California Applicant Privacy Notice and Policy

Last Updated: June 30, 2023

This California Applicant Privacy Notice and Policy (the “Notice”) describes how AEW Capital Management, L.P. ( “AEW,” “we” or “us”) collect and use personal information relating to California residents who are external job applicants and potential candidates for positions with AEW (each an “Applicant”) and is intended to satisfy our notice and privacy policy requirements under the California Consumer Privacy Act and the regulations issued thereto, each as amended (collectively, the “CCPA”).

The information in this Notice is intended to provide an overall description of our processing of Applicant personal information. We may provide Applicants additional notices about our data practices, such as those covered by other laws (e.g., if we conduct a background check). We encourage you to carefully read this Notice, together with any other privacy notice we may provide to you.

The personal information that we collect, and our use and disclosure of such personal information may vary depending on the circumstances, such as the position(s) or location for which you apply, as well as the associated qualifications and responsibilities. In addition, if you visit one of our offices or locations, we may collect information as part of our onsite security. The information in this Notice is intended to provide an overall description of our processing of personal information about Applicants.

1. Scope

This Notice applies, generally, to the Applicant personal information that we collect and otherwise process in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us. Your use of our website, or submission of an application or other information through our website available at www.aew.com/careers, is subject to our Terms of Use, which include terms governing limitations on liability and the resolution of disputes; our Terms of Use are incorporated by reference into this Applicant Notice.

This Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as consumer credit reports and background checks, publicly available data, or other information that is exempt under the CCPA. This Notice also does not apply to the personal information we collect from contractors or employees, which is subject to different privacy notices, or to the personal information we collect about our website visitors and investors, which is subject to the AEW Privacy Statement (posted at https://www.aew.com/privacy).

2. Categories of Personal Information Collected and Disclosed

The table below generally identifies the categories of personal information about Applicants that we collect and have collected in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. In some cases (such as where required by law), we may ask for your consent or give you certain choices prior to collecting or using certain personal information.

Sales and Sharing of Personal Information. California privacy laws define a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. We do not “sell” or “share” personal information of Applicants.

Further, we do not sell or share (as defined by the CCPA) sensitive personal information related to Applicants, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years of age.

Sources of Personal Information. In general, we may collect Applicant personal information identified in the table above from the following categories of sources:

• Directly from you
• Recruiters and recruiting platforms
• Referrals and references
• Former employers
• Publicly available information and data brokers
• Service providers, representatives, and agents
• Affiliates and subsidiaries

Retention. AEW retains the personal information we collect only as reasonably necessary for the purposes described below or otherwise disclosed to you at the time of collection. For example, we will retain your information as necessary to comply with our tax, accounting, and recordkeeping obligations, to consider you for additional positions (with your permission), as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations.

3. Purposes for Collecting, Using, Disclosing and Processing Personal Information

Subject to applicable legal restrictions, generally we collect, use, disclose and process Applicant personal information as reasonably necessary for the following general purposes:

Recruiting, hiring and managing, and evaluating Applicants: To review, assess, recruit, consider or otherwise manage Applicants, candidates and job applications, including:

• scheduling and conducting interviews;
• identifying candidates, including by working with external recruiters;
• reviewing, assessing and verifying information provided, and otherwise screening or evaluating Applicants’ qualifications, suitability and relevant characteristics;
• extending offers, negotiating the terms of offers, and assessing salary and compensation matters;
• satisfying legal and regulatory obligations;
• communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested;
• maintaining Applicant personal information for future consideration; and
• in support of our equal opportunity employment policy and practices.

Business operations and investor services: Relating to the organization and operation of our business and our performance of services to investors, including related to:

• auditing and assessing performance and business operations, including investor services and associated activities;
• training and quality control;
• investor development and providing services to investors;
• satisfying reporting and auditing obligations;
• facilitating business development opportunities, as relevant; and
• facilitating communications in furtherance of the foregoing.

• to detect, prevent, investigate and respond to security and privacy incidents;
• managing physical and technical access controls;
• maintaining and reviewing access and use in order to ensure the security and functioning of our systems and assets; and
• to ensure the security and functioning of our systems and assets, and secure our offices, premises and physical assets, including through the use of electronic access systems and video monitoring.

Health and safety: For health and safety purposes, such as contact tracing or including conducting appropriate screenings of Applicants prior to entering or accessing certain locations or premises.

Auditing, accounting, and corporate governance: Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

Other business transactions: For planning, due diligence, and implementation of commercial transactions, for example acquisitions, asset sales or transfers, or other similar business transactions.

Defending and protecting rights: To protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend, or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Complying with legal obligations: Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Contacting you about potential positions: To identify other positions for which an Applicant may be suited or interested, and to contact Applicants about such positions. (If you do not wish to be contacted about potential positions, please let us know using the contact information below.)

Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use or disclose sensitive personal information about Applicants beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about Applicants as reasonably necessary and proportionate: (i) to perform our services requested by the Applicant; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) to collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about an Applicant.

4. CCPA Rights

California resident Applicants have certain rights under the CCPA with respect to their personal information as described below, subject to certain limitations and exceptions.

• Deletion: The right to request deletion of their personal information that we have collected about them.

• Know/access: The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.

• Correction: The right to request correction of inaccurate personal information we maintain about them.

• Opt out of sales and sharing: The right to opt-out of the sale and sharing of their personal information. However, we do not sell or share Applicant personal information, thus this right is not available to Applicants.

• Limit use/disclosure of sensitive personal information: The right to request to limit certain uses and disclosures of their sensitive personal information. However, as discussed above, we do not use or disclose Applicant personal information beyond the purposes authorized by the CCPA, thus this right is not available to Applicants.

• Non-discrimination: The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. Applicants may exercise their CCPA privacy rights as set forth below:

Requests to know/access, correct, and delete. Applicants may submit a request to AEW to exercise their CCPA rights to know/access, to delete, and to correct their personal information held by us by submitting a privacy request to us using our online webform, by emailing us a request at DataPrivacy@aew.com or calling us at our toll-free number, 1-844-612-7994. We will take steps to verify your request by matching the information provided by you with the information we have in our records. Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (i.e., by completing all required fields on our webform if you choose to submit a request in that manner).
• Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

In some cases, we may request additional information in order to verify your request or where necessary to process your request. Authorized agents may initiate a request on behalf of another individual through one of the above methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

For additional details, or if you have questions regarding our use of your personal as described in this Notice, you may contact us at DataPrivacy@aew.com or call 1-844-612-7994.