Privacy Notice

At Franklin Templeton, we care about your privacy and value the trust you place in us when you share your personal information.

Accordingly, we want to let you know how we handle the personal information you give us or is given to us by another party. Please review the following notice for information about how we collect, use, and share your personal information. If you are an individual investor investing for personal, family, or household purposes, you may also refer to our Individual Investor Privacy Notice.

Personal Information We Collect or Receive About You

Depending on the nature of your relationship with Franklin Templeton, we may collect or receive from you or others the following categories of personal information about you:

Contact information, such as your name, email address, phone number, or address
Education and skills information, such as academic transcripts or grades, education and training-related information, languages spoken
Employment information related to your role as an employee, such as your employer or company’s name, location, job title, etc.
Family-related information such as your marital status, emergency contact details, children’s names, etc.
Financial and transaction-related information, such as account numbers, bank information, transaction history, assets under management, etc.
Health-related information such as vaccine status, dietary preferences/food allergies, etc.
Location-related information, such as your physical or device location
Images, recordings, or biometric information, such as audio recordings, CCTV/video recordings, or photographs
Inferences or profile information
Internet/network activity, such as website cookie information, device ID, IP address, browsing activity, etc.
Personal identification information, such as your age, gender, date of birth, tax ID number, signatures, etc.
Professional experiences and affiliations, such as professional memberships, qualifications, experience, etc.
Screening or background check information, such as criminal records, references, or background check results
Social media information, such as your social media ID or content of postings on Franklin Templeton pages/accounts
Travel or expense information, such as flight details, hotel reservations, itineraries, expense requests, etc.
User account information, such as your account login ID, password, account age, etc.

For more information about how Franklin Templeton collects, uses, and shares your personal information, visit Your Relationship to Franklin Templeton and select the most applicable relationship.

How We Use Your Personal Information

Depending on the nature of your relationship with Franklin Templeton, we may use your personal information for the following every-day business purposes, as defined in applicable state law, or other related purposes as described below:

To provide the information, products, or services you or your representative requested or as reasonably expected given the context in which the personal information was collected (such as providing customer service, personalization, and preference management, providing product updates, quality assurance, and dispute resolution)
For identity verification and access management and authentication, including system and technology administration
To protect the security and integrity of your information and our systems, networks, applications, and data, including detecting, analyzing, and resolving security threats, and collaborating with cybersecurity centers, consortia, and law enforcement about imminent threats
For fraud detection and prevention
For debugging and internal research for technical development and demonstration
For legal and regulatory compliance, including all uses and disclosures of personal information that are required by law or reasonably needed for compliance with company policies and procedures, such as: anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines
For corporate audit, analysis, and reporting, including analytics related to digital advertising
To enforce our contracts and to protect against injury, theft, legal liability, fraud, or abuse, to protect people or property, including physical security programs
To de-identify data or create aggregated datasets, such as for consolidating reporting, research, or analytics
To make back-up copies for business continuity and disaster recovery purposes
For corporate governance, including mergers, acquisitions, and divestitures
Where Franklin Templeton is a service provider to another business, for performing services on behalf of that business

For more specific purposes based upon your personal relationship with Franklin Templeton, visit Your Relationship to Franklin Templeton and select the most applicable relationship.

In the event we use or retain personal information that has been deidentified, Franklin Templeton is committed to maintaining and using that information without attempting to re-identify it.

Recipients of Your Personal Information

We may disclose your personal information to the following recipients for a business or commercial purpose as described below:

To our affiliated Franklin Templeton companies and entities for the purpose of servicing your account, maintaining our relationship with you, or advertising other Franklin Templeton or affiliated products or services you may be interested in
To companies that perform services on our behalf or assist us with provision of services, including marketing and advertising, to facilitate receipt or delivery of those services
Where Franklin Templeton is a service provider to another business, we may disclose information to that business to facilitate delivery of services
To government or regulatory agencies, such as the Internal Revenue Service (IRS), Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), local law enforcement, etc. to meet legal or regulatory obligations
To external auditors, legal advisors, or other professional advisors to receive advice, protect our rights or the rights of others, or if we are obligated to do so to comply with a legal or regulatory obligation
In the event of a merger or acquisition to facilitate completion of the event
To parties you authorize, access, or authenticate, such as when connecting your Franklin Templeton account to an external banking or financial services partner so you can use their services (like Plaid or TurboTax)

For more information about third parties we may share your personal information with and our purpose for doing so, visit Your Relationship to Franklin Templeton and select the most applicable relationship.

