Data Protection Policy (the "Policy")

Introduction

Eaton Vance Management, Eaton Vance Management (International) Limited, and other entities in the Eaton Vance group (“Eaton Vance”, “we”, “us” and “our”) collect information from individuals in the course of our business. Eaton Vance is committed to respecting your privacy and the confidentiality of this information.

About this policy

For the purposes of data protection law, Eaton Vance is a data controller in respect of your per-sonal data. We are responsible for ensuring that we use your personal data in compliance with data protection law. Personal data includes any information that relates to an identifiable natural person, or as otherwise specified in regulations applicable in the jurisdictions in which Eaton Vance operates.

This Policy applies to European Union residents whose personal data Eaton Vance collects, including individuals we deal with, receive information from, or send information to. This Policy also sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy policy. If you do not accept the terms of this privacy policy, your use of our website may be restricted.

Personal data that we collect

We will collect and process personal data provided on applications, in documents, and during transactions. We will also collect and process personal data about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include, but is not limited to, your name and contact information. You may pro-vide Eaton Vance with your personal data for the purposes of receiving information, product or services from Eaton Vance, or in connection with a job application or your employment with us. Eaton Vance may request personal data from you to facilitate the provision of a personalized service.

Eaton Vance may receive your personal data from other entities within the Eaton Vance Group, service providers, agents, financial advisers, brokers, and/or business partners. If such personal data is disclosed to us by a third party, it is the responsibility of the disclosing party to ensure that the personal data is disclosed in accordance with applicable rules and regulations and the neces-sary consents. We will process personal data disclosed to us by a third party in accordance with this privacy policy.

Eaton Vance may also incidentally collect data that falls within the scope of this privacy policy. For example, if you are an existing US resident who is a shareholder in an Eaton Vance fund, Eaton Vance collects your personal information. Eaton Vance may continue to do so if you relocate to a jurisdiction with different data protection laws, such as the European Union.

Eaton Vance does not knowingly solicit or receive information from individuals under the age of eighteen (18).

Uses of your personal data

Eaton Vance may store and process your personal data for a number of purposes. These pur-poses include, but are not limited to, the following legitimate business purposes:

  • To offer you with investment services and/or products.
  • To fulfill our contract with you.
  • To provide you with information about the products and services we offer.
  • To send you emails, mailings, and other information that you request.
  • To service and maintain accounts and records of transactions.
  • To archive communications between you and Eaton Vance.
  • To customize and improve your experience while using our websites and ensure the secu-rity of our websites.
  • To process applications, forms and other documentation.

Eaton may also use your personal data for the purposes of complying with our legal and regulatory obligations and the administration of justice in the jurisdictions in which Eaton Vance operates. We may also use your personal data to resolve disputes, to establish, exercise or defend our legal rights, or for the purpose of legal proceedings.

Eaton Vance may share your personal data with third-parties. We may provide your personal data to service providers, such as the providers of our electronic storage. Such service providers are subject to confidentiality requirements and will provide the service in accordance with this privacy policy. Eaton Vance may also disclose your personal data for due diligence purposes in connec-tion with mergers, reorganizations, sales, dissolutions, or transfers of business in which we are involved. At your request, Eaton Vance may share your personal data with your advisor, repre-sentative, agent, or other designated parties.

Transfers of personal data outside the European Economic Area

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who works for Eaton Vance affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, Eaton Vance will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

  • The country that we send the data to might be approved by the European Commission;
  • The recipient might have signed up to a contract based on “model contractual clauses” ap-proved by the European Commission, obliging them to protect your personal data; or
  • Where the recipient is located in the US, it might be a certified member of the EU-US Pri-vacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by var-ious criteria including:

  • The purpose for which we are using it – we will need to keep the data for as long as is nec-essary for that purpose; and
  • Legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

Cookies

Eaton Vance makes use of cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our of-fering and quickly identifying and fixing any issues that arise. For example, we might use perfor-mance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or website services that we think will be of interest to you based on your usage of the website. The information collected by these cookies is anonymous and is not associated with your personal information by us.

For additional information on Eaton Vance’s use of cookies, please see our Cookie Policy.

Registered Users

Some content or pages of the Eaton Vance website are available only to registered users. If you are a user who has previously registered or been registered for access, Eaton Vance may already have some of your personal data, such as your name and email address. Eaton Vance will handle this information in accordance with this policy.

If you register as a new user for access to restricted content and pages, you will be asked to attest that you have read and agreed to the terms set out in this policy. Any personal data that you provide to Eaton Vance at the time of registration, such as your name and email address, will be handled in accordance with this policy.

Your rights

You have a number of legal rights in relation to the personal data that Eaton Vance holds about you. These rights include:

  • The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • The right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • The right to request that we rectify your personal data if it is inaccurate or incomplete;
  • The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • The right to object to, and the right to request that we restrict, our processing of your per-sonal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and/or to refuse that request; andv
  • The right to lodge a complaint with the data protection regulator (details of which are pro-vided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the "Contacting us" section below.
You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to dataprotection@eatonvance.com.