Privacy statement

Macquarie Web Privacy Disclosure

Macquarie Management Holdings, Inc. and each of its affiliates (collectively, Macquarie, we, us, our) are committed to protecting the privacy of our website visitors, potential, current, and former customers. This Privacy Notice (this Notice) provides detail about we how collect, use, and disclose personal information we collect through our website and other online and offline services we provide.

Some US residents have certain rights with respect to the collection, processing, and disclosure of their personal information. For more information for certain US residents, please see our Supplemental US Privacy Notice.

Macquarie is a financial institution regulated under the Gramm-Leach-Bliley Act (GLBA). If you are an individual investor and a potential, current, and former customer, please see our privacy notice issued to you pursuant to Regulation S-P, 17 CFR Part 248, et seq., which is available here, and which controls how we use and process Nonpublic Personal Information NPI) under the GLBA.

Our Privacy Practices for Personal Information

We may collect personal information through our website and other online and offline services (collectively, the Services). This section generally applies to personal information we collect from website viewers and from business contacts.

Personal information We Collect

We collect two types of personal information from you: (1) information you provide when you interact with us; and (2) information we passively collected from you when you use our Services.

Information You Provide. We collect personal information you voluntarily provide to us, such as when you contact us via our Services, send us an email, or otherwise interact with us. We typically collect the following categories of personal information in this manner:

Contact details, such as name, email address, address, and telephone number.
Commercial Information, such as the products and services you buy from us.
Characteristics of Protected Classifications under state or federal law, such as age, gender, and marital status.
Professional information, such as your employer, business contact information and associated firm.
Audio or Electronic Information, such as call and video recordings.

Information Passively Collected. We collect personal information passively through our Services, such as via cookies and other tracking technologies. This information may include:

IP addresses, mobile advertising IDs, and other unique identifiers.
Commercial information, such as web pages you visit, how long you visited our website, and the products you view.
Geolocation data, such as device location.
Inferences drawn from any of the information listed above to create a profile about you reflecting your preferences, characteristics, behavior, and attitudes.

These cookies and other tracking technologies allow us to understand your use of our Services and to advise you of any products or services that may be of interest to you. It helps us to improve our services, content and marketing. Depending on your Internet browser, you may be able to change your cookie preferences by changing the setting on your web browser to delete or reject cookies. Please note that if you delete or reject cookies and similar technologies on our Services, some website pages may not function properly.

How We Use Your Personal Information

We use the personal information we collect about you to:

Provide our products and services to you.
Analyze and better understand consumers' needs, preferences, and interests.
Conduct internal business analysis and research.
Advertise and promote our products and services, including by contacting consumers regarding products, services, and topics that may be of interest to them.
Comply with our legal and regulatory obligations, and enforce our rights and policies.
Administer, monitor, and secure our information technology systems, websites, applications, databases, and devices, including detecting and preventing against security incidents and fraudulent activity.

We may also aggregate and/or anonymize personal information and analyze those data for statistical or any other purposes permitted by law. When we do so, we take reasonable measures to ensure that the information cannot be associated with a consumer or household, and we maintain and use the information in deidentified form. We will not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements. After it has been deidentified, the information is no longer personal information and is not subject to this Privacy Notice.

How We Disclose Your Personal Information

We may disclose personal information we collect in the following situations:

To vendors who process personal information on our behalf, including vendors who provide data hosting, information technology support, email hosting, marketing and analytics services, and other services for the operation of our business. We impose contractual limitations on our vendors'; use of personal information they collect in conjunction with providing services to us.
To third party marketing and analytics providers, including via cookies and other similar technologies.
To protect our rights, defend or pursue a legal claim, or investigate or prosecute illegal activities.
To government or judicial authorities to comply with a subpoena, court order, governmental inquiry, legal process, legal obligation, or to protect the rights, property, or safety of other users or the public.
To a successor entity or purchaser upon a merger, consolidation, or other corporate reorganization in which we participate, a sale of all or a portion of our assets, or pursuant to a financing arrangement. In this situation, we will seek assurances that the successor entity or purchaser will process personal information collected by us in accordance with this notice.