Franklin Templeton Privacy Notice

Information We Collect or Receive
How We Use Your Information
Recipients of Your Information
Your Relationship With Us
Retention Period
Information About Minors
External Links
Cookies and Tracking Technologies
Your Choices and Controls
How to Contact Us

Individual Investor Privacy Notice

Candidate and Employee Privacy Notices
Global Privacy Notices

Your Relationship to Franklin Templeton

Select the relationship that is closest to your personal relationship with Franklin Templeton for additional information about the categories of personal information we collect, the specific purposes for which we process your personal information, and why your information may be shared with third parties.

Building Tenants/Occupants and Visitors


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Purpose for Disclosing Personal Information to Third Parties
Contact Information Personal Identification Information Employment Information Health Information	From you directly From the building lease holder From a service provider, such as a conference room scheduling service From closed circuit video cameras (CCTV)	To contact you in the event of an emergency or for building-related information To administer building or parking lot operations, including access and security In the event vaccine status or other limited health-related information is collected, to ensure relevant precautions are taken For every-day business purposes noted above	None	Disclosures of your personal information are limited to what is described in Recipients of Your Personal Information

Personal information, including sensitive personal information, of building tenants/occupants and visitors is not sold to or shared with third parties.

Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about building tenants/occupants and visitors.

*A third party is anyone other than Franklin Templeton or our service providers and contractors with whom we maintain a contractual relationship. Refer to Recipients of Your Personal Information for additional information about why your information may be disclosed for a business or commercial purpose.

Contractors/Service Providers/Vendors


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Education & Skills Employment Information Financial Information Images and Recordings Personal Identification Screening Information	From you directly From a third party, such as your employer or a referral contact or agency From public sources such as websites or vendor directories	To contact you regarding establishment or maintenance of a business relationship To evaluate suitability and assess risk To make or receive payments To utilize contracted products or services For every-day business purposes noted above	Contact Information Employment Information Personal Identification	In addition to the disclosures described in Recipients of Your Personal Information we may also: Share personal information such as your name, email, and contact information to a business partner or peer when referring your services to others

Personal information, including sensitive personal information, of contractors, service providers, and vendors is not sold to or shared with third parties. Additionally, Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about contractors/service providers/vendors.

Event Attendees and Speakers


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Employment Information Health Information Images or Recordings Internet/Network Activity Personal Identification Social Media Information Travel Information User Account Information	From you directly From the event host or sponsor From service providers, such as online event platforms From a travel partner, such as a hotel or airline	To facilitate the event To facilitate travel arrangements, meals, entertainment, etc. To advertise our products or services to you To issue continuing education credits To communicate or publish your involvement with an event (for hosts and speakers) In the event vaccine status or other limited health-related information is collected, to ensure relevant precautions are taken For every-day business purposes noted above	Contact Information Employment Information Personal Identification Images or Recordings	In addition to the disclosures described in Recipients of Your Personal Information we may also: Share personal information of event speakers such as name, occupation, picture, etc. with other event attendees as part of event facilitation Share event attendee information with entities responsible for issuing continuing education credits

Personal information, including sensitive personal information, of event attendees is not sold to or shared with third parties. Additionally, Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about event attendees.

Financial Professionals


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Education and Skills Employment Information Family Information Financial Information Images, Recordings or Biometrics Inferences Internet/Network Activity Personal Identification Professional Experience and Affiliations Screening Information Social Media Information User Account Information	From you directly From your employer From service providers, such as industry-recognized financial information companies From your activities when acting as a Website, App or Social Media User From advertising partners with whom you have engaged	To contact you regarding requests or transactions on client accounts To advertise our products or services to you To monitor social media content, respond to inquiries, and promote our business and brand To evaluate suitability and assess risk For every-day business purposes noted above	Contact Information Employment Information Financial Information Personal Identification Internet/Network Activity	In addition to the disclosures described in Recipients of Your Personal Information we may also: Share personal information with advertising partners to advertise our products or services to you

