Terms and Conditions

TERMS AND CONDITIONS

PLEASE READ THE FOLLOWING TERMS AND CONDITIONS CAREFULLY. BY ACCESSING SSGA.COM AND ANY PAGES THEREOF (the “Site”), YOU AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS AS WELL AS ANY FUTURE REVISIONS STATE STREET GLOBAL ADVISORS (“SSGA”) MAY MAKE IN ITS DISCRETION. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS BELOW, DO NOT ACCESS THIS SITE, OR ANY PAGES THEREOF.

Access

You are accessing SSGA’s network pursuant to the terms of this Agreement and any existing agreement you may have with us. You and your authorized designees (“Authorized Designees”) access the Site “AS IS” and acknowledge that the Site and the remote access services related to use of certain portions of this Site are proprietary to and confidential property of SSGA and its relevant licensors and information and data suppliers (“Suppliers”). All equipment, systems, services and software are to be used for your business purposes only in accordance with the terms of this Agreement and your agreement(s) with SSGA. Unauthorized access, use or distribution is in violation of state and/or federal statutes. SSGA reserves the right to monitor and audit all transactions and data (including e-mail messages) for any purpose sent over this network and your use of this Site unless prohibited by law. You agree that a printed version of this Agreement shall be admissible in judicial or administrative proceedings to the same extent as other business documents and records.

Certain portions of this Site are secure. The secure portions of the Site and information therein that you receive are encrypted for privacy. SSGA takes reasonable and appropriate measures, including encryption, to ensure that information is disclosed only to you. However, the Internet is an open system and there is no absolute guarantee that the information you have retrieved will not be intercepted by others and decrypted, and you assume that risk in accessing the Site.

Not all products or services provided on the Site are available in all jurisdictions. SSGA’s products and services are only available in jurisdictions where it is lawful to advertise and market these products and services. The information on the Site has been prepared for informational purposes only without regard to any particular user’s investment objectives, or financial situation or position and SSGA is not soliciting any action based upon them.

Unless otherwise indicated either in the Site or herein, SSGA or its affiliates own the copyright and any other intellectual property rights subsisting anywhere in the world to the information on this Site. You may not copy, reproduce, duplicate, modify, adopt or lend, sell, disseminate or otherwise transfer, in whole or in part, any of the information contained in this Site, except for the purpose of accessing the Site and producing print-outs for your own personal use, or making a reasonable number of copies of such pages for internal use within your organization in accordance with this Agreement. Users of this Site shall not remove, alter, or obscure any copyright, trademark, trade secret or other proprietary rights notices appearing in or on the website, and shall reproduce all such notices on any copies of content made by or on behalf of users.

No Offer/Local Restrictions

Nothing contained in or on the Site should be construed as a solicitation of an offer to buy or offer, or recommendation, to acquire or dispose of any security, commodity, investment or to engage in any other transaction. SSGA offers a number of products and services designed specifically for various categories of investors in various countries and regions. Not all products will be available to all investors. These products or services are only offered to such investors in those countries and regions in accordance with applicable laws and regulations.

No information included on this Site is to be construed as investment advice or as a recommendation or a representation about the suitability or appropriateness of any advisory product or service; or an offer to buy or sell, or the solicitation of an offer to buy or sell, any security, financial product, or instrument; or to participate in any particular trading strategy. SSGA recommends that you seek independent financial and tax advice before making any investment decisions.

The information provided on the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. All persons and entities accessing the Site do so on their own initiative and are responsible for compliance with applicable local laws and regulations. The Site is not directed to any person in any jurisdiction where the publication or availability of the Site is prohibited, by reason of that person’s nationality, residence or otherwise. Persons under these restrictions must not access the Site.

Jurisdictional Matters

The information available by accessing the non-U.S. pages on this Site has been prepared and is maintained by non-U.S. affiliates of SSGA, including but not limited to State Street Global Advisors, Australia, Limited, State Street Global Advisors Asia Limited (道富環球投資管理亞洲有限公司), State Street Global Advisors Singapore Limited, State Street Global Advisors Limited, State Street Banque, S.A., State Street Bank Europe Ltd., State Street Global Advisors AG, State Street Global Investments SGR p.A., State Street Global Advisors GmbH, State Street Global Advisors, Ltd., State Street Trust and Banking Co., Ltd. and State Street Global Advisors (Japan) Co., Ltd. (collectively hereinafter referred to as “Non-U.S. Affiliates”).

The Non-U.S. Affiliates offer products and services designed specifically for non-U.S. investors. The information and other material contained on these non-U.S. web pages are only directed at and available to investors in specific countries. All content contained therein should be considered, and is subject to, the specific regulatory requirements under which these Non-U.S. Affiliates operate, respectively.

SSGA does not offer the products or services of the Non-U.S. Affiliates to U.S. investors, and investments from U.S. investors generally will not be accepted. Access to non-U.S. pages in this site is not permitted by U.S. residents.

