Global Online Privacy Statement

Last updated May 1, 2018

 

PGIM, Inc. and its affiliates comprising Prudential’s global investment management businesses (together, “PGIM,” “we” or “us”) respect your privacy, and we are committed to protecting it. We provide this Privacy Statement to tell you how we may collect, use, share, and retain information about you and your choices.

Websites Covered by This Privacy Statement

This Privacy Statement describes our practices in connection with information that we collect through PGIM.com and other websites operated by us from which you are accessing this Privacy Statement (the “Websites”). 

The Privacy Statement does not apply to those websites or communications that have their own privacy statements or to websites of other companies or entities that are linked to this website. See “Third Party Websites” below. To learn about the privacy policy of a linked site, please refer to the privacy statement for that site.

Personal Information

We may ask you to provide certain Personal Information, which is information that identifies an individual or relates to an identifiable individual, including: name, postal address, telephone number and email address.

We and our service providers collect Personal Information about you in a variety of ways, including: 

  • Through the Websites. For example, you may provide us with your name, address, email address, and telephone number when you request that a PGIM representative contact you, or when you fill out a survey or form, when you sign up for a newsletter. 
  • From Other Sources. We receive your Personal Information from other sources, such as publicly available databases and joint marketing partners when they share the information with us.

We need to collect Personal Information to provide services to you. If you do not provide the information requested, we may not be able to provide the services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Websites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

How We Use Personal Information

We and our service providers use Personal Information for business purposes including: 

  • Providing the functionality of the Websites and fulfilling our customers' requests.
    • To respond to inquiries and fulfill requests from our customers, administer their account(s) and manage our relationships; and
    • To verify an individual’s identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts; or conduct online transactions.

We will engage in these activities to manage our contractual relationship with our customers and/or to comply with a legal obligation.

  • Providing our customers with our newsletter and/or other marketing materials and facilitating social sharing.
    • To inform our customers about products or services which we believe may be of interest, including tailored ads or offers. 

We will engage in this activity because we have a legitimate interest or with your consent. 

  • Accomplishing our business purposes. 
    • For business purposes, including data analysis, audits, developing and improving products and services, identifying usage trends and determining the effectiveness of promotional campaigns, and enhancing, improving or modifying our services or Websites;
    • To contact individuals in connection with existing transactions and contractual agreements;
    • For risk management, for fraud detection and prevention, including "know your customer", anti-money laundering, due diligence requirements, credit checks, compliance with sanction rules, fraud monitoring, and tax reporting;
    • To comply with laws and regulations (including any legal or regulatory guidance, codes or opinions), and to comply with other legal process and law enforcement requirements;
    • To protect the security of accounts and Personal Information; and
    • To send administrative information to you, such as changes to our terms, conditions and policies.

We engage in these activities to manage our contractual relationship with our customers, to comply with a legal obligation, and/or because we have a legitimate interest.

How We Disclose Personal Information

We disclose Personal Information to:

  • The appropriate PGIM organization or affiliate so it can respond to your request
  • Third parties as permitted or required by law, for example:
    • Regulators
    • Vendors that provide service to us
    • Law enforcement authorities

How We Protect Your Information

We disclose Personal Information:

  • A listing of our affiliates can be provided by your client services representative. 
  • To our third-party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. 

Other Uses and Disclosures of Personal Information

We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • This can include laws outside your country of residence. 
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information we believe is important
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons. 
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 
  • In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

Other Information

We also collect Other Information about users of the Websites, which is any information that does not reveal a person’s specific identity or does not directly relate to an identifiable individual.  

The kind of information we collect includes:

  • The number of visitors to our site
  • The pages visited on our site
  • The features used
  • How long a visitor stays
  • The domain name of the site from which visitors connect to our site
  • Browser and device information
  • Information collected through cookies, pixel tags, and other technologies
  • Information that has been aggregated in a manner such that it no longer reveals your identity

We and our service providers may collect Other Information in a variety of ways, including: through a browser or device; using cookies and other similar technologies, and through IP addresses. Please see our Cookies Policy here for more information. 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Statement. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

How We Protect Your Information

PGIM seeks to use reasonable administrative, technical, and physical safeguards and other security measures necessary to protect Personal Information within our organization from the growing threats.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.  

