Rockefeller Capital Management appreciates your visit to this web site and your interest in our services and products. Your privacy is important to us and we want you to feel comfortable visiting our site. We take care to protect your personal data collected, processed and used during visits to our website.

By accessing the Rockefeller Capital Management Website you agree to accept this Privacy Statement (“Statement”). If you do not agree to this Statement, do not proceed to further web pages of this website.

This Statement may be updated or modified from time to time without notice. We therefore ask you to review it on a regular basis. We have indicated when the Statement was last updated.

“Purpose and Scope of this Statement

Rockefeller Capital Management and its affiliates (together, “Rockefeller Capital Management” or “our” or “we”) are committed to safeguarding the personal information that we collect from individuals who access and use the Rockefeller Capital Management Website. Accordingly, we have developed this Statement to describe how and what type of data will be collected from users of the Rockefeller Capital Management Website and the purposes for which we may collect, share or disclose the data. Rockefeller Capital Management also outlines reasonable precautions which are taken to keep your data secure.

This Statement applies to any information obtained by Rockefeller Capital Management through your use of the Rockefeller Capital Management Website. It is not applicable to any Internet websites controlled by third parties not affiliated with Rockefeller Capital Management that the Rockefeller Capital Management Website may link to (“Third Party Sites”). Please review the privacy statements of Third Party Sites as Rockefeller Capital Management is not responsible for and has no influence on the content or the privacy practices of Third Party Sites.

The terms of this Statement are subject to any additional terms of disclaimers or other contractual terms you have entered into with Rockefeller Capital Management such as client privacy statements or notices, and any applicable mandatory laws and regulations.

“Information Collected and Used

When you visit the Rockefeller Capital Management Website, our web server automatically records details about your visit (for example, your IP address, the web site from which you visit us, the type of browser software used, the Rockefeller Capital Management Website pages that you actually visit including the date and the duration of your visit).

In addition, we collect personal data which you provide through the Rockefeller Capital Management Website. For example, if you provide personal details (e.g. name, gender, address, e-mail address, phone/fax number) on a registration page or if you sign up for an email newsletter.

Rockefeller Capital Management may use your personal data: for the purposes of technical administration, analysis and development of our Website, for customer and user administration and marketing, to inform you about our services and products, and for such purposes as otherwise specified.

At all times, Rockefeller Capital Management respects the applicable laws and regulations in its use of personal data.

“Data Collection and Storage: How Do We Keep it?

Rockefeller Capital Management uses tracking technology such as cookies or tags to gather information as outlined above to understand how visitors use our website.

Tracking technology helps us manage and improve the usability of this website; including, for example detecting and tracking any contact between your computer and us so that we may identify the most popular sections or site visits of our website.

In many cases, you can control tracking technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept tracking technologies (such as cookies) where possible.

The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser. Please note, however, that refusing, disabling or deactivating of tracking technologies may result in a reduced availability of the services provided by the Rockefeller Capital Management Website or parts of the website may no longer function correctly.

“Disclosed or Shared Information Collection from the Rockefeller Capital Website

Rockefeller Capital Management may disclose your information to its affiliates, agents and third party providers to perform services for Rockefeller Capital Management and for the purposes stated above. Our affiliates, agents and third party providers who have access to personal data obtained through our website are also obligated to respect privacy.

We may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons to comply with applicable laws, regulations, court order or official request. We may also be asked or required to provide your information for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as either required or permitted by applicable law.

“Safeguarding Your Information

Rockefeller Capital Management has implemented reasonable technical and organizational security measures to protect your personal data collected via our website against unauthorized access, misuse, loss or destruction.

“Retention of Electronic Messages or E-Correspondence

All electronic messages sent to and from Rockefeller Capital Management are automatically retained in a distinct journaling system which preserves the e-mails as required by applicable law and regulation. We take all reasonable technical and organizational measures to protect these electronic messages. Rockefeller Capital Management may access and review these electronic messages or e-correspondence in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations, material breach of employment contract). Access and review of your electronic messages are given to specific persons in defined functions (e.g. Legal, Compliance, Risk). Every step of the process, as well as the search criteria used, are logged in an audit trail.

“Important Considerations When Sending Data Over the Internet

The Internet is generally not regarded as a secure environment, and information sent via the Internet (whether to or from our website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. You should be aware that even if both the sender and receiver are located in the same country, information sent via the Internet may be intercepted and transmitted across international borders to a country with a lower data protection level.

Please note that we accept no responsibility or liability for the security of your information transmitted over the Internet. In order to protect your privacy, you may want to choose another means of communication (be it telephonic or by e-correspondence) with Rockefeller Capital Management.

“Information From Individuals Under the Age of 18

At no time, does the Rockefeller Capital Management Website seek to collect the personal data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal data to Rockefeller Capital Management whether on the website or by any other means.

Last update of this Statement: January 2019.

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