Allspring International Privacy Notice

Last revised: February 2024

At Allspring Global Investments (Allspring), we are committed to protecting the privacy of our clients. This International Privacy Notice sets out our practices regarding the collection, storage, use, disclosure, and other processing of personal data as defined below. If you or your organization has a relationship or otherwise shares personal data with an Allspring entity in the U.S., a different privacy notice regarding that Allspring entity’s practices will govern those information collection and processing activities.

1. Definitions

The following definitions shall apply to this notice:

“Allspring,” “we,” “us,” and “our”: Allspring Global Investments is the trade name for the asset management firms of Allspring Global Investments Holdings, LLC, a holding company indirectly owned by certain portfolio companies of GTCR LLC and Reverence Capital Partners, L.P. These firms include but are not limited to Allspring Global Investments, LLC; Allspring Funds Management, LLC; Allspring Funds Distributor, LLC; Allspring Global Investments (UK) Ltd.; Allspring Global Investments Luxembourg S.A. (including those acting on behalf of the branches of Allspring Global Investments Luxembourg S.A.); Allspring Global Investments (Singapore) Pte. Ltd.; Allspring Global Investments (Hong Kong) Limited; Allspring Global Investments (Japan) Limited; and Galliard Capital Management, LLC (collectively, Allspring). Certain products managed by Allspring entities are distributed by Allspring Funds Distributor, LLC (a broker-dealer and Member FINRA/SIPC).

Where applicable, these terms shall also mean certain Luxembourg products (and their subsidiaries) managed by Allspring entities including, but not limited to, Allspring (Lux) Worldwide Fund SICAV and Allspring Worldwide Alternative Fund SICAV-SIF.

“You” and “your”: Outside the United States, we primarily have relationships and accounts only with corporations and other legal entities (customers). However, we may collect personal data about investors’ or prospective investors’ employees, directors, officers, trustees, beneficiaries, representatives, or intermediaries as part of our client on-boarding process and the provision of our services during the course of a client relationship.

In these circumstances our main client contact is responsible for ensuring that all affected individuals are made aware that their personal details will be provided to us and of the purposes for which we will use that information, for example by showing them a copy of this notice.

In addition, this notice covers the personal data of individuals who (1) engage with Allspring by signing up to receive communications such as email alerts and publications, or who attend events run by us (either alone or in conjunction with partner organizations) whether online or in person; and (2) have a business arrangement with Allspring, such as vendors, agents, or independent directors.

“Personal data”: This has the meaning given to it or any similar term (for example, personal data, nonpublic personal data, or personal identifiable information) in applicable data protection legislation, and for the avoidance of doubt it means any information that directly or indirectly identifies or otherwise relates to a living individual who is in the possession of or under the control of Allspring (or its representatives or service providers) and includes the personal data mentioned below.

“Process” or “processing”: These terms mean any operation that is carried out in respect of personal data, including but not limited to collecting, storing, using, disclosing, transferring, or deleting personal data.

2. The types of personal data we collect

Many of the services offered by Allspring require us to obtain personal data about you in order to perform the services we have been engaged to provide and to comply with applicable laws or policies (for example, know your client and anti-money laundering). In connection with the provision of those services, Allspring will collect personal data about you, including:

Details of your name, age, date of birth, email address, address, telephone number, identification number, location, gender, nationality, citizenship, and other contact information.
Information about your employer, title, position held, and length of employment.
Financial information or other information obtained as a result of your investment in any of our funds, such as banking details, financial relationships and transactions, salary and other income, and sources of wealth and assets.
For any tax implications related to your financial activities, your social insurance number or Social Security number or other tax identification number and details of tax residency.
Data provided by you in the context of us carrying out background checks and anti-money laundering, regulatory, tax, and know your client background checks, such as data included in identification documents, details of credit, criminal records, and sanctions, if permitted by local law.
Information required as a result of legal, tax, and regulatory requirements or internal policies.
Electronic data resulting from your online activity and the pages you visit on our website, including your internet protocol (IP) address, the type of device and browser you are using, information about your device operating system and information collected through cookies, tags and other technologies.

Please note that if you do not provide certain personal data to Allspring when requested, we may not be able to provide you with some or all of our services and products.

