NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY

UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

This Notice of Collection of Personal Information and Privacy Policy Under the California Consumer Privacy Act ("CCPA Privacy Notice") applies to the collection of personal information from California residents. This CCPA Privacy Notice is delivered on behalf of Old Westbury Funds, Inc. ("Old Westbury" or the "Company") and supplements the Old Westbury Funds, Inc. Privacy Policy to provide California residents with additional information about their privacy rights as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively "CCPA"). The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered "consumers" under the CCPA and from whom we collect "personal information" as described in the CCPA.

This CCPA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we collect, process, use, store, and disclose your personal information, and rights you may have in relation to your personal information under the CCPA. Old Westbury does not share your personal information with third party advertisers and other third parties for cross-context behavioral advertising within the meaning of the CCPA (i.e., providing you with advertising based on personal information obtained across businesses, websites, applications or services, other than the Company"s website or services).

For purposes of this CCPA Privacy Notice, we refer to personal information according to the following definition given in the CCPA: "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information that is outside the scope of the CCPA, including non-public personal information that is within the scope of the Gramm-Leach-Bliley Act ("GLBA").

By using our Site, you consent to the collection, processing, use, and disclosure of your personal information as set forth in this CCPA Privacy Notice, as it may be updated from time to time.

The Company does not presently recognize browser "do not track" requests or Global Privacy Control signals and does not sell your personal information to third parties or "share" it for purposes of cross-context behavioral advertising when you visit this Site.

What categories of personal information do we collect about you?

We may collect personal information from you through automated means when you use our Site including by use of "cookies" and other similar technologies."

We may collect the following categories of personal information:

Categories	Examples	Retention Period
A. Identifiers	This information may include IP address, browser or device identifier, and other identifying information you provide to us).	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.
B. Customer Information under California Civil Code §1798.80(e)	This information comprises information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our business records. Some personal information in this category may overlap with other categories.	For as long as you maintain an ongoing relationship with us or as necessary to fulfill the purposes set forth in this disclosure.
C. Internet and other electronic history	This category comprises electronic information concerning your use of the Site. This information may include information we automatically collect as you browse the Site, including your IP address, device type/identifier, browser type/identifier, pages visited, and other similar electronic information. We may collect such information concerning your Site usage through cookies and other technologies.	Generally, for as long as one [1] year
D. Geolocation data	We may determine your approximate geographic location through your IP address.	Generally, for as long as one [1] year

We do not collect sensitive personal information from you pursuant to this CCPA Notice, including for purposes of inferring characteristics.

What are our business reasons for collecting and using your personal information?

Depending on the individual circumstances, we collect, process, use and disclose personal information for legitimate business purposes. These purposes may include:

to provide you with information you have requested or communicate with you.
to analyze and improve the functionality and effectiveness of our Site.
to determine the general geographic region where visitors to our Site are located.
to protect the security of this Site.
to comply with our legal obligations.

We may collect personal information from the following categories or sources:

directly from you.
service providers providing services on our behalf.
public records or public sources.
third parties.
our affiliates.

Who do we provide your personal information to?

We do not sell your personal information to third parties, including the personal information of minors under sixteen 16 years of age, and have not done so in the past twelve (12) months.

In some instances, we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, customer service providers, website analytics providers, printers and shippers, and platform providers. Such outside organizations may be provided with access to your personal information to perform the functions for which they have been retained. By using our Site, you consent to the disclosure of your personal information to our service providers and other third parties as set forth herein.

We may disclose your personal information to our affiliates for our legitimate business purposes.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

In the past twelve (12) months, we have not shared the categories of personal information set forth in Categories [A - D] with third parties for purposes of cross-context behavioral advertising.

In the past twelve (12) months, we may have disclosed the categories of personal information set forth in Categories [A - D] for the purposes set forth above.

What are your rights regarding your personal information?

Under the CCPA, you may have the following rights in relation to your personal information:

You may have the right to request that the Company disclose the personal information that we collect, use, and disclose about you. You may "request to know": (i) the categories of personal information that the Company has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom the Funds discloses your personal information; and (v) the specific pieces of personal information that the Funds have collected about you. Your request may pertain to the personal information collected about you on or after January 1, 2022. If your request covers a time period beyond twelve [12] months from the date of your request, the Company may deny your request as to that time period where it would be impossible for the Company to provide you with the information or involve disproportionate effort. The Company may deny your request to search for certain information under certain circumstances (e.g., where the Company retains the information solely for legal and compliance purposes).
You may have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.
You may have the right to correct inaccurate personal information.
You may have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
You may have the right to know what information is shared with third parties, and to whom and to opt out of sharing for cross-context behavioral advertising. We do not sell or share your personal information within the meaning of the CCPA.
You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you products or services because you have exercised your rights.

You may submit requests concerning any of your rights by contacting us as set forth in How to Contact Us below.

We will use reasonable methods for verifying that the person making a request to know, data portability, request to correct or a request to delete is the individual about whom we have collected personal information.

This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten [10] business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five [45] calendar days to respond to your request.

Do we provide financial incentives to California Consumers for providing us with personal information?

We do not offer you financial incentives such as loyalty programs, discounts, and special offers when you provide us with personal information, in exchange for such personal information.

California Shine the Light Law/Online Privacy Protection Act

California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.

Revisions to This CCPA Privacy Notice

We may update this CCPA Privacy Notice at any time, by posting the amended version on this Site, including the effective date of the updated version. By accessing the Site or communicating with us after we make any such changes to this CCPA Privacy Notice, you are deemed to have accepted such changes. Please check this CCPA Privacy Notice regularly, and before you submit additional personal information via the Site.

How to Contact Us

If you have questions regarding our privacy practices or about this CCPA Privacy Notice, or would like to exercise rights you may have pursuant to the CCPA, please submit a request by clicking here, call us at 888-747-9591 or contact us at OWFprivacy@bessemer.com.

Last Updated: December 2024