Our Commitment to Privacy

Personal Information We Receive

Neuberger Berman processes “Personal Information” regarding (i) its clients’ representatives when using any of our financial services, (ii) users of our Site, (iii) anyone who sends us an inquiry, registers for one of our events, or subscribes to our newsletters, as well as (iv) job applicants. Personal Information generally is information that includes a personal identifier like your name, email address or physical address, phone number, IP address or device identifier, or any data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, back to a natural person, household, or device, subject to definitions and exceptions under applicable law.

Some of the Personal Information we receive may also fall under the sub-category of “Sensitive Personal Information,” or a similar term, as defined by certain laws. This information may include information such as your Social Security / Insurance Number, driver’s license number, state identification card number, passport number, financial account and credit card information in combination with any required security or access code, geolocation data, and racial and/or ethnic information. We only collect and use Sensitive Personal Information in accordance with privacy laws, upon your consent where required and as necessary to fulfill business and legal purposes. We do not use such information to infer characteristics about you, and do not sell or share Sensitive Personal Information.

Personal Information we receive may include the following:

Personal Information we collect to provide financial services:

• Contact information, including first name, last name, email address, physical address, work and personal telephone numbers, and other similar identifiers.
• Payment and transactional data needed to provide you with financial services, including billing information.
• Professional or employment-related information, including title, company, and business phone number.
• Financial-related information, including income, net worth, and marital status.
• Social security or insurance numbers and tax identification number.
• Username and password.
• Security questions, security image, and security phrase.
• Other information as reasonably necessary for Neuberger Berman to provide financial services.

We may receive information that you provide to us, that we collect automatically, and that we obtain from third parties. Specifically, we may receive Personal Information about you from sources such as our clients and interested third parties in relation to our financial services. Such Personal Information could include contact details and any other categories of Personal Information provided to us and relevant to the services provided.

Personal Information we collect to respond to your inquiries, inform you about our services and events, send your our newsletters, and register you for our website:

• Contact information, including first name, last name, email address, physical address, work and personal telephone numbers, and similar identifiers, and your areas of interest.
• Professional or employment-related information, including job title, company name, and business phone number.
• Other information as reasonably necessary for Neuberger Berman to respond to your inquiry, inform you about our services and events, or send you our newsletters.

Personal Information we collect when you use the Site:

• Our system may collect information about your browser or mobile device automatically when you enter or utilize the Site. We may use cookies and similar technologies to help us understand your activity on our Site, as well as for email communications. Data we collect automatically includes your IP address, internet browser, operating system and other device identifiers; access dates and times, referring and exiting URLs, and the Internet Domain and Internet Protocol (IP) address from which you access our website.
• With respect to the areas of the Site that require entry of log-in credentials, we will collect and process the Personal Information provided to us when signing, including your contact details, username, and password. You can manage your cookie preferences through the cookie management tool on our website.

Personal Information we collect to evaluate and process your application for employment:

• Contact information, including first name, last name, email address, physical address, work and personal telephone numbers, social media profile URLs, and similar identifiers.
• Professional or employment-related information, including current job title, company name, and business phone number, as well as employment and education history.
• Depending on how far your application progresses, we may collect Sensitive Personal Information, including your Social Security / Insurance Number, racial identity, gender identity, and immigration status (such as whether you are legally eligible to work in the country in which the position for which you are applying is located).
• Other information as reasonably necessary for Neuberger Berman to evaluate and process your application for employment.

How We Use Your Personal Information

Neuberger Berman processes Personal Information in order to:

• perform a contract with you;
• provide you with our financial services;
• manage our relationship with you and carry out any related administration;
• send you communications;
• manage payments, fees and charges and secure prompt payment of any fees, costs and debts with respect to our services;
• ensure we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism;
• provide you with online services and improve our Site;
• respond to your inquiries, inform you about our services and events, and send you our newsletters;
• notify you about changes to our terms of business or Privacy Policy;
• evaluate and process your application for employment;
• meet our corporate and social responsibility commitments;
• detect, and protect against breaches of our policies and applicable laws;
• comply with applicable legal and regulatory obligations, including responding to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities, and responding to valid legal process; and
• protect or defend your rights, property or security or ours.

