Notice of privacy policies and practices

We¹ consider customer relationships to be the hallmark of our business and are dedicated to protecting the confidentiality of any nonpublic personal information provided by our customers.² We understand the trust that our customers place in us and are committed to earning that trust well into the future. This Notice of Privacy Policies and Practices (“Privacy Policy”) covers personal information we collect from you offline, such as from written forms and online, by information submitted or collected automatically on our websites. Some or all of this Privacy Policy may apply to you depending on your relationship with us.

 

Sources from which we collect personal information and the types of personal information we process

We may collect personal information regarding our current and prospective investors and shareholders, and representatives of such investors and shareholders through a variety of ways, including applications, forms, transaction histories, and correspondence (electronic, written, and telephonic). Personal information may also be gathered and made available to authorized associates through complaints, issue resolution events, data inputs to Natixis websites, issuance of required mailings, regulatory monitoring and retention, and shareholder voting. Personal information collected can include identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers, telephone number, geolocation data, such as your physical or business address, financial information, such as investor account name and number, and inferences drawn from the information identified above.

We may also collect personal information about our business contacts, including through surveys, data inputs to Natixis websites, interactions with electronic marketing material and employer platforms, conversations, correspondence, sales reports, and from vendors working on our behalf. Personal information collected includes: identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; signature; telephone number; geolocation; internet or electronic network activity; professional or employment information; financial information; commercial information, including trading history, sales activity, and preferred products; geolocation data, such as your physical or business address; and inferences drawn from any of the information identified above. A portion of the data collected is statistical in nature and is not attributable to any specific individual.

We may collect personal information from you automatically when you use our websites by cookies and other tracking technologies. This may include online identifiers such as your IP address, unique personal identifier, device ID, advertising ID, geolocation data, such as the city, state or country associated with your IP address, internet or electronic network activity, such as information regarding your interactions with our webpages and products and services, browser type, or inferences drawn from this information.

Natixis collects trustee information to comply with auditing requirements, regulatory disclosures and mailings, and accounts payable processes. Trustee personal information collected includes identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers, telephone number, and information regarding protected characteristics.

We may collect information you provide to us via social media platforms, including when you interact with our social media pages and accounts. Those interactions are governed by the privacy policies of the relevant social media platforms and Natixis is not responsible for the privacy policy or actions of those social media platforms.

 

How we use your personal information

We may use the personal information we collect from you or receive about you in a variety of ways depending on the type of information and your relationship with us. For example, we may use your personal information to consider your or your employer’s eligibility for or products or services or service your or your employer’s account and to provide you with additional information about products and services. Your personal information may be used for auditing, regulatory reporting and retention, compliance testing, customer relationship management, portal functionality, research, and verification services for purposes of servicing your account and analytics, problem resolution, statement fulfilment, and debugging purposes.

We may also use your personal information to (i) present our websites and their contents to you and operate our websites; (ii) deliver the information, products or services you have requested from us; (iii) reach out to you about and market or promote new information, products or services to you that we believe you may be interested in; (iv) communicate with you; (v) help us improve our websites and services and deliver a more personalized experience, (vi) carry out our obligations and enforce our rights; (vii) for our legitimate interests and in any other way we may describe when you provide us with your personal information, or otherwise at your directing or with your consent; (viii) to monitor the security of our office; (ix) as permitted or required by law or as we may notify you.

 

Analytics and targeted advertising

We may use your personal information, including information we collect from you automatically via cookies and other tracking technologies when you visit our websites to conduct analytics, deliver targeted and interest-based advertising to you. We may also engage third party companies to deliver targeted and interest-based advertising to you. These companies may track your online activities across websites and other online services over time and use this information to display ads or other targeted content to you that is believed to be relevant to your perceived interests.

Refer to our cookie policy for more information about how we use cookies and steps to take to opt-out of cookies.

 

How we share your personal information

The information we collect, as described above, may be shared in various ways depending on the information we process and our relationship with you. For example, we may share your personal information (a) with our corporate affiliates in the financial services industry to enhance and improve customer communications, services, and products designed to meet our customers' needs; (b) with federal, state, or local regulators and self-regulatory organizations pursuant to applicable federal and state law; and (c) with third-party service providers, business partners and vendors that perform services on our behalf and/or support our account maintenance and service capabilities by providing services such as preparing and mailing prospectuses, reports, account statements, conducting research on client satisfaction, gathering votes for shareholder proxies, providing marketing, analytic, and processing services. We share your “non-public personal information” as defined by federal law as permitted or required by law, and unaffiliated service providers that process such information on our behalf have agreed not to retain, use, or disclose personal information for any purpose other than as contractually specified or as may be required by applicable federal and state law.

We may also share your personal information (i) to the extent necessary to fulfill your request when you request any of our products or services; (ii) when required to do so by law, such as in response to a court order, subpoena, or law enforcement agency’s request; and (iii) with entities in the analytics and advertising ecosystem to serve targeted advertisements to you.

Please note that if we or any of our subsidiaries or lines or business are merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we possess about you, and information collected pursuant to this Privacy Policy, may, in whole or in part, by sold, disposed of, transferred, divested or otherwise disclosed as part of that transaction or proceeding.