Personal information of financial professionals may be “sold” to or shared with third parties. We may share information about financial professional’s assets under management and transaction flows at a product level with industry-recognized financial information companies in exchange for insights about total portfolio holdings. This may include Contact Information, Employment Information, and Financial Information. This exchange of information helps us service you effectively by focusing our interactions on products that you and your clients may be most interested in. (While we do not sell any personal information for money, this sharing may be considered a "sale" under some U.S. state privacy laws.) You may opt out of this activity at the following link:

Do Not Sell or Share My Personal Information

Franklin Templeton does not sell or share sensitive personal information of financial professionals. Additionally, Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about financial professionals.

Investors


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Education and Skills Employment Information Family Information Financial Information Geolocation Information Images or Recordings Internet/Network Activity Personal Identification Screening Information User Account Information	From you directly From a financial professional From your employer, in the event of employer-sponsored accounts From service providers, such as for identity verification and financial screenings From third parties, such as the U.S. Postal Service, bank partners, or referral sources	To fulfill legal requirements related to your account, such as tax filings or responding to subpoenas To make or receive payments To advertise our products or services to you To evaluate suitability and assess risk For every-day business purposes noted above	Contact Information Employment Information Financial Information Personal Identification	Disclosures of your personal information are limited to what is described in Recipients of Your Personal Information

Personal information, including sensitive personal information, of investors is not sold to or shared with third parties. Additionally, Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about investors.

Individuals Associated with Investor Accounts (Signatories, Beneficiaries, etc.)


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Family Information Financial Information Images or Recordings Personal Identification Screening Information User Account Information	From you directly From the investor whose account you are associated with From service providers, such as for identity verification and financial screenings From third parties, such as the U.S. Postal Service	To facilitate maintenance of the account you are associated with To make or receive payments To evaluate suitability and assess risk For every-day business purposes noted above	Contact Information Employment Information Financial Information Personal Identification	Disclosures of your personal information are limited to what is described in Recipients of Your Personal Information

Personal information, including sensitive personal information, of individuals associated with investor accounts, such as signatories and beneficiaries, is not sold to or shared with third parties.

Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about individuals associated with investor accounts, such as signatories and beneficiaries.

Industry Peers


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Education and Skills Employment Information Images or Recordings Personal Identification Social Media Information	From you directly From referral contacts/agencies From industry or public sources such as websites or industry directories	To contact you for knowledge sharing, consulting, etc. To send press releases, address media inquiries/appearances, and other related communications To monitor social media content, respond to inquiries, and promote our business and brand For facilitation of events For quality assurance, if you contact us on a recorded line For every-day business purposes noted above	None	Disclosures of your personal information are limited to what is described in Recipients of Your Personal Information

Personal information, including sensitive personal information, of industry peers is not sold to or shared with third parties.

Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about industry peers.

Website, App, or Social Media Users, and Other Individuals Who Contact Franklin Templeton


Categories of Personal Information Collected	Source	Specific Purposes	Categories of Personal Information Disclosed to Third Parties*	Business/Commercial Purpose for Disclosing Personal Information to Third Parties
Contact Information Images or Recordings Internet/Network Activity Personal Identification Social Media Information User Account Information	From you directly From third parties, such as analytics providers, social media platforms, or external banking providers From our web logs, such as device information (e.g., device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access) From website cookies and similar technologies	To personalize and improve your experience of our website or app To monitor social media content related to Franklin Templeton, respond to inquiries, and promote our business and brand To advertise our products or services to you For every-day business purposes noted above	Internet/Network Activity	In addition to the disclosures described in Recipients of Your Personal Information we may also: Share your Internet/Network Activity information via website cookies and similar technologies with advertising partners to advertise our products or services to you

Personal information of website, app, and social media users may be “sold” to or shared with third party advertising providers. (While we do not sell any personal information for money, this sharing may be considered a "sale" under some U.S. state privacy laws.) This activity occurs using Internet/Network Activity contained in cookies and similar technologies for the purpose of serving you relevant advertising about our products or services. You may opt out of this activity by changing your cookies settings at the following link:

Do Not Sell or Share My Personal Information

Franklin Templeton does not sell or share sensitive personal information of website, app, and social media users. Additionally, Franklin Templeton does not use or disclose sensitive personal information for the purpose of inferring characteristics about website, app, and social media users.

