Our Commitment to Privacy

Your privacy is important to us. Neuberger Berman and its subsidiaries (collectively “Neuberger Berman” or “we” or “us” or “our”) is committed to safeguarding the privacy of our clients, business partners, contacts, job applicants, website visitors, and subscribers (collectively, “you”) and to protect the personal information you share with us. To view the Gramm-Leach-Bliley Act (GLBA) Privacy Notice applicable to customers of Neuberger Berman and its affiliated companies and mutual funds, please click here.

This Privacy Policy applies to the processing of personal information by Neuberger Berman, acting as a controller, in connection with:

  • your use of our website https://www.nb.com and any online services offered through the website (collectively, the “Site”);
  • the services offered by Neuberger Berman to its clients and business partners; and
  • communications with you, including to respond to your inquiries, inform you about our services and events, and to send you our newsletters (including blogs, client alerts, invitations to webcasts, or other materials).

This Privacy Policy explains our privacy practices, including the types of personal information collected by Neuberger Berman, and how such information may be collected, used, processed, utilized, maintained, or shared.

Highlights

What information do we collect?

The types of personal information (“Personal Information”) we collect about you will vary, depending on your use of our services and our Site. This information may include:

  • Contact information (e.g., name, email address, physical address, work and personal telephone numbers, and other similar identifiers);
  • Payment and transactional information, such as billing information;
  • Professional and employment-related information (e.g., title, company);
  • Financial-related information (e.g., income, net worth, marital status);
  • Government ID numbers, such as social security / insurance or tax identification number;
  • Account information (e.g., username, password, security questions, security image, security phrase);
  • Marketing information (e.g., areas of interest);
  • Application information (e.g., resume, cover letter, application materials, social media profile URLs) if you apply for a job with us, or other required information if you progress in the application process (e.g., social security / insurance number, racial and gender identity, immigration status);
  • Technical information when you use our Site (e.g., information of the device and browser used to access our Site, such as IP address, internet browser, operating system and other device identifiers; access dates and times, referring and exiting URLs, and the Internet Domain and IP address from which you access our Site); and
  • Other information reasonably necessary in order to provide our services, or as otherwise required or permitted by law.

For more information, see below.

Why do we collect this information?

We use the information above for the following purposes:

  • To perform a contract with you, including to provide you with our financial services;
  • To manage our relationship with you and carry out related administrative tasks;
  • To send you communications, respond to inquiries, inform you about services and events, notify you about changes to our terms of business or privacy policy, and send you newsletters;
  • To manage payments, fees and charges, and to secure prompt payment of our service fees;
  • To meet our corporate and social responsibility commitments, including to ensure we do not accept proceeds of crime or assist in fraudulent or unlawful activities;
  • To provide our online services and operate and improve our Site;
  • To evaluate and process your application for employment (if applicable); and
  • Otherwise with your consent or where permitted or required by law, including to enforce our legal rights, detect and protect against breaches of our policies and applicable laws, and comply with legal or regulatory obligations (including requests from governmental authorities).

For more information, see below.

How is your information shared?

We may disclose your Personal Information under the following circumstances:

  • To authorized third parties and service providers who assist us in achieving the purposes set out above, including IT services, web analytics, email distribution, and other service providers;
  • To advertising and analytics partners;
  • To facilitate a merger, acquisition, reorganization or sale of all or a portion or Company assets;
  • When you have expressly consented to the disclosure; and
  • As required or authorized by law to do so without your consent.

For more information, see below.

What are the risks?

We take steps to ensure that the Personal Information that we collect is protected. These steps include physical, technical and administrative safeguards. However, perfect security does not exist, and we cannot guarantee the absolute security of your Personal Information.

For more information, see below.

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.

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.

Last updated March 2025

How Does Neuberger Treat Your Personal Information?

Neuberger is committed to preserving your privacy and strictly adheres to applicable law, which requires us to tell you how we collect, use, disclose, process and protect your personal information. Where there is inconsistency between this statement and applicable law, we will apply the standard that affords a stronger level of protection. Please read this statement carefully to understand what we do.

Who is providing this statement

This notice is provided by Neuberger Berman Asia Limited

Types of personal information we collect

The types of personal information we collect, use and disclose will depend on our relationship with you and may include:

  • your name, address, occupation, email address, telephone/facsimile number(s), identification document number
  • marital status, date of birth, number of dependents
  • your financial status, income, assets and transaction history
  • your education and/or employment history
  • your credit history and credit scores (in Australia, we do not collect, use or disclose this information)
  • government related identifiers that identify you (in Australia, this may include ABN, Medicare card number, pension card number, driver’s licence number and tax file number)
  • other information relating to your relationship with Neuberger
  • technical information when you use our website (e.g., information of the device and browser used to access our website, such as IP address, internet browser, internet domain, operating system and other device identifiers, access dates and times, referring and exiting URLs)

When our relationship with you ceases, we may continue to retain, use and disclose your information as described in this statement provided there is a business or legal purpose to do so.

Why we collect your personal information

Generally, we collect, use, disclose, process and update personal information for our everyday business purposes, which may include:

  • providing you with Neuberger product(s) or services
  • your employment with Neuberger
  • complying with our obligations under applicable law relating to the Neuberger product(s) or service or your employment with Neuberger (as the case may be)
  • meet our ongoing obligations to you in providing you with the Neuberger product(s) or service or as your employer (as the case may be)
  • processing your transactions
  • maintaining your account(s) or administering any facility you have with us
  • protecting against fraud
  • meeting our obligations under applicable law, such as customer identification requirements relating to “know your client” (“KYC”) due diligence, search and registration purposes, data collection and retention, taxation anti-money laundering (“AML”), and/or combating terrorist financing (in Australia these laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Personal Property Securities Act 2009 (Cth), the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1997 (Cth) and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation))
  • responding to government agency's requests, court orders and legal investigations
  • receiving reports from, or reporting to, credit bureaus
  • to share your personal information with related bodies corporate

How we collect your personal information

We may collect your personal information when, for example, you

  • open an account or provide account information
  • become an employee of Neuberger (for example through your curriculum vitae or from references given to us in connection with your employment)
  • transact with us or others (including information regarding your income and transaction history)
  • seek advice about your investments or give us your income information
  • give us your contact information
  • use our website

We may also collect your personal information from other sources, such as credit bureaus, affiliates or other third parties who provide us with specific information to assist us in delivering our products and services to you.

How we protect your personal information

Your personal information may be stored in hard copy documents or electronically in our software or systems. When no longer required, we take reasonable steps to destroy or de-identify your personal information.

To protect your personal information from unauthorized access, disclosure, use and other similar risk, we take security measures that comply with applicable law. These measures include technological, administrative and organizational measures including computer safeguards and secured files and buildings.

We restrict access to your personal information to those personnel at Neuberger, and our service providers, who have a bona fide need for this information in order to perform their job responsibilities.

You can sometimes access other organisations’ websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites.

What happens if you don’t allow us to collect your personal information

If you do not provide us with any requested personal information this may mean that we are unable to provide you with a product or service.

For example, if you choose to restrict our website from placing a “cookie”* on your hard drive, you may not be able to use some of the features on our website that depend on cookies.

* Cookies are tiny packets of information that websites store on your computer’s hard drive so that your computer will “remember” information about your visit. Our website makes use of these cookies to enhance your experience when you visit.

Who your personal information may be disclosed to and their locations

We may disclose your personal information to affiliates in order to meet our obligations to you and for other purposes as described above. We may also disclose your personal information for such purposes to other organizations, such as:

  • external service providers involved in our provision of products and services to you, such as mailing houses, professional advisers (such as our lawyers and compliance advisers), identity verification services, call services, researches, data analysts, auditors
  • your agents, advisers or lawyers, in such circumstances where you have obtained a product or service from us through them or are otherwise dealing with us in any way through them
  • parties involved in markets and systems related to the products and services we provide to you, such as market operators and participants, counterparties, intermediaries and custodians
  • entities assisting us to maintain and improve our systems, products and services
  • entities to whom we are required or authorised by applicable law to disclose your personal information, such as government and regulatory bodies
  • members of the Neuberger group and related entities
  • other financial institutions, government bodies and credit providers
  • your nominated referees
  • organisations through whom you choose to make payments to the Neuberger group
  • organisations wishing to acquire an interest in any part of Neuberger’s business for assessing or implementing any such acquisition

Because our operations involve activities both within and outside the jurisdiction in which you have a relationship with Neuberger, some of these disclosures may be to entities that are overseas. It is not practicable to list every country in which such recipients are located but it is likely that the countries to which your information may be disclosed include the United States of America, the United Kingdom, Ireland, China, Australia, Hong Kong, Taiwan and Singapore.

How long will your personal information be retained

We will retain your personal information for as long as is necessary to satisfy the purpose for which it was collected or as required by relevant laws, whichever is the longer. We will cease to retain your personal information if there is no longer any business or legal purpose to do so.

How we use your personal information

We may collect, process and use your personal information manually or through automated means (such as through computers), provided always that we will collect, process and use your personal information by means which are lawful and fair in the circumstances.

Access to personal information and other rights

You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions allowed by applicable law. We will respond to your request in accordance with applicable law. If we deny your access request we will provide you with reasons for doing so. Please note that we may charge a fee for complying with your request.

We aim to keep your personal information held by us up-to-date. If you believe that the personal information we hold about you is incorrect, please let us know so we can correct this.

To access or update your personal information, please contact our Data Protection Officer (details for whom are set out below).