Third Party Sites and Services

Our website may contain links to third-party websites. Information collected by third parties via their websites, which may include personal information, is governed by the third parties' privacy practices. You should review the privacy practices of any third party whose website you visit via a link on our website to understand their policies and privacy practices.

Children's Privacy

Our Services are not intended for children under age 13 and are not designed to attract the attention of anyone under age 13. Further, for compliance with the Children's Online Privacy Protection Act of 1998, we do not knowingly collect personal information of children under age 13. If you are a parent or guardian and believe we have collected personal information about your child in error, please contact us immediately at privacy@macquarie.com so that we can make reasonable efforts to promptly remove all personal information relating to the child from our systems.

Request Changes to Your Personal Information

We allow you to review and request changes to the personal information we collect about you through our Services. To make a change, please contact us at privacy@macquarie.com.

Changes to our Privacy Policy

From time to time, we may update or revise this Notice. To the extent we make any material changes to our Notice, we will notify you the next time you visit our site.

II. Contact Us

If you have any questions regarding this Privacy Notice or our Services generally, please contact us at privacy@macquarie.com.

Last Revised May 2024

Supplemental US Privacy Notice

Last Updated May 1, 2024

This Supplemental US Privacy Notice (Supplemental Notice) describes the practices of Macquarie Management Holdings, Inc. and each of its affiliates, such as direct or indirect subsidiaries, and any fund or product sponsored by or otherwise affiliated with Macquarie (Macquarie, we, us, our) regarding the collection, use, and disclosure of Personal Information about residents of California and Oregon through both online and offline interactions with you and how you can exercise your privacy rights under applicable US state comprehensive privacy laws (US Privacy Laws).

Please note that this Supplemental Notice does not apply to individuals with whom we interact in an employment-related context. For our disclosures applicable to California residents with whom we interact in an employment-related context, please see our Employee/Applicant Privacy Notice.

This Supplemental Notice also does not apply to nonpublic information we collect that is subject to the Gramm-Leach-Bliley Act (15 U.S.C. Section 6801 et seq.). For our disclosures applicable to collection and use of nonpublic information, please see here.

If you have a disability and need to access this policy in an alternative format, please Contact Us.

Definitions

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information also includes Personal Data, Sensitive Data, and Sensitive Personal Information, as defined by the US Privacy Laws. Personal Information does not include nonpublic personal information as defined under the Gramm-Leach-Bliley Act (15 U.S.C. Section 6801 et seq.) or any other categories of information that are carved out from Personal Information under the US Privacy Laws.
Sell,Sale, or q>Sold means renting, releasing, or transferring an individual's Personal Information to a Third Party for money or other valuable consideration.
Share,Shared, or Sharing means transferring an individual's Personal Information to a Third Party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration.
Third Party means any non-affiliated person that is not a Vendor.
Vendor means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your Personal Information only as directed by us.

Collection & Processing of Personal Information

We, and our Vendors, collect and have collected in the past 12 months the following categories of Personal Information about you:

Contact details, such as name, email address, address, and telephone number.
Commercial Information, such as the products and services you buy from us.
Characteristics of Protected Classifications under state or federal law, such as age, gender, and marital status.
Professional information, such as your employer, business contact information and associated firm.
Audio or Electronic Information, such as call and video recordings.
IP addresses, mobile advertising IDs, and other unique identifiers.
Commercial information, such as web pages you visit, how long you visited our website, and the products you view.
Geolocation data, such as device location.
Inferences drawn from any of the information listed above to create a profile about you reflecting your preferences, characteristics, behavior, and attitudes.

Sources of Personal Information

We collect these categories of personal information directly from consumers, from our vendors and third parties when they disclose personal information to us, from your employer, from public databases, and from third-party media publishers.

Purposes for Processing and Disclosing Personal Information

We, and our Vendors, collect, process, and disclose the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:

Provide our products and services to you.
Analyze and better understand consumers’ needs, preferences, and interests.
Conduct internal business analysis and research.
Advertise and promote our products and services, including by contacting consumers regarding products, services, and topics that may be of interest to them.
Comply with our legal and regulatory obligations, and enforce our rights and policies.
Administer, monitor, and secure our information technology systems, websites, applications, databases, and devices, including detecting and preventing against security incidents and fraudulent activity.