No Reliance

Information contained in the Site is checked and updated by SSGA with due diligence on a regular basis. However, data and information on the Site may become outdated. Therefore, neither State Street Corporation, SSGA, nor any of their affiliates assumes any liability or guarantee for the timeliness, accuracy and completeness of the information provided. SSGA uses reasonable efforts to obtain information from sources which it believes to be reliable; however, SSGA makes no representation that the information or opinions contained on the Site are accurate, reliable or complete. The information on the Site is provided for informational purposes only and is subject to change without notice. The investments and strategies discussed in the contents may not be suitable for all investors and are not obligations of SSGA or guaranteed by SSGA. The investments are not bank deposits and are not insured by the FDIC, CIPF, CDIC or any other entity and are subject to investment risks, including the loss of the principal amount invested. Nothing contained on the Site constitutes investment, legal, tax or other advice nor is to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.

No Warranty

THE SITE AND THE INFORMATION INCLUDED ON THE SITE ARE PROVIDED TO YOU “AS IS” WITHOUT ANY WARRANTIES OF ANY KIND. NEITHER STATE STREET CORPORATION NOR SSGA, NOR ANY OF THEIR RESPECTIVE AFFILIATES OR SUPPLIERS, WARRANTS THE ACCURACY, ADEQUACY, COMPLETENESS, OR TIMELINESS OF THE MATERIALS PROVIDED ON THIS SITE OR THE SITE’S ERROR-FREE USE OR CONNECTIVITY OR AVAILABILITY OF THE SITE OR CONTENT. THERE IS NO WARRANTY OF ANY KIND - EITHER EXPRESS OR IMPLIED - INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF NON-INFRINGEMENT OF THIRD-PARTY RIGHTS, TITLE, MERCHANTABILITY, ACCURACY, AVAILABILITY AND FITNESS FOR ANY PARTICULAR PURPOSE AND FREEDOM FROM COMPUTER VIRUS.

SSGA MAKES NO WARRANTY WHATSOEVER TO YOU, EXPRESS OR IMPLIED, REGARDING THE SECURITY OF THE SITE, INCLUDING WITH RESPECT TO THE ABILITY OF UNAUTHORIZED PERSONS TO INTERCEPT OR ACCESS INFORMATION TRANSMITTED BY YOU THROUGH THIS SITE.

Limitations of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT, INCLUDING NEGLIGENCE, SHALL STATE STREET CORPORATION, SSGA OR ANY OF THEIR RESPECTIVE AFFILIATES OR SUPPLIERS BE LIABLE FOR ANY LOSS OR DAMAGE OF ANY KIND, INCLUDING ANY DIRECT, SPECIAL INDIRECT OR CONSEQUENTIAL DAMAGES (INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF DATA, LOSS OF PROGRAMS, OR ANY OTHER PECUNIARY LOSS), ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE ACCESS OF, USE OF, PERFORMANCE OF, BROWSING IN OR LINKING TO OTHER SITES FROM THE SITE , OR ANY INFORMATION AND RELATED GRAPHICS CONTAINED IN OR MADE AVAILABLE THROUGH THE SITE, EVEN IF STATE STREET CORPORATION, SSGA, OR ANY AFFILIATE OR SUPPLIER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME STATES AND JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. YOU HEREBY RELEASE AND FOREVER WAIVE ANY AND ALL CLAIMS YOU MAY HAVE AGAINST STATE STREET CORPORATION, SSGA OR THEIR RESPECTIVE AFFILIATES AND SUPPLIERS, OR THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, INFORMATION PROVIDERS OR SUPPLIERS FOR LOSSES OR DAMAGES YOU SUSTAIN IN CONNECTION WITH YOUR USE OF THIS SITE.

Hyperlinks

SSGA is not responsible for the content or accuracy of third-party sites hyperlinked from this Site, nor does State Street or SSGA guarantee the products or services offered on third-party sites. You acknowledge and agree that neither SSGA nor any of its affiliates is responsible for the availability of such third-party sites, does not endorse, approve, investigate or verify, and is not responsible or liable for any content, advertising, products, or other materials on or available from such sites. You further agree that neither SSGA nor any of its affiliates shall be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, products or services available on such external sites. These links are provided as a convenience and solely for informational purposes. SSGA is not making any recommendation to invest in, purchase, or sell any securities or other products or services offered on the linked sites, nor has SSGA sought to verify or confirm the information contained in the linked sites. Accordingly, SSGA disclaims any responsibility for the linked sites. Review the privacy statements of any Web site you visit before you provide any personal/confidential information or conduct a transaction.

No other site, without the prior written permission of SSGA, is authorized to link to any part of this Site.