 

Policies and practices to protect the security of your personal information

Only employees that have a business need for personal information are given access to that information. We maintain physical, electronic, and procedural safeguards that are designed to comply with federal standards to protect your nonpublic personal information. For example, we take precautions to keep our information systems secure, including the use of firewalls for internet-based systems. When appropriate, we also use encryption technologies, user authentication systems, and access control mechanisms. Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal information or other information will never be disclosed in a manner that is inconsistent with the statements set forth in this Privacy Policy.

 

Links to third-party websites

Our website may contain links to third-party sites and services whose privacy practices may be different than ours. We may also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services, and you should consult their privacy policies to better understand their privacy practices.

 

Children’s privacy

Our website and services are not intended for users under the age of 16, Natixis does not knowingly collect or retain the personal information of anyone under 16. No one under the age of 16 is permitted to access or use the Natixis services or to provide Natixis with personal information.

 

Changes to this privacy policy

This Privacy Policy may be changed by us at any time and subject to applicable law, such changes will apply to information we collected from you pursuant to a previous privacy policy. The revised privacy policy will be posted on the appropriate portion(s) of our website and will indicate at the top when it was most recently updated. We encourage you to periodically check back to review this policy so that you know what information we collect, how we use it and with whom we share it.

 

How to contact us

If you have any questions or concerns about this Privacy Policy, please contact us at USPrivacy@natixis.com.

How we disclose personal information

In the last twelve months, we have disclosed the following categories of personal information for business purposes:

• Identifiers
• Categories of Personal Information described in Cal. Civ. Code Section 1798.80(e)
• Commercial Information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, thermal, olfactory or similar information
• Professional or employment information
• Inferences drawn from other Personal Information
• Sensitive Personal Information

 

We do not currently sell consumer personal information for purposes of the CCPA

We do not currently sell personal information for purposes of the CCPA. 

 

Sharing of personal information for cross-context behavioral advertising

In the past 12 months, we have shared the following categories of personal information with third-party companies for purposes of cross-context behavioral advertising in an effort to serve targeted, interest-based advertisements to you:

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

 

Minors under the age of 16

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

 

Your rights as a California resident

As a California resident, you may have certain rights in relation to your Personal Information.

Right to know

You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:

• The categories of personal information we have collected about you.
• The categories of sources from which we have collected your personal information.
• The business or commercial purpose for which we collect, sell or share your personal information.
• The categories of third parties to whom we have disclosed your personal information.
• The categories of personal information that we have sold or shared about you and the categories of third parties to whom it was sold or shared.
• The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom we have disclosed it.

In addition, you may have the right to know the specific pieces of personal information we have collected about you. Subject to certain limitations, you may request that we provide this information dating back to January 1, 2022.

Right to make a deletion request

You may have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers and contractors to delete your personal information.

Right to correct inaccurate personal information

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

Right to opt-out of sales of personal information

If we were to sell your personal information for purposes of the CCPA, you may have the right to opt-out of the sale of your personal information.

Right to opt-out of sharing of personal information

You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Right to limit use and disclosure of sensitive personal information

Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information. We do not use or disclose your sensitive personal information in a manner that gives rise to this right.
 

Right to non-discrimination

You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.

“Do Not Track” signals 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” of personal information for cross-context behavioral advertising purposes.

How to exercise your California privacy rights

If you wish to exercise your right to know, delete or correct inaccuracies in your personal information, please submit a request to us by calling us at 800-862-4863 (extension 2828) or contacting us via email at CCPAinforequest@natixis.com.

If you wish to exercise your right to opt-out of sharing of your personal information for cross-context behavioral advertising purposes, please click the “Do Not Share My Personal Information” link located at the bottom of our website pages to manage your cookie settings. If you opt-out of cross-context behavioral advertising using this tool, an “opt-out cookie” will be placed on your device. Opt-out cookies are device- and browser- specific, meaning that you must opt-out across all devices and browsers. If you clear your cache or deletes cookies from your browser, the opt-out cookie will also be deleted, meaning that you will need to opt-out again.

Verifying your requests

We only respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information.

We may need to ask you for personal information to verify your request so we can match it to the personal information we already have about you. We may also need to obtain additional information about you that we do not already have. If you provide us with new personal information that we do not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your identity, we will let you know.

Responding to your requests

We aim to promptly verify and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, 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 to the extent 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.

Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of Personal Information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access Personal Information via postal mail rather than email, please let us know when submitting your request(s).

Limitations

The CCPA does not apply in full to all personal information we collect from California residents. As set out in “Scope” above, the CCPA is not fully applicable to much of the Personal Information we collect from California residents. Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request.

We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of Personal Information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.

Information for Authorized Agents

You can authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. To submit a request to us on behalf of another person as an Authorized Agent, please submit a request to us by calling us at 800-862-4863 (extension 2828) or contacting us via email at CCPAinforequest@natixis.com.

Changes to the California Resident Privacy Notice

Natixis may update or revise this California Resident Privacy Notice. If such changes are instated, relevant website materials will be amended accordingly.