Privacy policy

This privacy statement is issued by DWS Distributors, Inc., DWS Investment Management Americas, Inc., DWS Trust Company and the DWS Funds.

Code of ethics   I   Business continuity program

Our commitment to privacy
We regard protecting our customers’ personal information as one of our fundamental responsibilities. We diligently strive to safeguard your personal information by maintaining strict standards for security and privacy.

This Privacy Statement provides an explanation of the type of information we collect about you, how we collect it, process it, and protect it from misuse. To learn more about your privacy rights and some of the ways we protect your personal information, please take a moment to read below.

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The information we collect
We collect, retain and use (including possible disclosure as described below) your personal information to provide services, better assist your financial needs, and administer our business. We endeavor to limit the collection and use of your personal information to the minimum required for delivering outstanding service to our clients. All the information we collect about you will be done in accordance with and as required by law or regulation.

The types of personal information we collect, retain and use (including possible disclosure as described below) may include:

  • Your name, address, telephone number or other contact information;
  • Your Social Security number, driver’s license number, visa number, passport number, or national identity card;

This information may be collected on a new account opening form, through our website, and through other materials you submit during the course of your relationship with us1. Additionally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (for example, recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis.

You may learn about our products and services or access your account information through one of our many websites. Through these websites, we may request and collect personal information about you in order to enhance your experience and provide you with account information. We will make every effort to collect this information in a secure manner and provide you a secure connection to access your account information.

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How we use the information we collect
We will use the information collected about you to:

  • Manage, facilitate, or administer your relationship with us or one of our affiliates.
  • Provide you with the products or services you requested.
  • Contact you or your representative in connection with your relationship.
  • Offer you information, recommendations or advice regarding our products and services.
  • Facilitate internal operations, such as risk analysis, monitoring and reporting metrics.
  • Comply with reporting and other legal requirements.
  • Assist in fraud prevention.

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Sharing your information
We will not sell your personal information and will only disclose your information to affiliates and nonaffiliated third parties in accordance with all applicable state and federal laws and regulations and any related industry standards.

In general, we adhere to a “need to know” policy with respect to sharing any personal information or other information about its clients - meaning that we only share the information that is necessary for an affiliated or non-affiliated third party to know in the course of servicing your account and/or providing our products and services to you. Additional information on how your personal information is protected within our organization is provided below under Safeguarding Your Information.

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Entities with whom we may share your information

Affiliated entities
In the course of providing timely and reliable services, more than one entity within DWS may be provided access to your personal information. For example, information may be shared between our affiliates to facilitate the settlement of your transactions or the maintenance of your accounts. We may also share your personal information with affiliates as part of the performance of specialized services, such as US and International brokerage, asset management, and advisory and trust services.

Nonaffiliated third parties
We are permitted to share the information we collect about you, as described above, with nonaffiliated third party service providers, such as broker-dealers, custodians and transfer agents, to facilitate your account transactions, to support our business activities, or to carry out transactions or services as instructed by you. These activities may include preparing your monthly statements, initiating transactions on your behalf, or maintaining your account. Other nonaffiliated third parties with whom we may share your information also include credit reporting agencies to which we report information about your transactions with us. We require all nonaffiliated third parties that have access to your personal information to safeguard your information in the same manner as our organization and to use it only for the purpose for which it was given to them.

1. Your relationship with DWS means any interaction you may have with us, including anything to do with opening and managing your account, offering you new products and services, or making any changes to the information we hold about you.

Information sharing for marketing and other purposes
Subject to your right to opt out, as described below, we are also permitted by law to share all the information we collect, as described above, with 1) companies that perform marketing services on our behalf, and 2) with other financial institutions with whom we have joint marketing arrangements. For example, we may share information with financial services providers through which we offer products.

In addition to the situations described above where we are permitted by law to share your information, we may also disclose your information in the following scenarios. All information sharing or disclosures will be in accordance with local, state and federal laws.

In connection with the sale, assignment, or other transfer of DWS business, in which case we will require any buyer to agree to treat your information in accordance with this Privacy Policy and use it for the same purposes; or

To respond to authorized law enforcement requests or where required by applicable laws, court orders, or government regulations.

Information sharing in different jurisdictions
The collection, use, and disclosure of information described in this Privacy Statement may involve a transfer of the information to jurisdictions located outside of your country of residence or the country in which you maintain your account or relationship that may not have equivalent laws and rules regarding your personal information. In some cases, you will be asked to consent to such transfers before they occur in accordance with this Privacy Policy and applicable laws.

