MetLife Investment Management Privacy Statement 

Last Updated: July 31, 2026

MetLife Investment Management, which includes MetLife Investment Management, LLC PineBridge Investments LLC, and PineBridge Investments Singapore Limited, among others, is MetLife, Inc’s (“MetLife”) institutional investment management business. MetLife Investment Management (“MIM or “we”) strongly believes in the responsible use of personal information we collect and is committed to protecting all information we retain. To further this commitment, we have adopted this MetLife Investment Management Privacy Statement (“MIM Privacy Statement”) to tell you how MIM and its affiliates (“we”, “our”, “us”) collect, use, disclose, process, share, and protect information we obtain.

Besides this MIM Privacy Statement, we also have other privacy notices that may apply to you in your interactions with MIM, including as a MIM client or potential client or as a resident of certain states / jurisdictions. For more information about our privacy notices, please visit us https://investments.metlife.com/privacy-policies/.

Information Covered by this MIM Privacy Statement

This MIM Privacy Statement applies to all personal information we collect, use, disclose and/or process about you, including when you: (i) interact with our websites, product portals, and online applications (“Sites”); (ii) download, register, or use our mobile software applications (“Apps”); and (iii) interact with us in-person or through telephone, chat, physical mail, email, fax, and social media.

By visiting and using the Sites, Apps and/or otherwise interacting with us, you accept and agree to be bound by the terms of this MIM Privacy Statement, as may be amended from time to time, and consent to us collecting, using, disclosing and/or processing your personal information as described herein.

For example, we process personal information about you from the following sources:

• Applications, subscription agreements, investment management agreements, or other forms;
• Interaction with you on the telephone, in-person, or through email;
• Transactions with us, our affiliates, or others, including service providers that are necessary for everyday business purposes, such as to maintain accounts and process transactions;
• Third parties with whom we deal, such as consumer-reporting agencies, to verify information we receive from you and your creditworthiness; and
• Through MIM websites, applications, or other online systems.

This MIM Privacy Statement only applies to the services and interactions described herein. It does not apply to services and interactions provided by other companies or organizations to which we link to or you interact with. MIM is, therefore, not responsible for the content or activities provided by other companies or organizations. This MIM Privacy Statement does not apply to MIM job applicants, employees, or contractors, or anonymized information that does not identify or cannot be reasonably used to identify you.

Personal Information We Collect

Personal information is information that identifies or reasonably can be used to identify you, as well as equivalent or analogous concepts under applicable law. We may collect from you and third parties your personal information, including but not limited to the following types of personal information: 

• Name, signature, addresses, email address, telephone numbers, dates of birth, Singapore National Registration Identification Card (“NRIC”) number, passport number, driver’s license number, passport number, or other similar identifiers, employment information, and your preferences
• Assets, income, account balances and transactions, financial information
• Internet Protocol (IP) address, Browsing history, search history, interaction with web sites, applications, or advertisements

In general, we only collect, use, disclose and/or process your NRIC number (or copies of your NRIC) in accordance with applicable law, such as where:

a. collection, use, disclosure and/or processing of NRIC numbers (or copies of NRIC) is required under applicable law (or an exception under applicable law applies); or

b. collection, use, disclosure and/or processing of NRIC numbers (or copies of NRIC) is necessary to accurately establish or verify your identity to a high degree of fidelity.

Minors

Our sites are not directed at nor intended for minors under the age of 18. We do not knowingly collect personal information from minors under the age of 18.

Information We Collect Through Technology 

We may collect, use, disclose and/or process your information through certain MIM and third-party technologies, including artificial intelligence (“AI”), machine learning (“ML”), and generative AI tools, to enhance our ability to deliver products and services to you and improve our customer support, processes, and technologies.

When you come to one of our Sites or Apps, we may collect your IP address. An IP address is often associated with the portal you used to enter the Internet, like your ISP (Internet Service Provider), company, association, or university. At times, we also use IP addresses to study the frequency that our visitors visit various areas of our websites. We may combine this information with personal information. Finally, our websites do not respond to browser Do Not Track signals.

Cookies, Web Beacons, and Other Tracking Technologies

Our Sites and Apps may use cookies, web beacons, and other tracking technologies to collect and store information. For more information, please review our Cookie Policy located at [insert link to Singapore Cookie Policy].

Network Advertisers

Advertisements managed by third parties may be placed on our websites. These companies are called 'network advertisers’. Network advertisers placing advertisements on our websites may also use cookies, web beacons, and other tracking technologies to collect information when you click on or move your cursor over one of their banner advertisements. You may not realize this information is being collected. In some cases, we may have access to information from web beacons, cookies, and other tracking technologies used by network advertisers on our sites, and this information may permit us to identify other sites that you have visited that are also associated with the network advertiser.  