How we will deal with a complaint

If you believe your personal information has not been treated consistently with our legal obligations or that we have failed to comply with our legal obligations, please contact our Data Protection Officer (details for whom are set out below). You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it.

We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within a reasonable time after we receive your notice.

If your personal information was collected in Australia and you are unhappy with the handling of your complaint you also have rights to complain to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).

Communication and marketing

We will not use your personal information for direct marketing purposes unless we have your express consent. If you wish to withdraw your consent, please call us using the details below.

You understand that we may contact you by all relevant means (for example, by letter, email or phone). If you provide Neuberger with an email address, you consent to electronic communications being sent to you via that email address, including notices and reminders. To protect your privacy, we recommend that any email address you provide to us be your personal email address rather than, for example, an email address accessible by your work colleagues or family members.

Contacts

To access or update your personal information, please write to us at:

Neuberger Data Protection Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

or call:

  • Hong Kong +852.3664.8800
  • Australia +61.3.9649.0900
  • Singapore +65.6645.3760
  • Shanghai +86.21.5203.7768

Neuberger Berman India Private Limited
1302, Tower-3, One International Center, Senapati Bapat Marg, Elphinstone Road (West), Mumbai, Maharashtra, India- 400 013

If you have any complaints regarding our handling of your personal data, please let us know at:

Neuberger Complaints Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

How Does Neuberger Treat Your Personal Information?

Neuberger is committed to preserving your privacy and strictly adheres to applicable law, which requires us to tell you how we collect, use, disclose, process and protect your personal information. Where there is inconsistency between this statement and applicable law, we will apply the standard that affords a stronger level of protection. Please read this statement carefully to understand what we do.

Who is providing this statement

This notice is provided by Neuberger Berman Australia Limited (ABN 90 146 033 80)

Types of personal information we collect

The types of personal information we collect, use and disclose will depend on our relationship with you and may include:

  • your name, address, occupation, email address, telephone/facsimile number(s), identification document number
  • marital status, date of birth, number of dependents
  • your financial status, income, assets and transaction history
  • your education and/or employment history
  • your credit history and credit scores (in Australia, we do not collect, use or disclose this information)
  • government related identifiers that identify you (in Australia, this may include ABN, Medicare card number, pension card number, driver’s licence number and tax file number)
  • other information relating to your relationship with Neuberger
  • technical information when you use our website (e.g., information of the device and browser used to access our website, such as IP address, internet browser, internet domain, operating system and other device identifiers, access dates and times, referring and exiting URLs)

When our relationship with you ceases, we may continue to retain, use and disclose your information as described in this statement provided there is a business or legal purpose to do so.

Why we collect your personal information

Generally, we collect, use, disclose, process and update personal information for our everyday business purposes, which may include:

  • providing you with Neuberger product(s) or services
  • your employment with Neuberger
  • complying with our obligations under applicable law relating to the Neuberger product(s) or service or your employment with Neuberger (as the case may be)
  • meet our ongoing obligations to you in providing you with the Neuberger product(s) or service or as your employer (as the case may be)
  • processing your transactions
  • maintaining your account(s) or administering any facility you have with us
  • protecting against fraud
  • meeting our obligations under applicable law, such as customer identification requirements relating to “know your client” (“KYC”) due diligence, search and registration purposes, data collection and retention, taxation anti-money laundering (“AML”), and/or combating terrorist financing (in Australia these laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Personal Property Securities Act 2009 (Cth), the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1997 (Cth) and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation))
  • responding to government agency's requests, court orders and legal investigations
  • receiving reports from, or reporting to, credit bureaus
  • to share your personal information with related bodies corporate

How we collect your personal information

We may collect your personal information when, for example, you

  • open an account or provide account information
  • become an employee of Neuberger (for example through your curriculum vitae or from references given to us in connection with your employment)
  • transact with us or others (including information regarding your income and transaction history)
  • seek advice about your investments or give us your income information
  • give us your contact information
  • use our website

We may also collect your personal information from other sources, such as credit bureaus, affiliates or other third parties who provide us with specific information to assist us in delivering our products and services to you.

How we protect your personal information

Your personal information may be stored in hard copy documents or electronically in our software or systems. When no longer required, we take reasonable steps to destroy or de-identify your personal information.

To protect your personal information from unauthorized access, disclosure, use and other similar risk, we take security measures that comply with applicable law. These measures include technological, administrative and organizational measures including computer safeguards and secured files and buildings.

We restrict access to your personal information to those personnel at Neuberger, and our service providers, who have a bona fide need for this information in order to perform their job responsibilities.

You can sometimes access other organisations’ websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites.

What happens if you don’t allow us to collect your personal information

If you do not provide us with any requested personal information this may mean that we are unable to provide you with a product or service.

For example, if you choose to restrict our website from placing a “cookie”* on your hard drive, you may not be able to use some of the features on our website that depend on cookies.

* Cookies are tiny packets of information that websites store on your computer’s hard drive so that your computer will “remember” information about your visit. Our website makes use of these cookies to enhance your experience when you visit.

Who your personal information may be disclosed to and their locations

We may disclose your personal information to affiliates in order to meet our obligations to you and for other purposes as described above. We may also disclose your personal information for such purposes to other organizations, such as:

  • external service providers involved in our provision of products and services to you, such as mailing houses, professional advisers (such as our lawyers and compliance advisers), identity verification services, call services, researches, data analysts, auditors
  • your agents, advisers or lawyers, in such circumstances where you have obtained a product or service from us through them or are otherwise dealing with us in any way through them
  • parties involved in markets and systems related to the products and services we provide to you, such as market operators and participants, counterparties, intermediaries and custodians
  • entities assisting us to maintain and improve our systems, products and services
  • entities to whom we are required or authorised by applicable law to disclose your personal information, such as government and regulatory bodies
  • members of the Neuberger group and related entities
  • other financial institutions, government bodies and credit providers
  • your nominated referees
  • organisations through whom you choose to make payments to the Neuberger group
  • organisations wishing to acquire an interest in any part of Neuberger’s business for assessing or implementing any such acquisition

Because our operations involve activities both within and outside the jurisdiction in which you have a relationship with Neuberger, some of these disclosures may be to entities that are overseas. It is not practicable to list every country in which such recipients are located but it is likely that the countries to which your information may be disclosed include the United States of America, the United Kingdom, Ireland, China, Australia, Hong Kong, Taiwan and Singapore.

How long will your personal information be retained

We will retain your personal information for as long as is necessary to satisfy the purpose for which it was collected or as required by relevant laws, whichever is the longer. We will cease to retain your personal information if there is no longer any business or legal purpose to do so.

How we use your personal information

We may collect, process and use your personal information manually or through automated means (such as through computers), provided always that we will collect, process and use your personal information by means which are lawful and fair in the circumstances.

Access to personal information and other rights

You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions allowed by applicable law. We will respond to your request in accordance with applicable law. If we deny your access request we will provide you with reasons for doing so. Please note that we may charge a fee for complying with your request.

We aim to keep your personal information held by us up-to-date. If you believe that the personal information we hold about you is incorrect, please let us know so we can correct this.

To access or update your personal information, please contact our Data Protection Officer (details for whom are set out below).

How we will deal with a complaint

If you believe your personal information has not been treated consistently with our legal obligations or that we have failed to comply with our legal obligations, please contact our Data Protection Officer (details for whom are set out below). You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it.

We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within a reasonable time after we receive your notice.

If your personal information was collected in Australia and you are unhappy with the handling of your complaint you also have rights to complain to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).

Communication and marketing

We will not use your personal information for direct marketing purposes unless we have your express consent. If you wish to withdraw your consent, please call us using the details below.

You understand that we may contact you by all relevant means (for example, by letter, email or phone). If you provide Neuberger with an email address, you consent to electronic communications being sent to you via that email address, including notices and reminders. To protect your privacy, we recommend that any email address you provide to us be your personal email address rather than, for example, an email address accessible by your work colleagues or family members.

Contacts

To access or update your personal information, please write to us at:

Neuberger Data Protection Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

or call:

+61.3.9649.0900

If you have any complaints regarding our handling of your personal data, please let us know at:

Neuberger Complaints Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

路博迈如何处理阁下的个人资料？

路博迈致力保障阁下的隐私，并严格遵守适用法律，有关法律要求本公司向阁下阐述本公司如何收集、使用、披露、处理和保护阁下的个人资料。本声明与适用法律如有歧异，路博迈将采用保障性较强的标准，请仔细阅读本声明以了解本公司的行事。

那些机构作出本声明

本通告由路博迈信息咨询（上海）有限公司(Neuberger Berman Information Consulting (Shanghai) Limited)提供。

我们所收集的个人资料种类

本公司所收集、使用和披露的个人资料种类，将根据合法、正当、必要的原则，仅收集实现产品或提供服务功能所必要的信息，并将根据本公司与阁下的关系，且可能包括：

  • 阁下的姓名、地址、职业、电邮地址、电话/传真号码、身份证明文件号码
  • 婚姻状况、出生日期、受养人数目
  • 阁下的财政状况、收入、资产和交易纪录
  • 阁下的教育及/或就业纪录
  • 阁下的信用纪录和信用评分(在澳大利亚，我们不会收集、使用或披露这些资讯)
  • 可识别阁下的政府相关识别资料(在澳大利亚，这可能包括澳洲商务号码、医疗保健卡号码、退休金卡号码、驾驶执照号码和报税号码)
  • 路博迈与阁下的关系有关的其他资料

