracies in Personal Information we maintain about you, taking into account the nature of the Personal Information and the purposes for which we process it.  Upon receipt from you of a Verified Request (as defined below) requesting correction of inaccuracies in your Personal Information, we shall use commercially reasonable efforts to correct those inaccuracies. 

You have the right to request information about our collection of your Personal Information. Upon receipt from you of a Verified Request (as defined below) for information about our collection of Personal Information about you, we shall disclose to you the following for the 12-month period preceding our receipt of your Verified Request:

• the categories of Personal Information we have collected about you;
• the categories of Information Sources from which we collected your Personal Information;
• a description of the business or commercial purpose for collecting,  selling or sharing your Personal Information;
• descriptions by category or type of Third Parties to whom we disclose your Personal Information; and
• the specific pieces of Personal Information we have collected about you.

You also may request the above-described information beyond the 12-month period with respect to any Personal Information we have collected since January 1, 2022, which we will provide to you except to the extent it is impossible for us to do so or would require disproportionate effort by us. 

You have the right to request information about our sale, sharing and disclosure of Personal Information about you. Upon receipt from you of a Verified Request (as defined below) for information about our sale, sharing and disclosure of Personal Information about you, we shall disclose to you the following for the 12-month period preceding our receipt of your Verified Request:

• the categories of Personal Information we have collected about you;
• the categories of Personal Information about you that we have sold or shared, and the categories of Third Persons to whom we sold or shared that Personal Information; and
• the categories of Personal Information about you that we have disclosed for a business purpose, and the categories of Contractors and Service Providers to which we disclosed that Personal Information.

You also may request the above-described information beyond the 12-month period with respect to any Personal Information we have collected since January 1, 2022, which we will provide to you except to the extent it is impossible for us to do so or would require disproportionate effort by us.

You may use any of the options listed below to submit a request to us to delete Personal Information about you that we have collected from you, or to correct inaccurate Personal Information about you, or a request for information about our collection of your Personal Information (including a copy of that information), or a request for information about our sale, sharing and disclosure of Personal Information about you:

• Call us, toll free, at 1-855-825-9101
• Send a letter to our US Data Protection Officer at the postal address provided in the Privacy Statement
• Send an email to our US Data Protection Officer at the email address provided in the Privacy Statement
• Use our online request submission form available here

If you wish to opt out of the sale of Personal Information about you, please see “Sale and Sharing of Your Personal Information and Your Opt-Out Rights” above.

You also may authorize another person or a company to submit a request on your behalf. (These are called “Authorized Agents” –  see below for more information on submitting requests through an Authorized Agent.)

If you send us a request by letter or email, it is important that you provide some basic information to us so that we can process your request.  At a minimum, please include the following:

• Your name, including any nicknames and prior legal names
• Your company name, mailing address and physical address
• Your email address
• Your state of residency
• Your preferred method of contact (for example, email or telephone)
• Your relationship with us (for example, current or former employee or business contact)
• A description of your request (for example, do you want to know what categories of information we hold about you or do you want a copy of the specific pieces of information we have collected about you?)
• If another person or a company is submitting the request on your behalf, include an explanation of your relationship with that other person or company.

A “Verified Request” is a request that we can verify (using commercially reasonable efforts) as having been submitted by you on your own behalf, or by you on behalf of any of your children under 18 years of age, or by your Authorized Agent. 

Promptly after receiving your request, we will take such reasonable steps as may be needed to verify that the person making the request is the person about whom we have collected the Personal Information that is the subject of the request or, if applicable, that the person or company submitting the request on behalf of another is authorized to do so. In attempting to verify the request, we may request:

• sufficient information to enable us to identify the person making the request (for example, your full name, postal address, email address, employee number, account number, social security number, passport number, or birth date);
• sufficient information to enable us to identify the person that is the subject of the request;
• proof of identity (such as a copy of your driver’s license or passport, a recent utility bill or a recent account statement); or
• sufficient information to enable us to confirm that a person is your Authorized Agent (see “Submitting Your Request Through an Authorized Agent” below for more information).

Any Personal Information we collect to verify a request, and which do not otherwise possess for other purpose, will be used solely for the purposes of verification of your request.

In some cases, another person or company may submit a request for you.  These are called “Authorized Agents.”  This is permitted if:

• you have authorized the other person to submit the request on your behalf;
• the company is registered with the California Secretary of State and you have authorized it to submit the request on your behalf;
• the other person has power of attorney to act on your behalf; or
• the other person is your conservator.