For more information about our ad service provider and its tracking technologies, including information about how to opt out of these technologies, please visit  https://www.google.com/intl/en/policies/privacy/ and https://www.aboutads.info/consumers. Once you have clicked on an advertisement and left our websites, our MIM Privacy Statement no longer applies, and you must read the privacy policy or statement of the advertiser to see how your personal information will be handled on their website.

Finally, on our websites, a Cookies Banner will allow you the opportunity to manage your cookies preferences.

How We Use Your Personal Information

We collect, use, disclose and/or process your personal information in accordance with applicable law, including based on your consent, for legitimate business purpose (including for business improvement purposes), legitimate interests, such other purposes as described in this MIM Privacy Statement, and/or such other legal bases under applicable law.

For example, we collect, use and process your personal information to:

• Authenticate your identity;
• Provide you with online planning tools;
• Provide you with information, services, features and/or functionalities that may be available through our Sites and/or Apps, including but not limited to processing an application for our products and administering your account information;
• Provide services to you as part of our business operations and/or fulfill your requests, including to manage and administer your holdings in our funds and any related accounts on an ongoing basis in accordance with the contract between you and us;
• Respond to your product, service information or other requests;
• Investigate into and respond to your enquiries, feedback, complaints or claims;
• For other everyday business purposes, such as product development and website administration;
• Comply with legal and regulatory obligations applicable to you, us and our affiliates from time to time, including applicable anti-money laundering and counter terrorist financing, know-your-customer (KYC), customer due diligence, sanctions compliance and other regulatory requirements, including where we act as investment manager, sub-adviser or service provider; and
• Transfer, disclose and otherwise make available personal data to our affiliates, whether within or outside your jurisdiction (please also refer to the section “Cross Border Disclosure” below), for the purposes described in this MIM Privacy Statement.

In addition, where permitted under applicable law, we may also collect, use and disclose your personal information for the following purposes:

• Maintain, analyze and/or improve our and our affiliates’ business, products and/or services including managing and developing relationships with existing and prospective clients, investors, and their representatives, and conducting business development and marketing activities;
• Send you customer newsletters and updates;
• Provide you with additional materials that may be of interest, including marketing materials; and
• Carry out statistical analysis and market research which are in our or our affiliates’ legitimate business interest.

We may also use and disclose any information not considered to be personal information, including aggregated and anonymized data, for any legal purposes, including analytics and assessments of business relationships and opportunities.

How We Share Your Personal Information

Subject to legal, regulatory, or other governmental requirements, it is our policy not to disclose any of an individual’s personal information to third parties without their consent, unless those parties are providing services or support to us and have agreed to keep such personal information confidential. Examples of these parties include, but are not limited to, fund administrators, attorneys, and accountants.

We may distribute certain personal financial information, such as the schedule of investors to the fund agreement and capital account information, to all investors in each specific fund, to any regulatory authority having jurisdiction over us or any of our funds, or in connection with any litigation or other dispute or otherwise as necessary or appropriate to enforce the terms of our agreements with you or investigate, defend, or assert legal rights.

Our provision of the relevant product or service to you is not conditional upon your consent to us to use your personal information for our own direct marketing purpose.

Purchase or Sale of Businesses

From time to time, we may purchase a business or sell one or more of our businesses, and your personal information may be transferred as a part of that purchase or sale. If we purchase a business, the personal information received with that business would be treated in accordance with all our privacy policies, including this MIM Privacy Statement, if it is practicable and permissible to do so.

Other Disclosures, Including Disclosures Required by Law and Disclosures to Help Protect the Security and Safety of Our Websites and Others

We may disclose any information as permitted or required by applicable law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Terms of Use or any contest rules. We may also disclose information about you to our auditors, regulators, legal advisors, or to respond to a subpoena or any other order or directive from the courts or regulatory authority. 

Third-Party Terms and Conditions for Site and App Users

If you are using one of our Sites or Apps, please note that your access to and use of the Site or App may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, and third parties whose services you access through the Site or App. You recognize and agree that MetLife is not liable for any such third-party terms and conditions and their use of your personal information. MetLife may, in its discretion, make available links through advertisements or otherwise enable you to access third-party products or services. Please note that while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by MetLife. MetLife is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that MIM is linked to those products or services does not constitute our sponsorship of or affiliation with those people or companies.