Disclosure of Personal Information

For the purposes referred to under this Privacy Policy, we may need to disclose certain Personal Information to certain recipients. We may disclose your Personal Information in the following limited circumstances:

• Authorized Third Parties and Service Providers: We may disclose your Personal Information to processors (e.g., our affiliates and offices) that provide us with the services necessary for the achievement of the purposes described above, and our third-party services providers that provide various types of services, including IT services and companies that provide web analytics, email distribution, and other services. These third parties are only permitted to use your Personal Information to the extent necessary to enable them to provide their services to us. They are required to follow our instructions and to comply with appropriate security measures to protect your Personal Information.
• Advertising and analytics partners: We may use cookies to enhance your experience when you visit our Site, to enable additional functionality, or to show you ads on our website or third-party websites that are more relevant to you.
• Other Parties When Required by Law or as Necessary: We may disclose your Personal Information to our affiliates, offices and other entities, which may be legal or government authorities or third parties in connection with claims, disputes, litigation or investigations where we reasonably believe that disclosure is required by law or pursuant to legal process, or is necessary to establish, exercise or defend legal claims, including to protect or defend your rights, property or security or ours.
• Other Parties With Your Consent: There may be instances where we disclose your Personal Information to other authorized third parties when you expressly consent to such sharing.
• Other Parties In Connection With a Transfer of Assets: If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer, we may transfer your information to one or more third parties as part of that transaction in a manner consistent with this Privacy Policy.

Neuberger Berman does not knowingly collect, use, or disclose, and does not sell or share, Personal Information from children. If Neuberger Berman is made aware that it has collected Personal Information from a child that is not provided by a parent or guardian in the course of our services or in a manner that is inconsistent with applicable laws, Neuberger Berman will delete this information as soon as possible.

Your Privacy Rights

Depending on the jurisdiction in which you live, you may have the following rights subject to the exceptions allowed by law, including under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), as well as other state and national laws in the US and Canada:

• Access / know / portability of the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which the personal information is collected, the business purpose for collecting the Personal Information, and the categories of third parties with whom we share personal information. You may also have the right to have your Personal Information released to you or another person in a structured, commonly used technological format.
• Delete: personal information under certain circumstances.
• Transparency: Businesses that collect Personal Information subject to the above listed laws are required to provide you with notice regarding the categories of Personal Information to be collected, the purposes for which the categories of Personal Information are collected or used, 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, among other information.
• Correct inaccurate or obsolete Personal Information that Neuberger Berman may maintain. Registered website users are permitted to change their personal information by logging in to the "Customize NB.com Content" section of our website. We also allow customers to change their registered email address in NB DeliverESM and our other electronic delivery services, by logging in to account access and changing their email address in the appropriate account maintenance area.
• Not to be discriminated against on the basis of your exercising any of your rights afforded by state law.
• Limit the use and disclosure of Sensitive Personal Information. Neuberger Berman does not use your Sensitive Personal Information in any manner that requires the right to limit because Neuberger Berman only collects, uses, or discloses Sensitive Personal Information as necessary to provide you with goods or services, and does not sell or share Sensitive Personal Information.
• Opt out of the sale or sharing of Personal Information: Under some state privacy laws, our sharing of Personal Information via cookies may be considered a “sale” or “share” for targeted advertising. You may opt out by using our Cookie Management Tool and rejecting relevant cookies (i.e., selecting “Reject All”). We also process valid opt-out preference signals that use the Global Privacy Control (“GPC”) signal. Through an opt-out preference signal, you can opt out of sharing your Personal Information with all businesses that you interact with online without having to make individualized requests.
• Withdraw Consent to the continued use or disclosure of your Personal Information, where the information was collected with your consent (and subject to contractual and legal limitations, and reasonable notice).

To exercise your rights, you may contact us through any of the following methods:

• Via email at NBPrivacyOfficer@nb.com; or
• Via phone at 1-866-483-1046 or 1-646-497-4003.

We will timely acknowledge receipt of your request within 10 business days and then provide a substantive response within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing. If we deny your request, you may appeal our decision by emailing your request to NBPrivacyOfficer@nb.com or calling us at 1-866-483-1046. Within 45 calendar days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision.