In connection with processing your request, we may request additional information to verify that the person or company submitting the request on your behalf is authorized to do so. For example, we may require:

• a written certification from you confirming the authority of that other person or company to submit the request on your behalf;
• proof that a company submitting the request is registered with the California Secretary of State;
• a certified copy of the power of attorney; or
• a certified copy of the court documents appointing the conservator.

If we cannot reasonably verify the request, then we will not consider the request to be a "Verified Request" and we will not be required to honor the request. Similarly, we may refuse to process a request submitted by another person or company on your behalf if we cannot verify that the person is your Authorized Agent or we believe that the request is otherwise fraudulent.

If we are unable to verify a request to delete Personal Information, the request will be treated as a request to opt out of the sale and sharing of Personal Information about you (see “Sale and Sharing of Your Personal Information and Your Opt-Out Rights” above).

We will respond to a Verified Request to provide information within 45 days of receiving the request, unless a longer period of time is reasonably necessary to provide the requested information, in which case we may take up to 90 days to provide the requested information. If providing the requested information will require more than 45 days, then within 45 days of having received your request, we will notify you of the delay and the reason(s) for it.

Our response to a Verified Request to provide information will be in writing and will be delivered to you in the manner specified by you in your request. Information disclosed pursuant to the Verified Request, including any specific pieces of Personal Information we have collected about you that you have requested we provided to you, will be in a readily useable format that you can transmit to others.

If responding to a Verified Request does not require that we provide information to you (for example, if you are requesting that we delete Personal Information we have collected from you), then we will act on the request within 45 days of receipt, unless a longer period of time is reasonably necessary to act on the request, in which case we may take up to an additional 90 days (for a total of 135 days) to act on the request. If acting on such a request will require more than 45 days, then within 45 days of having received your request, we will notify you of the delay and the reason(s) for it.

If we have questions about your request or otherwise need to discuss it with you, we will attempt to contact you in the manner you have specified in your request for communicating with you.

If we do not take action on your request, we will inform you of that decision and the reasons for it within the time periods specified above.

We are not required under CCPA to provide information to you about our collection of your Personal Information or our sale, sharing and disclosure of Personal Information about you more than twice within a 12 month period. Additionally, we may refuse to honor unfounded or excessive repetitive requests to us, or charge a reasonable administrative fee for honoring those requests, and in either case, will notify you of our decision.

Except as noted above, you will not be charged by us for determining whether your request is a Verified Request, responding to your request (whether or not a Verified Request), providing information in response to your request, acting on your request, or communicating with you about your request.

If you wish to contact us about a request you have submitted to us, or if you believe we have made a mistake in responding to or denying your request, you may contact our US Data Protection Officer by telephone, email or U.S. mail as specified above under "How to Submit a Request".

We shall not discriminate against you if you exercise your rights under CCPA. This means that we will not do any of the following things just because you have exercised your CCPA rights:

• deny goods or services to you;
• charge different prices or rates for goods or services, including through the use of discounts or other benefits of imposing penalties; or
• provide a different level or quality of goods or services to you

At this time we do not offer (a) monetary payments or other financial incentives in exchange for individuals permitting us to collect, sell, share or retain their Personal Information or (b) alternative prices or rates, or different levels or quality of goods or services, based on the value to us of your Personal Information.

The provisions of CCPA can be found in sections 1798.100 et seq of the California Civil Code.

Please be aware that in certain circumstances, the provisions of CCPA, including some or all of the provisions of this Disclosure, may be wholly or partially inapplicable. Please refer to CCPA for more information about those circumstances.

If we rely on an exception to CCPA in refusing to honor or act on your request to us, we will so notify you in our response to your request. If you are uncertain whether an exception to CCPA may apply to you or Personal Information about you, or if you have more questions regarding your rights under CCPA, please contact an attorney.

This Disclosure is provided on behalf of the Aegon AM listed below:

Aegon USA Investment Management LLC and Aegon USA Realty Advisors LLC, having their registered office in Cedar Rapids, IA, US

Aegon Asset Management UK plc, having its registered office at 3 Lochside Crescent, Edinburgh, EH12 9SA

From time to time we may make changes to this Disclosure.  This Disclosure was last updated on January 1, 2024.