PRIVACY POLICY AND NOTICE OF FIRST TRUST PORTFOLIOS L.P. AND FIRST TRUSTADVISORS L.P. (“FIRST TRUST”) FOR CALIFORNIA RESIDENTSFirst Trust values our relationship with you and considers your privacy an important priority in maintainingthat relationship. We are committed to protecting the security and confidentiality of your personal
information.
This Privacy Policy and Notice for California Residents supplements the information contained in First
Trust’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State ofCalifornia (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy
Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the CPRA) and any
terms defined in the CPRA have the same meaning when used in this policy.
Information We CollectFirst Trust collects information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular individual as part of
the gathering of information to provide services to certain First Trust clients, its pre-qualification of job
applicants, ongoing maintenance of necessary employee information and the provision of access tocertain information on our website by financial intermediaries (“personal information”). In particular, First
Trust has collected the following categories of personal information from its employees, job applicantsand financial intermediaries within the last twelve (12) months:
Category

A. Personal
Identifiers.

B. Personal
information
categories listed
in the California
Customer
Records statute(Cal. Civ. Code §1798.80(e)).
C. Protected
personal
classification
characteristics
under California
or federal law.

Collected

YES

YES

YES

D. Personal
Commercial
information.

YES

E. Biometric
information.

NO

First Trust CPRA Privacy Notice revised 4.3.23

Retention Period

Sold or Shared

7 years or as
Sharedrequired byapplicable law,whichever is longer
7 years or as
Sharedrequired byapplicable law,whichever is longer

7 years or as
Sharedrequired byapplicable law,whichever is longer

7 years or as
Sharedrequired byapplicable law,whichever is longer
N/A

N/A

F. PersonalInternet or othersimilar network
activity.

YES

7 years or as
Sharedrequired byapplicable law,whichever is longer

G. Personal
Geolocation
data.

YES

7 years or as
Sharedrequired byapplicable law,whichever is longer

H. Sensory data.

NO

N/A

I. Professional or
personal
employmentrelated
information.
J. Non-public
education
information (perthe Family
Educational
Rights andPrivacy Act (20
U.S.C. Section
1232g, 34 C.F.R.
Part 99)).
K. Inferences
drawn from otherpersonal
information.

YES

N/A

7 years or as
Sharedrequired byapplicable law,whichever is longer

N/A

N/A

N/A

N/A

NO

NO

Personal information does not include:•••

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CPRA’s scope, such as personal information covered by certain
sector-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA).

In addition, the CPRA also requires us to disclose whether we collected certain sensitive personal
information in the last twelve (12) months:

First Trust CPRA Privacy Notice revised 4.3.23

Category
L. personal
Government
identifiers (social
security, driver's
license, state
identification
card, or passportnumber)Collected

YES

M. Complete
personal accountaccesscredentials (usernames, accountnumbers, or card
numberscombined withrequiredaccess/security
code orpassword).

YES

N. Precise
geolocation.

NO

O. Racial or
ethnic origin.

NO

Retention Period

Sold or Shared

For term of
employment plus
any additional
period required bylaw

SharedFor term of
employment plus
any additional
period required bylaw

Shared

N/A

N/A

N/A

N/A

P. Religious orphilosophicalbeliefs.

NO

N/A

N/A

Q. Union
membership.

NO

N/A

N/A

R. Genetic data.

NO

N/A

N/A
SharedYES

7 years or as
required byapplicable law,whichever is longer

T. Uniqueidentifying
biometric
information.

NO

N/A

N/A

U. Health, sexlife, or sexual

NO

N/A

N/A

S. personal mail,email, or text
messages
contents.

First Trust CPRA Privacy Notice revised 4.3.23

orientation
information.

Personal information that we collect without the purpose of inferring characteristics about you is nottreated as sensitive personal information.
First Trust obtains the categories of personal information listed above from the following categories ofsources:
•
•
•
•
•
•

Directly from you—For example, from forms you complete.
Job board websites you may use to apply for a job with us.
Employment agencies and recruiters.
Your educational institutions.
Online activity information that we and our service providers collect using server logs, “cookies”
and similar technologies.
Other First Trust personnel.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following businesspurposes:
•
•
•
•
•
•
•

To fulfill or meet the reason you provided the information.
To provide, support, personalize, and develop our Website, products, and services.
To provide you with support and to respond to your inquiries, including to investigate and address
your concerns and monitor and improve our responses.
To deliver content on First Trust products.
To help maintain the safety, security, and integrity of our Website, products and services,
databases and other technology assets, and business.
To respond to law enforcement requests and as required by applicable law, court order, orgovernmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or othersale or transfer of some or all of First Trust’s assets, whether as a going concern or as part ofbankruptcy, liquidation, or similar proceeding, in which personal information held by First Trust
about our Website users is among the assets transferred.

First Trust will not collect additional categories of personal information or use the personal information wecollected for materially different, unrelated, or incompatible purposes without providing you notice.
Selling and Sharing Personal Information
First Trust may disclose your personal information to a third-party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the purpose andrequires the recipient to both keep that personal information confidential and not use it for any purpose
except performance of the contract.
We send your personal information to the following categories of third-parties:•

Service providers.