To protect your personal information, we will verify your identity using data points you have previously provided to us. Depending on how you interact with us, we may require that you provide at least two pieces of Personal Information, such as your name, email address, client number, or other information that we already have in our possession. We will verify your request by comparing the information you provide to information already in our possession to minimize the risk of fraud. We will only use the Personal Information provided in the context of your request to verify your identity or the authority of your authorized agent to make the request.

You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and you have taken steps to verify your identity directly with us. Only you or your authorized agent may make a verifiable consumer request related to your Personal Information.

Should you need access to this policy in an alternative format due to a disability, please contact us through the methods provided above.

Security and Storage

We are committed to providing a safe and secure online environment. Neuberger Berman maintains appropriate technical and organizational security procedures in order to protect your Personal Information from loss, misuse, unauthorized access, disclosure or alteration, in accordance with applicable data protection and privacy laws. We use Transport Layer Security (TLS) encryption whenever personal information is made available via our website, as well as usernames, passwords, security questions, and device matching to secure access to your information. As part of our overall commitment to privacy, we limit access to your personal and financial data to those personnel at Neuberger Berman and our service providers who have a bona fide need for this information.

In addition to such measures, Neuberger Berman maintains confidentiality policies that govern all information that all employees receive and are made aware of in the course of their employment. Despite our efforts, we cannot guarantee that Personal Information may not be accessed, disclosed, or altered by breach of our safeguards. You should take adequate precautions to protect your Personal Information.

Retention of Personal Information

General principles

The data retention period applied by Neuberger Berman for the retention of personal information may vary, depending on the relevant purpose. The criteria used to determine our retention periods may include:

• The length of time Neuberger Berman has an ongoing relationship with you, including to provide you with services;
• Whether you modify or delete information through your online account with us (if applicable);
• Whether we have a legal obligation to keep the data; or
• Whether retention is advisable due to our legal position (for example, in relation to enforcing any agreements we have entered into, litigation, or inquiries from government regulators).

Third-Party Links

The Site may contain hyperlinks to websites of third parties. This Privacy Policy does not apply to such third-party content or websites. If individuals decide to follow such links, they must be aware that Neuberger Berman does not take any responsibility for the third-party content or compliance of the third-party website with data privacy laws. Individuals are encouraged to make themselves aware of applicable privacy policies before they submit Personal Information to third-party websites.

Changes to this Policy

Neuberger Berman reserves the right to change or update this Privacy Policy at any time. The applicable version of this Privacy Policy is available on the Site. If such change to the Privacy Policy requires your consent, you will have a choice to consent as to whether or not Neuberger Berman may use your Personal Information in the revised manner.

Additional Information for Residents of Canada

Transfer of Personal Information

The Site is hosted and operated in the United States and other jurisdictions through Neuberger Berman and its service providers, and laws in the United States and other jurisdictions may differ from the laws where you reside. If you are located in Canada, your Personal Information may be transferred outside of Canada. Similarly, if you are located in Quebec, your Personal Information may be transferred outside of Quebec.

We and our service providers may disclose your Personal Information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate. For information about the manner in which we or our service providers treat Personal Information, please see the Disclosure of Personal Information section above. If you are located in Alberta, and you have any questions, or wish to receive written information about our practices or policies with respect to the processing of personal information by service providers or affiliates outside of your jurisdiction, you may contact our Global Privacy Officer at NBPrivacyOfficer@nb.com.

Your Canadian Privacy Rights

In addition to the rights listed in the main Your Privacy Rights section above and depending on the jurisdiction in which you live, you may also have the following rights subject to the exceptions allowed by law:

• De-indexation. You may have the right to require that we cease disseminating information about you, or to require us to de-index or re-index any hyperlink attached to your name that provides access to the information by technological means.
• Challenging Compliance. You may have the right to challenge our compliance with applicable privacy and data protection laws, and make complaints or inquiries regarding same.

Contact

For any requests, questions or comments about this Privacy Policy or the collection, processing, or storage of your Personal Information by Neuberger Berman, please contact Neuberger Berman’s Privacy Officer via e-mail at NBPrivacyOfficer@nb.com or call us at 1-866-483-1046 or 1-646-497-4003.