Retention Period

The retention periods for personal information within each category may vary depending on the nature of the business records in which the personal information is maintained. Retention periods for our business records are set based on the following criteria: (1) the length of time the record is needed for the purposes for which it was created, (2) the time the record is needed for other operational purposes, such as audits and reporting, (3) the length of time the record is needed for legal or regulatory compliance, including maintaining opt-out/in lists, legal defense, and legal holds.

Personal Information About Minors

Our website and apps are neither intended for, nor targeted to children under 18, and we do not collect personal information directly from children under 18. We receive limited personal information about children from parents/guardians and other responsible adults only as required to establish and maintain accounts for the child’s benefit.

Additionally, Franklin Templeton does not sell the personal information of minors, nor do we direct targeted advertising to minors.

External Links

Our website and app may contain links to online websites or content operated and maintained by third parties, over which we have no control. Please consult the privacy policies of those third-party sites to become familiar with their privacy practices and to learn about any choices that these companies may offer you with respect to your personal information.

Cookies and similar tracking technologies

Some of our web pages and emails may use cookies (small text files that identify your device to our network) and/or web beacons, clear GIFs, tags or pixels (electronic image files that track navigation through our sites) placed by Franklin Templeton or third-party advertisers. Cookies and similar tracking technologies are widely used to make websites work efficiently, to collect information about your online preferences, and to customize content and advertisements you receive.

Tracking in Mobile Apps

Cookies are not used within mobile apps. Instead, we use unique identifiers associated with your device, such as the device ID and other data such as your geolocation or your network location. This data is used in the same way as cookies, e.g., to analyze usage and to improve our services.

For simplicity, we refer to all these technologies as “cookies.”

How do we use cookies?

We may use cookies to customize content, provide social media features, count users who have visited our pages, see how visitors navigate our website, improve the services we offer you, and to deliver customized advertising content, which may include the placement of ads about our products and services on other websites and services.

We may also engage analytics and advertising providers to track and analyze your usage of our website through the use of cookies. These providers collect and share with us usage information about visits to our website and, sometimes by correlating this information with other information (such as your IP address), help us track page usage, target our recommendations and advertising, and measure and research the effectiveness of our recommendations and advertisements.

These providers may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Tracking in the app is limited to information about usage of the app, device information (such as operating system, device model, etc.), in-app purchases, and anonymous geographic information.

Enabling and Disabling Cookies on Our Website

You can learn more about each type of cookie we use on our website and choose which cookie categories you wish to allow by visiting the website Cookie Preference Center.

Your Choices and Controls

The state you reside in may provide you with certain choices or privacy rights over your personal information as described below. Although these rights do not apply to Franklin Templeton investors covered under applicable Federal privacy law or expressly exempt from your state’s law, other state residents may be covered.

Right to know – Requires that we inform you about the personal information and sensitive personal information we collect.
Right to access – Allows you to request a copy of the personal information we have on file for you and to be informed about how we use and share your personal information.
Right to delete – Allows you to request that we delete or anonymize your personal information where we do not have a legal or regulatory obligation or other valid reason to continue to retain it.
Right to rectification – Allows you to request that Franklin Templeton correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Right to object/opt-out – Allows you to request to opt out of the processing of your personal information for the purposes of:
- the sale or sharing of personal information as defined by the state law applicable to your state residency;
- profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you; and
- targeted advertising.
Right to appeal – Allows you to request that Franklin Templeton review a decision to not fulfill a privacy rights request.
Right to equal treatment – You have the right not to be discriminated against for exercising a privacy right.

To exercise a privacy right under applicable state law, use one of the methods listed below. To protect the security and privacy of your personal information, we may need to verify your identity, and the identity of your authorized agent if the request is submitted by someone other than you, against the information we have on file for you before we can fulfill your request. This is to ensure that your personal information is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us locate your personal information, including, for example, the nature of your relationship with Franklin Templeton.

