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Wilshire Associates Incorporated

Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the European Economic Area

The scope and purpose of this privacy statement

Wilshire Associates Incorporated (“we” or “Wilshire”) is a global company and thus may conduct business and collect Personal Data (as defined below) from individuals and institutions located within the European Economic Area (“EEA”). This Privacy Statement explains how Wilshire uses Personal Data that we collect from individuals and institutions located within the EEA in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”).

Personal Data

The term “Personal Data” as used in this Privacy Statement means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What information do we collect about you, how do we collect it and what do we use it for?

The kinds of Personal Data we may collect depends on the nature of the relationship you have with us. This information may include your contact details such as your address, email address and telephone number and, where required for contractual, legal or regulatory obligations, additional information (including, but not limited to your date of birth, bank account details and tax identification documents or copies of identification documents). In most cases, we will collect the Personal Data directly from you (e.g., through account applications, investment policy statements and electronic or verbal correspondence), but we may also obtain it from other sources (e.g. through public registers for background searches).

In accordance with applicable data privacy laws and the GDPR, we will only process your Personal Data for specific purposes where there is a lawful basis for doing so. The lawful basis, and purposes that we may rely on are:

• you have consented to us doing so (consent) – in limited circumstances, we may obtain your consent to send you information about our products and services (but, in such cases, you can opt out of receiving such communications at any time through the method provided in the communications themselves or by using the contact information provided below);

• we need it to perform the contract we have entered into with you (contract) – this includes, but is not limited to, where we have entered into an agreement with you and the Personal Data is needed to ensure that the terms of the contract can be fulfilled;

• we need it to comply with a legal obligation (legal obligation) – these obligations include, for example, where we have a regulatory obligation to conduct customer due diligence or are required to provide information to tax authorities; or

• we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms (legitimate interest) – this includes the provision of services by us and our direct marketing activities. To this end, we will use your Personal Data to deliver services to you and/or to work or act for you. Furthermore, we will also use your Personal Data to inform you about us and our services and to build our relationship with you.

Where we use your Personal Data to inform you about us and our services, we will ensure that these are targeted and proportionate.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

What might we need from you?

We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This security measure is designed to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

What if you do not provide the personal data we request?

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our services, to enter into a contract with you or to send you information about us (e.g. marketing materials).

Change of purpose and anonymization

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances, and where it is attributable to a lawful basis, we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with vendors that we work with. Depending on the nature of your relationship with Wilshire these other vendors may include, but are not limited to, accountants, tax advisors, payroll agents, auditors, lawyers, regulatory advisors, insurance brokers and IT providers. We may also have to share your Personal Data with regulators, public institutions or courts. Wilshire will not sell your Personal Data nor will we distribute, disseminate or disclose your Personal Data to third party sales or marketing agencies. When sharing your Personal Data with others, we will ensure that we have an appropriate legal basis to do so and will take all reasonable steps to ensure that your Personal Data is treated in a manner that is consistent with applicable laws and regulations.

Will your information be stored outside of the EEA?

Wilshire is a California corporation and the bulk of our operations are based in the United States. For the purposes described above, your Personal Data will likely be stored outside of the European Economic Area (“EEA”). In such cases, we will always ensure that there is a legal basis and a relevant safeguard method for such data transfer.

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

• request access to your Personal Data (commonly known as a “data subject access
request”) and request certain information in relation to its processing;
• request rectification of your Personal Data;
• request the erasure of your Personal Data;
• request the restriction of processing of your Personal Data;
• object to the processing of your Personal Data.

Please note, some of the above rights may only be exercised in specific circumstances ‐ they are not absolute. In addition, you may also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or, as the case may be, another competent supervisory authority of an EU member state.

Right to withdraw consent

You may withdraw consent at any time where consent is the lawful basis for processing your Personal Data. Should you withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, you may be unable to avail yourself of the services we provide.

How long will we retain your information?

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more information about our retention practices, please contact us using the information provided below..

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.

Fees

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Statement. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Changes to this Privacy Statement

Wilshire reserves the right to update this Privacy Statement at any time and, in such cases, we will make an updated copy available on our website, or where required by law, we will contact you directly.

Further information

If you have any queries, questions, concerns or require any further information in relation to the Privacy Statement or you wish to exercise any of your rights, please do not hesitate to contact Wilshire at WAILegal@wilshire.com.