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Your information sharing rights (opting out)
Unless we are permitted by law to disclose your personal information to a nonaffiliated third party (e.g., as necessary to service or administer a customer account or relationship), we will provide you with the opportunity to opt out of having your personal information shared - that is, you may direct us not to disclosure your personal information except as permitted by law. We will provide you with notice and the opportunity to opt out prior to disclosing your information.

In addition, some state and federal regulations require us to provide you with the opportunity to opt out of having your personal information shared with our affiliates for marketing purposes or sharing your credit information. All opt out requests must be submitted to the entity with whom you have your account. Please contact your customer service representative for more information.

Right of access
In some jurisdictions in which our organization operates, you may have the right to view and correct the information we hold about you. Please contact your customer relationship manager or local customer service representative for more information.

Safeguarding your information
We are committed to implementing physical, electronic, and procedural safeguards to protect your personal information against loss, misuse, damage and unauthorized access, modifications or disclosures. We continuously review and enhance our policies and security measures to consistently maintain a high level of security.

A few key features of our information security program include:

  • The use of firewalls, encryption, and other specialized technology;
  • A dedicated information security team that designs, tests, implements, and provides oversight to our information security and risk management program;
  • Continuous monitoring of our technical environment for vulnerabilities and potential intrusions;
  • Review and recertification of user access to our applications on a periodic basis;
  • Logical and physical controls to identify, authenticate and authorize access to our applications and building facilities;
  • Training is provided to information security personnel to update them on new regulations, vulnerabilities, and the latest technology used to safeguard our technical infrastructure; and
  • Annual privacy awareness training is provided to all of our employees, and in-depth privacy training is provided to those employees who handle your information directly.

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Websites
Pages where we collect personal data from our website visitors are usually encrypted to secure the collection and transmittal of your personal information. We have implemented additional, comprehensive state-of-the-art security procedures for our internet-banking-system. A firewall prevents external access to account information from our system. Moreover, multiple layers of encryption and identification prevent unauthorized inquiries or interception of the transmission of client information.

We may use cookies or web beacons (invisible 1X1 pixels) to obtain information about you while visiting our websites.

Cookies
A cookie is a very small text file that is sent to your browser from our servers and stored on your computer’s hard drive. It assigns your computer with a unique identifier, which in turn, becomes your identification card whenever you return to one of our websites.

Cookies can also help us provide you with a personalized on-line experience in the following ways:

  • they store your user name and password for future visits, making each login more efficient;
  • they may provide you with a personalized experience by allowing us to store your preferences;
  • they can help to ensure you obtain all requested information; and
  • they help us deliver communications that are relevant and responsive to your interests and location.

Our cookies are limited to our websites only, and are not designed to follow you when you surf the Internet after leaving our websites.

If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the “privacy options” section of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our websites and our ability to recognize you from one visit to the next.

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Web beacons
We may also employ invisible 1x1 pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain any personal information about you or your computer. We may use this information to improve marketing programs and website content.

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Other ways to protect your privacy

Marketing lists
You can reduce the amount of marketing material and credit applications you receive via mail, telephone or e-mail by writing the Direct Marketing Association at the addresses listed below or contacting the National Do Not Call Registry. You must provide your name, address, and telephone number with your request.

Telephone Preference Service
National Do Not Call Registry
888-382-1222
https://www.donotcall.gov

E-Mail Preference Service
http://www.DMAchoice.org

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Identity theft
Identity theft is a serious and prevalent trend. If you believe that someone has fraudulently used your identification to establish credit, report the incident immediately to each of the credit reporting agencies listed below. Request a fraud alert be placed on your file. You should also contact us and law enforcement officials to notify them of the possible fraud. 

For more information about identity theft, please see the Federal Trade Commission’s website at http://www.ftc.gov/bcp/edu/microsites/idtheft/

Additionally, it is a good idea to periodically review your credit report for any unusual account activity or misuse of your information. Contact these credit reporting agencies to obtain a copy of your credit report.

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Please note this information regarding marketing lists and identity theft is being provided to you as a service. DWS is not affiliated with any of the listed companies and does not guarantee their accuracy or effectiveness.

Contact us
If at any time you are not satisfied with our procedure to protect your privacy, or if you have questions regarding the collection and/or use of your personal information or regarding our privacy policy, please contact us. We will use all reasonable efforts to promptly address your concern. Contact the customer service representative representing your account at any time. 

Updates to the privacy statement
DWS may update this Privacy Statement occasionally to comply with changes in the regulatory environment, our business needs, or to satisfy the needs of our customers and service providers. New versions will be date stamped when posted to our website.

This privacy statement is issued by DWS Distributors, Inc. 

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