Complete the U.S. Privacy Rights Request Form and email or mail it to the address noted in the form.
Call 1-800-632-2301 to speak to a service associate and request to exercise your privacy rights.
You may use one of the following methods to opt out of targeted advertising:
- Visit the Cookie Preference Center and disable tracking cookies.
- Enable the Global Privacy Control (GPC) in your browser. When enabled in your web browser, the GPC automatically opts you out of tracking and social media cookies upon visiting our website. (Our website does not respond to “Do Not Track” signals. If you wish to use this option, please consider using the Global Privacy Control.)
- Visit Do Not Sell or Share My Personal Information to opt out of the selling or sharing of your personal information.

How to Contact Us

We may update this privacy notice periodically and any new version will be posted on our website. We recommend you review this notice regularly to ensure that you are aware of our current privacy practices. If you would like further information regarding the collection or use of your personal information, please email us at [email protected].

Last Updated January 1, 2023

Investor Privacy Notice

Your Privacy Is Our Priority

Franklin Templeton* is committed to safeguarding your personal information. This notice is designed to provide you with a summary of the non-public personal information Franklin Templeton may collect and maintain about current or former individual investors; our policy regarding the use of that information; and the measures we take to safeguard the information. We do not sell individual investors’ non-public personal information to anyone and only share it as described in this notice.

Information We Collect

When you invest with us, you provide us with your non-public personal information. We collect and use this information to service your accounts and respond to your requests. The non-public personal information we may collect falls into the following categories:

Information we receive from you or your financial intermediary on applications or other forms, whether we receive the form in writing or electronically. For example, this information may include your name, address, tax identification number, birth date, investment selection, beneficiary information, and your personal bank account information and/or email address if you have provided that information.
Information about your transactions and account history with us, or with other companies that are part of Franklin Templeton, including transactions you request on our website or in our app. This category also includes your communications to us concerning your investments.
Information we receive from third parties (for example, to update your address if you move, obtain or verify your email address or obtain additional information to verify your identity).
Information collected from you online, such as your IP address or device ID and data gathered from your browsing activity and location. (For example, we may use cookies to collect device and browser information so our website recognizes your online preferences and device information.) Our website contains more information about cookies and similar technologies and ways you may limit them.
Other general information that we may obtain about you such as demographic information.

Disclosure Policy

To better service your accounts and process transactions or services you requested, we may share non-public personal information with other Franklin Templeton companies. From time to time, we may also send you information about products/services offered by other Franklin Templeton companies although we will not share your non-public personal information with these companies without first offering you the opportunity to prevent that sharing.

We will only share non-public personal information with outside parties in the limited circumstances permitted by law. For example, this includes situations where we need to share information with companies who work on our behalf to service or maintain your account or process transactions you requested, when the disclosure is to companies assisting us with our own marketing efforts, when the disclosure is to a party representing you, or when required by law (for example, in response to legal process). Additionally, we will ensure that any outside companies working on our behalf, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we asked them to perform.

Confidentiality and Security

Our employees are required to follow procedures with respect to maintaining the confidentiality of our investors’ non-public personal information. Additionally, we maintain physical, electronic and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.

At all times, you may view our current privacy notice on our website at franklintempleton.com or contact us for a copy at (800) 632-2301.

*For purposes of this privacy notice Franklin Templeton shall refer to the following entities:

Fiduciary Trust International of the South (FTIOS), as custodian for individual retirement plans
Franklin Advisers, Inc.
Franklin Distributors, LLC, including as program manager of the Franklin Templeton 529 College Savings Plan and the NJBEST 529 College Savings Plan
Franklin Mutual Advisers, LLC
Franklin, Templeton and Mutual Series Funds
Franklin Templeton Institutional, LLC
Franklin Templeton Investments Corp., Canada
Franklin Templeton Investments Management, Limited UK
Legg Mason Funds serviced by Franklin Templeton Investor Services, LLC
Templeton Asset Management, Limited
Templeton Global Advisors, Limited
Templeton Investment Counsel, LLC

If you are a customer of other Franklin Templeton affiliates and you receive notices from them, you will need to read those notices separately.

The Investor Privacy Notice was last updated January 1, 2023.

This site is intended only for U.S. Institutional Investors and Consultants. Using it means you agree to our Terms of Use.

If you would like information on Franklin Templeton’s retail mutual funds, please visit www.franklintempleton.com.