当本公司与阁下关系终止，在出于业务或法律的目的下，本公司可能如本声明所述继续保留、使用和披露阁下的数据。

我们收集阁下的个人资料的目的

一般来说，本公司收集、使用、披露、处理和更新个人资料以作日常业务用途，这些用途可能包括：

  • 为阁下提供路博迈产品或服务
  • 让阁下受雇于路博迈
  • 履行本公司在适用法律下，与路博迈产品或服务或是让阁下受雇于路博迈相关的义务(视属何情况而定)
  • 持续履行本公司为阁下提供路博迈产品或服务，或作为阁下的雇主的义务(视属何情况而定)
  • 处理阁下的交易
  • 维持阁下的账户或处理阁下在本公司的任何融通服务
  • 防范欺诈
  • 履行本公司在适用法律下的义务，例如与「了解阁下的客户」(“know your client”, “KYC”)的尽职调查有关的客户识别要求、搜寻和登记目的、收集和保留数据、反清洗黑钱税务安排，及/或打击恐怖分子融资活动(在澳洲，这些法律包括 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) 、 Personal Property Securities Act 2009 (Cth) 、 Taxation Administration Act 1953 (Cth)、Income Tax Assessment Act 1997 (Cth) 及其他税务法律(例如履行与就业有关的义务或响应由税务局局长发出的索取资料要求))
  • 响应政府机构的要求、法令和法律调查
  • 自信用局获取报告或向其汇报
  • 进行有关客户服务和网站开发的内部分析与研究
  • 我们可能会就内部分析与研究，与您联系
  • 与相关企业机构分享阁下的个人资料

我们如何收集阁下的个人资料

本公司在以下情况下可能收集阁下的个人资料，例如当阁下：

  • 开立帐户或提供帐户数据
  • 成为路博迈的雇员(例如透过阁下的履历或就阁下的聘任而提供予本公司的推荐函)
  • 与本公司或其他方进行交易(包括有关阁下的收入和交易纪录的数据)
  • 就阁下的投资寻求意见或向本公司提供阁下的收入数据
  • 向本公司提供阁下的联系数据
  • 使用本公司的网站，将收集网站技术性资讯，例如IP地址、网际网路浏览器、网际网路网域、作业系统及其他装置识别码、访问日期及时间、连入及离开之网址，提升用户体验

本公司也可能自其他来源收集阁下的个人资料，例如信用局、关联机构或其他可提供特定数据的第三方，以协助本公司为阁下提供本公司的产品和服务。我们将按照本声明以及相关法律法规对待其他来源收集的阁下的个人资料。

我们如何保护阁下的个人资料

阁下的个人资料可能以纸本文件存放或以电子方式储存于本公司的软件或系统内。当有关数据不再需要时，本公司将采取合理步骤销毁阁下的个人资料或将之匿名化。

为了保障阁下的个人资料免在未经授权下被取览、披露和使用以及免受其他类似风险，本公司采取了符合适用法律的安全措施。此等措施包括科技、行政和组织架构的措施，涵盖计算机防护和档案及建筑物防御。

本公司将阁下的个人资料之取览，限于真正需要此等数据以履行职务的路博迈人员或其他服务供货商。

若发生个人信息泄露等安全事件，我们会启动应急预案，阻止安全事件扩大，并以推送通知、公告等形式告知您。

阁下有时候可透过本公司网站内的连结进入其他机构的网站。请注意，本公司不会就该等机构和外部网站的私隐标准和处理过程负责。

如阁下不容许我们收集阁下的个人资料之后果

如阁下没有向本公司提供任何所要求的个人资料，可能意味着本公司无法为阁下提供产品或服务。

举例说，如阁下选择限制本公司的网站在阁下的计算机硬盘内放置cookie*，阁下便可能无法使用本公司网站内倚赖cookie提供的部分服务。

* Cookies是网站储存于阁下的计算机硬盘内的小型文本文件，让阁下的计算机能够「留存」阁下浏览网站的数据。路博迈网站使用此等 cookies 是为提升阁下到访本公司网站的体验。

阁下的个人资料有可能向那些机构披露及其所在地

为履行本公司对阁下的义务及出于以上所述的其他目的，本公司可能向关联机构披露阁下的个人资料。本公司亦可能基于该等目的向其他机构披露阁下的个人资料，例如：

  • 本公司为阁下提供产品和服务所涉及的外部服务供货商，例如邮递公司、专业顾问(例如本公司的律师和合规顾问)、身份核实服务、电话服务、研究、数据分析师、审计师等
  • 阁下的代理、顾问或律师，在该等情况下，阁下透过他们获得本公司的产品或服务，或在其他情况下以任何方式透过他们与本公司进行事务往来
  • 本公司为阁下提供的产品和服务所涉及的市场和系统方，例如市场营运商和参与者、合约对手方、中介人和保管人
  • 协助本公司维持和改善本公司的系统、产品和服务的实体
  • 适用法律要求或授权本公司向其披露阁下的个人资料的实体，例如政府和监管机构
  • 路博迈集团和相关实体的成员
  • 其他金融机构、政府机构和信贷供货商
  • 阁下指定的咨询人
  • 阁下选择透过其支付路博迈集团的机构
  • 有意收购路博迈任何业务部分的权益，并须评估或落实任何该收购计划的机构

由于本公司的营运涉及在阁下与路博迈建立关系所在司法管辖区区内及区外之活动，因此本公司可能向海外实体披露部分此等数据。要逐一列出该等收件人的所在国家并不切实可行，但阁下的资料有可能向以下 国家/地区披露，包括美国、英国、爱尔兰、中国、澳洲、香港、台湾和新加坡。

如阁下的个人信息被披露至中国以外的区域，我们将进行安全评估以确保由转移引起的风险是具有正当理由的。就转移到路博迈集团海外实体，本公司将承诺该等披露被严格监控并符合相关的保密原则。

本公司要求所有第三方实施严格的个人资料的保密制度。如该等第三方是本公司聘请的管理或保存个人资料的服务商，本公司将监督该等服务商是否满足事先约定的合同义务。但本公司无法保证该等第三方在使用阁下的个人信息是违反相关法律或合同义务。

阁下的个人资料将保留多久

只要符合收集的目的或是根据相关法律的要求(以时间较长者为准)，本公司在有需要时将一直保留阁下的个人资料。如再没有任何业务或法律的需要，本公司不会保留阁下的个人资料。

我们如何使用阁下的个人资料

只要本公司透过合法途径和在公平的情况下收集、处理和使用阁下的个人资料，本公司可经人手或透过自动化方式(例如透过计算机)，收集、处理和使用阁下的个人资料。

个人资料取览权和其他权利

阁下有权要求取览本公司所持有的阁下的个人资料，阁下的取览权在适用法律容许下将受一些例外情况所约束。本公司将根据适用法律响应阁下的要求。如本公司拒绝阁下的取览要求，本公司将向阁下提供理由。请注意， 本公司可能需要收取费用以响应阁下的要求。

本公司致力于确保所持有的阁下的个人资料符合现况。如阁下相信本公司所持有的阁下的个人资料并不正确，请通知本公司加以更正。

阁下可以随时以合理通知本公司的资料保障主任的方式取消阁下的同意。

本公司非常重视对未成年人个人信息的保护。若阁下是18周岁以下的未成年人，在使用本公司的服务前，应事先取得您家长或法定监护人的书面同意。本公司根据国家相关法律法规的规定保护未成年人的个人信息的保密性及安全性。

要取览或更新阁下的个人资料，请联络本公司的数据保障主任(联络数据在下文详列)。

我们如何处理投诉

如阁下相信阁下的个人资料未有根据与本公司的法律义务相符的方式处理，或是本公司未有履行法律义务，请联络本公司的数据保障主任(联络数据在下文详列)。在本公司收到阁下的投诉后，本公司将在合理可行的范围内尽快向阁下发出确认接获投诉的通知。

本公司会调查所有投诉，并将在合理可行的范围内尽快回复，目标是在接获阁下的通知后的合理时间内处理阁下的投诉。

传播和营销

除非获得委托表示同意，否则本公司不会将征集的个人资料作为直销用途。若委托人希望撤回回地下水已同意的安排，请采用以下方式与我们联系。

若询向路博迈提供询价地址，则表示询价同意本公司经询询函或电话通讯，包括通知和提示。对于询价的私隐，本公司建议询价向本公司提供询价的个人地址，或例如询价的同事或家庭成员能够取览的另一个地址。

联系资料

希望取览或更新阁下的个人资料，请致函本公司，地址为：

路博迈资料保障主任
香港中环康乐广场 1 号
怡和大厦 20 楼

或致电:

  • 香港 +852.3664.8800
  • 上海 +86.21.5203.7768

如阁下就本公司处理阁下的个人资料有任何投诉，请致函通知本公司，地址为：

路博迈投诉主任

香港中环康乐广场 1 号
怡和大厦 20 楼

Our Commitment to Privacy

This policy applies to:

  1. Neuberger Berman Europe Limited (company number 05463227) with registered office The Zig Zag Building, 70 Victoria Street, London SW1E 6SQ (“NBEL”), on behalf of itself, its representative offices, branches and subsidiaries (and their respective branches and representative offices) including:
  2. Neuberger Berman AIFM S. à r. l. (company number B222747), with registered office 9 rue du Laboratoire, L-1911, Grand Duchy of Luxembourg;
  3. Neuberger Berman Asset Management Ireland Limited (company number 629805), with registered office 2 Central Plaza, Level 2, Dame Street, Dublin, D02 T0X4, Ireland;
  4. Neuberger Berman (Switzerland) GmbH (company number CHE-314.552.483, with registered office Börsenstrasse 26, Ground Level, Zurich 8001 – Switzerland; and
  5. Neuberger Berman Saudi Investment Company (company number 1009185808), with registered office Dhahban Street, Al-Mohammadiyah District, Postal Code 12363 Riyadh, Kingdom of Saudi Arabia,

    6. (together “Neuberger Berman”, “Neuberger Berman Group” “we”, “us”, “our” or “the firm”).

