Legal and Privacy Information

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 your existing agreement(s) with us and the terms of this Agreement. 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 this Site are proprietary to and confidential property of SSgA and its relevant licensors and its 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.

You are accessing a Site certain portions of which are secure. The Site and any information 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, and are subject to the final applicable agreement. By offering products and services on the Site, SSgA hereby makes no solicitation to any individual or entity to use information, products or services in jurisdictions where prohibited by law.

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.

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 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 outside their intended countries or regions, and funds from U.S. investors will not be accepted. Access to non-U.S. pages in this site by U.S. residents is for informational purposes only and should not be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation for any security under U.S. law.

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 nor SSgA 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 is 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 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.

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 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, OR ANY 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 ITS 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. Review the privacy statements of any Web site you visit before you provide any personal/confidential information or conduct a transaction.

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 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 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 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 (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.

Privacy Statement

SSgA's goal is to provide you with a personalized Internet experience that delivers the information, resources, and services that are most relevant and helpful to you. To achieve this, we may collect personally identifiable as well as anonymous information during your visits to the site. Personally identifiable information is information that can be used to uniquely identify you, such as your name, job title, telephone number and e-mail address. Anonymous information is information that tells us what you do on the site, such as functions utilized, searches conducted, the time of day you visited the site. Any information gathered is confidential and is used in the delivery of the service you have requested and to allow SSgA to improve the service and your on-line experience.

Policy and Practices

Although information about your needs helps us to provide superior service, nothing is more important to our business than the trust and confidence you have in us. That is why we want you to know how we will manage any information we obtain about you when you visit this Site.

Recognizing your expectation of privacy on the Internet, we will make every effort to:

  • Safeguard any information you share with us by applying strict standards of security and confidentiality
  • Limit the collection, use and retention of information to what we believe is necessary or useful in order to provide quality service
  • Permit only authorized employees to have access to your information
  • Share information with external organizations only when we have previously informed you in disclosures or agreements, have received your authorization or are required by law
  • Require any organization we hire to provide support services to conform to our privacy standards and to allow us to audit them for compliance
  • Keep your files complete, accessible, up-to-date and accurate
  • It is important to note that this policy is for general guidance. It neither constitutes a contract nor creates legal rights. It does not modify or amend any agreements we have with you. We reserve the right to change these privacy principles listed above at any time without prior notice

Since your use of the Site constitutes your acceptance of the terms of this privacy statement, you should periodically review it for changes. If you have any question about this Privacy Statement, please contact your SSgA Relationship Manager or SSgA. This privacy statement applies only to the Site.

It is SSgA's policy to treat customer, employee, and vendor Social Security numbers that we obtain in the course of business as confidential and to protect them throughout their lifecycle from accidental, malicious or unauthorized disclosure, misuse, modification, destruction, loss and/or damage.

To that end, SSgA has developed controls and procedures reasonably designed to protect the confidentiality of, prohibit unauthorized disclosure of, and limit access to customer, employee, and vendor Social Security numbers.

Security Measures: Maintaining Privacy

Maintaining your privacy and personal data we may obtain in the course of business requires that we guard against unauthorized access to your information. Therefore, we operate secure data networks protected by industry-standard security measures designed to protect against the loss, misuse, and alteration of the data you share with us, either directly or indirectly.

User Authentication

Your access to certain portions of the Site is password-protected and for higher risk applications may have an additional authentication challenge. Once you select your personal password, you may enter and access information.

Browser Security Measures

To ensure browser security, (i) we require that your browser support SSL and (ii) you do not allow information to be stored on your hard drive unless you specifically download it and save it on your computer.

Data Security Measures

We take industry-standard steps to protect against any anticipated threat or hazards to the security or integrity of your data. We utilize information-scrambling technologies to protect the information sent to or from this Site. This Site uses VeriSign® global certificates that automatically enable 128-bit encryption with all versions of the required browser.

Nonetheless, no representation is made regarding the unconditional security of such submissions.

Firewalls

To prohibit unauthorized access that may harm your records or inconvenience you, we utilize specialized computers ("firewalls") that limit the entry of those without proper authorization. These shields check to make sure that communication occurs between approved individuals in accordance with proper protocol.

Ongoing Surveillance

Our security systems regularly monitor the Web server to help maintain the security of this Site. This includes monitoring SSgA's employees to ensure that only authorized individuals have access to the information you provide us.

Use of Personal Information Provided

Other than the collection of information as described above, we will not collect personal information about you when you visit the Site, unless you choose to directly provide such information to us when contacting us via this Site or via e-mail. We will use this personal information to process your request and, when applicable, respond to you. By contacting us in this manner, you consent to the collection and the use of your personal information for purposes of responding to your request and in the support of services requested.