First Trust CPRA Privacy Notice revised 4.3.23

Sharing of Personal Information for a Business Purpose
In the preceding twelve (12) months, First Trust has disclosed the following categories of personal
information for a business purpose:
Category A: Personal identifiers.
Category B: Personal information.
Category C: Protected personal classification characteristics under California or federal law.

.

Category D: Personal commercial information.
Category F: Personal internet or other similar network activity.
Category G: Personal geolocation data.
Category I: Professional or personal employment-related information.
Category L: Personal government identifiers (social security driver’s license, state identification card or
passport number.
Category M: Complete personal account access credentials (user names, account numbers, or card
numbers combined with required access/security code or password).
Category S: Personal mail, email or text messages contents.
We disclose your personal information for a business purpose to the following categories of third-parties:•

Service providers.

Sharing of Personal Information for Cross-Context Behavioral Advertising
In the preceding twelve (12) months, First Trust has not shared personal information for the purpose ofcross-context behavioral advertising. To the extent that First Trust ever changed its policy and chose toshare information for cross-context behavioral advertising, you would have the right to opt-out of the
sharing of your personal information for such purpose.
Sales of Personal Information
In the preceding twelve (12) months, First Trust has not sold personal information.
To the extent that First Trust ever changed its policy and chose to sell personal information, you would
have the right to opt-out of the sale of your personal information.
Your Rights and Choices
The CPRA provides California consumers with specific rights regarding their personal information. Thissection describes your CPRA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that First Trust disclose certain information to you about our collection anduse of your personal information over the past 12 months. Once we receive and confirm your verifiableconsumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:•••

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.

First Trust CPRA Privacy Notice revised 4.3.23

•••The categories of third-parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
If we disclosed your personal information for a business purpose, two separate lists disclosing:o Disclosures for a business purpose—identifying the personal information categories thateach category of recipient obtained.

Deletion Request Rights
You have the right to request that First Trust delete any of your personal information that we collectedfrom you and retained, subject to certain exceptions. Once we receive and confirm your verifiableconsumer request (see Exercising Access, Data Portability, Deletion, Correction and Use Limit Rights),
we will delete (and direct our service providers to delete) your personal information from our records,
unless an exception applies. We will also pass deletion requests on to service providers, contractors,
and, unless impossible or involving disproportionate effort, to all third parties to whom the business soldor shared the information, if any.
We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:
•

•
•
•
•
•
•
•

Complete the transaction for which we collected the personal information, provide a good orservice that you requested, take actions reasonably anticipated within the context of our ongoing
business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights,
or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et.
seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based onyour relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context inwhich you provided it.

Right to Correct
You have the right to request that we correct any inaccuracies in the personal information we hold aboutyou. If you make such a request, we are obligated to use commercially reasonable efforts to correct any
identified inaccurate personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information
If we disclose sensitive personal information for reasons other than those set forth in the CPRA, you havethe right to limit the use or disclosure of sensitive personal information by us to only those purposes
specifically permitted by the CPRA. This includes Social Security, driver’s license, state identification
card and passport numbers; account log-in, financial account, debit card, and credit card numbers incombination with credentials allowing access to an account; geolocation; information relating to yourhealth; and biometric information.
Exercising Access, Data Portability, Deletion, Correction and Use Limit Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiableconsumer request to us by either:

First Trust CPRA Privacy Notice revised 4.3.23

Calling us at toll free at 1-800-621-1675
CLICK HERE to Submit an Email
Only you, or a person registered with the California Secretary of State that you authorize to act on yourbehalf, may make a verifiable consumer request related to your personal information
You may only make a verifiable consumer request for access or data portability twice within a 12-month
period. The verifiable consumer request must:••

Provide sufficient information that allows us to reasonably verify you are the person about whom
we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, andrespond to it.

We cannot respond to your request or provide you with personal information if we cannot verify youridentity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If werequire more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer
request’s receipt. The response we provide will also explain the reasons we cannot comply with arequest, if applicable. For data portability requests, we will select a format to provide your personal
information that is readily useable and should allow you to transmit the information from one entity toanother entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why
we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of your CPRA rights. Unlesspermitted by the CPRA, we will not:
•
•
•
•
•

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts orother benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level orquality of goods or services.
Retaliating against an employee, applicant for employment, or independent contractor forexercising their rights under the CPRA.

First Trust CPRA Privacy Notice revised 4.3.23

Other California Privacy Rights
Websites operated by First Trust currently do not respond to “do not track” signals or similar mechanisms.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are
California residents to request certain information regarding our disclosure of personal information tothird-parties for their direct marketing purposes. First Trust does not disclose personal information to thirdparties for direct marketing purposes.
Changes to Our Privacy PolicyFirst Trust reserves the right to amend this privacy policy at our discretion and at any time. When we
make changes to this privacy policy, we will post the updated policy on the Website and update thepolicy’s effective date. Your continued use of our Website following the posting of changes constitutes
your acceptance of such changes.
Contact Information
If you have any questions or comments about this policy, the ways in which First Trust collects and uses
your information described below and in our general Privacy Policy, your choices and rights regarding
such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1-800-621-1675 or 1-800-222-6822
Website: www.ftportfolios.com
CLICK HERE to Submit an EmailPostal Address: 120 E. Liberty Drive, Wheaton Illinois 60187

Effective Date: 4/03/2023

First Trust CPRA Privacy Notice revised 4.3.23