BESSEMER TRUST ON-LINE PRIVACY POLICY

CLIENT PRIVACY

Last Updated: April 1, 2024

Bessemer Trust (“Bessemer” or the “Company”) is committed to maintaining the privacy and security of your personal information consistent with applicable privacy and data protection laws. This On-line Privacy Policy (“Privacy Policy”) explains what and how we may collect, process, use, disclose, and protect your personal information, who it may be disclosed to, and provides information on your individual privacy rights when you visit or use our public website (www.bessemertrust.com) (the “Site”).

Other privacy policies could apply depending on how you interact with us, the financial products or services you may ultimately obtain from us, or the jurisdiction in which we are doing business with you.

If you are a California resident, you may have rights under the California Privacy Rights Act as described in our Notice of Collection of Personal Information and Privacy Policy (“CPRA Privacy Notice”). Please see our CPRA Privacy Notice for additional disclosures and privacy protections concerning your use of the Site for California Residents. Similarly, European Union and United Kingdom residents may have specific privacy rights under the U.K. and E.U. General Data Protection Regulations (collectively “GDPR”).

We may update this Privacy Policy at any time by posting the amended version on the Site with the effective date of the updated version. By using our Site or requesting information from us after we make such changes to this Privacy Policy, you are deemed to have accepted such changes.

How do we safeguard or protect your information?

We take our responsibility to protect the privacy and confidentiality of your information, including personal information, seriously. We maintain reasonable physical, electronic, and procedural safeguards and follow generally accepted industry data practices that comply with applicable legal standards to protect personal information about you from accidental loss and from unauthorized access, use, destruction, alteration and disclosure.

How does the Gramm-Leach-Bliley Act protect my non-public personal information if I am a client?

If you are a client, your privacy rights in connection with your non-public personal information are governed by the Gramm-Leach-Bliley Act (“GLBA”). In accordance with law, our GLBA Notice governs your privacy rights once you become a client of Bessemer Trust, including your use of our client portal, and our collection, use and disclosure of your non-public personal information protected under the GLBA.

Do we sell your personal information for advertising or other purposes?

Bessemer Trust does not sell your personal information or share your personal information with third party advertising vendors for purposes of targeting you with advertising based on tracking your online activity across different websites.

What personal information is covered by our On-Line Privacy Policy?

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person. Personal information does not include publicly available information or information that is de-identified or aggregate consumer information.

We collect your personal information when you provide it voluntarily to us. By using our Site, viewing our online briefing materials and other content (including our educational videos) or submitting your personal information to us, you consent to the collection, processing, use, and disclosure of your personal information as set forth in this Privacy Policy, as it may be updated from time to time. We may also automatically collect personal information about you and your devices or browser in connection with your visit to our Site using cookies and similar technology. Our technology may, for instance, automatically identify your device or browser in connection with the particular web page you access on the Site that may contain written materials or a video. We may also aggregate personal information across our Site visitors to track trends and analyze patterns on the Site.

What types of personal information do we collect on this Site?

The nature of the information that we collect depends on our relationship with you, the services provided, and applicable law. We may collect, process, use and disclose the following types of personal information in connection with your use of our Site or when you communicate with us, including through online forms or on our private client website.

Contact Data: Name, mailing address, telephone number, email address.
Profile Data: Username and password for our online services that you have access to, investments made by you, services requested, marketing communications, responses to surveys.
Financial Data: Account number, client reference number; account statements, investment history.
Professional Information Data: Position or job title, business address, business telephone number, business email address
Services Data: Details of services provided to you and payment details to and from you as part of accessing or using our Services.
Technical Data: Your use of and interaction with our online services through your IP address, including browsing history, searches, page and video views, and other similar information regarding your session on our Site.
Sensitive Personal Information: In limited circumstances, we may collect sensitive personal information, when legally required or in seeking to accommodate your specific needs; for example, like dietary requirements, if we are arranging catering, or disability, to make reasonable accommodations for you in our buildings.

What types of cookies and other technologies do we use to automatically collect your personal information?

