Common use of Information Security and Other Matters Clause in Contracts

Information Security and Other Matters. (a) BNY Mellon will implement and maintain an information security program with written policies and procedures reasonably designed to protect the confidentiality and integrity of the Customer’s Confidential Information provided to BNY Mellon in accordance with this Agreement and when in BNY Mellon’s possession or under BNY Mellon’s control. The information security program will contain administrative, technical and physical safeguards, appropriate to the type of information concerned, reasonably designed to: (i) maintain the security and confidentiality of such information; (ii) protect against any reasonably foreseeable threats or hazards to the security or integrity of such information; (iii) reasonably protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to the Customer or its Series; and (iv) provide for the secure disposal of such information. BNY Mellon will monitor and review its information security program and revise it, as necessary and in its sole discretion, to address as it deems necessary any reasonably foreseeable and applicable legal and regulatory requirements. BNY Mellon shall periodically test and audit its information security program. (b) BNY Mellon shall: (i) promptly notify the Customer in the event of a declared Security Incident; (ii) provide updates to the Customer regarding BNY Mellon’s response to the extent any such updates may be available and not privileged information or otherwise part of an investigation; (iii) use reasonable efforts to resolve the Security Incident, mitigate any harm resulting from the Security Incident and implement measures designed to prevent a recurrence of Security Incidents of a similar nature. “Security Incident”, as used herein, shall mean any known loss or unauthorized access of Customer’s Confidential Information that in BNY Mellon’s reasonable determination is sufficiently serious enough to notify to Client.

Information Security and Other Matters. (a) BNY Mellon will implement and maintain an information security program with written policies and procedures reasonably designed to protect the confidentiality and integrity of the Customer’s Confidential Information provided to BNY Mellon in accordance with this Agreement and when in BNY Mellon’s possession or under BNY Mellon’s control. The information security program will contain administrative, technical and physical safeguards, appropriate to the type of information concerned, reasonably designed to: (i) maintain the security and confidentiality of such information; (ii) protect against any reasonably foreseeable threats or hazards to the security or integrity of such information; (iii) reasonably protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to the Customer or its Series; and (iv) provide for the ensure secure disposal of such information. BNY Mellon will monitor and review its information security program and revise it, as necessary and in its sole discretion, to address as it deems necessary any reasonably foreseeable and applicable legal and regulatory requirements. BNY Mellon shall periodically test and audit its information security program. (b) BNY Mellon shall: (i) promptly notify the Customer in the event of a declared Security Incident; (ii) provide updates to the Customer regarding BNY Mellon’s response to the extent any such updates may be available and not privileged information or otherwise part of an investigation; (iii) use reasonable efforts to resolve the Security Incident, mitigate any harm resulting from the Security Incident and implement measures designed to prevent a recurrence of Security Incidents of a similar nature. “Security Incident”, as used herein, shall mean any known loss or unauthorized access of Customer’s Confidential Information that in BNY Mellon’s reasonable determination is sufficiently serious enough to notify to Client.

Information Security and Other Matters. (a) BNY Mellon will implement and maintain an information security program with written policies and procedures reasonably designed to protect the confidentiality and integrity of the Customer’s Confidential Information provided to BNY Mellon in accordance with this Agreement and when in BNY Mellon’s possession or under BNY Mellon’s control. The information security program will contain administrative, technical and physical safeguards, appropriate to the type of information concerned, reasonably designed to: (i) maintain the security integrity, confidentiality and confidentiality availability of such information; (ii) protect against any reasonably foreseeable threats or hazards to the security or integrity of such information; (iii) reasonably protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to the Customer or its SeriesCustomer; and (iv) provide for the secure disposal of such information. BNY Mellon will monitor and review may revise its information security program and revise it, as necessary and in its sole discretion, discretion at any time to address as it deems necessary any reasonably foreseeable and applicable legal and regulatory requirementstechnological changes or changes in the threat landscape. BNY Mellon shall periodically test and audit its information security program. (b) BNY Mellon shall: (i) promptly notify the Customer in the event of a declared Security Incident; (ii) provide updates to the Customer regarding BNY Mellon’s response to the extent any such updates may be available and not privileged information or otherwise part of an investigation; and, (iii) use reasonable efforts to resolve the Security Incident, mitigate any harm resulting from the Security Incident and implement measures designed to prevent a recurrence reoccurrence of Security Incidents of a similar nature. “Security Incident”, as used herein, shall mean any known loss or unauthorized access of Customer’s Confidential Information that in BNY Mellon’s reasonable determination is sufficiently serious enough to notify to Client.