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 3. Privacy Policy
    


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.



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.

*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.

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.

*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.

External Officers and Other Corporate Authorized Persons

          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

 * Personal Identification

 * Professional Experience and Affiliations

 * Screening Information

 * From you directly
 * From your employer
 * From service providers, such as identity verification services or financial
   screenings

 * To evaluate suitability for the role and assess risk
 * For facilitating your duties as an external fund officer or other corporate
   authorized person
 * To make payments
 * To include your identity in required publications such as Fund or Corporate
   documents
 * For every-day business purposes noted above

 * Contact Information
 * Employment Information
 * Financial Information
 * Personal Identification
 * Professional Experience and Affiliations

In addition to the disclosures described in Recipients of Your Personal
Information we may also:

 * Share personal information such as name, employment information, etc. with
   government or regulatory agencies when legally required
 * We may publish the name, employer, employment history, year of birth,
   address, and payments received in Fund documents as legally required

Personal information, including sensitive personal information, of external
officers and other corporate authorized persons 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 external officers and other corporate authorized persons.

*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.

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

 * 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.

*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.

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.

*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.

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.

*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.

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.

*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.

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.

*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.

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.

Change Your Cookie Settings

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.

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 DataProtectionOfficer@franklintempleton.com.

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.

Franklin Distributors, LLC. Member FINRA/SIPC. Prior to July 7, 2021, Franklin
Templeton Distributors, Inc., and Legg Mason Investor Services, LLC served as
mutual fund distributors for Franklin Templeton.




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and similar information stored on your browser, advertising identifiers on your
mobile device, and/or the IP address of your device when you visit our site or
use our apps. We and our partners use that information to collect information
for analytics, personalize your browsing experience, and deliver online
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Such sharing may be considered a “Sale” under some state privacy laws. These
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