California Residents Privacy Statement

Last Updated: June 30, 2023

This Privacy Notice and Policy (“Policy”) provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA.

Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we may collect about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

Categories of Personal Information Collected		Categories of Third Party Disclosures
Identifiers	Identifiers such as a 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.	Advisors and agents Regulators, government entities and law enforcement Affiliates and subsidiaries Data analytics providers Business customers Others as required by law
Customer Records	Signature, physical characteristics or description, telephone number, education, employment, financial information, medical information, or health insurance information. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.	Advisors and agents Regulators, government entities and law enforcement Affiliates and subsidiaries Data analytics providers Others as required by law
Commercial information	Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.	We do not share this information with third parties.
Internet and electronic network activity information	Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.	Internet service providers, operating systems, and platforms. Data analytics providers Others as required by law
Location data	Location information about a particular individual or device.	Internet service providers, operating systems, and platforms. Data analytics providers Others as required by law
Audio, visual and other electronic data	Includes audio, electronic, visual, or similar information, such as, CCTV footage (e.g., collected from visitors to our offices) and call recordings (e.g., of customer support calls).	We do not share this information with third parties.
Professional information	Includes professional and employment-related information such as current and former employer(s) and position(s), business contact information, and professional memberships.	We do not share this information with third parties.
Education Information	Information about an individual’s educational history, [such as the schools attended and degrees you were awarded].	We do not share this information with third parties.
Protected classifications	We collect some information that is considered a protected classification under California/federal law, such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.	We do not share this information on an individual level. Such information is only shared in aggregate.
Sensitive personal information	In limited circumstances, we may collect: Social security, driver’s license, state identification card, or passport number. Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Precise geolocation. Racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. Biometric information.	Regulators, government entities and law enforcement, as required by law Affiliates and subsidiaries

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” (as defined by the CCPA) personal information.

We do not sell or share sensitive personal information about California residents, 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 the categories of personal information identified in the table above from the following categories of sources:

Client Intake Process. Data we receive from clients (or third parties authorized by the client to provide information) in investment management agreements, subscription agreements or other forms, which may include the client’s name and address, social security or tax identification number, total assets and other information.
Website Analytics. Through applications, which provides high level website traffic data.
Direct Data. Data we receive directly from the individual.
Client History. Data about client transactions with AEW including transactional activity and balances in accounts with us.

Purposes of Collection, Use, and Disclosure. As described in more detail in the Sections titled, “How We Use Your Personal Data” and “Disclosures of Personal Data,” in our general Privacy Statement, we collect, use, disclose, and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:

Services and support
Analytics and improvement
Marketing and advertising
Planning and managing events
Research and surveys
Security and protection of rights
Legal proceedings and obligations
General business and operational support
In support of business transfers (e.g., if we are acquired by other company)

Sensitive Personal Information. Notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (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) for purposes other than inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorized pursuant to section 7027(m) of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).

Retention. We will retain your personal information only as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this, we will have regard to the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for seven years following the last date of activity, as required by applicable law.

California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):

To opt out of sales and sharing. The right to opt-out of our sale and sharing of their personal information. However, we do not sell or share the personal information we collect, thus this right is not available.

To limit certain uses and disclosures of sensitive personal information. The right to limit our use or disclosure of sensitive personal information to those uses authorized by the CCPA. We do not use sensitive personal information beyond the purposes permitted under the CCPA, thus this right is not available to California residents.

Deletion. The right to the deletion of their personal information that we have collected, subject to certain exceptions.

To 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 correct inaccurate personal information that we maintain about them.

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

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below.

Request to know/access, correct, delete and limit. California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us online by emailing us a request at DataPrivacy@aew.com. Alternatively, California residents may submit a request by calling us at 1-844-612-7994 or submit a request through this webform.

We will take steps to verify your request by matching the information provided by you with the information we have in our records. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.

Authorized agents may initiate a request on behalf of another individual by contacting us at DataPrivacy@aew.com or calling at 1-844-612-7994. 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 more information about our privacy practices, you may contact us at DataPrivacy@aew.com or call 1-844-612-7994.

PRIVACY Privacy Notice and Policy for California Residents