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California Consumer Privacy Act ("CCPA" or the "Act")

This document provides specific information for California Consumers, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"). California privacy law requires that Gateway Investment Advisers, LLC (Gateway) provide California Consumers information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement.

Under the CCPA, "personal information" is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. We collect personal information through, 1) direct interaction with you and/or your agents, 2) account opening or updating documentation, 3) account custodian documentation, and 4) consultants.

Categories of Personal Information that We Collect, Disclose, and/or Sell

Below please find the categories of personal information about California Consumers that we collect, and/or disclose to third parties or service providers for a business purpose in order to provide the investment management services for which we have been engaged.

Gateway DOES NOT sell Consumer's personal information.

Categories of personal information Do we collect? Do we disclose for business purpose? Do we sell?
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers. YES YES
NO
Signature, physical characteristics or description, telephone number, education, employment, financial information, medical information, or health insurance information. YES NO NO
Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. NO NO NO
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES - 
Products/Services
NO NO
Biometric information. NO NO NO
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident's interaction with an Internet Web site, application, or advertisement. NO  NO NO
Geolocation data. NO NO NO
Audio, electronic, visual, thermal, olfactory, or similar information. NO NO NO
Professional or employment-related information. NO NO NO
Education information, defined as information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). NO NO NO
Inferences drawn from any of the information identified above to create a profile about a resident reflecting the residents' preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO NO NO

California Consumers' Rights

California law grants California Consumers certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell. California Consumers have the right to opt-out of the sale of their personal information. Gateway DOES NOT sell Consumer's personal information.

Requests for Right to Know and Deletion. Subject to certain exceptions, California Consumers have the right to make the following requests, at no charge, up to twice every 12 months:

  1. Right to Know Categories: the right to request that we provide you certain information about how we have handled your personal information in the prior 12 months, including:

    • The categories of personal information collected.
    • The categories of sources of personal information.
    • The business and/or commercial purposes for collected and/or selling your personal information. (Gateway DOES NOT sell your personal information)
    • The categories of third parties with whom we have disclosed or shared your personal information.
    • The categories of personal information that we have disclosed or shared with a third party for a business purpose.
    • The categories of personal information that we have disclosed or shared with a third party for a business purpose.
    • The categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party. (Gateway DOES NOT sell your personal information)

  2. Right to Know Specifics: the right way to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.
  3. Deletion: the right to request deletion of your personal information that we have collected about you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, for debugging, or to comply with a legal obligation)
Discrimination. The CCPA prohibits discrimination against California Consumers for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level of quality of goods or services, or charges (or suggests that it will charge) different prices or rates or impose penalties on Consumers who exercise their CCPA rights.

Submitting Requests. Requests to exercise the right-to-know or the right to deletion may be submitted on our California Consumers' Rights Form, by contacting us at 1.800.354.6339 (toll free), or by contacting your client service representative.

California Privacy Rights under California's Shine-the-Light Law

Under California's "Shine the Light" law (Cal. Civ. Code § 1798.83), California Consumers who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in their prior calendar year.

Gateway DOES NOT share or sell Consumer's personal information to third parties for their own direct marketing use.

 

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Headquarters
Gateway Investment Advisers, LLC
312 Walnut Street, 35th Floor
Cincinnati, OH 45202-9834

Phone: 513-719-1100
Fax: 513-719-1199
Boston Location
888 Boylston Street, Suite 800
Boston, MA 02199

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All Rights Reserved.
California Consumer Privacy Act
Gateway Investment Advisers, LLC
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