Our Site uses “cookies” and similar technologies to analyze your visits to our Site, and to improve and customize your browsing experience. Other cookies are necessary for the Site to function properly. By accessing and using our Site, you consent to our use of all cookies and similar technologies. You can choose whether to accept cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. However, if you choose not to accept functional or necessary cookies, the Site may not function properly and some features may not work as they were intended.

For analytics of our Site, we use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics may set cookies on your browser or read cookies that are already there to collect information concerning your Site visit to help us analyze usage of our Site. We use the information provided by Google Analytics to improve our Site and your user experience. For more information regarding how Google Analytics collects and uses your personal information please visit http://www.google.com/policies/privacy/partners/. By using our Site, you consent to the processing of data about you by Google as described here and in Google’s privacy policy. You can control the information provided to Google by using one of the methods set forth in http://www.google.com/policies/privacy/partners/ or use the Google Analytics opt out browser add-on at http://tools.google.com/dlpage/gaoptout?hl=en.

When you communicate with us by email, we may embed a tracking pixel in the email we send to you to determine whether you have opened it. Our website uses Session and Persistent Cookies to permit us and our website service partners to:

Measure your use of our website in an effort to improve its quality and enhance your overall experience, including tracking page views, time and date of website access, and other usage and navigation data, and identifying your operating system and browser type (but not other information about your computer or the files or programs on it) and your general geographic location; and
Aggregate usage data to track trends and analyze patterns on the website.

If you do not wish to accept Cookies from our website, please either disable them or refrain from using this website. If Cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using all or part of this website.

Most browsers are initially set to accept Cookies. However, you have the ability to change your browser settings. It may also be possible to configure your browser settings to enable acceptance of specific Cookies or to notify you each time a new Cookie is about to be stored on your device enabling you to decide whether to accept or reject the Cookie. You can also disable Cookies by configuring your browser setting to reject Cookies. Please refer to the help section of your browser for instructions on disabling Cookies.

What are our business reasons for collecting, processing, using and disclosing your personal information?

Depending on the individual circumstances, we collect, process, use and disclose personal information for legitimate business purposes. These purposes may include:

to communicate with you and respond to your inquiries.
to provide you with educational materials and other information regarding our services.
to show you educational videos.
to market services tailored to your interests.
to analyze and improve the functionality and effectiveness of our Site.
to determine the general geographic regions where visitors to our Site are located.
to protect the security of our Site.
to prevent, detect and investigate fraud.
to fulfill the purpose for which you provided us with your personal information.
to comply with our legal obligations.
to improve our services and products.
to further our other legitimate interests, including to make available and highlight content and opportunities that are relevant to you and other visitors to our Site.

To whom do we disclose your personal information?

We do not sell your personal information to third parties.

We share personal information with affiliates and with others when we believe it will enhance the services and products we can provide to you or for legal and routine business reasons. For example, we may retain third party companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, technology services, customer service providers, video content providers, website analytics providers, platform providers, and shippers. Such outside organizations and individuals may be provided with access to your personal information to perform the functions for which they have been retained. For example, if you view a video on our Site, you consent to your personal information being shared with the outside organization we use to enable videos on our Site. The Company requires its service providers, who provide services on our behalf to maintain the privacy and security of your personal information.

We may disclose your personal information to our affiliates and others for legitimate business purposes to provide you with services and products made available on this Site.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

How long do we store your personal information?

We do not retain your personal data for longer than is necessary to fulfill the business purposes for which the information is being collected or processed or in order to comply with applicable legal or regulatory requirements.

What are your options regarding your personal Information?

You have choices about how we use your personal information to communicate with you and send you marketing information. You can opt out from receiving future marketing communications from us at any time by:

Using the unsubscribe function in the email or marketing information you receive from us; or
Contacting us as set forth under “How to contact us” below.

In addition, you have choices available to you through the device or browser you use to access the Site regarding your cookies and other browser settings. For information about privacy settings on your browser, see, for example, Google Chrome. You may also change the settings on your mobile device, which lets you choose how and whether your approximate geographic location is shared with us. See, for example, Apple.