Investment Performance

YOU ACKNOWLEDGE THAT ALL DATA AND INFORMATION TRANSMISSIONS VIA THE SITE ARE SOLELY FOR THE INFORMATIONAL AND OTHER PURPOSES SET FORTH HEREIN, AND ARE NOT INTENDED AS FINANCIAL ADVICE OR AS AN OFFER, SOLICITATION OR RECOMMENDATION OF SECURITIES OR OTHER FINANCIAL PRODUCTS, OR TO SATISFY REGULATORY REQUIREMENTS OR COMPLY WITH ANY APPLICABLE LAWS, RULES, REQUIREMENTS OR STANDARDS OF ANY FEDERAL, STATE OR LOCAL GOVERNMENTAL AUTHORITY, AGENCY OR INDUSTRY REGULATORY BOARD, INCLUDING THE SECURITIES INDUSTRY, WHICH COMPLIANCE IS YOUR SOLE RESPONSIBILITY. HISTORICAL PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE PERFORMANCE OF AN INVESTMENT. THE VALUE OF INVESTMENTS MAY FALL AS WELL AS RISE AND INVESTORS MAY NOT GET BACK THE AMOUNT INVESTED.

Security Procedures

You agree to comply, and to cause your Authorized Designees to comply, with remote access operating standards and procedures and with user identification or other password control requirements and other security procedures as may be issued from time to time by SSGA for use of the secure portions of the Site and access to the remote access services. You agree to advise SSGA immediately in the event that you learn or have reason to believe that any person to whom you have given access to the Site has violated or intends to violate the terms of this Agreement and you will cooperate with SSGA in seeking injunctive or other equitable relief. You agree to discontinue use of the Site and remote access services, if requested, for any security reasons cited by SSGA without liability to State Street, SSGA, its affiliates or its Suppliers.

Single Sign-On

SSGA has enabled single sign-on to grant users access to multiple applications, functionality and reports after the initial authentication and log-on to the secure portions of the Site. Certain sensitive and high risk products may require 2-factor authentication using a secure token or digital certificate. Upon being authenticated at a higher level, SSGA’s single sign-on will make all the Site products available to users, including, high access level products. To close or log-off of all the Site products, including high level access products, you must completely log-off of the Site. Please be advised that if you do not completely log-off of the Site, then your access, including that to high level products, will continue throughout the Site session. If your Site session is inactive for a period of time, then SSGA will automatically close all sessions to effect a log-off of all products.

Proprietary Information/Injunctive Relief

The Site described herein and the databases, computer programs, screen formats, report formats, interactive design techniques, formulae, processes, systems, software, know-how, algorithms, programs, training aids, printed materials, methods, books, records, files, documentation and other information made available to you by SSGA as part of the remote access services and through the use of the Site and all copyrights, patents, trade secrets and other proprietary rights of SSGA related thereto are the exclusive, valuable and confidential property of SSGA and its relevant licensors (the “Proprietary Information”). You agree on behalf of yourself and your Authorized Designees to keep the Proprietary Information confidential and to limit access to your employees and Authorized Designees (under a similar duty of confidentiality) who require access to the Site for the purposes intended. The foregoing shall not apply to Proprietary Information in the public domain or required by law to be made public.

Restrictions on Use

You agree to use the remote access services only in connection with the proper purposes of this Agreement. You will not, and will cause your employees and Authorized Designees not to, (i) permit any third party to use the Site or the remote access services related to the Site, (ii) sell, rent, license or otherwise use the Site or the remote access services related to the Site in the operation of a service bureau or for any purpose other than as expressly authorized under this Agreement, (iii) use the Site or the remote access services related to the Site for any fund, trust or other investment vehicle without the prior written consent of SSGA, (iv) allow or cause any information transmitted from SSGA’s databases, including data from third party sources, available through use of the Site or the remote access services, to be published, redistributed or retransmitted for other than use for or on behalf of yourself, as SSGA’s customer, and (v) use more than one asset identifier per security. In no event may you use the data and information on the Site in lieu of obtaining appropriate licenses from the applicable Supplier, and SSGA may limit the use of this Site accordingly.

Modification of the Site

You agree that neither you nor your Authorized Designees will modify the Site in any way, enhance or otherwise create derivative works based upon the Site, nor will you or your Authorized Designees reverse engineer, decompile or otherwise attempt to secure the source code for all or any part of the Site.

Indemnification

You agree to make SSGA and its subsidiaries and affiliates whole for any and all claims, losses, liabilities, and expenses (including attorneys’ fees) arising from your use of the Site or any violation of this Agreement unless prohibited by law.

Commodities Management

SSGA generally delegates commodities management for separately managed accounts to SSGA FM, a wholly owned subsidiary of State Street and an affiliate of SSGA. SSGA FM is registered as a commodity trading advisor (“CTA”) with the Commodity Futures Trading Commission and National Futures Association.

This communication is not specifically directed to investors of separately managed accounts (SMA) utilizing futures, options on futures or swaps. SSGA SMA clients should contact SSGA Relationship Management for important CTA materials.

