Privacy statement for Russell Investments

This section, which is provided for California residents, supplements the Russell Investments Privacy Statement and applies solely to individuals who reside in California for purposes of the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (collectively CPRA). As used in this section,” personal information” means information that meets the CPRA definition of ”personal information.“

In some cases, Russell Investments may have no obligation under the CPRA to accept certain CPRA requests, and in other cases, may have no obligation to honor a particular CPRA request because of the nature of personal information collected and maintained. For example:

• The CPRA does not apply to personal information we collect and process about you pursuant to the federal Gramm-Leach-Bliley Act (GLBA); therefore, we have no obligation to honor a CPRA request.
• If you participate in a workplace retirement plan or other employee benefit plan sponsored or provided through your employer, and that plan is serviced or administered by Russell Investments, CPRA requests should be directed to your employer.

The personal information we collect about California consumers will depend on our relationships and interactions with you. We may collect the following categories of personal information about California consumers:

• Contact information such as name, postal address, e-mail address, telephone number, account name, or other similar identifiers
• Government-issued and similar identifiers such as Social Security, passport, and driver’s license numbers
• Protected classification characteristics such as age, gender, and marital status
• Financial and commercial information such as investment background, interest or experience, products or services purchased, as well as purchasing or consuming histories or tendencies
• Information regarding interactions with our websites, applications and advertisements, IP addresses, device identifiers, browser information, browsing history, and server and application logs
• Geolocation information such as device location identified using your IP address Professional or employment-related information, such as job title and business contact information
• Inferences drawn from such information including for the creation of a summary about your preferences, behavior, and characteristics

We collect the categories of personal information listed above from the following categories of sources:

• Directly from you or from those acting on your behalf, such as when using our products or services from forms you complete online or at events, or when you or your representative call us to request information about or obtain our products and services
• Automatically collected from Internet or other network activity based on your interaction with our websites, applications, and advertisements
• Third parties that perform services for us or provide our products and services to you
• Other third-party sources, including government sources, data brokers, and social networks

We have used or disclosed personal information, including where applicable, sensitive personal information, when collected for one or more of the following business purposes:

• To conduct our business and provide our products and services, including developing, supporting, managing, and improving our products and services, and, where necessary, to verify your identity
• To support our operations, including communicating with you, fulfilling your requests, addressing your inquiries and concerns, monitoring inquiries, and improving our responses, and to carry out the purposes for which you provide your personal information
• To meet our legal and compliance obligations, including monitoring and reporting, supporting our information security and fraud prevention programs, performing due diligence, supporting audit, investigations, and legal requests, and complying with our internal policies, procedures, and contractual obligations
• For our marketing and promotional event services, including market data and research
• To personalize your experience with our business and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email (with your consent, where required by law)
• To help maintain the safety, security, and integrity of our business, including our products and services, and to respond, where necessary, to requests from regulators and law enforcement or as otherwise required by applicable law, regulation, court order, or similar demand

We have disclosed the categories of personal information listed above for business purposes to the following categories of parties (excluding disclosures we may be prohibited from reporting under applicable law):

• Our affiliated entities and unaffiliated service providers, including those that may not be defined as such under the CPRA, to help conduct our business such as providing our products and services, supporting our everyday operations, marketing, business development and management
• Government agencies to support our legal and regulatory requirements
• Our lawyers, auditors, and consultants

Russell Investments does not “sell” or “share” (as defined in the CPRA) your personal information to third parties and has not done so at any time during the 12-month period preceding the date this privacy policy was updated.

We do not knowingly sell or share personal information of consumers under 16 years of age.

Because we do not sell or share personal information, Russell Investments does not have any obligation under CPRA to accept CPRA requests requesting Russell Investments not sell or share a consumers’ personal information.

We have established retention periods and requirements to retain the categories of Personal Information described above for as long as is necessary for our business and operational purposes such as audits and reporting, and for our legal and regulatory compliance obligations, such as books and records requirements and legal holds.

You may exercise your data rights (subject to certain exceptions and limitations) by submitting a verifiable request to us by e-mail or by calling our toll-free number and stating the specific data rights request you are making.

You should generally expect to receive a response to your request within 45 calendar days of the date we receive your request. However, in some instances, we may require additional time of up to an additional 45 days to respond to your request in which case we will notify you and explain why an extension is necessary.

We may ask you to provide additional information to verify your identity. We will only use additional information we collect for the purposes of verifying your identity and for security or fraud-prevention purposes. In cases where additional information is required and we are unable to contact you with the contact information you have provided or are otherwise unable to sufficiently verify your identity, we may be unable to respond to your request.

If your request covers the personal information of other individuals, including individuals with a shared address and device or service, we may be obligated to take additional steps to verify the request, including obtaining the consent of the other individuals whose personal information is covered by the request.

Toll-free number
Call us at 1-800-426-7696 to submit your requests.

E-mail address
webmaster@russellinvestments.com

Authorized Agents
You can designate an authorized agent to make a data rights request under the CPRA on your behalf.

An authorized agent is a person or a business entity that you have authorized to act on your behalf. If you are an authorized agent and submit a data rights request on behalf of a California Consumer, we may require that the California Consumer provide you with written authorization to make the request on their behalf and verify their own identity directly with us.

You have the right not to receive discriminatory treatment for exercising any of these data rights. Russell Investments does not discriminate or retaliate against any California Consumer for exercising their rights under the CPRA.

If you have questions or comments about this Notice or any of Russell Investments' other privacy policies and practices, please call 1-800-426-7969 or e-mail us at webmaster@russellinvestments.com.

We recognize data privacy is an ongoing responsibility. We reserve the right to update or amend this Notice from time to time, and any such updates or amendments will be reflected in the Notice available on our website.