3. How we use your personal data

Your personal data may be collected, stored, disclosed, and processed by Allspring for the following purposes to:

Provide you with marketing communications and inform you about news, information, and events relating to our business and services, including new product launches and product updates (in accordance with the scope of marketing set forth below)
Assess your application for Allspring’s products and services, where applicable
Understand your needs and interests and respond to your inquiries
Provide the services requested by you and comply with our contractual obligations under our agreements and carry out related business functions, including performing data and transaction processing, conducting credit checks, and managing our relationship with you
Analyze and improve our services
Manage and administer our busines
Provide you with the products and services for which you subscribe
Comply with—and in order to assess compliance with applicable laws, rules, and regulations (including know your client obligations based on applicable anti-money laundering and anti-terrorism requirements; economic and trade sanctions; suspicious activity reporting; foreign exchange and international trade; and tax reporting pursuant to applicable laws, regulations, ordinances, and obligations anywhere in the world)—good practices and internal policies and procedures
Confirm and verify your identity and conduct due diligence, background, and related checks (this may involve the use of credit reference agencies and/or other third parties acting as our agents to conduct these verifications and related reviews, including screens against publicly available government and/or law enforcement agency sanctions lists)
Confirm a person’s authority as a representative or agent for you with which Allspring has entered or intends to enter into various arrangements, including but not limited to deposit contracts, loan contracts, contracts for foreign exchange transactions, contracts for derivative transactions, and letters of credit; we collect and use work contact details, position descriptions, and authentication data
Detect, investigate, and prevent fraud and other crimes or malpractice
Obtain legal advice or establish, exercise, or defend legal rights
Administer and maintain databases that store personal data
Conduct recordkeeping
Operating our website including providing content to you and interacting with you (in accordance with the scope of our Cookies Notice linked below).

4. Legal bases for using your personal data

Processing activity	Legal basis for processing
Entering into, and providing services associated with investment management and contacting you regarding said services	Processing is necessary in connection with any contract that you may enter into with us, or the steps taken prior to entering into a contract with us
Carrying out “Anti-Money Laundering”, “Know Your Client” and other compliance and risk management checks	Processing is necessary for compliance with legal obligations
Carrying out IT operations	We have a legitimate interest in carrying out Processing for the purpose of managing our IT systems and ensuring the security of those systems
Contacting you about new or existing products and services, or providing you with other information that we think is relevant using the contact information that you have provided	We have a legitimate interest in being able to improve and market our products/services
Operating our Website including providing content to you and interacting with you	We have obtained your prior consent to the Processing which is entirely voluntary

5. Disclosure of your personal data

Allspring does not sell personal data to third parties or target advertising to individuals based on their personal data collected. Allspring may have to share and disclose your personal data as follows, in each case only to the extent necessary and on a need-to-know basis:

Affiliates. As an international company, Allspring shares your personal data among our affiliates on a worldwide basis, and such affiliates may use the data for the purposes described above. Your personal data is shared in accordance with intra-group transfer agreements.
Beneficiaries, counterparties, and other parties related to a transaction. Allspring may disclose personal data to beneficiaries, counterparties, or other parties related to a transaction on a worldwide basis to provide the services requested by our customers and to comply with legal obligations and regulations.
Service providers. Allspring may have to share your personal data with information technology (IT) providers or other service providers around the world that act under our instructions regarding the processing of such data (data processors). Data processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the personal data and to process personal data only as instructed. Allspring may also disclose personal data to independent external third parties, such as accountants, administrators, auditors, custodians, depositories, third-party managers, paying agents, professional advisors, IT, and communications providers or any entity around the world we reasonably consider necessary for the purposes outlined above. Such service providers will be subject to any necessary contractual obligations regarding the protection and processing of such personal data.
Legal requirements. Subject to applicable law, Allspring may disclose personal data if required or permitted by applicable laws or regulations, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Allspring may do business; (b) protect and defend the rights or property of Allspring; (c) act in urgent circumstances to protect the personal safety of individuals, customers, and contractors/employees of Allspring or others; or (d) protect against any legal liability. In addition, Allspring may share your personal data with U.S. regulators and with other self-regulatory bodies to which we are subject, wherever Allspring may do business.
Business transfers, combinations, and related activities. As we develop our business, Allspring might sell, buy, restructure, or reorganize businesses or assets. In the event of any actual or proposed sale, merger, reorganization, restructuring, dissolution, or any similar event involving our business or assets, personal data may be shared with the relevant entity or may be part of the transferred assets.

The recipients of personal data identified in this section may be located in the United States and other jurisdictions that may not provide the same level of data protection as your home country. As needed, we will take steps to establish appropriate data transfer agreements or otherwise address cross-border data transfer restrictions and requirements.

