Privacy Statement

Aviva Investors understands the importance of protecting nonpublic personal information provided to us via our website. With that in mind, we have set forth the following information relating to our use of such information. By visiting this website, you are accepting the practices described in this privacy policy.

Online Information We Collect and Use

The types of information that may be collected via our website include: name, email, address, telephone number, fax number, company, and profession, as well as any other information you may send to us via email message. Except as set forth herein, the information you submit via our website will be used to provide you with information about Aviva Investors’ products and services, and for administration and customer services. We may also use your information to help us review our services, marketing and communications.

We do not store information about you through the use of cookies or web beacons. When you visit our site, we may log your IP address, a unique identifier for your computer or other access device.

The internet is worldwide and if you are visiting this site from outside the USA, your visit will necessarily result in the transfer of information across international borders. By visiting this site and communicating electronically with us, you are consenting to such transfers.

If you provide us with information about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal information including sensitive personal data and that you have informed them of our identity and the purposes (as set out herein) for which their personal data may be used.

Non-Disclosure of Client Information:

Aviva Investors does not share any nonpublic personal and/or confidential information with any nonaffiliated third parties, except in the following circumstances: (1) as necessary to provide the service that the client has requested or authorized, or to maintain and service the client’s account; (2) as required by regulatory authorities or law enforcement officials who have jurisdiction over Aviva Investors, or as otherwise required by any applicable law; and (3) to the extent reasonably necessary to prevent fraud and unauthorized transactions. By accessing this site, you authorize us to disclose information in the above circumstances.

Security of Client Information

Aviva Investors seeks to restrict access to nonpublic personal and/or confidential information to those employees who need to know that information in order to provide services to you. Aviva Investors maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal and/or confidential information.

E-mail and Marketing

Aviva Investors does not sell its customers’ e-mail addresses, or provide personal information to unaffiliated third parties for their marketing purposes.

Our website provides users the option of receiving communications from us via e-mail. If you supply us with your e-mail address on-line and subscribe to our e-mail news service, we will endeavor to send you periodic messages with information on our products, services, and website updates. Our site also gives users the option of unsubscribing so that a user may elect not to receive future communications or services and be removed from our distribution lists.

Requests for Personal Information

You may request a copy of your nonpublic personal information. We will send it to you by mail, or by other method of your choosing. You may request changes of data you believe to be in error. We are under no obligation to make the requested change(s). We will inform you if we do not take the requested action. We will also provide an explanation of why we have not taken the requested action. We will maintain the request and our decision as part of your file. We will make the request, our decision, and any changes made, available to other parties to whom we have made proper disclosure of such data.

Changes to the Privacy Policy

Aviva Investors reserves the right to change, modify, add, or remove portions of this privacy policy at any time for any reason, and will notify you of changes to the extent required by law. We suggest that you review this policy regularly for changes.

Scope

This privacy policy is intended to apply to nonpublic personal information obtained via the Aviva Investors website. For persons who become or are advisory clients of Aviva Investors, the privacy policy contained in Aviva Investors’ Investment Adviser Policies and Procedures Manual will additionally be applicable to you.

To Whom This Policy Applies

Aviva Investors is a member of the Aviva family of companies. This privacy policy applies to Aviva Investors. Aviva Investors will share information with other members of the Aviva family of companies.

Contact Us

If you have any questions about this privacy policy or your interaction with this website, please contact:

Aviva Investors North America, Inc.
215 10th Street, Ste. 1000
Des Moines, IA 50309
Tel 800/281-4607