PGIM Privacy Protection Policy

PGIM collects Social Security numbers in the course of its business activities. PGIM has a privacy policy that protects personal information, including Social Security numbers. This policy is as follows:

PGIM requires that all personal information about its customers and employees, and employees of our vendors and business partners, must be kept secure and confidential. Access to personal information must be limited to employees who need the information or access to it to perform their job responsibilities. Employees may not access or disclose personal information for any purpose except as authorized for PGIM’s business purposes.

Sensitive Information

Unless specifically requested, we ask that you not send us, and you not disclose, any other sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Websites.

Accessing, Changing or Deleting Personal Information

If you would like to request to review, correct, update, suppress, restrict or delete, or object to the processing of Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by sending an e-mail to pgim.privacy@pgim.com or write to us at the following address: 655 Broad Street, Newark, NJ, 07102 Mail Stop: 08-19-70. We will respond to your request consistent with applicable law.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include: 

  • The length of time we have an ongoing relationship with our customer and provide the Websites 
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of certain transactions for a certain period of time before we can delete them); or 
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

Third-Party Websites

This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Websites link. The inclusion of a link on the Websites does not imply endorsement of the linked site or service by us or by our affiliates.  

Cross-Border Transfer

Personal information may be stored and processed in any country where PGIM has facilities or in which we engage service providers, and if you provide Personal Information to us you understand that the information will be transferred to countries outside your country of residence, including the United States, which may have different data protection rules than those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access the Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect Personal Information. You may obtain a copy of these measures by contacting https://ec.europa.eu/info/about-european-commission/contact_en or by following this link: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en

Children’s Online Privacy

This website is not directed toward individuals under the age of eighteen (18) and we do not knowingly collect or post Personal Information from children under the age of 16. 

Effective Date

This privacy statement is effective as of the “LAST UPDATED” legend above. We reserve the right to change this statement. If we change it, we will post the current privacy statement on this page. Any changes to this statement will be effective as of the day they are posted. Use of the Websites following these changes signifies acceptance of the revised Privacy Statement. 

Contact Us

PGIM Inc. located at the address below is the company responsible for the collection, use, and disclosure of your Personal Information under this Privacy Statement. 

If you have any questions about this Privacy Policy, please email us at pgim.privacy@pgim.com with your questions or comments or write to us at the following address: 655 Broad Street, Newark, NJ, 07102 Mail Stop: 08-19-70. We will respond to your request in accordance with applicable law.

 

Cookies & Similar Technologies Statement

This Cookies & Similar Technologies Statement (“CST Statement”) describes the different types of cookies and similar technologies that are used on www.pgim.com (the “Website”). We may change this CST Statement at any time. Any changes in this CST Statement will become effective when we make the revised CST Statement available on or through the Website.

What Are Cookies and Similar Technologies? 

Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to the Website. Cookies help us learn which areas of the Website are useful and which areas need improvement. For this purpose, we may also use technologies similar to cookies, such as Flash Local Shared Objects (also known as Flash cookies) or pixel tags.

You can choose whether to accept the use of cookies and similar technologies in general by changing the settings on your browser. However, if you disable cookies and similar technologies, your experience on the Website may be diminished and some features may not work as intended.

What Cookies and Similar Technologies Do We Use?

Below we list the different types of cookies and similar technologies that are used on the Website. To the extent any personal information is collected through cookies, our Privacy Statement applies and complements this CST Statement. A session cookie is used to identify a particular visit to the Website. These cookies expire after a short time, or when you close your web browser after using the Website. A persistent cookie will remain on your devices for a set period of time specified in the cookie. We use these cookies where we need to identify you over a longer period of time.