6. Cross-border transfers of personal data

Since Allspring operates globally, personal data is processed and disclosed as described above in any country in which we conduct business or have a service provider. Accordingly, by providing your personal data to Allspring, you acknowledge and agree that we disclose your personal data to recipients (including but not limited to service providers, Allspring affiliates or agents, and Allspring IT servers) located in jurisdictions other than your own for purposes described in this notice.

To the extent that applicable data protection legislation does not allow or permit us to obtain your valid consent by virtue of providing this notice to you or otherwise rely on the other legal grounds for disclosing your personal data outside of your jurisdiction, we will obtain your explicit consent through other means (if applicable) or, where relevant, ensure that the recipient is required to provide a standard of protection to your personal data that is equivalent to that under the data protection legislation of your jurisdiction (for example, by using standard contractual clauses for such international transfers).

You may revoke your consent at any time by notifying us as provided in this notice. Prior uses and disclosures will not be affected (unless required by applicable law), and we may otherwise continue to process personal data as permitted or required by law.

7. How we store and safeguard your personal data

Allspring safely stores personal data in its databases located in the U.S. and the U.K. Please note that some of our third-party service providers may include cloud-based service providers that may store and process personal data in the cloud within or outside your jurisdiction. Allspring has implemented appropriate physical, technical, organizational, and security measures to prevent your personal data from being accidentally lost, misused, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. Personal data is protected with safeguards according to the sensitivity of the information contained therein.

Additionally, we have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8. Retention and destruction of personal data

Allspring will retain your personal data for a period of up to seven (7) years from the date of termination of our relationship with you and will not retain your personal data for longer than is reasonably necessary to fulfill the purposes outlined in this notice or for such period as may be required under relevant laws, regulations, and policies, including those related to record retention periods.

Allspring will destroy personal data without delay when it becomes unnecessary due to lapse of the retention period or fulfilment of the purpose of processing. Allspring will identify the personal data for which the reason for destruction has occurred and destroy the record of personal data upon obtaining approval from the record owner. Personal data stored in electronic files will be destroyed in an irrevocable manner, and personal data stored in paper documents will be destroyed by shredding.

9. Your rights

To the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal data Allspring holds about you. Please use the links below to review jurisdiction-specific privacy regulations:

For residents or data subjects in Australia

When we collect and use personal data about you, we may be subject to the applicable laws, including the Australia Privacy Act 1988 (Cth). Below you will find the additional specific provisions applicable to you as a resident or data subject within Australia.

Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data. You may request amendments or corrections if your personal data is inaccurate, irrelevant, outdated, or incomplete.
Data portability: This right enables you to ask us, in certain circumstances to provide you with the personal data you have provided to us in a structured, commonly used, and machine-readable format or to transmit the personal data that you have provided to us to another party. We will give access to the personal data in the manner requested by you if it is reasonable and practical to do so.

If you want to exercise any of the above rights in connection with your personal data or if you have any queries or complaints about our privacy notice or how we handle your personal data, please contact us in writing at the address provided under the How to Contact Us section below.

What we may need from you
If you exercise any of the above rights, we may need to request specific information from you to help us confirm your identity and that you are entitled to make such a request. This is to ensure that personal data is not disclosed to any person who has no right to receive it.

For residents or data subjects in Hong Kong

When we collect and use personal data about you, we may be subject to the applicable laws, including the Personal Data (Privacy) Ordinance. Below you will find the additional specific provisions applicable to you as a resident or data subject within Hong Kong.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you can contact us by email to check whether we hold your personal data and request access to such data. You may also request a copy of your personal data records.
Request correction of your personal data. You may request amendments or corrections if your personal data is inaccurate, irrelevant, outdated, or incomplete.
Object to direct marketing at any time. You can inform us if you want us to cease processing your personal data for the purposes of direct marketing and we shall not use your personal data for direct marketing purposes after you communicate your objection to us.
Ascertain our policies and practices in relation to personal data.
Be forgotten. You can let us know if you wish to suspend, withdraw, or order the blocking, removal, or destruction of your personal data.

If you want to exercise any of the above rights in connection with your personal data, please reach out to us in writing at the address provided under the How to Contact Us section below and we will provide you with the appropriate form to make your request. You may also contact us at this address if you have any queries or complaints about our privacy notice or how we handle your personal data.