    We are committed to protecting and respecting the privacy of our customers, clients, users of our website, suppliers, individuals who contact us, and those other external parties whose personal data we may otherwise process in the course of our business (“you” and “your”).

    This privacy policy ("Policy") sets out the basis on which we will collect, process and protect your personal data in order to provide our services to you, when you visit our website or interact with us. The terms of this Policy shall also apply to the handling of the personal data of any individual in the European Union (“EU”) or United Kingdom ("UK") by a member of the Neuberger Berman Group established outside of the European Economic Area (“EEA”), to the extent that such handling is subject to Data Protection Legislation. This Policy shall also apply to the handling of the personal data of any individual based in the Kingdom of Saudi Arabia (“KSA”) by a member of the Neuberger Berman Group outside KSA.

    In this Policy, “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679 ("GDPR"), the GDPR as it as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”), the Luxembourg law of 1 August 2018, the Swiss Data Protection Act and its Ordinances (together the "Swiss DPA") and the KSA Personal Data Protection Law issued pursuant to the Saudi Royal Decree No. (M/19) dated 16 September 2021 and its amendment pursuant to the Royal Decree No. (M/148) dated 27 March 2023 (“KSA PDPL”); together with all other applicable legislation relating to privacy or data protection in the jurisdictions in which we operate and the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives) shall have the meanings given to them in the Data Protection Legislation.

    Information We Collect

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    We may collect, record and use information about you and the services you receive from us in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Policy.

    Your ‘information’ includes your personal data, which means information that can be used to identify you, including (but not limited to) the following types of personal information:

    • your contact information, such as your home or work address and contact details (including your mobile telephone number);
    • your date of birth, marital/civil partnership status, details of dependents and next of kin;
    • your employment status and national insurance number;
    • other information about you that you disclose to us;
    • details of any complaints or concerns raised by you;
    • information we collect from the way you do business with us, such as or when you use our telephone services or websites;
    • information we collect when you write to us; or when you apply for our products or services; or any other time you contact us, including through social media; and
    • information we obtain from third parties for a legitimate purpose, such as information that we obtain when verifying details supplied by you as part of your application. This information obtained from other third party organisations or people may include other Neuberger Berman Group companies, employers, credit reference agencies, employers, fraud prevention agencies or other similar organisations.

    Some of the information that we collect about you may include special categories of personal data (such as information about or that infers your racial or ethnic origin, criminal or alleged criminal offences, your political beliefs1, data that indicates that one or both of your parents is unknown2, or your health and lifestyle) in connection with our obligations under applicable anti money laundering laws.3

    Any such special categories of personal data or sensitive information will be processed only as is necessary for this purpose.

    If you fail to provide us with the personal data we request from you, or you object to us processing such information (see below for more information about your rights in relation to your information) the consequences are that we may be unable to provide our services to or for you.

    Providing third party information to us

    If any information which you provide to us relates to any third party, by providing us with such personal information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with the above provisions, or are otherwise permitted to give us this information. You further confirm that you will make such third parties aware of this Policy.

    Purposes and Legal Bases for using your personal data

    We will process your personal data only in accordance with the applicable Data Protection Legislation. Most commonly, we will use your personal data for the purposes and on the legal bases set out in the table below. Generally, we do not rely on consent as a legal basis for processing your personal data. Where we have asked for your consent and you have given it, you have the right to withdraw it at any time by contacting us. You always have the right to unsubscribe from any direct marketing that you receive from us, by clicking the link that is included in each message or by contacting your usual Neuberger Berman contact in the first instance.. For more detail on your rights regarding your personal data, see below.

    This table describes in more detail the various categories of personal data we collect (as set out above in "Information We Collect") and the lawful ground on which we rely for processing this personal data.



How Does Neuberger Treat Your Personal Information?

Neuberger is committed to preserving your privacy and strictly adheres to applicable law, which requires us to tell you how we collect, use, disclose, process and protect your personal information. Where there is inconsistency between this statement and applicable law, we will apply the standard that affords a stronger level of protection. Please read this statement carefully to understand what we do.

Who is providing this statement

This notice is provided by Neuberger Berman Asia Limited

Types of personal information we collect

The types of personal information we collect, use and disclose will depend on our relationship with you and may include:

  • your name, address, occupation, email address, telephone/facsimile number(s), identification document number
  • marital status, date of birth, number of dependents
  • your financial status, income, assets and transaction history
  • your education and/or employment history
  • your credit history and credit scores (in Australia, we do not collect, use or disclose this information)
  • government related identifiers that identify you (in Australia, this may include ABN, Medicare card number, pension card number, driver’s licence number and tax file number)
  • other information relating to your relationship with Neuberger
  • technical information when you use our website (e.g., information of the device and browser used to access our website, such as IP address, internet browser, internet domain, operating system and other device identifiers, access dates and times, referring and exiting URLs)

When our relationship with you ceases, we may continue to retain, use and disclose your information as described in this statement provided there is a business or legal purpose to do so.

Why we collect your personal information

Generally, we collect, use, disclose, process and update personal information for our everyday business purposes, which may include:

  • providing you with Neuberger product(s) or services
  • your employment with Neuberger
  • complying with our obligations under applicable law relating to the Neuberger product(s) or service or your employment with Neuberger (as the case may be)
  • meet our ongoing obligations to you in providing you with the Neuberger product(s) or service or as your employer (as the case may be)
  • processing your transactions
  • maintaining your account(s) or administering any facility you have with us
  • protecting against fraud
  • meeting our obligations under applicable law, such as customer identification requirements relating to “know your client” (“KYC”) due diligence, search and registration purposes, data collection and retention, taxation anti-money laundering (“AML”), and/or combating terrorist financing (in Australia these laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Personal Property Securities Act 2009 (Cth), the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1997 (Cth) and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation))
  • responding to government agency's requests, court orders and legal investigations
  • receiving reports from, or reporting to, credit bureaus
  • to share your personal information with related bodies corporate

How we collect your personal information

We may collect your personal information when, for example, you

  • open an account or provide account information
  • become an employee of Neuberger (for example through your curriculum vitae or from references given to us in connection with your employment)
  • transact with us or others (including information regarding your income and transaction history)
  • seek advice about your investments or give us your income information
  • give us your contact information
  • use our website

We may also collect your personal information from other sources, such as credit bureaus, affiliates or other third parties who provide us with specific information to assist us in delivering our products and services to you.

How we protect your personal information

Your personal information may be stored in hard copy documents or electronically in our software or systems. When no longer required, we take reasonable steps to destroy or de-identify your personal information.

To protect your personal information from unauthorized access, disclosure, use and other similar risk, we take security measures that comply with applicable law. These measures include technological, administrative and organizational measures including computer safeguards and secured files and buildings.

We restrict access to your personal information to those personnel at Neuberger, and our service providers, who have a bona fide need for this information in order to perform their job responsibilities.

You can sometimes access other organisations’ websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites.

What happens if you don’t allow us to collect your personal information

If you do not provide us with any requested personal information this may mean that we are unable to provide you with a product or service.

For example, if you choose to restrict our website from placing a “cookie”* on your hard drive, you may not be able to use some of the features on our website that depend on cookies.

* Cookies are tiny packets of information that websites store on your computer’s hard drive so that your computer will “remember” information about your visit. Our website makes use of these cookies to enhance your experience when you visit.

Who your personal information may be disclosed to and their locations

We may disclose your personal information to affiliates in order to meet our obligations to you and for other purposes as described above. We may also disclose your personal information for such purposes to other organizations, such as:

  • external service providers involved in our provision of products and services to you, such as mailing houses, professional advisers (such as our lawyers and compliance advisers), identity verification services, call services, researches, data analysts, auditors
  • your agents, advisers or lawyers, in such circumstances where you have obtained a product or service from us through them or are otherwise dealing with us in any way through them
  • parties involved in markets and systems related to the products and services we provide to you, such as market operators and participants, counterparties, intermediaries and custodians
  • entities assisting us to maintain and improve our systems, products and services
  • entities to whom we are required or authorised by applicable law to disclose your personal information, such as government and regulatory bodies
  • members of the Neuberger group and related entities
  • other financial institutions, government bodies and credit providers
  • your nominated referees
  • organisations through whom you choose to make payments to the Neuberger group
  • organisations wishing to acquire an interest in any part of Neuberger’s business for assessing or implementing any such acquisition

Because our operations involve activities both within and outside the jurisdiction in which you have a relationship with Neuberger, some of these disclosures may be to entities that are overseas. It is not practicable to list every country in which such recipients are located but it is likely that the countries to which your information may be disclosed include the United States of America, the United Kingdom, Ireland, China, Australia, Hong Kong, Taiwan and Singapore.

How long will your personal information be retained

We will retain your personal information for as long as is necessary to satisfy the purpose for which it was collected or as required by relevant laws, whichever is the longer. We will cease to retain your personal information if there is no longer any business or legal purpose to do so.

How we use your personal information

We may collect, process and use your personal information manually or through automated means (such as through computers), provided always that we will collect, process and use your personal information by means which are lawful and fair in the circumstances.

Access to personal information and other rights

You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions allowed by applicable law. We will respond to your request in accordance with applicable law. If we deny your access request we will provide you with reasons for doing so. Please note that we may charge a fee for complying with your request.