Use of Cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are and help you navigate the site. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number. SSgA uses temporary Session Cookies that allow users to navigate across pages without having to re-enter an ID/password. Each time you visit this Site, we may collect information by use of a "cookie." Cookies may be tracked during each visit, thereby helping us understand what parts of the Site you find most useful and where, over time, you are likely to return. This information allows us to improve the Site's content, navigation, and customization features, providing you with a more satisfying service experience.

Disabling/Enabling Cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, this Site cannot be accessed if cookies are disabled. For more information about cookies, their uses and instructions on modifying related browser settings, you may visit public sites such as allaboutcookies.org as well as other public resources on the subject.

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 Services 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.

For Australia Investors

State Street Global Advisors, Australia, Limited Privacy Policy. Last updated March 12, 2014.

IMPORTANT: You should read this Privacy Statement if you are an individual whose ‘personal information’ we collect. This Privacy Statement is our Privacy Policy for the purposes of the Privacy Act 1988 (Cth) (the Act) and provides information on how we manage your ‘personal information’, which is any information or an opinion about an identified or reasonably identifiable individual. It also provides information on certain matters relevant to individuals whose personal information we may collect, hold, use and disclose from time to time.

This Privacy Statement (the “Privacy Statement”), is the Privacy Policy of the following State Street entities in Australia, for the purposes of the Privacy Act 1988 (the Act) and provides information on how your “personal information” is managed, including how it is collected, held, used and disclosed from time to time by these APP entities, which are all part of the “State Street Group”, including other branches, subsidiaries and related entities.

  • State Street Australia Limited (“SSAL”) ABN 21 002 965 200, AFSL 242429
  • State Street Bank and Trust Company, Sydney Branch (“SSBT”) ABN 70 062 819 630, AFSL 239679
  • State Street Global Markets International Limited (“SSGMIL”) ARBN 120 116 065
  • State Street Global Advisors, Australia, Limited (“SSgA AL”) ABN 42 003 914 225, AFSL 238276
  • State Street Global Advisors, Australia Services Limited (“SSgA ASL”) ABN 16 108 671 441, AFSL 274900

In this document, “we”, “us”, “our” means the individual APP entity.

We may make any changes to this Privacy Statement from time to time and for any reason. Any changes will be reflected in brochures and our website, www.ssga.com

Contents
  • Respecting and protecting your privacy
  • Personal information we may collect
  • Why do we collect, hold, use and disclose personal information?
  • How we collect personal information
  • Do we disclose your personal information to others?
  • Anonymity and adoption of a pseudonym
  • Keeping your personal information secure
  • Keeping your personal information accurate and up-to-date
  • Accessing and correcting your personal information
  • How to contact us (includes complaints)
Respecting and protecting your privacy

At State Street we respect your right to privacy and are committed to ensuring your personal information is collected, used, disclosed, and maintained in accordance with the Australian Privacy Principles (APP) under the Act, our global and local policies.

We protect your personal information with the same integrity that we would use to handle our own individual personal information. This enables us to conduct business and exchange information in a secure environment, meeting employee, customer and regulator expectations for privacy, security and confidentiality.

Personal information we may collect

The type of personal information that we may collect and hold will vary depending on: (i) the service we provide, which includes custody, fund administration, funds management and other financial services or both; and (ii) the circumstances in which we are dealing with you. For example, in the case of SSAL, where you are engaged by, or connected with, our Client as its representative, such as officer, employee, agent or any similar capacity, or where you are a client of our Client, we will only collect and hold personal information relevant to the services we provide to our Client.

Also, where you have applied for a position with us, we will only collect and hold personal information relevant to that relationship with you.

The personal information we collect may include your name, address, and other contact details, date of birth and occupation. We may also collect your tax file number, but only where we are required or authorized by law to do so.

The Act restricts the collection of sensitive personal information. Examples of this include health information and information about an individual’s criminal record. Generally, we do not collect this sort of information. However, we may do so if you are applying for a job with us and you have provided your consent to the collection.

Why do we have to collect, hold, use and disclose personal information?

We collect, hold, use and disclose your personal information as is reasonably necessary for our business purposes and as permitted by law.