Applicable Law

Your use of this Site and this Agreement is governed by the Commonwealth of Massachusetts and applicable federal law.

If any provision of this Agreement shall be held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions shall not in any way be affected. No term or provision shall be deemed waived and no breach excused unless such waiver or consent shall be in writing and signed by the party claimed to have waived or consented. You shall not assign this Agreement, or any of your rights and obligations hereunder, without SSGA’s prior written consent.

SSGA reserves the right, in its sole discretion, to change, modify, add or remove portions of this Agreement at any time without notice to Site users. Similarly, SSGA reserves the right, in its sole discretion, to change, modify, add or remove the content of this Site, including the country-specific sections, or to terminate the website in whole or in part. You must check this Agreement periodically for changes. Any changes, modifications, or additions to, or deletions from this Agreement shall be effective upon posting on this Site. If you access this Site, including the country-specific sections, after changes to the Agreement are posted changes, you further acknowledge the Agreement as changed and agree to be bound by them.

General Privacy

This Privacy Notice applies to the State Street Global Advisors' ("SSGA") websites and any mobile app (collectively, our "Sites"). This Privacy Notice applies to any personal information we may collect from you through our Sites, independent of the device (i.e.mobile, computer) used to access our Sites.

Privacy on SSGA's Sites

SSGA operates its Sites to provide you with tools and resources to help you learn more about us. When you visit our Sites we want you to feel confident that we are committed to maintaining the privacy of your personal information. By visiting our Sites, and/or using the services offered on or through our Sites ("Services"), you agree to the terms of this Privacy Notice ("Privacy Notice"), as they may be amended from time to time, and to SSGA’s collection, use, processing, and disclosure of your information as described below. SSGA may change this Privacy Notice at any time without prior notice to you. Any changes or updates will be effective immediately upon posting to our Sites.

What information we collect

We collect and process the personal information you provide to us when you:

Register to use or use our Services via our Sites and provide information required to use our Services.
Fill out forms on our Sites. Register or subscribe to our newsletters or conferences.

Ask us to authenticate you as an authorized user and ask us to facilitate communications between us that you request.

Contact SSGA with a request.

Complete surveys issued by SSGA (we will process information provided by you for research and monitoring purposes).
SSGA also may collect your IP address and information regarding the computer or mobile device ("Device") used to access our Sites, such as its operating system, unique identifier, and model name, as well as its user configurations and settings. And as discussed in detail below, we may also collect information relating to your use of our Sites and our Services.

We may combine the information that we collect through our Sites or Services with personal or other information that we obtain from third parties (such as social media networks or marketing partners) or that we collect from you in other contexts (such as when you email us, call us, or attend one of our events). If the information collected is about you or relates to you, or is combined with such information, SSGA will treat it as personal information.

Sensitive personal information

SSGA recognizes that certain jurisdictions have enacted laws that require higher protection of certain sensitive personal information. "Sensitive personal information" includes categories of personal data identified by European and other data privacy laws as requiring special treatment. This may include personal identity numbers, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including suspected criminal activities). As a general rule, SSGA does not require such sensitive personal information from you.

In the limited cases where we do seek to collect such information, we will seek to do so in accordance with applicable data privacy law requirements. If you choose to provide us with unsolicited sensitive personal information, you consent to us using the information, subject to applicable law as described in this Privacy Notice.

Cookies and online tracking

SSGA may periodically collect information from you through automated means. When you browse our Sites, use the Services, or read our emails or newsletters, we may use "cookies" or other online tracking mechanisms in order to provide better service, facilitate your use of our Sites or Services, store online preferences, track usage of our Sites or Services, tailor the marketing of business services to our institutional customers, or enhance security.

What are cookies?

Cookies are text files containing small amounts of information downloaded to your computer or device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user's device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and they generally improve the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

The cookies used on our Sites have been categorized on the basis of the categories found in the International Chamber of Commerce UK Cookie guide issued in April 2012. A list of the types of cookies used by SSGA is set out below.

Some of our cookies are used for web analytics and intelligence about our Sites. This information may be combined with other information for the purposes described below, including marketing. We may also use web beacons or other technologies for similar purposes and we may include these in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor online activity.

What if I don't want cookies or website tracking of my activities?
By using our Sites you agree that we can place cookies on your device and use other online tracking mechanisms as explained in this Privacy Notice. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies and other tracking devices see www.allaboutcookies.org/manage-cookies.

Deleting and blocking cookies will have an impact on your user experience as parts of our Sites may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our Sites, even if you have previously deleted our cookies.

What types of cookies are there and which ones does our Sites use?

There are four types of cookies explained below. We use three of them on our Sites: Strictly necessary cookies, Performance cookies, and Functionality cookies. We do not use Targeting cookies on our Sites; however while on our Sites you may visit other sites and encounter them there.

Strictly necessary cookies - These cookies are essential in order to enable you to move around our Sites and use its features, such as accessing secure areas of our Sites. Without these cookies, services you have asked for cannot be provided.