Your Privacy Choices

We do not share personal information with unaffiliated third parties for their own direct marketing purposes. If you have signed up to receive newsletters or other e-mail messages from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message.

Retention of Personal Information

MIM’s Global Record Retention Schedule establishes the retention periods for our records consistent with MetLife business needs and global legal and regulatory requirements. MIM, consequently, will retain personal information only for as long as is necessary for the purpose set out in our policies, for as long as an account or relationship with MIM is active, as needed to provide services to our customers, to the extent necessary to comply with our legal and regulatory obligations, or to comply with our Global Record Retention Schedule, subject always to applicable law.

Security Measures to Safeguard your Personal Information

The security and confidentiality of your personal information is extremely important to us. That is why we have technical, administrative, and physical security measures and safeguards in place to protect your personal information from (a) unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks, and (b) the loss of any storage medium or device on which personal data is stored.. For example, the areas of our website that enable or require you to submit personal information online use encryption to protect that information. We also review our security procedures periodically to consider appropriate new technology and updated methods. However, despite our reasonable efforts, no security measure is ever perfect or impenetrable. To further protect personal information, we restrict access to such information to only employees who need the information to provide products or services to you and have been trained on the proper handling of such information.

Updating your Personal Information

We take steps to ensure that information is current and accurate by updating our records as needed. From time to time, and only when necessary, we may request confirmation of information that reasonably appears to be inaccurate or outdated.

You may exercise rights under applicable law to request access to or correct your personal information in our possession or under our control.

Subject to exceptions under applicable law, on your request:

(a) to access your personal information, we will, as soon as reasonably possible, provide you with (i) personal information about you that is in our possession or under our control; and (ii) information about the ways in which such personal information has been, or may have been, used or disclosed by us within a year before the date of your request; and/or

(b) to correct an error or omission in your personal information, unless we are satisfied on reasonable grounds that a correction to your personal information should not be made, we will (a) correct the personal data as soon as practicable; and (b) send the corrected personal data to every other organization to which your personal information was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.

Any requests for access or corrections to personal information must be made in writing and sent to our Privacy team at MIMprivacy@metlife.com or our Personal Data Protection Officer at our Singapore office at enquiry.sg@pinebridge.com.

All lawful requests to make corrections to an individual’s personal data will be made as soon as practicable, unless otherwise prohibited by law or regulation. If we are unable or otherwise prohibited from adhering to a request to correct an individual’s personal data, such requests will be annotated in our records.

You can also contact your Relationship Manager directly to update your personal information.

Withdrawal of Consent

Individuals, including current, former, and prospective clients and investors, may exercise rights under applicable law to withdraw their consent for the collection, use, disclosure and/or processing of personal information by providing reasonable written notice to our Privacy team at MIMprivacy@metlife.com or our Personal Data Protection Officer at our Singapore office at enquiry.sg@pinebridge.com. Upon lawful request, we shall inform the individual of the likely consequences of the withdrawal of consent and will cease to collect, use, disclose and/or process the personal information unless otherwise permitted or required by applicable laws and regulations.

Cross Border Disclosure

In order to collect, use disclose and/or process the personal information, such information may be transferred internationally, including from the European Economic Area to the U.S. and other countries which the European Union has deemed do not provide “adequate” protection for personal information, and from Singapore to other jurisdictions. During such transfers, we will apply the same or comparable standards of privacy protection as set out in this privacy policy regardless of the international transfer or processing of personal information, and in accordance with applicable law. If such transfer occurs with respect to the non-public personal information relating to an individual residing in the European Union, we are required to ensure that processing of such personal data is in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679) and the United Kingdom General Data Protection Regulation and, in particular, that appropriate measures are in place such as entering into Model Contractual Clauses (as published by the European Commission) or ensuring that the recipient is Privacy Shield certified, if appropriate.

Changes to this MIM Privacy Statement

We may change this MIM Privacy Statement from time to time. When we do, we will post the revised MIM Privacy Statement with a new “Last Updated” date. Any changes to this MIM Privacy Statement will become effective when posted unless indicated otherwise. 

If, at any time in the future, it is necessary to collect, use, disclose and/or process any individual’s personal information, including current, former, and prospective clients and investors, in a way that is inconsistent with this policy, we will give such investor written notice of the change and, where required under applicable law, obtain consent to such change.

Contact Us for More Information

For any privacy issues, questions or complaints concerning the application of this MIM Privacy Statement or to exercise your rights as described above, you may contact our Privacy team via email: MIMprivacy@metlife.com, or our Personal Data Protection Officer at our Singapore office at enquiry.sg@pinebridge.com.