We aim to keep your personal information held by us up-to-date. If you believe that the personal information we hold about you is incorrect, please let us know so we can correct this.

To access or update your personal information, please contact our Data Protection Officer (details for whom are set out below).

How we will deal with a complaint

If you believe your personal information has not been treated consistently with our legal obligations or that we have failed to comply with our legal obligations, please contact our Data Protection Officer (details for whom are set out below). You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it.

We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within a reasonable time after we receive your notice.

If your personal information was collected in Australia and you are unhappy with the handling of your complaint you also have rights to complain to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).

Communication and marketing

We will not use your personal information for direct marketing purposes unless we have your express consent. If you wish to withdraw your consent, please call us using the details below.

You understand that we may contact you by all relevant means (for example, by letter, email or phone). If you provide Neuberger with an email address, you consent to electronic communications being sent to you via that email address, including notices and reminders. To protect your privacy, we recommend that any email address you provide to us be your personal email address rather than, for example, an email address accessible by your work colleagues or family members.

Contacts

To access or update your personal information, please write to us at:

Neuberger Data Protection Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

or call:

+852.3664.8800

If you have any complaints regarding our handling of your personal data, please let us know at:

Neuberger Complaints Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

令和4年4月

〒100-6512
東京都千代田区丸の内一丁目5番1号
新丸の内ビルディング12階
ニューバーガー・バーマン株式会社
代表取締役社長　　大平　亮

当社では、お客様にご信頼いただくことができる金融商品取引業者となるため、お客様に関する個人情報については、その取扱いにつき関係法令等を遵守し、お客様のご同意なく目的外に利用することなく、またお客様からいただいた苦情についても早期解決に努めるなど、個人情報保護に誠意をもって適切に取り組んでおります。


1.情報を取得する目的

お客様の個人情報は、お客様とのお取引を安全かつ確実に進め、より良い金融商品・サービスを提供させて頂くために取得しています。具体的には、以下に掲げる目的のために利用されます。

個人情報の利用は、利用目的の範囲内で、業務の逐行上必要な限りにおいて行い、目的外の利用は行いません。


2.取得する情報の種類

最も一般的なものは、お客様の住所、氏名、生年月日、性別、電話番号等となります。その他に取引開始に際しお尋ねした情報等が含まれます。


3.情報の取得方法

当社は、十分な安全管理措置を講じた上で、郵便物、インターネット、電話等の電子機器を用いてお客様の情報取得をすることがあります。


4.情報の利用目的の通知・公表

当社は、お客様の同意を得た場合及び法令等により例外として取り扱われる場合を除き、次に定める事業内容および利用目的の達成に必要な範囲内でお客様の個人情報を取り扱います。


１．事業内容

  • 投資運用業
  • 第二種金融商品取引業
  • 投資助言・代理業
  • 前各号の業務の他、金融商品取引法その他の法律により金融商品取引業者が営むことのできる業務
  • その他金融サービスおよび上記に付随し又は関連する一切の業務

２．利用目的

  • 当社の行う金融商品取引業及び取扱う金融商品（取引契約）の勧誘・販売、サービスの案内を行なうため
  • 当社又は関連会社、提携会社の金融商品の勧誘・販売、サービスの案内を行うため
  • 適合性の原則等に照らした商品・サービスの提供の妥当性を確認するため
  • 顧客が本人であること又は本人の代理人であることを確認するため
  • 顧客に対し、取引結果などの報告を行うため
  • 顧客との取引に関する事務を行うため
  • 市場調査、並びにデータ分析やアンケートの実施等による金融商品やサービスの研究や開発のため
  • リスク管理や法令の遵守等、当社における内部管理を行うため
  • 上記の他、顧客との取引を適切かつ円滑に遂行するため

5.情報の利用・提供

当社では、次の場合を除いてお客様の個人情報を利用したり、第三者に提供することはありません。

  • お客様が同意されている場合
  • 法令に基づく場合
  • お客様または公共の利益のため必要であると考えられる場合（ただし、利用に限ります）
  • お客様に高いご関心をお持ち頂けると思われる当社の金融商品やサービスをご案内する場合（ただし、利用に限ります）
  • 個人データの取扱業務を委託する為に個人情報を第三者に預託する場合（この場合においては、当該第三者について調査の上必要な契約を締結し、その他法令上必要な措置を講じます）

当社は、違法又は不当な行為を助長し、又は誘発するおそれがある方法によりお客様の個人情報を利用しません。

当社は、お客様の同意を得て個人情報を外国に提供する場合で、お客様の同意を得ようとする時点において個人情報の提供先の第三者が所在する外国が特定できず、①事後的に提供先の第三者を特定できたときには、お客様からの求めに応じて、個人情報保護法に従って当該外国の名称等に関する情報を、②事後的に提供先の第三者が講ずる個人情報の保護のための措置についての情報提供が可能となったときには、お客様からの求めに応じて、個人情報保護法に従って当該第三者が講ずる個人情報の保護のための措置に関する情報を、お客様に提供します。また、当社は、お客様の同意によらずに個人情報を外国に提供する場合には、個人情報保護法に従って、お客様からの求めに応じて、個人情報取扱事業者が講ずべきこととされている措置に相当する措置の当該提供先による継続的な実施を確保するために必要な措置に関する情報をお客様に提供します。


6.共同利用

当社は、当社が取得しましたお客様の個人情報の一部または全部を下記に記載のとおりニューバーガー・バーマン・グループとの間で共同利用する場合があります。

１．共同利用される個人情報の項目

  • 住所、氏名、生年月日、性別、電話番号等のお客様に関する情報
  • お客様の取引に関する情報
  • お客様の取引管理に必要な情報

２．共同利用する者の範囲

３．利用目的

  • 当社グループとしての総合的なサービスを開発、案内、提供するため
  • 当社グループの統合的な経営管理及び内部管理を行うため

４．共同利用される個人情報の管理について責任を有する者

  • ニューバーガー・バーマン株式会社

7.情報の管理方法

当社では、お客様の情報を正確、最新なものにするよう常に適切な措置を講じています。

また、当社は、当社の委託を受けてお客様の個人データの取扱い等を行う会社にも同様に適切な管理を行わせ、当該委託を受けた会社を監督しています。

  • 個人データの適正な取扱いの確保のため、関係法令・ガイドライン等の遵守、質問及び苦情処理の窓口等についての基本方針を策定しています。
  • 取得、利用、保存、提供、削除・廃棄等の段階ごとに、取扱方法、責任者・担当者及びその任務等について個人データの取扱規程を策定しています。
  • 個人データの安全管理措置について役職員等の責任と権限を明確に定め、安全管理に関する規程等を整備・運用し、その実施状況の点検・監査を行うこと等の体制整備及び実施措置を講じています。
  • 役職員等に対する教育・訓練等を実施し、個人データの安全管理が図られるよう役職員等を監督する措置を講じています。
  • 個人データの取扱者及び個人データの利用及び複製等を業務上必要な範囲内に限定し、個人データを保存場所外へ持ち出す際には十分な安全管理措置を講じています。
  • 取り扱う個人データに応じて、個人データの利用者の識別及び認証、個人データの管理区分の設定及びアクセス制御、個人データへのアクセス権限の管理、個人データの漏えい等防止策、個人データへのアクセスの記録及び分析、個人データを取り扱う情報システムの稼動状況の記録及び分析並びに個人データを取り扱う情報システムの監視及び監査等の技術的措置を講じています。
  • 取り扱う個人データの一部を米国にて保管しており、これらの国の個人情報の保護に関する制度を把握した上で安全管理措置を実施しています。

8.お客様からの利用目的の通知、開示、訂正、利用停止等、中止のご請求

１．利用目的の通知、開示、訂正、利用停止等
お客様からご自身に関する個人データの利用目的の通知又は、個人データ若しくは第三者提供記録の開示のご依頼があった場合は、特別な理由のない限りお答えしています。また、お客様に関する情報が不正確である場合には、正確なものに訂正させていただきます。個人情報保護法に定めるところに従って、お客様に関する情報の利用停止、消去及び第三者提供の停止についても対応させていただきます。下記のお問い合わせ先までお申し出下さい。当社は、請求者がご本人であることを確認させて頂きます。

２．中止
ダイレクトメール、郵便物、電話、電子メール等によるご案内をお客様がご希望されない場合は下記のお問い合わせ先までお申し出下さい。以降、取扱いを中止させて頂きます。


9.お客様からのお問い合せ窓口

お問い合わせ先
個人情報に関する利用目的の通知・開示・訂正・利用停止等・中止のご請求、ご不明な点についてのご質問は下記電話番号にて承っております。

ニューバーガー・バーマン株式会社
〒100-6511　東京都千代田区丸の内一丁目5番1号 新丸の内ビルディング
TEL：03－5218－1930
受付時間　9：00〜17：00 （土日祝日、年末年始の休業日を除く）


10.認定個人情報保護団体

当社は、金融庁の認定を受けた認定個人情報保護団体である一般社団法人　日本投資顧問業協会及び一般社団法人　投資信託協会の協会員です。同協会では、協会員の個人情報の取扱についての苦情・相談をお受けいたします。

苦情・相談窓口
一般社団法人　日本投資顧問業協会事務局　苦情相談室（個人情報担当）
電話（03-3663-0505）

一般社団法人　投資信託協会事務局　会員調査部　投資者相談室
電話（03-5614-8440）


11.変更

上記ご案内の内容は、法令の改正その他の理由に基づき内容を変更する場合があります。

How Does Neuberger Treat Your Personal Information?