Retention of Personal Information.

We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section D.

Categories of Personal Information We Have Disclosed, Sold, or Shared

We have disclosed, sold, or shared the following categories of Personal Information to Vendors and Third Parties for a business purpose in the past twelve months. We do not, to be best our knowledge, have actual knowledge that we Sell or Share Personal Information of California residents who are under 16 years of age.

Category of Personal Information	Categories of Entities to Whom We Have Disclosed This Category of Information for a Business Purpose	Categories of Third parties with Whom This Category of Personal Information is Sold and/or Shared
Contact Details	Vendors Regulatory authorities	N/A
Characteristics of Protected Classifications	N/A	N/A
Professional information	N/A	N/A
Audio, Electronic, Visual and Similar Information	N/A	N/A
Internet or other network information	N/A	N/A
Commercial information	N/A	N/A
Geolocation data	N/A	N/A
Inferences	N/A	N/A

G. Data Subject Rights

California consumers have the following rights regarding our collection and use of the personal information, subject to certain exceptions.

Rights that Require Verification. You may exercise the data subject rights below by contacting us at privacy@macquarie.com, by calling toll-free 800 523-1918, or by clicking here and submitting details regarding your request. You may also authorize an agent to make data subject requests on their behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your Personal Information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or ask you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
- Right to Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Supplemental Notice. You may also request that we provide you with information about the following aspects of how we have handled your Personal Information specifically in the 12 months preceding your request:
  - The categories of Personal Information we have collected about you;
  - The categories of sources from which we collected such Personal Information;
  - The business or commercial purpose for collecting, Selling, or Sharing Personal Information about you;
  - The categories of Personal Information about you that we disclosed and the categories of Third Parties to whom we disclosed such Personal Information;
  - The categories of Personal Information about you that we sold, shared, or used for targeted advertising purposes, and the categories of Third Parties with whom we sold or shared such Personal Information;
  - If we collect Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and
  - The length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
- Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you.
- Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Access Specific Pieces of Personal Information and Data Portability: You may ask to obtain the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.
Rights that Do Not Require Verification. You may exercise these rights through the Your Privacy Choice link below.
- Right to Opt-Out of Sale: You have the right to opt out of the Sale of your Personal Information.
- Right to Opt-Out of the Sharing of Your Personal Information or the Use of Your Personal Information for Targeted Advertising. You have the right to opt-out of the Sharing of your Personal Information or our use of your personal Information for targeted advertising purposes.
- Right to Revoke Consent for or Limit the Use of Your Sensitive Personal Information. You also have the right to revoke consent for or limit the use of your Sensitive Personal Information to the purposes authorized by the applicable US Privacy Laws. We do not collect Sensitive Personal Information from California consumers.

Your Privacy Choices

Opt-Out Preference Signal. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by US Privacy Laws, we treat such opt-out preference signals as a valid request to opt-out of sale or sharing, for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of sale and sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. Please note that these opt-out preference signals are not the same as browser based Do Not Track signals, which we do not respond to.
Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
Appeals. Residents of certain states have the right to appeal our decisions on their data subject requests. This section does not apply to California residents, or to residents who reside in other states where the applicable US Privacy Law does not give them the right to appeal Controllers’ decisions regarding data subject rights. To appeal our decision on your data subject requests, you may contact us at privacy@macquarie.com or by calling toll-free 800 523-1918. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

H. Other Disclosures

Residents Under Age 18. If you are under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to privacy@macquarie.com. Please note that your request does not ensure complete or comprehensive removal of the content or data as, for example, some of your content or data may have been reposted by another user.
Direct Marketing. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of certain kinds of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not make such disclosures, but you are still permitted to request information. To make such a request, please send an email to privacy@macquarie.com with the subject Shine the Light Request.
Financial Incentives for California Residents. We do not provide financial incentives to California residents who allow us to collect, retain, Sell, or Share their Personal Information. We will describe such programs to you if and when we offer them to you.

I. Changes and Contact Information

Changes to our Supplemental Notice. We reserve the right to amend this Supplemental Notice in our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.
Contacting Us. If you have any questions, comments, requests, or concerns related to this Supplemental Notice, please contact us by mail at Macquarie Asset Management, Legal Department, 100 Independence, 610 Market Street, Philadelphia, PA 19106, or by email at privacy@macquarie.com.