For residents or data subjects in Japan

When we collect and use personal data about you, we may be subject to the applicable laws, including the Act on the Protection of Personal Information and the related Cabinet Order/Enforcement Rules. Below you will find the additional specific provisions applicable to you as a resident or data subject within Japan.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you can contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data. You may request corrections, additions or deletion if your personal data is inaccurate, irrelevant, outdated, or incomplete.
Request erasure or to cease utilization/provision to third parties of your personal data if it has been obtained or processed in violation of the PIPA, when it becomes unnecessary to utilize it, or when individuals’ rights or justifiable interests of data subjects are being threatened.

For residents or data subjects in New Zealand

When we collect and use personal data about you, we may be subject to the applicable laws, including the New Zealand Privacy Act 2020. Below you will find the additional specific provisions applicable to you as a resident or data subject within New Zealand.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you can contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data. You may request amendments or corrections if your personal data is inaccurate, irrelevant, outdated, or incomplete.

If you want to exercise any of the above rights in connection with your personal information or if you have any queries or complaints about our privacy notice or how we handle your personal information, please contact us in writing at the address provided under the How to Contact Us section below.

For residents or data subjects in Singapore

When we collect and use personal data about you, we may be subject to the applicable laws, including the Personal Data Protection Act 2012. Below you will find the additional specific provisions applicable to you as a resident or data subject within Singapore.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you can contact us by email and request access to the personal data we hold about you. This enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data. You may request amendments or corrections if your personal data is inaccurate, irrelevant, outdated, or incomplete.
Withdraw consent. You may withdraw consent at any time by giving reasonable notice unless it would frustrate the performance of a legal obligation.

Please note that the withdrawal of certain types of consent may affect the ability of Allspring to continue providing you with the requested services.

For residents or data subjects in South Korea

As the controller, when Allspring Global Investments, LLC, collects and uses personal data about you, it may be subject to the applicable laws, including the Personal Information Protection Act. Below you will find the additional specific provisions applicable to you as a resident or data subject within South Korea.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you can contact us by email and request access to the personal data we hold about you. This enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data. You may request amendments or corrections if your personal data is inaccurate, irrelevant, outdated, or incomplete.
Object to direct marketing and profiling. You can inform us if you want us to cease processing your personal data for the purposes of direct marketing.
Be forgotten. You can let us know if you wish to suspend, withdraw, or order the blocking, removal, or destruction of your personal data.

Disclosure of personal data to third parties
As described above, Allspring may have to share and disclose your personal data with third-party service providers to the extent necessary to fulfill the purposes outlined in this Notice.

For residents or data subjects in member countries of the European Economic Area (EEA), Switzerland and the United Kingdom

When we collect and use personal data about you, we may be subject to the applicable laws, including the EU and U.K. General Data Protection Regulation, the UK Data Protection Act 2018 and the Swiss revised Data Protection Act 2020. Below you will find the additional specific provisions applicable to you as a resident or data subject within the EEA, Switzerland or the U.K.

Your rights in connection with personal data
Depending on your jurisdiction, under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to the personal data we hold about you. This enables you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us in certain situations to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us in certain circumstances to suspend the processing of personal data about you (for example, if you want us to establish its accuracy or the reason for processing it).
Data portability: This right enables you to ask us, in certain circumstances to provide you with the personal data you have provided to us in a structured, commonly used, and machine-readable format or to transmit the personal data that you have provided to us to another party.
Not be subject to automated decision-making: The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

Additionally, you may withdraw consent for the processing of your personal data at any time by giving notice. Please note that the withdrawal of certain types of consent may affect the ability of Allspring to continue providing you with the requested services.

For residents or data subjects in the Middle East

When we collect and use personal data about you, we may be subject to the applicable laws, including Saudi Arabia Data Protection Law and UAE Federal Law on the Protection of Personal Data.

Your rights in connection with personal data
Depending on your jurisdiction, under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
Request destruction or deletion of your personal data. This enables you to ask us in certain situations to destruct or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us in certain circumstances to suspend the processing of personal data about you (for example, if you want us to establish its accuracy or the reason for processing it).
Data portability: This right enables you to ask us, in certain circumstances to provide you with the personal data you have provided to us in a structured, commonly used, and machine-readable format or to transmit the personal data that you have provided to us to another party.
Not be subject to automated decision-making: The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

For residents or data subjects in South Africa

When we collect and use personal data about you, we may be subject to the applicable laws, including the Protection of Personal Information Act.

