Our Commitment to Privacy

Fidelity takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Fidelity may collect public and non-public personal information about you from any of the following sources:

• You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
• You or your employer or plan sponsor if Fidelity provides them with recordkeeping services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with Fidelity (for example, discussions with our customer service staff, information you enter into our websites or when you enroll in our authentication services)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Fidelity)

Fidelity considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Fidelity, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.

Fidelity does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Fidelity's direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other third-parties, with your consent or as directed by your representative (for example, if you use Fidelity as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Fidelity financial account on your behalf)
• Other organizations as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Fidelity.

Based on the nature of your relationship with Fidelity, we may exchange information with other third parties as described below:

• If Fidelity provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits recordkeeping services, Fidelity may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with Fidelity through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
• If you transact business through Fidelity's life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

We may share personal information about you with various Fidelity corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Fidelity directly as an individual investor (including joint account holders) or if Fidelity provides services to your employer or plan sponsor, we may exchange certain information about you with Fidelity financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals' customers is not shared with Fidelity affiliates for marketing purposes, except with your consent and as allowed by law.

Fidelity and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (e.g., computer, tablet or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Fidelity cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device or your online preferences.

Both Fidelity and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below.

Fidelity advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about Fidelity and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Fidelity products and services may be of interest to you. These service providers may collect information about your activity on Fidelity digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns, and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Fidelity and not for their own purposes.

Fidelity also advertises our products and services on digital offerings not affiliated with Fidelity and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Fidelity and these third-party online advertising companies may use the data collected, along with other information we have about you and your Fidelity relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Fidelity and non-Fidelity websites. These advertisements are known as "interest-based advertisements".

You may opt-out of receiving interest-based advertisements from online advertising companies by clicking on the AdChoices icon (which appears on all Fidelity interest-based ads) and following the opt-out instructions. For more information about interest-based advertising please see http://www.networkadvertising.org/managing/opt_out.asp.

Non-Fidelity websites and mobile applications are not subject to Fidelity's Privacy Policy. You may visit the individual sites for additional information on their privacy practices.

Fidelity provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Fidelity Mobile^® applications ("apps") allow you to access your accounts, trade securities, move money, and access news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Fidelity websites are not directed to individuals under the age of thirteen (13). Fidelity does not intentionally collect information on Fidelity websites from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Fidelity offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If you transact business through Fidelity's life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

• Fidelity Brokerage Services LLC
• Fidelity Distributors Corporation
• Fidelity Workplace Services LLC
• Fidelity Investments Institutional Operations Company, Inc.
• Fidelity Investments Institutional Services Company, Inc.
• Fidelity Management Trust Company
• Fidelity Personal Trust Company, FSB
• Fidelity Personal and Workplace Advisors LLC
• Fidelity Stock Plan Services, LLC
• Fidelity Investments Life Insurance Company
• Empire Fidelity Investments Life Insurance Company
• Fidelity Health Insurance Services, LLC
• Fidelity Insurance Agency, Inc.
• FIAM LLC
• National Financial Services LLC
• Strategic Advisers LLC
• Other companies owned by Fidelity Investments using the Fidelity name to provide financial or payroll services to customers