Privacy Notice for Individual Investors

We are committed to protecting the privacy of our potential, current, and former customers. To provide the products and services you request, we must collect personal information about you. We do not sell your personal information to third parties. We collect your personal information and share it with third parties as necessary to provide you with the products or services you request and to administer your business with us. This notice describes our current privacy practices. While your relationship with us continues, we will update and send our privacy practices notice as required by law. We are committed to continuing to protect your personal information even after that relationship ends. You do not need to take any action because of this notice.

Information we may collect and use

We collect personal information about you to help us identify you as our potential, current, or former customer; to process your requests and transactions; to offer investment services to you; or to tell you about our products or services we believe you may want to use. The type of personal information we collect depends on the products or services you request and may include the following:

Information from you: When you submit your application or other forms or request information on our products (online or otherwise), you give us information such as your name, address, Social Security number, your financial account information, and your financial history.
Information about your transactions: We keep information about your transactions with us, such as the products you buy from us; the amount you paid for those products; your investment activity; and your account balances.
Information from your employer: In connection with administering your retirement plan, we may obtain information about you from your employer.
Information received from third parties: In order to verify your identity or to prevent fraud, we may obtain information about you from third parties.

How we use your personal information

We do not disclose nonpublic personal information about our potential, current, and former customers unless allowed or required by law. We may share your personal information within our companies and with certain service providers. They use this information to process transactions you have requested; provide customer service; and inform you of products or services we offer that you may find useful. Our service providers may or may not be affiliated with us. They include financial service providers (for example, third-party administrators; broker/dealers; and other financial services companies with whom we have joint marketing agreements). Our service providers also include nonfinancial companies and individuals (for example, consultants; information services vendors; and companies that perform mailing or marketing services on our behalf). Information obtained from a report prepared by a service provider may be kept by the service provider and shared with other persons; however, we require our service providers to protect your personal information and to use or disclose it only for the work they are performing for us, or as permitted by law.

We also may provide information to regulatory authorities, law enforcement officials, and others to prevent fraud or when we believe in good faith that the law requires disclosure. In the event of a sale of all or part of our businesses, we may share customer information as part of the sale. We do not sell or share your information with outside marketers who may want to offer you their own products and services.

Security of information

Keeping your information safe is one of our most important responsibilities. We maintain physical, electronic, and procedural safeguards to protect your information. Our employees are authorized to access your information only when they need it to provide you with products and services or to maintain your accounts. Employees who have access to your personal information are required to keep it strictly confidential. We provide training to our employees about the importance of protecting the privacy of your information.

Macquarie Asset Management (MAM) is the asset management division of Macquarie Group. MAM is an integrated asset manager across public and private markets offering a diverse range of capabilities, including real assets, real estate, credit, equities, and multi-asset solutions.

Other than Macquarie Bank Limited ABN 46 008 583 542 (Macquarie Bank), any Macquarie Group entity noted in this document is not an authorized deposit-taking institution for the purposes of the Banking Act 1959 (Commonwealth of Australia). The obligations of these other Macquarie Group entities do not represent deposits or other liabilities of Macquarie Bank. Macquarie Bank does not guarantee or otherwise provide assurance in respect of the obligations of these other Macquarie Group entities. In addition, if this document relates to an investment, (a) the investor is subject to investment risk including possible delays in repayment and loss of income and principal invested and (b) none of Macquarie Bank or any other Macquarie Group entity guarantees any particular rate of return on or the performance of the investment, nor do they guarantee repayment of capital in respect of the investment.

This privacy practices notice is being provided on behalf of the following:

Macquarie Management Holdings, Inc. and each of its affiliates, such as direct or indirect subsidiaries, and any fund or product sponsored by or otherwise affiliated with Macquarie
Central Park Group (CPG) Funds
Macquarie Funds
Macquarie ETF Trust
Macquarie Investment Management Austria Kapitalanlage AG
Macquarie Investment Management Europe Limited
Macquarie Investment Management Europe S.A.
Macquarie Investment Management Global Limited
Optimum Fund Trust

Revised January 2025

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