Below you will find the additional specific provisions applicable to you as a resident or data subject within South Africa.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request confirmation on whether we hold personal data about you.
Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Correct or delete personal data we hold about you that is inaccurate, irrelevant, excessive, out-of-date, incomplete, misleading, or obtained unlawfully.
Request destruction or deletion of personal data that we no longer authorized to retain.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

For residents or data subjects in the Bahamas

When we collect and use personal data about you, we may be subject to the applicable laws, including the Data Protection (Privacy of Personal Information) Act.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request rectification of the personal data that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us in certain situations to delete or remove personal data where there is no good reason for us to continue processing it.
Stop or restrict processing of your personal data for direct marketing purposes.

For residents or data subjects in the Cayman Islands

When we collect and use personal data about you, we may be subject to the applicable laws, including the Data Protection Act.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request rectification of the personal data that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
Stop or restrict processing of your personal data under certain circumstances. You also have the right to object where we are processing your personal data for direct marketing purposes.
Not be subject to automated decision-making: The right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

For residents or data subjects in Canada

When we collect and use personal data about you, we may be subject to the applicable laws, including the Personal Information Protection and Electronic Documents Act.

Below you will find the additional specific provisions applicable to you as a resident or data subject within Canada.

Your rights in connection with personal data
Under certain circumstances, by law you have the right to:

Request access to your personal data. Subject to certain exceptions, you may contact us by email and request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. This enables you to ask us to have any incomplete or inaccurate information we hold about you corrected.
Request deletion of your personal data. This enables you to ask us in certain situations to delete or remove personal data where there is no good reason for us to continue processing it.

10. Marketing

To the extent permitted by applicable law, Allspring would like to send you information on our products and services that we believe may be of interest to you. We may contact you by mail, email, SMS/text, telephone, and other electronic means unless you object to receiving such information. If at any time you do not want to receive such communications from us, please follow the “unsubscribe” instructions provided in those communications or submit a written request to the contact details provided below.

Your option not to receive promotional and marketing material shall not: (a) preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (for example, your account status and activity or our responses to questions or inquiries you pose to us); (b) preclude us, including our employees, contractors, agents, and other representatives, from accessing and viewing your personal data for our internal business purposes; and (c) preclude us from disclosing your personal data as described in this policy for purposes other than sending you promotional and marketing materials.

11. Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For more information on how we use cookies and what type of cookies we use, please see the Allspring Cookies Notice.

12. Links to other websites

Our website may contain links to other third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.

We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.

13. Children’s privacy

Our website is not directed to children under the age of 13, and we do not knowingly collect personal information from such children.

14. Changes to our privacy notice

This notice is under regular review, and Allspring reserves the right to update this privacy notice at any time. Please review it periodically. This notice was last updated in February 2024 .

15. Complaints

You may have the right under applicable law to make a complaint if you think we have not adhered to this notice or any of the applicable privacy laws in handling your personal data. If you would like to make a complaint, please submit your complaint in writing to the contact details below. We will respond to your written complaint within 30 days of receipt. If you feel that we have not addressed your concern in a satisfactory manner, you may contact the data protection authority in your jurisdiction.

16. How to contact us

If you have any questions or concerns about this notice or if you would like to exercise one of your data protection rights (subject to the jurisdiction you are located in), please contact the Allspring Global Privacy Officer in writing at PrivacyOfficer@allspringglobal.com.

Terms of Use

Allspring International Privacy Notice

1. Definitions

2. The types of personal data we collect

3. How we use your personal data

4. Legal bases for using your personal data

5. Disclosure of your personal data

6. Cross-border transfers of personal data

7. How we store and safeguard your personal data

8. Retention and destruction of personal data

9. Your rights

Asia Pacific

Europe, Middle East and Africa

Caribbean

North America

For residents or data subjects in Australia

For residents or data subjects in Hong Kong

For residents or data subjects in Japan

For residents or data subjects in New Zealand

For residents or data subjects in Singapore

For residents or data subjects in South Korea

For residents or data subjects in member countries of the European Economic Area (EEA), Switzerland and the United Kingdom

For residents or data subjects in the Middle East

For residents or data subjects in South Africa

For residents or data subjects in the Bahamas

For residents or data subjects in the Cayman Islands

For residents or data subjects in Canada

10. Marketing

11. Cookies

12. Links to other websites

13. Children’s privacy

14. Changes to our privacy notice

15. Complaints

16. How to contact us