What is our policy on children’s personal information?

Our Site is not intended for use by children under thirteen [13] years of age. We do not knowingly collect or use personal information from children under thirteen [13]. No one under age thirteen [13] may provide any information to us through the Site. If you are a parent or a legal guardian, and you reasonably believe that your child under thirteen [13] provided us with any personal information on the Site or on or through any of its features without parental consent, please contact us marking your inquiry “COPPA Information Request.”

Does our Privacy Policy apply to links to other websites and services?

The Site may have links to third-party websites that are not operated by us. We have no control over how these third-party websites may collect your information and no liability for the practices, policies and security measures implemented on these websites or for their content. Our Privacy Policy does not apply to third-party websites. You should read the privacy notices on those other websites before you submit your information through them.

Do we honor “Do Not Track” requests or Global Privacy Controls?

We do not presently recognize browser “do not track” requests or Global Privacy Controls. As noted above, we do not sell your personal information to third parties or share your personal information for purposes of targeting you with ads based on your online activity at other websites.

How do you contact us?

If you have any questions about this Policy or our use of your personal information, please send us an email at [email protected]. You may also contact us at (888) 811-8417 or by mail at:

Attention: Legal Department
Bessemer Trust
1271 Avenue of the Americas
New York, NY 10020
United States

NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY
UNDER THE CALIFORNIA PRIVACY RIGHTS ACT

This Notice of Collection of Personal Information and Privacy Policy (“CPRA Privacy Notice”) applies to the collection of personal information from California residents on and after January 1, 2023. This CPRA Privacy Notice supplements Bessemer Trust’s “Privacy Policy” to provide California residents with additional information about their privacy rights as required by the California Privacy Rights Act (“CPRA”). The CPRA Privacy Notice applies only to individuals residing in the State of California who are considered “consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.

This CPRA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we collect, process, use, store, and disclose your personal information, and your rights in personal information under the CPRA. Bessemer Trust (“Bessemer” or the “Company”) does not share your personal information with third party advertisers for cross-context behavioral advertising within the meaning of the CPRA (i.e., targeting you with advertising based on personal information obtained across businesses, websites, applications or services, other than the Company’s website or services). We do not sell your personal information.

For purposes of this CPRA Privacy Notice, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA, including non-public personal information that is within the scope of the Gramm-Leach-Bliley Act (“GLBA”).

By using our Site, viewing our content (including our videos) or submitting your personal information to us, you consent to the collection, processing, use and disclosure of your personal information as set forth in this CPRA Privacy Policy, as it may be updated from time to time.

What categories of personal information do we collect about you?

We may collect personal information from you in various ways including:

when you voluntarily provide us with information (e.g., through your communications with us by using our Site);
when you communicate with us to request information concerning our services and products; and
through automated means when you use our Site including by use of “cookies” and other similar technologies.

We collect the following categories of personal information. This table also sets out personal information we may have collected over the last twelve (12) months:

Categories	Examples	Retention Period
A. Identifiers	This information may include your name and contact details (including mailing addresses, telephone numbers, email addresses, IP address, browser or device identifier, and other identifying information you provide to us). For example, we may collect your name and email address when you request to receive information on our services.	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.
B. Customer Information under California Civil Code §1798.80(e)	This information comprises information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our business records. Some personal information in this category may overlap with other categories.	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.
C. Commercial Information	This category includes information concerning the services and products you requested to receive educational information on.	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.
D. Internet and other electronic history	This category comprises electronic information concerning your use of the website (www.Bessemer.com) and dependent pages (the “Site”), other than our secure client portal. This information may include information we automatically collect as you browse the Site, including your IP address, device type/identifier, browser type/identifier, pages visited, and other similar electronic information. We may use services provided by outside organizations, including Google Analytics, concerning your website activity to monitor your usage. We may collect information concerning your website usage through cookies and other technologies.	Generally, for as long as one [1] year
E. Geolocation data	We may determine your approximate geographic location through your IP address.	Generally, for as long as one [1] year
F. Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes	We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our services.	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.