Neuberger is committed to preserving your privacy and strictly adheres to applicable law, which requires us to tell you how we collect, use, disclose, process and protect your personal information. Where there is inconsistency between this statement and applicable law, we will apply the standard that affords a stronger level of protection. Please read this statement carefully to understand what we do.

Who is providing this statement

This notice is provided by Neuberger Berman Singapore Pte. Limited

Types of personal information we collect

The types of personal information we collect, use and disclose will depend on our relationship with you and may include:

  • your name, address, occupation, email address, telephone/facsimile number(s), identification document number
  • marital status, date of birth, number of dependents
  • your financial status, income, assets and transaction history
  • your education and/or employment history
  • your credit history and credit scores (in Australia, we do not collect, use or disclose this information)
  • government related identifiers that identify you (in Australia, this may include ABN, Medicare card number, pension card number, driver’s licence number and tax file number)
  • other information relating to your relationship with Neuberger
  • technical information when you use our website (e.g., information of the device and browser used to access our website, such as IP address, internet browser, internet domain, operating system and other device identifiers, access dates and times, referring and exiting URLs)

When our relationship with you ceases, we may continue to retain, use and disclose your information as described in this statement provided there is a business or legal purpose to do so.

Why we collect your personal information

Generally, we collect, use, disclose, process and update personal information for our everyday business purposes, which may include:

  • providing you with Neuberger product(s) or services
  • your employment with Neuberger
  • complying with our obligations under applicable law relating to the Neuberger product(s) or service or your employment with Neuberger (as the case may be)
  • meet our ongoing obligations to you in providing you with the Neuberger product(s) or service or as your employer (as the case may be)
  • processing your transactions
  • maintaining your account(s) or administering any facility you have with us
  • protecting against fraud
  • meeting our obligations under applicable law, such as customer identification requirements relating to “know your client” (“KYC”) due diligence, search and registration purposes, data collection and retention, taxation anti-money laundering (“AML”), and/or combating terrorist financing (in Australia these laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Personal Property Securities Act 2009 (Cth), the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1997 (Cth) and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation))
  • responding to government agency's requests, court orders and legal investigations
  • receiving reports from, or reporting to, credit bureaus
  • to share your personal information with related bodies corporate

How we collect your personal information

We may collect your personal information when, for example, you

  • open an account or provide account information
  • become an employee of Neuberger (for example through your curriculum vitae or from references given to us in connection with your employment)
  • transact with us or others (including information regarding your income and transaction history)
  • seek advice about your investments or give us your income information
  • give us your contact information
  • use our website

We may also collect your personal information from other sources, such as credit bureaus, affiliates or other third parties who provide us with specific information to assist us in delivering our products and services to you.

How we protect your personal information

Your personal information may be stored in hard copy documents or electronically in our software or systems. When no longer required, we take reasonable steps to destroy or de-identify your personal information.

To protect your personal information from unauthorized access, disclosure, use and other similar risk, we take security measures that comply with applicable law. These measures include technological, administrative and organizational measures including computer safeguards and secured files and buildings.

We restrict access to your personal information to those personnel at Neuberger, and our service providers, who have a bona fide need for this information in order to perform their job responsibilities.

You can sometimes access other organisations’ websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites.

What happens if you don’t allow us to collect your personal information

If you do not provide us with any requested personal information this may mean that we are unable to provide you with a product or service.

For example, if you choose to restrict our website from placing a “cookie”* on your hard drive, you may not be able to use some of the features on our website that depend on cookies.

* Cookies are tiny packets of information that websites store on your computer’s hard drive so that your computer will “remember” information about your visit. Our website makes use of these cookies to enhance your experience when you visit.

Who your personal information may be disclosed to and their locations

We may disclose your personal information to affiliates in order to meet our obligations to you and for other purposes as described above. We may also disclose your personal information for such purposes to other organizations, such as:

  • external service providers involved in our provision of products and services to you, such as mailing houses, professional advisers (such as our lawyers and compliance advisers), identity verification services, call services, researches, data analysts, auditors
  • your agents, advisers or lawyers, in such circumstances where you have obtained a product or service from us through them or are otherwise dealing with us in any way through them
  • parties involved in markets and systems related to the products and services we provide to you, such as market operators and participants, counterparties, intermediaries and custodians
  • entities assisting us to maintain and improve our systems, products and services
  • entities to whom we are required or authorised by applicable law to disclose your personal information, such as government and regulatory bodies
  • members of the Neuberger group and related entities
  • other financial institutions, government bodies and credit providers
  • your nominated referees
  • organisations through whom you choose to make payments to the Neuberger group
  • organisations wishing to acquire an interest in any part of Neuberger’s business for assessing or implementing any such acquisition

Because our operations involve activities both within and outside the jurisdiction in which you have a relationship with Neuberger, some of these disclosures may be to entities that are overseas. It is not practicable to list every country in which such recipients are located but it is likely that the countries to which your information may be disclosed include the United States of America, the United Kingdom, Ireland, China, Australia, Hong Kong, Taiwan and Singapore.

How long will your personal information be retained

We will retain your personal information for as long as is necessary to satisfy the purpose for which it was collected or as required by relevant laws, whichever is the longer. We will cease to retain your personal information if there is no longer any business or legal purpose to do so.

How we use your personal information

We may collect, process and use your personal information manually or through automated means (such as through computers), provided always that we will collect, process and use your personal information by means which are lawful and fair in the circumstances.

Access to personal information and other rights

You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions allowed by applicable law. We will respond to your request in accordance with applicable law. If we deny your access request we will provide you with reasons for doing so. Please note that we may charge a fee for complying with your request.

We aim to keep your personal information held by us up-to-date. If you believe that the personal information we hold about you is incorrect, please let us know so we can correct this.

To access or update your personal information, please contact our Data Protection Officer (details for whom are set out below).

How we will deal with a complaint

If you believe your personal information has not been treated consistently with our legal obligations or that we have failed to comply with our legal obligations, please contact our Data Protection Officer (details for whom are set out below). You will receive an acknowledgement of receipt of your complaint from us as soon as reasonably practicable after we receive it.

We investigate all complaints and will respond to you as soon as reasonably practicable. We aim to resolve your complaint within a reasonable time after we receive your notice.

If your personal information was collected in Australia and you are unhappy with the handling of your complaint you also have rights to complain to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).

Communication and marketing

We will not use your personal information for direct marketing purposes unless we have your express consent. If you wish to withdraw your consent, please call us using the details below.

You understand that we may contact you by all relevant means (for example, by letter, email or phone). If you provide Neuberger with an email address, you consent to electronic communications being sent to you via that email address, including notices and reminders. To protect your privacy, we recommend that any email address you provide to us be your personal email address rather than, for example, an email address accessible by your work colleagues or family members.

Contacts

To access or update your personal information, please write to us at:

Neuberger Data Protection Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

or call:

+65.6645.3760

If you have any complaints regarding our handling of your personal data, please let us know at:

Neuberger Complaints Officer
20th Floor, Jardine House
1 Connaught Place, Central, Hong Kong

路博邁如何處理您的個人資訊？

我們對隱私權之承諾

路博邁承諾保存您的隱私並嚴格遵守適用之法律，該法律要求我們告知您我們如何蒐集、揭露及保護您的個人資訊。若此聲明與適用之法律間有不一致之情況，我們將適用對您較完善之保護。請仔細閱讀此聲明並瞭解我們的作法。

此聲明之提供者

此聲明係由「路博邁證券投資信託股份有限公司」(下稱「路博邁投信」)提供。
臺北市信義區忠孝東路五段68號20樓

蒐集、處理及利用個人資料之機構

您的個人資訊可能係由下列對象蒐集、處理及利用：

  • 路博邁投信及其集團公司、其各自員工、代理人、專業顧問(例如律師和法遵顧問)及顧問、服務提供者(例如郵政機構及身份核實服務商)或商業夥伴；
  • 在您透過代理人、顧問或律師獲得我們的產品或服務之情況，或在其他情況下您以任何方式透過他們與我們進行交易時；
  • 我們為您提供產品和服務或相關維護所涉及的對象(例如市場或系統營運商、參與者、中介機構、合約對手方及保管機構)；
  • 適用法律要求或授權我們向其揭露您個人資料的實體，包括任何主管機關、政府機關、授權機構或其他人對路博邁或其任何集團公司，或其指定之代表人或代理人之控制營運或其他事務(包括法人事務)具有監管、監督、行政、調查或審核職責者。前述包括但不限於，個人資料保護委員會、金融監督管理委員會、中華民國證券投資信託暨顧問商業同業公會、財團法人金融聯合徵信中心、財金資訊股份有限公司、台灣票據交換所、中華民國證券商業同業公會、台灣證券交易所、台灣期貨交易所、證券櫃檯買賣中心、臺灣集中保管結算所及財團法人金融消費評議中心。