We categorize the following cookies as strictly necessary:

1. Registered Visitor Cookie - A unique identifier given to each registered user, used to recognize them through their visit and when they return to our Sites. (see also Functionality cookies below).

Performance cookies - These cookies collect information about how visitors use our sites, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works.

We categorize the following as performance cookies:

1. Referrer URL (internal page) - Used to store the URL of the previous page visited. Allows us to track how visitors navigate through our Sites.

2. Referrer URL - Used to store the URL which refers a visitor to our Sites so we may understand what URLs are referring visitors to our Sites.

3. URL history - Used to store the page visited by a user before that user submits a form. Also, used to display recently viewed articles to each visitor.

4. Unregistered Visitor Cookie - A unique identifier given to each visitor to allow analysis on how unregistered visitors use our Sites.

5. Session management cookies - These cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window. Our session management cookies are created temporarily. Once you close your browser, our session management cookies are deleted.

Functionality cookies - These cookies allow a site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a site may be able to provide you with local information by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. We may use information collected from our cookies to identify user behaviour and to serve content and information on products and services based on your profile. We may pass or share this information within SSGA or with affiliates for marketing or analysis purposes. In most cases we will not be able to track individuals by name; only if you are a registered user can we associate the cookie information with your name.

These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for online advertising on other sites or remembering where you've been on the internet outside our Sites.

We categorize the following as functionality cookies:

1. Recently viewed pages - Stores pages visited by the user on our Sites and displays them in right hand navigation for easy reference.

2. Search history - Stores searches on our Sites conducted by the user and displays them for the user in the right hand navigation for easy reference.

3. Registered Visitor Cookie - A unique identifier given to each registered user to our Sites, or each user who voluntarily provides personal information on our Sites to request information from us, used to serve them content and offers based on their profiles. Also used for analysis and marketing purposes (see also Strictly necessary cookies above).

Targeting cookies - These cookies are used to deliver online advertisements on other websites that are more relevant to you and your interests. They are also used to limit the number of times you see such advertisements as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the site operator's permission. They remember that you have visited a site and this information is shared with other organizations such as advertisers. Quite often they will be linked to site functionality provided by the other organization.

Third party tracking

Third party social media networks may log information about you if you take certain actions on our Sites, for example if you click an "Add This" or "Like" button for a social media site while on our Sites. We do not control such sites or their activities. You may be able to find information about social media sites on the sites themselves. We recommend you read the terms of use and privacy policy of such sites before using them.

‘Do not Track' disclosure

Do Not Track (DNT) is a technology standard that is currently under development that will allow you to restrict tracking when browsing from site to site on the Web. When you choose to turn on the DNT setting in browsers that support this feature, the browser sends an automated browser signal to the web sites and other web services (such as analytics services, advertising networks, and social platforms) you encounter while browsing to prohibit tracking.

At this time, SSGA does not recognize automated browser signals regarding tracking mechanisms, such as "do not track" requests.

How we use and share personal information

The information that we collect enables SSGA to provide you with access to our Sites and the Services you request, process online job applications, tailor the marketing of business services to our institutional customers, and further other purposes which we describe to you at the point where the information is collected. The purposes for which your information may be processed include but are not limited to the following:

To offer you an enhanced, personalized online experience by enabling us to better tailor and personalize our Services.
To authenticate you as an authorized user and to facilitate communications between us that you request.
To fulfill your requests, including sending you white papers, newsletters and other supplements.
To contact you for marketing purposes in-line with the applicable laws. (See the section below entitled "Marketing communications and your choices")
To operate our business in a prudent manner in accordance with industry standards and applicable law, which may include, in addition to supporting the Services; responding to inquiries and requests; preventing fraud; and monitoring and archiving communications.
SSGA may disclose or share personal information to its affiliates for various purposes, as permitted by law, including in order for its affiliates to provide services.

SSGA may also share personal information with government agencies, exchanges, or other self regulatory organizations and law enforcement authorities as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights SSGA may have against you as necessary. Personal information about you that is collected on our Sites, or in the course of the provision of Services, including any of your financial information, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. In addition, if you have an account at SSGA, because your account(s) may include information about more than one individual and about your business relations with SSGA and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates.

SSGA may disclose your personal information (i) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (ii) to our internal or external auditors or attorneys; (iii) when SSGA believes disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity, or (iv) if disclosure is necessary to protect the vital interests of a person.

SSGA may disclose or share personal information to nonaffiliated third parties with whom it has contracted to perform services on its behalf. SSGA requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as SSGA when processing personal information. In addition, SSGA may share personal information and other information collected through our Sites and the Services with a successor entity in the event of a merger, acquisition or similar transaction.