Essential Cookies. Essential cookies enable you to navigate the Website and to use its services and features. Without these absolutely necessary cookies, the Website will not perform as smoothly for you as we would like it to and we may not be able to provide the Website or certain services or features. 

Cookie Name Description Persistent or Session 1st or 3rd Party
territory Contains country value populated via Google API if a user's browser allows location detection Persistent 1st Party
territoryCookie Contains Pru/PLC value to serve content based on county selected Persistent 1st Party
AWSALB Amazon load balancer cookie Persistent 1st Party
JSESSIONID Generated by Portal Server and its default behavior of Portal Server Session 1st Party
PGIM_AWS Required until cloud migration to AWS is stabilized Session 1st Party
investorTypePGIM Used to store Global Attestation Investor type Persistent 1st Party
attestedRegionPGIM Used to store Global Attestation Region Persistent 1st Party
cookie-disclaimer Used to store information that the user has seen the cookie disclaimer Persistent 1st Party
fp-cookie Used to store that the user has attested as an FA/FP Persistent 1st Party
fa-cookie Used to store that the user is an Analyst Persistent 1st Party
analyticsAuth Stores whether the user has logged in to a prudential site Persistent 1st Party
01AI Content delivery network Session 3rd Party (Akamai)
NID Used to store browser preferences for Google Chrome Persistent 3rd Party (Google)

Preference Cookies. Preference cookies collect information about your choices and preferences, and allow us to remember language or other local settings and customize the Website accordingly.

Cookie Name Description Persistent or Session 1st or 3rd Party
_ceg.s Visitor heatmapping tool Persistent 1st Party
__ceg.u Visitor heatmapping tool Persistent 1st Party
_gat Backup web analytics tool Persistent 1st Party
mmapi.p.pd Customer profile information: anonymous visitor id, historical visitor profile (generated experiences and tracked actions) Persistent 1st Party
mmapi.p.srv Maxymiser Content Generator service node name Persistent 1st Party
uuid Used to track unique user sessions  Persistent 1st Party
ELOQUA Tracks user behavior for marketing automation Persistent 3rd Party (Eloqua)
ELQSTATUS Tracks user behavior for marketing automation Persistent 3rd Party (Eloqua)

Social Media Cookies. Social media cookies collect information about social media usage. The Website has no Social Media cookies.

Analytics Cookies. Analytics cookies collect information about your use of the Website and enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages on the Website, help us record any difficulties you have with the Website, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Website, rather than the usage of a single person. We use the information to analyze Website traffic, but we do not examine this information for individually identifying information.

Cookie Name Description Persistent or Session 1st or 3rd Party
gpv_pn Used to determine the previous page in the visit Persistent 1st Party
s_cc Used to determine if cookies are enabled Session 1st Party
s_dfa Allows integration between Adobe Analytics and DoubleClick For Advertisers Persistent 1st Party
s_getNewRepeat Used to determine if new or repeat visitor to the site Persistent 1st Party
s_ppv Used to determine how far the user scrolled on previous page Session 1st Party
s_ppvl

Used to identify the previous page in the visit

Session 1st Party
s_sq Used to generate dynamic heatmaps as page overlays Session 1st Party
AMCV_A3F5 A8DC5886052D0A 495CC3%40AdobeOrg Used to analyze visitors across domains Persistent 1st Party
AMCVS_A3F 5A8DC5886052D0A 495CC3%40AdobeOrg Used to analyze visitors across domains Session 1st Party
AMCV_A3F 5A8DC5886052D0A 495CC3%40AdobeOrg Used to analyze visitors across domains Persistent 1st Party
_gat_pruISTracker Backup web analytics tool Persistent 1st Party
_gid Backup web analytics tool Persistent 1st Party
_ga Backup web analytics tool Persistent 1st Party

Advertising Cookies. Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the Website or to manage our advertising. These cookies collect information about your activities on the Website and other sites to provide you with targeted advertising.