如收受者位於海外，個人資料可能在台灣境內或境外進行蒐集、處理及傳輸。

我們蒐集之個人資料類型

我們所蒐集之個人資料類型將視與您之關係而定，並可能包括下列事項：

  • 身分識別類-(C001) 識別個人者；(C002)識別財務者；(C003)政府資料中之識別者。
  • 特徵類 - (C011)個人描述；(C012)身體描述。
  • 家庭情形 - (C021)家庭情形；(C023)家庭其他成員之細節。
  • 社會情況 - (C031)住家及設施；(C032)財產；(C033)移民情形；(C034)旅行及其他遷徙細節；(C038)職業。
  • 教育、考選、技術及其他專業 - (C051)學校記錄；(C052)資格或技術；(C053)職業團體會員資格；(C054)職業專長；(C057)學生(員)及應考人紀錄。
  • 就業狀況 - (C061)現行之受僱狀況；(C062)僱用經過；(C063)離職經過；(C064)工作經驗；(C065)工作、差勤紀錄；(C066)健康與安全紀錄；(C068)薪資及預扣款；(C070)工作管理之細節；(C071)工作之評估細節；(C072)受訓紀錄；(C073)安全細節。
  • 財務資訊 - (C081)收入、所得、資產與投資；(C083)信用評等；(C085)外匯交易紀錄；(C086)票據信用；(C087)津貼、福利、贈款；(C088)保險細節；(C089)社會保險給付、就養給付及其他退休給付；(C091)資料主體所取得之財貨或服務；(C092)資料主體提供之財貨或服務；(C093)財務交易；(C094)賠償。
  • 商業資訊 - (C101)資料主體之商業活動；(C102)約定或協議；(C103)商業相關執照。
  • 其他資訊類型 - (C111)健康紀錄；(C116)犯罪嫌疑資料；(C131)書面文件之檢索；(C132)未分類之資料。
  • 其他契約提供之個人資料或其他足以識別您身份之資訊。

我們蒐集您個人資訊之理由

一般而言，我們係為每日營運之目的而蒐集、更新並使用個人資訊，包括：

  • 向您提供路博邁之產品或服務
  • 路博邁與您的僱傭關係
  • 為符合關於路博邁之產品或服務、或路博邁與您的僱傭關係（依個案而定）所適用法律之義務
  • 為符合向您提供路博邁之產品或服務、或作為雇主（依個案而定）之持續性義務
  • 為處理您的交易
  • 維持您的帳戶（們）或管理任何您在我方的設備
  • 為保護免於欺詐
  • 為符合適用法律之義務，例如「瞭解您的客戶」（下稱「KYC」）、洗錢防制（下稱「AML」）及/或打擊資恐(下稱「CFT」)相關之客戶身分要求
  • 回應法院之命令或司法調查
  • 自信用機構取得報告或向信用機構為報告

上述事項可能依台灣法律反映於下列特定目的之準則：(001)人身保險；(002)人事管理；(003)入出國及移民；(009)中央銀行監理業務；(022)外匯業務；(030)仲裁；(031)全民健康保險、勞工保險、農民保險、國民年金保險或其他社會保險；(036)存款與匯款；(037)有價證券及有價證券持有人登記；(039)行政裁罰、行政調查；(040)行銷(包括金控共同行銷業務) (044)投資管理；(047)兩岸暨港澳事務；(052)對股東、會員（含股東與會員指派之代表）、董事、監察人或其他成員名冊之內部管理；(053)法制行政；(059)金融服務業依法令規定及金融監理需要，所為之蒐集處理及利用；(060)金融爭議處理；(061)金融監督、管理與檢查；(063) 非公務機關依法定義務所進行個人資料之蒐集處理及利用；(068)信託業務；(069)契約、類似契約或其他法律關係事務；(090)消費者、客戶管理與服務；(104)帳務管理及債權交易業務；(107)採購與供應管理；(114)勞工行政；(120)稅務行政；(129)會計與相關服務；(136)資(通)訊與資料庫管理；(137)資(通)訊安全與管理；(150)輔助性與後勤支援管理；(152)廣告或商業行為管理；(154)徵信；(157)調查、統計與研究分析；(166)證券、期貨、證券投資信託及顧問相關業務；(168)護照、簽證、及文件證明處理；(173)其他公務機關對目的事業之監督管理；(177)其他金融管理業務；(181)其他經營合於營業登記項目或組織章程所定之業務；(182) 其他諮詢與顧問服務。

我們如何蒐集您的個人資訊

在下述情況下我們得蒐集您的個人資訊，例如於您

  • 開設帳戶或提供帳戶資訊
  • 成為路博邁之員工
  • 就您的投資尋求建議，或給予我們您的收入資訊
  • 給予我們您的聯絡資訊
  • 使用本網站，將蒐集網站技術性資訊，例如IP 位址、網際網路瀏覽器、網際網路網域、作業系統及其他裝置識別碼、存取日期及時間、連入及離開之網址，以提升使用者體驗

我們亦可自其他來源蒐集您的個人資料，例如信用機構、關係企業或其他第三人。

我們如何保護您的個人資訊

為保護您的個人資訊免於未經授權之取得及使用，我們採取符合適用法律之加密措施。該措施包括電腦安全防衛及加密文件與安全性建築。

我們限制只有路博邁員工及為履行職務義務而對此資訊有善意需要之服務提供者，方得取得您個人資訊。

您有時可能藉由本網站之連結進入其他組織之網站。敬請注意，我們對該組織或外部網站之隱私權標準與程序不負任何責任。

未允許我們蒐集您個人資訊之後果

若您未提供予我們任何要求之個人資訊，可能導致我們無法向您提供產品或服務。

例如，若您選擇限制本網站而未於您硬碟中裝置「cookie」*，您可能無法使用本網站之部分功能（依cookies而定）。

*Cookies為將網站儲存於您電腦硬碟之微小數據封包，以便您的電腦「記憶」您造訪過的資訊。本網站使用該cookies以於您造訪時提升您的經驗。

個人資訊之保留期間

我們得依下列保留期間(視何者較長)保留您的個人資料。

    您與路博邁投信的協議或其他關係終止後五年；

    仍具有蒐集個人資料之特定目的之期間。

    路博邁投信依相關法律得保留之期間或其履約期間（例如依商業會計法之要求）；或

    路博邁投信從事業務所需之其他期間。

我們如何利用您的個人資訊

只要我們透過合法途徑和在公平情況下蒐集、處理和使用您的個人資料，我們可經人手或透過自動化方式(例如：透過電腦)，蒐集，惟個人資料之蒐集、處理及利用將以合法且公平之方式適當地為之。

個人資訊取得權及其他權利

您有權要求取得我們所持有的您的個人資訊，您的取得權在適用法律容許下將受一些例外情況所約束。我們將依據適用法律回應您的要求。若我們拒絕您的取得要求，我們將向您提供理由。

我們致力於確保所持有您的個人資料符合現況。如您相信我們所持有的您的個人資料並不正確，請聯絡我們加以更正。

您亦有權(1)查詢或請求閱覽您的個人資料；(2)請求製作您的個人資料之複製本；(3)請求補充或更正您的個人資料; (4)請求路博邁投信停止蒐集、處理或利用您的個人資料；以及(5)請求路博邁投信刪除您的個人資料。若您欲行使上述權利，請聯絡路博邁投信。

聯繫資料

希望取得或更新您的個人資訊，請致函我們，地址為：

路博邁證券投資信託股份有限公司

臺北市信義區忠孝東路五段68號20樓

或撥打: (02) 8726 8280

© 2026 路博邁投信及版權所有

Category of personal data collected Purpose for collection Legal basis for processing
Your contact information, such as your home or work address and contact details (including your mobile telephone number).
  • to manage and administer any of the services provided by us to you;
  • for day to day operational and business purposes;
  • investor relationship management;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to carry out statistical analysis and market research;
  • to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes;
  • certain marketing purposes, unless you have opted out of this; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to prevent fraud;
    • to protect our business interests; or
    • to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Your employment status and national insurance number.
  • to consider you for potential employment or engagement by us;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes;
  • to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to prevent fraud; or
    • to protect our business interests.
Your date of birth, marital/civil partnership status, details of dependents and next of kin.
  • for day to day operational and business purposes;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to carry out statistical analysis and market research;
  • to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes;
  • for the purposes of credit risk reduction; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to prevent fraud; or
    • to protect our business interests.
Other information about you that you disclose to us.
  • to manage and administer any of the services provided by us to you;
  • to consider you for potential employment or engagement by us;for day to day operational and business purposes;
  • investor relationship management;
  • to track your visits to our website, in order to provide you with a better service and to understand how you use it;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to carry out statistical analysis and market research;
  • to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes;
  • for the purposes of credit risk reduction;
  • to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings);
  • certain marketing purposes, unless you have opted out of this; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to prevent fraud;
    • to protect our business interests;
    • to ensure that complaints are investigated;
    • to evaluate, develop or improve our products and services; or
    • to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Details of any complaints or concerns raised by you.
  • for day to day operational and business purposes;
  • investor relationship management;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); or
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests:
    • to protect our business interests;
    • to ensure that complaints are investigated; or
    • to evaluate, develop or improve our products and services.
Information we collect from the way you do business with us, such as or when you use our telephone services, online conference services, or websites.
  • to manage and administer any of the services provided by us to you;
  • for day to day operational and business purposes;
  • to track your visits to our website, in order to provide you with a better service and to understand how you use it;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to carry out statistical analysis and market research;
  • certain marketing purposes, unless you have opted out of this; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where it is necessary for our legitimate interests to evaluate, develop or improve our products and services.
Information we collect when you write to us; or when you apply for our products or services; or any other time you contact us, including through social media.
  • to manage and administer any of the services provided by us to you;
  • to consider you for potential employment or engagement by us;
  • for day to day operational and business purposes;
  • investor relationship management;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • to carry out statistical analysis and market research;
  • certain marketing purposes, unless you have opted out of this; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to protect our business interests;
    • to evaluate, develop or improve our products and services; or
    • to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Information we obtain from third parties for a legitimate purpose, such as information that we obtain when verifying details supplied by you as part of your application. This information obtained from other third party organisations or people may include other Neuberger Berman Group companies, employers, credit reference agencies, company registries, employers, fraud prevention agencies or other similar organisations.
  • to consider you for potential employment or engagement by us;
  • for day to day operational and business purposes;
  • for record keeping, security and/or training purposes;
  • for any other specific purposes where you have given specific consent to that processing for those purposes;
  • for the purposes of credit risk reduction; and
  • for other legitimate business purposes as may be determined by us from time to time.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or where permitted by applicable law those of a third party):
    • to prevent fraud;
    • to protect our business interests;
    • to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.

Automated processing

When we use your information, we may use automated processes. In particular, in order to comply with our obligations under AML legislation, we are required to verify the identity of all clients and other information (including but not limited to details of any nationality, citizenship or rights of residence you hold) to satisfy our regulatory obligations. We may do this using an electronic verification system that we consider suitable or by asking you for documentary evidence. We do not carry out any automated decision making when processing your personal data.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk:

  • we may refuse to provide the services you have requested, or we may stop providing existing services to you; and
  • a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

If you want to know more about your rights in relation to automated processing, please see below or contact us using the details below.

Recipients of your personal data

We may disclose your information to other recipients or categories of recipients, including associates or affiliates within the Neuberger Berman Group, or to our or their agents, counterparties and support service or data providers, wherever located. In certain circumstances, we may transfer your information abroad. See “International Transfers” below for more information.

We will ensure that if we share your information with third parties, any such disclosure is at all times in compliance with Data Protection Legislation.

The following recipients, or categories of recipients, may receive your personal data and process it for the purposes outlined above:

  • our third party suppliers, service providers and other agents or advisers, including anyone providing a service to us or our funds or acting as our agent (which may include distributors, depositaries, investment managers, administrators or companies within their groups of companies);
  • our advisers (including, but not limited to, accountants, lawyers, auditors or other professional advisers);
  • any revenue service or tax authority including to HMRC, the Revenue Commissioners (in Ireland) and Luxembourg tax authorities, if obliged to do so under any applicable legal or regulatory requirements;
  • credit reference agencies in order to perform credit and identity checks. To do this, we will supply your personal information to the credit reference agencies and they will give us information about you and they may record that a search has been made and the results of such search (including the information that we provide). We may continue to exchange information about you with credit reference agencies while you have a relationship with us. The credit reference agencies may in turn share your personal information with other organisations;
  • fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. We and fraud prevention agencies may also enable law enforcement agencies to access and use your information to detect, investigate and prevent crime. If fraud is detected, you could be refused certain services or finance;
  • other UK and overseas regulators (such as, but not limited to, the Central Bank of Ireland, the Commission de Surveillance du Secteur Financier in Luxembourg, and the Swiss Financial Market Supervisory Authority) and authorities in connection with their duties (such as crime prevention), or other organisations who are required by law to receive such data, or who need to receive it for the purposes of crime prevention, fraud reduction, to comply with any legal obligation, or to protect people’s rights, property, or safety;
  • any other person or organisation after a restructure, sale or acquisition of any Neuberger Berman Group company, as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both);
  • anyone to whom we may transfer our rights and/or obligations under our terms with you; and
  • your advisers (including, but not limited to, accountants, lawyers or other professional advisers) where authorised by you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In any case where we share personal data with a third party controller (including, as appropriate, other members of the Neuberger Berman Group), the use by that third party of the personal data will be subject to the third party’s own privacy and data protection policies.

International Transfers

Information about you in our possession may be transferred to other countries (which may include countries outside the United Kingdom, EEA, Switzerland, KSA or the country from which it originates, such as jurisdictions in which and through which transactions are effected; jurisdictions where your investments are held; jurisdictions from which you regularly receive or transmit information about your investments; or jurisdictions where our third parties conduct their activities). The above recipients of your personal data may also be based either within or outside the United Kingdom, EEA, Switzerland, KSA or the country from which it originates (based primarily in North America or Asia).

You understand and accept that such other countries may have differing (and potentially less stringent) laws relating to the protection of your data and the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

Where your personal data is transferred to outside of the United Kingdom, EEA, Switzerland, KSA or the country from which it originates to any country not considered to have an adequate level of data protection under the applicable Data Protection Legislation, we or our permitted third parties will impose contractual obligations on the recipients of that data to protect your information to the standard required under applicable Data Protection Legislation, unless we can rely on a legal derogation4. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where the transfer is to a country deemed to provide adequate protection of your information by the relevant supervisory authority; or where permitted by applicable law you have requested the transfer For the purposes of the GDPR and UK GDPR (as the context requires), there are adequacy decisions in place for transfers to the EEA, UK, Canada, Japan, and Switzerland and other countries and therefore, collectively, these decisions will govern transfers to the relevant group companies in those countries.

If we transfer your information outside the UK, EEA, Switzerland or country from which it originates in other circumstances (for example because we have to provide such information by law), we will put in place appropriate safeguards to ensure that your information remains adequately protected. This, in particular, relates to the USA and Singapore where no adequacy has been adopted with the European Commission and, as the case may be, the Federal Data Protection and Information Commissioner ("FDPIC") or the Swiss Federal Council.

You can request further information on our data transfers including (i) whether or not an adequacy decision exists for the relevant jurisdictions and (ii) for a copy of such safeguards by contacting us in writing using the contact details below.

Retention of your Personal Data

We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes. We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject or if we have a legitimate interest, pursuant to the Neuberger Berman Group Retention Policy. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.

Your rights in relation to your personal data

Depending on the applicable Data Protection Legislation, you have the following rights, at any time and under certain circumstances, in respect of your personal data which we process:

  • to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated processing, including profiling, and the logic, significance and envisaged consequences);
  • to request access to or a copy of any personal data we hold about you;
  • to request the rectification of your personal data, if you consider that it is incomplete or inaccurate;
  • to request the erasure of your personal data, if you consider that we do not have the right to hold it;
  • to object to your personal data being processed for a particular purpose, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing, or to request that we stop using your information;
  • as a general rule, to request not to be subject to a decision based solely on automated processing (including profiling) which produces legal or similarly significant effects and to have safeguards put in place if any such processing of your personal data occurs;
  • to ask us to transfer a copy of your personal data to you or to another service provider or third party where technically feasible;
  • to withdraw any consent that you have previously given to us for our use of your personal data;
  • to ask us to stop or start sending you marketing messages at any time;
  • to lodge a complaint with a supervisory authority; and
  • in some jurisdictions, the right not to be discriminated against for exercising the above rights and the right to claim compensation for material or moral damage if you are harmed as a result of any violation stipulated under the applicable laws.

You can exercise any of these rights by contacting us in writing using the contact details below and we will respond within one month unless taking into account the complexity and number of requests an extension is required. Please note that we may ask you to verify your identity and ask you for more details about your request. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, as long as there is no overriding legitimate ground or other legal reason for us to continue to hold or use that information. There may be some information which we are not legally able to disclose to you. Also, in exceptional circumstances, it may not be practicable for us to provide you with copies of all the personal data that you request. If this is the case, we will explain our reasoning to you. Please note that if you exercise some or all of the above rights, the performance of our services may be impaired or no longer possible.

If you have any concerns about our use of your information, you also have the right to complain to our regulators about the firm's information rights procedures. Our UK regulator is the UK Information Commissioner's Office (the "ICO"). Our Swiss regulator is the FDPIC. Our lead EU regulators are the Irish Data Protection Commission. Our KSA regulator is the Saudi Data and Artificial Intelligence Authority (“SDAIA”) The contact details of the firm's regulators are set out below. Where we have branches in other locations, we may also have local regulators there, details of which are available on request:

UK Information Commissioner's Office https://ico.org.uk/concerns/
Ireland Data Protection Commission https://www.dataprotection.ie/en/contact/how-contact-us
Luxembourg Commission nationale pour la protection des données (« CNPD ») https://cnpd.public.lu/fr.html
Switzerland Federal Data Protection and Information Commissioner https://www.edoeb.admin.ch/edoeb/en/home.html
Kingdom of Saudi Arabia Saudi Data and Artificial Intelligence Authority https://sdaia.gov.sa/en/SDAIA/about/Pages/RegulationsAndPolicies.aspx

The Internet

Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing the website and communicating electronically with us, you acknowledge and understand that your personal data may be processed in this way.

We will do our best to protect your personal data, but we cannot guarantee the security of any data transmitted to our website; and to the extent permitted by Data Protection Legislation, any transmission is at your own risk.

The website may, from time to time, contain links to other websites. These are not covered by this Policy and are outside of our control. If you access other websites using the links provided we do not accept any responsibility or liability for these other websites. Please check the privacy policies of those websites before you submit any personal data to them.

Cookies

Some of your personal data that we process may consist of cookies, which are small text files that often include a unique identifier that is sent by a web server to your internet enabled device when you visit a website. For details of how we deal with cookies, please see our Cookie Policy.

Marketing Communications

We and other members of the Neuberger Berman Group may use your information from time to time to inform you by letter, telephone, text (or similar) messages, email and other electronic methods, about similar products and services (including those of third parties) which may be of interest to you in accordance with the requirements under Data Protection Legislation.

You may, at any time, request that we and/or other members of the Neuberger Berman Group do not send such information to you by one, some or all channels, by contacting us in the way described below.

Contacting Us

Any queries or complaints regarding our use of personal data or the exercise of your rights should be addressed in the first instance to your usual Neuberger Berman relationship manager or NBEuropeDataProtection@nb.com or in writing to the following address: NB Data Protection Adviser c/o Neuberger Berman Europe Limited, The Zig Zag Building, 70 Victoria Street, London, SW1E 6SQ.

We may make changes to this Policy and how we use your information in the future. If we do this, we’ll post an updated version of this Policy on our website.

Last updated: 1 April 2025