Marketing communications and your choices

SSGA uses information collected on our Sites to market business services to our institutional customers. Specifically, we may collect, use, and/or share your information with our affiliates and service providers in order to provide specific information that you request, thought leadership materials, industry information, invitations to events and webinars, and other communications or solicitations that we believe will be of interest to you. We target and tailor such communications based on your interaction with SSGA’s websites, mobile apps, and emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. No client proprietary information, and no information about any of the individuals or entities that your firm may service, will be collected, used, or shared for purposes of delivering these communications to you. By voluntarily submitting your contact information on our Sites, you consent to the use and sharing of your information for such purposes. You may, however, opt out of receiving such marketing communications by following the opt-out instructions contained in each communication.

How we transfer and store personal information

SSGA is a global organization; personal information we collect may be transferred internationally throughout the world to countries where SSGA does business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place in an effort to achieve an equivalent level of protection is in place across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.

By providing your information to SSGA in the course of your access and use of our Sites or the Services, you agree that your personal information, for the purposes explained in this Privacy Notice, may be transferred to and stored in other countries where SSGA does business, which may not have the same data protection laws as the country in which you reside.

How we protect your personal information

We use security measures, in compliance with applicable law, to protect personal information from unauthorized access or use. Yet you should understand that the open nature of the Internet is such that information and personal information may flow, without security measures, over networks connecting you to our systems and may be accessed and used by people other than those for whom the data is intended.

To safeguard against unauthorized access to personal information by third parties, all electronic personal information held by SSGA is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding personal information are "backed up" (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire detection and response system.

When you contact SSGA with questions about our Sites or the Services, we must confirm your identity on the phone before discussing your information. The questions and answers you select when logging into our Sites for the first time are used for this identification process.

Our Sites may, from time to time, contain links to and from the sites of third parties. If you follow a link to any of these sites, please note that these sites have their own privacy notices or practices and that we do not accept any responsibility or liability for these notices, practices or sites. Please check these policies before you submit any personal information to these sites.

Your rights

As a person who provides SSGA with personal information, you may inquire as to the nature of the personal information stored at and/or processed by SSGA. You will be provided reasonable access to your personal information held by SSGA and, where appropriate, with the ability to review and correct inaccuracies. SSGA will cooperate in providing such access. All such requests for access may be made by sending a request in writing to: www.SSGA.com

To help protect your privacy and provide security, SSGA takes reasonable steps to verify your identity before granting access to information. SSGA shall respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific personal information that you require. If you demonstrate that the purpose for which the personal information is being processed is no longer legal or appropriate, the personal information will be deleted, unless the law or applicable data retention requirements require otherwise.

How to contact us

If you have questions or comments about this Privacy Notice, or about how your data is processed, please contact: www.SSGA.com

United Kingdom Users

This communication is directed at professional persons (this includes persons who are market counterparties and intermediate customers as defined by the Financial Conduct Authority) who have professional experience in matters relating to investments. The products and services to which this communication relates are only available to such persons and persons of any other description (including private investors) should not rely on this communication.

To the extent this communication refers to collective investment schemes, this communication is directed at persons having professional experience of participating in unregulated schemes and at trustees of high value trusts. Units in the scheme(s) to which this communication relates are available only to such persons. Persons who do not have professional experience in participating in unregulated schemes or who are not trustees of a high value trust should not rely on it. Participation in exempt collective investment schemes is restricted to pension schemes or funds which satisfy the criteria set out in the Income Tax (Pension Funds Poling Schemes) Regulations 1996.

GDPR Privacy Notice

At State Street Global Advisors (“SSGA”) we are committed to handling your Personal Data (defined below) responsibly and would like to let you know that we recognise and respect your right to privacy. This notice explains how SSGA and any fund or product sponsored, managed, or otherwise affiliated with SSGA (the “Funds”) (together “we”, “our”, “us”) collect, use, share or otherwise process Personal Data in connection with your relationship with us. For a list of the SSGA entities and Funds acting as a controller for the purposes of GDPR, please see annex I.

We may provide supplemental notices from time to time, for example where we collect or use your sensitive personal data, which should be read together with this notice. We will publish the current notice on our websites (the “Sites”) which will apply each time you share Personal Data with us. We reserve the right to amend or update this notice at any time.

How we collect your Personal Data

We may collect your contact details (such as your address, email address and telephone number) or other information (such as your job title, identifying information required for anti-money laundering and related matters, your IP address, and information regarding the computer or mobile device ("ElectronicDevice") used to access our Sites, such as its operating system, unique identifier, and model name, as well as its user configurations and settings etc.) from which you can be identified (“Personal Data”). We may collect and use, for example, details you provide:

1. by filling in online/application/dealing forms,
2. during our onboarding process;
3. during telephone calls or meetings with us or our representatives/agents,
4. when you register to use or use our Services (including via our Sites),
5. when registering or subscribing to our newsletters or conferences,
6. when asking us to authenticate you as an authorised user and to facilitate communications between us that you request,
7. by completing surveys issued by SSGA (we will process information provided by you for research and monitoring purposes).

