International Transfer of Personal Information Statement

As of October 29. 2024

Bloomberg Finance L.P., its operating agent Bloomberg L.P., and affiliates (“Bloomberg”) are committed to compliance with their data protection obligations throughout the world. This International Transfer of Personal Information Statement (“Statement”) sets out information about the measures we put in place to protect personal information we transfer.

Bloomberg has implemented robust processes and protections to meet the requirements of exporting or transferring personal information in accordance with applicable data protection laws. Accordingly, where Bloomberg transfers personal information to Bloomberg group members overseas, the relevant Bloomberg group members enter into appropriate Intra-Group Personal Data Protection Agreements (“IGAs”), which identify the Bloomberg group members acting as data exporter and data importer, and ensure that personal information transferred overseas is subject to appropriate safeguards, as required by applicable data protection laws.

For example, for personal information originating in the European Union, Switzerland or the United Kingdom, the IGAs incorporate EU Commission-approved Standard Contractual Clauses (“SCCs”), which include specific obligations and rights around transfers of personal information. The IGAs will also contain amendments required by applicable data protection law to extend their application to transfers of personal information from non-EU jurisdictions, where relevant. The IGAs include the operational procedures and security measures used by Bloomberg to maintain the accuracy and integrity of personal information and adequately protect personal information.

The IGAs include the safeguards we put in place to ensure that personal information continues to be protected to a standard required under applicable data protection laws, including after it has been transferred overseas. These include:

•Governance – We maintain a robust personal information governance program. We regularlyreview and update our governance framework, including roles and responsibilities ofpersonnel, and maintain a working group to oversee data protection regulation complianceand document results and decisions as they relate to personal information management.

•Accountability and Recordkeeping – We map the personal information life cycle andmaintain a personal data map inventory, including documenting flows of personalinformation within Bloomberg’s systems and any disclosures to third-party systems.

•Security – We invest in and maintain organizational, technical, and physical safeguardsintended to ensure the protection of personal information. We engage in ongoing monitoringand testing of the efficacy of these safeguards. Our data centers are dedicated solely to ourproducts, services, and operations, and have secure and monitored access controls.

•Privacy By Design – We integrate mapping of and accountability for personal informationinto our product design processes, and build personal information security into ourdevelopment and product life cycles.

•Administrative controls – We regularly review and update our policies, procedures, andcontrols to address our data protection obligations. We conduct company-wide privacytraining, data protection executive education and tailored training programs for dataprotection compliance.

•Government Requests for information – We take a company-wide approach to lawenforcement, government, and regulatory agency disclosure, which extends beyond personalinformation and applies to all client data. Please see our Law Enforcement Data RequestStatement for further information.

Bloomberg has also certified to the U.S. Department of Commerce that certain Bloomberg group members adhere to the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework set forth by the U.S. Department of Commerce. For more information, see our Data Privacy Framework Notice here.

Contact information

Questions or comments regarding this Statement should be submitted to privacy@bloomberg.com.

Bloomberg reserves the right to change this Statement at any time by indicating revisions through the date at the top of the Statement. Such changes will be effective upon posting.