We do not collect sensitive personal information for purposes of inferring characteristics.

What are our business reasons for collecting and using your personal information?

Depending on the individual circumstances, we collect, process, use and disclose personal information for legitimate business purposes. These purposes include:

to communicate with you and respond to your inquiries.
to provide you with educational materials and other information regarding our services.
to show you educational videos.
to market services tailored to your interests.
to analyze and improve the functionality and effectiveness of our Site.
to determine the general geographic region where visitors to our Site are located.
to protect the security of our Site.
to prevent, detect and investigate fraud.
to fulfill the purpose for which you provided us with your personal information.
to comply with our legal obligations.
to improve our services and products.
to further our other legitimate interests, including to make available and highlight content and opportunities that are relevant to you and other visitors to our Site.

What are our categories of sources of personal information?

The Company may collect personal information from the following categories of sources:

directly from you;
service providers providing services on our behalf. We require our service providers who we provide your personal information to in order to provide services to maintain the privacy and security of your personal information;
our affiliates.

Who do we disclose your personal information to?

We do not sell your personal information to third parties, including the personal information of minors under sixteen [16] years of age.

In some instances, we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, customer service providers, video content providers, website analytics providers, platform providers, and shippers. Such outside organizations may be provided with access to your personal information to perform the functions for which they have been retained. The Company requires its service providers, who provide services on our behalf to maintain the privacy and security of your personal information. By using our Site, you consent to the disclosure of your personal information to our service providers, including but not limited to our video content providers.

We may disclose your personal information to our affiliates for our legitimate business purposes.

In the past twelve (12) months, we have not shared the categories of personal information collected in Categories [A-F] with third parties.

In the past twelve (12) months, we have disclosed the categories of personal information collected in Categories [A-F] with the following organizations or entities who are not service providers or contractors providing services on our behalf: other Bessemer Trust affiliates or as required by applicable law.

What are your rights regarding your personal information?

Under the California Privacy Rights Act, you have the following rights in personal information held by us:

You have the right to request that the Company disclose the personal information that we collect, use, and disclose about you. You may “request to know”: (i) the categories of personal information that the Company has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom the Company discloses your personal information; and (v) the specific pieces of personal information that the Company has collected about you. Your request may pertain to the personal information collected about you on or after January 1, 2022. If your request covers a time period beyond twelve [12] months from the date of your request, the Company may deny your request as to that time period where it would be impossible for the Company to provide you with the information or involve disproportionate effort. The Company may deny your request to search for certain information under certain circumstances (e.g., where the Company retains the information solely for legal and compliance purposes).
You have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.
You have the right to correct inaccurate personal information.
You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
You have the right to know what information is shared with third parties, and to whom and to opt out of sharing for cross-context behavioral advertising.
You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you products or services because you have exercised your rights.

You may submit verifiable requests concerning any of your rights by contacting us by e-mail at [email protected], or by mail at the address provided below or by telephoning us at (888) 811-8417.

Attention: Legal Department
Bessemer Trust
1271 Avenue of the Americas
New York, NY 10020
United States

We will use reasonable methods for verifying that the person making a request to know, data portability, request to correct or a request to delete is the individual about whom we have collected personal information.

This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten [10] business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five [45] calendar days to respond to your request.

Do we provide access to the CPRA Privacy Notice to persons with disabilities?

Persons with disabilities who need assistance accessing this CPRA Privacy Notice may contact us as provided for above, and depending on your individual needs, the Company will grant reasonable requests to furnish this policy in an alternative format.

Do we provide financial incentives to California Consumers for providing us with personal information?

We do not offer you financial incentives such as loyalty programs, discounts, and special offers when you provide us with contact information and identifiers such as your name and email address.

California Shine the Light Law/Online Privacy Protection Act

California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided above.

Revisions to This CPRA Privacy Notice

We may update this CPRA Privacy Notice at any time, by posting the amended version on this Site, including the effective date of the updated version. By accessing the Site or communicating with us after we make any such changes to this CPRA Privacy Notice, you are deemed to have accepted such changes. Please check this CPRA Privacy Notice regularly, and before you submit additional personal information via the Site.