Cookie Name Description Persistent or Session 1st or 3rd Party
AID Tracks user behavior for targeted advertising Persistent 3rd Party (Google)
AID Tracks user behavior for targeted advertising Persistent 3rd Party (Google)
BizoCustomSegments Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
BizoData Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
BizoID Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
BizoUserMatchHistory Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
HRL8 Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
IDE Tracks user behavior for targeted advertising Persistent 3rd Party (Google)
UserMatchHistory Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
VID Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
_ga Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
_guid Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
_lipt Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
bcookie Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
demdex Used to analyze visitors across domains Persistent 3rd Party (Adobe)
dpm Used to analyze visitors across domains Persistent 3rd Party (Adobe)
ev_sync_dd Used to analyze visitors across domains Persistent 3rd Party (Adobe)
everest_g_v2 Used to analyze visitors across domains Persistent 3rd Party (Adobe)
lang Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
liap Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
lidc Tracks user behavior for targeted advertising Persistent 3rd Party (LinkedIn)
mt_misc Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
mt_mop Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
uuid Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
uuidc Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
bkdc Tracks user behavior for targeted advertising Persistent 3rd Party (BlueKai)
bku Tracks user behavior for targeted advertising Persistent 3rd Party (BlueKai)
EE Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
HRL8 Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
IDE Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
RCID2 Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
SEUNCY Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
bkdc Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
bku Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
bs_mop_u3s Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
c Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-bs Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-co Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-g Tracks user behavior for targeted advertising Session 3rd Party (MediaMath)
data-mm Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-o Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-p Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-r Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-r1 Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-rk Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-sov Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
data-xu Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
gtm_usr Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
mt_misc Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
mt_mop Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
tuuid Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
tuuid_lu Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
ud Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
uid Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
uuidc Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)
visitor-id Tracks user behavior for targeted advertising Persistent 3rd Party (MediaMath)

Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Adobe Analytics. We use Adobe Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Adobe’s practices by going to:  https://marketing.adobe.com/resources/help/en_US/sc/implement/opt_out.html and opt out of them by downloading the Adobe Analytics opt-out browser add-on, available at https://www.adobe.com/privacy/opt-out.html 

Pixel tags. Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of the Website, measure the success of our marketing campaigns, and compile statistics about usage of the Website and response rates.

Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Website you are using. We use this information to ensure that the Website functions properly.

Physical Location. We collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. We use your device’s physical location to provide you with personalized location-based services and content. We also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you can allow or deny such uses and sharing of your device’s location, but if you do, we and our marketing partners may not be able to provide you with the applicable personalized services and content. 

Device Fingerprinting. In order to be able to offer you content that we believe may interest you based on your activity on the Website, and for fraud prevention and authentication purposes, we may also use other technologies that are similar to cookies. For example, we may gather device attributes and combine information collected by most browsers or automatically through your device to create a unique ID that identifies your browser or device to us with reasonable certainty. In this context we may collect, use, and combine the following information:

  • Number of visits
  • Last visit
  • First visit
  • External IP address
  • Internal IP address
  • Screen resolution
  • Geolocation (latitude/longitude based on IP address)
  • Device performance benchmark
  • Device bandwidth benchmark
  • Device user-agent (browser type, version)
  • Device capabilities (Modernizer string for browser capabilities)
  • Device operating system
  • Device plugins installed
  • Browser language
  • Flash enabled or disabled
  • Device time on file
  • Keywords used if coming from search engine
  • Pages visited
  • Length of visit
  • Referral page
  • Mouse cursor position
  • Mouse clicks
  • Page scroll position

How Do I Manage Cookies and Similar Technologies? 

You can refuse or accept cookies from the Website at any time by activating the settings on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, not all features of the Website may operate as intended. 

If you want to clear all cookies left behind by the websites you have visited, here are links where you can download three programs that clean out tracking cookies:

Affiliate Website Privacy and Cookie Information

For the privacy and cookie information of our affiliate websites, please visit: