This statement details AEGON Asset Management's policy on Data Protection and Privacy.

AEGON Asset Management regards the lawful and correct treatment of personal data as important to its successful operations, and to the maintenance of confidence between it and those with whom it deals. We will ensure that our staff and those acting on our behalf obtain, use and disclose personal data lawfully and correctly. To this end we fully endorse and adhere to the principles of Data Protection, as set out in the Act.

Specifically, the principles require that personal data shall:

• Be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met
• Be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes
• Be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed
• Be accurate and, where necessary, kept up-to-date
• Not be kept for longer than is necessary for that purpose or those purposes
• Be processed in accordance with the rights of the individual under the Act
• Have in place appropriate technical and organisational measures against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data
• Not be transferred to a country or territory outside the European Economic Area (the countries of the European Union plus Norway, Liechtenstein and Iceland) unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data or unless specific agreement has been sought from the individuals concerned.

AEGON Asset Management will, through the use of appropriate and consistent management and application of controls:

• Observe the conditions in the Act regarding the fair collection and use of personal data
• Meet its legal obligations to specify the purposes for which personal data is used, this data being set out in the AEGON Asset Management Data Protection Notification particulars which can be found on the Information Commissioner’s website at http://www.informationcommissioner.gov.uk/
• Collect and process appropriate data, only to the extent that it is needed to fulfil our operational needs or to comply with a legal requirement
• Ensure the quality and accuracy of data
• Apply checks to determine the length of time data is held
• Ensure that the rights of people about whom data is held, are able to be fully exercised under the Act
• Take appropriate technical and organisational security measures to safeguard personal data
• Ensure that personal data is not transferred outside the EEA without suitable safeguards or agreement from the individual.

The purpose of the Web Site is to provide information, resources and services for site visitors and policyholders.  It also provides links to other services provided by AEGON Asset Management.  These may relate to the servicing of those policies and could include underwriting and valuations.

AEGON Asset Management collects and uses certain types of personal data about people (data subjects) with whom it deals in order to operate. These data subjects include current, past and prospective clients, visitors, and others with whom it communicates.  Examples of personal data include names, salaries, fund contributions, gender, and age.

Where necessary, AEGON Asset Management will process ‘sensitive data’ in accordance with the Act.  We have a confidentiality policy which means that all personal data is held securely and access is limited to those who need to see it. We apply extra security to sensitive personal data.

In addition, AEGON Asset Management will disclose information to certain bodies where it has a legal obligation to do so, for example to regulatory bodies or authorities such as the Financial Services Authority or the Inland Revenue. AEGON Asset Management may also be required to disclose information in order to comply with money laundering laws and for other purposes, for example detecting crime. We will also share permitted relevant information with persons acting as agents on your behalf (for example your Independent Financial Adviser) to allow them to carry out fully their role as your agent.

A cookie is a piece of data stored on a user's hard drive containing information about the user.  These work by setting a cookie on the visitor’s browser to anonymously track the pages they visit on our site and provide us with statistics.  We also use action tags (sometimes referred to as Web Beacons) to measure usage of the website.

We currently use cookies / tracking on our websites for the following purposes:

• Anonymously tracking participation in online surveys accessed on or from the AEGON Asset Management website. We’ll set a cookie so that we remember your decision on whether you wish to participate in such a survey. This is used to enhance the user experience, by avoiding having to ask if you wish to participate each time you visit the website. No personal data will be stored or collected.
• Anonymously tracking usage of the website, either by AEGON Asset Management or its appointed third party. We use a third party company to place adverts on the World Wide Web. These adverts link to the AEGON Asset Management website. When someone clicks on one of these adverts and arrives at the AEGON Asset Management website, we will anonymously track which pages they visit on the website. This helps us to develop our website and online advertising to help improve user experience.
• Anonymously tracking the usage of the AEGON Asset Management website by visitors.  When someone visits the AEGON Asset Management website, we will track which pages they access. This helps us to understand which pages are most used and to use this knowledge to develop our website further and to help improve user experience.

AEGON Asset Management, and/or the third party may use non -personal data about your visits to the website. This data may include: date/time of visit, the cookie, and the first three octets of the IP address. Neither AEGON Asset Management nor the third party collects personally identifying information.

More information about cookies, including how to block them and/or delete them, can be found at http://www.aboutcookies.org/.

You do have the option to transfer to web sites that have links on our sites. If you choose to use one of these links, you may be asked for separate login ID and passwords for these services.  We will not hold onto any information to do with that transfer.

We cannot guarantee that any e-mail sent to us will be received, or that the contents will remain private during transmission. If you are concerned about this, then please consider other means of communication. You will be responsible for ensuring that any electronic message or information you send to us is free from any virus or defect that may harm our systems in any way.

• AEGON Asset Management currently operates their Security requirements through the Security Policy:
• Breaches in Security - are dealt with by the Security Policy
• Ensuring that staff treat the data with respect:
  • All members of staff, including temporary members of staff, sign confidentiality agreements
  • Staff are restricted to certain systems to which are required in order to comply with their job function
• AEGON Asset Management ensures that personal information is passed to only those people and organisations that are entitled to know. Checks are made to confirm that people are whom they say, and that these organisations or people are allowed to have access to this information. Every business area has their own verification checks that relate to the data held and types of people who may require access.
• AEGON Asset Management trains its entire staff in Data Protection every two years. This ensures that members of staff know how to treat personal data and the risks involved if data is poorly treated.

We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors' personal data.

AEGON Asset Management includes AEGON Asset Management UK plc (No. 113505), and AEGON Investment Management UK ltd (No. 212159). Both are registered in Scotland and have their Registered Offices at AEGON House, Edinburgh Park, Edinburgh, EH12 9SA. AEGON Asset Management UK plc is authorised and regulated by the Financial Services Authority.

The Investment Manager and Authorised Corporate Director of AEGON ICVC is AEGON Asset Management UK plc.