As of: April 2024

NOTICE OF COLLECTION OF PERSONAL DATA AND PRIVACY POLICY UNDER
THE GENERAL DATA PROTECTION REGULATION (GDPR)

This Notice of Collection of Personal Data and Privacy Policy (“GDPR Privacy Notice”) applies to the collection of Personal Data from residents of the European Union and United Kingdom. This GDPR Policy Notice supplements our “Privacy Policy” above to provide European Union residents with information and rights required by the GDPR.

For purposes of this GDPR Privacy Notice, we refer to personal data according to the following definition given in the GDPR: “personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

What are our lawful basis for processing your Personal Data

Bessemer is committed to processing personal data only where there is a lawful basis:

where you have given consent to the processing of your personal data for one or more specific purposes.
where the sole basis for our use of the personal data is your consent, you have the right to withdraw your consent at any time;
where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
where processing is necessary for compliance with a legal obligation to which Bessemer is subject;
where processing is necessary for the purposes of the legitimate interests pursued by Bessemer or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Bessemer’s legitimate interests are to effectively manage our business and customers, market, sell and deliver our products, manage your account, improve our services, maintain the security of our Site, and comply with our legal obligations.
processing of special category personal data shall only occur where you have given explicit consent to the processing of the personal data for one or more specified purposes or where permitted by applicable law. We are located in the United States. By providing us with your personal data, you consent to the transfer of your personal data to our systems located in the United States.

Your rights regarding your Personal Data

Under the GDPR, you have the following rights in personal data held by us:

the right to access your personal data and request certain information concerning our use of your personal data, such as an explanation of the purpose of the processing, categories of personal data processed and disclosure of outside organizations to who Bessemer has disclosed your personal data;
the right to rectify inaccuracies in your personal data or to ensure that it remains up to date;
the right to erasure of your personal data under certain circumstances. For example, you may request erasure if the data is no longer needed in connection with the reasons it was collected or processed or if you withdraw your consent to further processing. Bessemer may deny your request where it is required or permitted by law to retain your personal data or when we need to retain your information in connection with the exercise or defense of legal claims;
right to restrict processing where you contest the accuracy of the data in order to permit time to rectify the inaccuracies and in other circumstances;
the right to data portability by requesting a copy be provided in a structured, commonly used and machine-readable format and/or requesting that Bessemer transmit your personal data to a third party where technically feasible;
the right to object to our use of your personal data where you contest that the processing is necessary for the purposes of Bessemer’s legitimate interests. Bessemer may deny your request because it has compelling legitimate business interests or in connection with the exercise or defense of legal claims. You also have the right to advise us at any time that you no longer wish to receive direct marketing materials from Bessemer and we will no longer use your personal data for marketing purposes; and
the right to bring a complaint before the applicable governmental privacy regulator. Contact details for data protection authorities in the EEA are available here.

We will take action on your requests concerning any of your rights without undue delay and in any event within one month of receipt of the request. We may extend that time period by two further months where necessary, taking into account the complexity and number of the requests. If we need more time, we will inform you of any such extension within one month of receipt of the request, together with the reasons we need more time. The information you requested shall be provided by electronic means where possible unless you request otherwise.

Revisions to This GDPR Privacy Notice

We may update this GDPR Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. Please check this GDPR Privacy Notice regularly, and before you submit additional personal data via the Site.

How Long Do We Retain Your Data

We retain your personal data for the length of the customer relationship, plus the length of applicable statutory limitations periods, or as necessary to fulfill the purposes set out in this disclosure or as required by applicable law.

***

How To Contact Us

If you have questions regarding any of the above privacy notices or if you would like to exercise your rights, please send us an email to [email protected]. You may also contact us by phone at (888) 811-8147 or by mail at:

Attention: Legal Department
Bessemer Trust
1271 Avenue of the Americas
New York, NY 10020
United States

As of April 2024