We use cookies on our Sites. Cookies are small files stored on a computer that are designed to hold small amounts of data specific to a user and the websites to help tailor that user’s experience with the Sites. See the section below entitled “Cookies”.

We may combine the information that we collect with personal or other information that we obtain from third parties (such as social media networks or marketing partners) or that we collect from you in other contexts (such as when you email us, call us, or attend one of our events). If the information collected is about you or relates to you, or is combined with such information, we will treat it as Personal Data.

Any Personal Data which you provide to us or our agents is at your sole discretion. However, we may not be able to engage with you (fully or at all) if you do not provide requested Personal Data. Please do let us know if your Personal Data changes during our relationship. Please note that if your Personal Data is anonymised, it is no longer Personal Data.

Basis of and Use of Personal Data

In order to effectively manage our relationship with you, we will collect, use, process, or arrange processing of this Personal Data if and to the extent that we have a lawful basis to do so; that is:

1. you have consented;
2. we need to do so in order to perform the contract we have entered into with you/in relation to your investment in our Fund or the provision of State Street services as well as to effect administrative or operational processes by SSGA, our Funds or their service providers (“Services”);
3. if we need to do so in order to comply with an EU legal or regulatory obligation; or
4. if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests may include direct marketing by State Street entities or our regulatory obligation as a global financial institution. You have the right to unsubscribe from such direct marketing. See the section below entitled "Marketing Communications and Your Choices".

We will also use your Personal Data and the Funds and their service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) will use your Personal Data to:

1. provide Services to you and/or the institution that you act for;
2. to facilitate the opening of your account, the management and administration of your holdings and/or your holdings in a Fund and any related account on an on-going basis;
3. carry out anti-money laundering checks and related actions;
4. carry out fitness and probity checks and related actions;
5. to report tax related information to tax authorities in order to comply with a legal obligation;
6. to monitor and record calls and electronic communications for (a) processing and verification of instructions, (b) investigation and fraud prevention purposes, (c) for crime detection, prevention, investigation and prosecution, (d) to enforce or defend SSGA, the Funds and their affiliates', directly or through third parties to whom they delegate such responsibilities or rights in order to comply with any applicable legal obligation, (e) for quality, business analysis, training and related purposes (f) to pursue our legitimate interests in relation to such matters or (g) where the processing is in the public interest;
7. to update and maintain records and fee calculations;
8. enhance or personalise your online experience ;
9. authenticate you as an authorised user and to facilitate communications between us that you request;
10. fulfil your requests, including sending you white papers, newsletters and other supplements;
11. contact you for marketing purposes in-line with the applicable laws (see the section below entitled "Marketing Communications and Your Choices");
12. operate our business in a prudent manner in accordance with industry standards and applicable law, which may include, in addition to supporting the Services; responding to inquiries and requests; preventing fraud; and monitoring and archiving communications;
13. to take advice from our advisors;
14. for governance and management reporting purposes.

We may use or disclose your Personal Data if we are required to do so by law or if we reasonably believe that we need to do so to protect our rights or to comply with a judicial or regulatory requirement or to pursue our legitimate interests. If we need to use your Personal Data for a reason which is not reasonably compatible with the original purpose, we will notify you and explain the basis on which we are permitted to so use your Personal Data.

Marketing Communications and Your Choices

SSGA uses information collected to market business services to our institutional customers. Specifically, we may collect, use, and/or share your information with our affiliates and service providers in order to provide specific information that you request, thought leadership materials, industry information, invitations to events and webinars, and other communications or solicitations that we believe will be of interest to you. We target and tailor such communications based on your interaction with us such as on our Sites and with our emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. If you do not wish to receive this information from us, please manage your preferences accordingly. You can also unsubscribe by clicking on the unsubscribe link in any of our emails or by letting your SSGA contact know.

How we may share Personal Data

We may disclose or share Personal Data:

1. to our affiliates for various purposes, as permitted by law, including in order for its affiliates to provide services;
2. with government agencies, exchanges, or other self-regulatory organisations and law enforcement authorities as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights SSGA may have against you as necessary. Personal Data about you that is collected on our Sites, or in the course of the provision of Services, including any of your financial information, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. In addition, if you have an account at SSGA, because your account(s) may include information about more than one individual and about your business relations with SSGA and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates.
3. at the request of a regulatory agency or in connection with an examination of us by bank or other examiners;
4. at the request of our internal or external auditors or attorneys;
5. when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity,
6. if disclosure is necessary to protect the vital interests of a person;
7. to non-affiliated third parties with whom we have contracted to perform services on its behalf. We require our third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as we do when processing Personal Data.
8. with a successor entity in the event of a merger, acquisition or similar transaction.