We may also collect, hold, use and disclose your personal information for the following purposes:

  • recruitment and employment purposes – for example, to assess your suitability to the position you are applying for;
  • engaging service providers, contractors or suppliers;
  • to maintain your details so we are able to respond to any of your inquiries;
  • dealing with complaints;
  • meeting legal and regulatory requirements. Various Australian laws may expressly require the APP entities to collect your personal information or the APP entities may need to do so in order to be able to comply with other obligations under those laws. Such laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (for example, to comply with obligations to combat money laundering and financing of terrorism) or the Taxation Administration Act 1953, the Income Tax Assessment Act 1936 and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation); enforcing our rights, including undertaking legal proceedings;
  • promoting our products and services – for example, for direct marketing purposes where the law permits. In the event that you do not want to receive direct marketing materials please notify us using the contact details set out below.
How we collect personal information

If it is reasonable and practical to do so, we will collect personal information directly from you. For example, if we are dealing with you as a representative of a Client (such as a director or other officer of a Client) or as a client of a Client, you may provide personal information as a result of your dealings with us. We may collect your personal information through application forms, over the telephone, the internet, or in person when you visit our office. We may also collect your personal information when you call us. We may monitor and/or record telephone calls for the purposes of staff training and to verify statements made during the telephone call.

We may also need to collect personal information from third parties, including:

  • Client’s clients, for example, where SSAL provides unit registry services;
  • your representative (such as a legal adviser, financial adviser, accountant), for example where we need to verify information you have provided;
  • and government agencies, such as the Federal Police, for example where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation for reporting of the matter.

If you do not provide the information requested, or it is incomplete or inaccurate, we may not be able to provide the services to our Client or provide you with other opportunities (for example, a role with us) that you have applied for.

Do we disclose your personal information to others?

We may disclose or share your personal information for the purposes listed above or as otherwise permitted by the Act to third parties that include the following:

  • entities within State Street, locally or overseas, including without limitation the U.S. and China;
  • entities outside State Street situated in Australia, the U.S., and the Asia-Pacific region (including without limitation, India, and the Philippines) – for example:
    • service providers;
    • insurers;
    • superannuation funds;
    • our accountants, auditors or lawyers;
    • third parties that act on your behalf or that are otherwise connected with you (such as your legal adviser);
    • courts, tribunals, government and regulatory agencies or bodies, police; and
    • other persons and entities as permitted under the Act.

As referred to above, some of the recipients to whom we disclose your personal information may be based overseas. We require overseas service providers to take reasonable steps to protect personal information from unauthorized use or disclosure and also comply with the relevant APPs.

Anonymity and adoption of a pseudonym

Although the Act allows for you to deal with us anonymously or by using a pseudonym, we can only allow this in limited circumstances, such as in relation to enquiries of a general nature. We are unable to allow anonymous dealings or the adoption of a pseudonym in relation to more specific enquiries about your account with us if you don’t identify yourself.

Keeping your personal information secure

We have security systems, policies, processes and procedures that meet current industry standards, to protect your personal information from misuse, loss and unauthorised access, modification or disclosure and we regularly review their effectiveness. The only people who are allowed to handle or have access to your personal information are those employees of State Street Australia and the State Street Group and those who perform services for us who need your personal information to do their jobs.

Keeping your personal information accurate and up-to-date

We maintain the quality of your personal information by taking reasonable steps to make sure that the information collected, used and disclosed is accurate, complete and up-to-date and we encourage you to contact us about the changes to your personal details.

Accessing and correcting your personal information

You can request access to the personal information we hold about you by contacting us with your request, using the contact details set out below.

We may not always be able to give you access to all the personal information we have about you. For instance, we may not be able to give you access to information that:

  • would reveal personal information about another person;
  • would reveal a commercially sensitive decision-making process;
  • we are prevented by law from providing to you; or
  • relates to existing or anticipated legal proceedings.

You can also request correction to the personal information we hold about you by contacting us with your request, using the contact details set out below.

How to contact us (includes making a complaint)

You can contact us about this Policy, to request access or correction to your personal information, or if you have a complaint about the way we handled your personal information, by;

for SSAL, SSBT and SSGMIL:

  • mail to the Privacy Officer [insert name of APP entity], Compliance Department, Level 14, 420 George Street, Sydney NSW 2000, Australia.
  • calling us on: +612 9323 6000, and ask to be connected to the Privacy Officer in the Compliance Department.

for SSgA AL and SSgA ASL:

  • mail to the Privacy Officer [insert name of APP entity], Compliance Department, Level 14, 420 George Street, Sydney NSW 2000, Australia.
  • calling us on: +612 9240 7600, and ask to be connected to the Privacy Officer in the Compliance Department.

We aim to complete/resolve your request/complaint within 30 days of receiving it, or longer for a more complex request or complaint. Please note that our process also includes notifying our Corporate Privacy Office in the U.S.

If you are unhappy with the handling of your complaint you also have rights to complaint to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).