How we Transfer and Store Personal Data

SSGA is a global organisation and part of the global State Street group; Personal Data we collect may be transferred internationally throughout the world to countries where State Street does business, which may not have the same data protection laws as the country in which you reside. We have relevant legal safeguards, internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organisation. To find out more about the safeguards that SSGA has in place please contact Jill Stoller (Chief Privacy Officer) at JStoller@StateStreet.com. The transfer of Personal Data to other countries is based on a business need or to comply with applicable laws. Personal Data stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.

By providing your information to SSGA in the course of your access and use of our Sites or the Services, you agree that your Personal Data, for the purposes explained in this privacy notice, may be transferred to and stored in other countries where SSGA does business, which may not have the same data protection laws as the country in which you reside.

How we protect your Personal Data

We use security measures, in compliance with applicable law, to protect Personal Data from unauthorised access or use. Yet you should understand that the open nature of the Internet is such that information and Personal Data may flow, without security measures, over networks connecting you to our systems and may be accessed and used by people other than those for whom the data is intended.

To safeguard against unauthorised access to Personal Data by third parties, all electronic Personal Data held by SSGA is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding Personal Data are "backed up" (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such Personal Data and are stored in facilities with appropriate security and fire detection and response system.

When you contact SSGA with questions about our Sites or the Services, we must confirm your identity on the phone before discussing your information. The questions and answers you select when logging into our Sites for the first time are used for this identification process.

Our Sites may, from time to time, contain links to and from the sites of third parties. If you follow a link to any of these sites, please note that these sites have their own privacy notices or practices and that we do not accept any responsibility or liability for these notices, practices or sites. Please check these policies before you submit any Personal Data to these sites.

Retention Period

We will retain your Personal Data for as long as required and for as long as necessary to provide our Services, products and information or as permitted / required by applicable law. This period may extend beyond the termination of our relationship with you.

Your Rights

Any person who has sent us Personal Data has the right to:

• Be informed about the Personal Data
• Access to the Personal Data
• Rectification of Personal Data, where it is inaccurate or incomplete
• Erasure of Personal Data in certain circumstances (for example, where the Personal Data is no longer necessary in relation to the purposes for which it was collated).
• Obtain restriction of processing in certain circumstances (for example, where the accuracy of the Personal Data is contested, for the period enabling State Street to verify the accuracy of that Personal Data)
• Object to the processing of the Personal Data
• Receive Personal Data in a structure, commonly used and machine-readable format, and to have that Personal Data transmitted directly to another data controller (data portability)
• Lodge a complaint to the relevant local data protection authority

In the interests of security, we may request specific information from you to help us confirm your identity when you are exercising your rights.

If you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. If you choose to withdraw your consent, we will no longer process your Personal Data for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You may also unsubscribe from any direct marketing at any time.

You will not generally have to pay a fee in relation to the exercise of the above rights but please note that a reasonable fee may be levied on excessive or manifestly unfounded requests or in such cases, we may refuse to comply with such excessive or unreasonable requests.

How to Contact Us

If you have questions or comments about this privacy notice, or about how your data is processed, please contact:

Jill Stoller (Chief Privacy Officer) at JStoller@StateStreet.com

Annex I

Last updated: 25 May 2018

Cookie Policy

How We Use Cookies and the Collection of Website Usage Data

By using the website [www.ssga.com/www.spdrs.com], you agree that State Street Global Advisors (SSGA) can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve your online experience. This can include information related to your use of the website, the browser and device type you are accessing the website from and where you are located.

What are cookies?

Cookies are small text files downloaded to your computer or device by websites you visit. Cookies are widely used in order to allow websites to function properly, as well as to provide business and marketing information to the owners of the site.

When do we use cookies?

State Street Global Advisors (SSGA) uses cookies on [www.ssga.com/www.spdrs.com] for the following purposes:

Technical
Cookies are used for technical reasons to enable [www.ssga.com/www.spdrs.com] to work efficiently. These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for cannot be provided.

Ease of Use
Cookies are used to enhance the usability of the site for visitors, such as by capturing visitor preferences on our site so that they are remembered for subsequent visits improving the visitor experience.

Tracking
Cookies are used to gather statistics on how visitors use our site. This allows us to gain insight into how visitors use the website so that we may make improvements to its usability.

Marketing
Cookies are used for web analytics and intelligence about our Site. This information may be combined with other information for the purposes described below, including marketing. We may also use web beacons or other technologies for similar purposes and we may include these in marketing email messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor online activity.

How do I refuse or withdraw consent to the use of cookies?

If you want to remove existing cookies from your device, you can do this using your browser options. You may refuse to accept cookies by changing your browser settings. For more information on managing cookies and other tracking devices see www.allaboutcookies.org/manage-cookies.

Deleting and blocking cookies will have an impact on your user experience as parts of the Site may not function properly or be accessible. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our Site, even if you have previously deleted our cookies.

The following table details the most frequently used cookies on [www.ssga.com/www.spdrs.com] and explains their use.

Cookie Lifespan

Unless stated above, the lifespan of the cookies we use is limited and will not exceed 13 months.