PRIVACY STATEMENT

Last Updated: November 2023.

INTRODUCTION

This Website is operated by PGIM Ireland (“PGIM Ireland”, “we”, “us” or “our”). Please use the contact information provided at the end of this statement if you have any complaints or queries regarding this Privacy Statement and your Personal Data we may hold. We want you to be familiar with how we collect, use, and disclose information. This Privacy Statement describes our practices in connection with information that we collect through https://www3.prudential.com/pgim/secured/pramerica-ie (the “Website”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through our social media pages and apps located at (collectively, our “Social Media Pages”) through HTML-formatted email messages that we send to you that link to this Privacy Statement (collectively, including the Website, the Apps and our Social Media Pages, the “Services”) as well as the and the other ways we collect Personal Data as set forth below the section entitled Collection of Personal Data below.

This Privacy Statement does not apply to other websites, platforms, or activities that have their own privacy statements. Please refer to our online Privacy Center for more information about these other notices and the types of activities they cover.

This Privacy Statement also does not apply to websites of other companies or entities that are linked to the Services. See “Third-Party Websites” below for more information. To learn about the privacy policy of a linked site, please refer to the privacy statement for that site.

PERSONAL INFORMATION

“Personal Data” is information that identifies you as an individual or relates to an identifiable individual.

• Online identifiers provided by devices, Internet Protocol addresses, cookie identifiers – see cookies policy for more information

Please note that a separate Privacy Statement is used and will be presented to you when you submit an application for an available or speculative role at our Company.

COLLECTION OF PERSONAL INFORMATION

We and our service providers collect Personal Data in a variety of ways, including:

• Through the Services
  • We collect Personal Data through the Services, for example, when you sign up for a newsletter or register an account to access the Services.
• Offline
  • We collect Personal Data from you offline, e.g., when you visit us, attend one of our events or attend a careers fair
• From Other Sources
  • We receive your Personal Data from other sources, for example:
    • public databases that are available to everybody; and
    • joint marketing partners, when they are allowed to share the information with us;

We need to collect Personal Data in order to provide the requested 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 Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

USE OF PERSONAL INFORMATION

We and our service providers use Personal Data for legitimate business purposes, including:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services’ functionality to you
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request more information about our Company and/or Services.
  • To respond to job applications submitted by you for available or speculative roles advertised by our company or behalf of our company. A separate Privacy policy statement is provided to you during the application process should you apply for a role.
  • To send administrative information to you, such as changes to our terms, conditions and policies.
  • To facilitate social sharing functionality that you choose to use.
  • To allow you to send messages to another person if you choose to do so.

We will do so to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing personalized services.
  • To better understand you, so that we can personalize our interactions with you and provide you with information and/or invitations tailored to your interests.
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services.
  • To better understand your preferences so that we can deliver you the content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

• Aggregating and/or anonymizing Personal Data.
  • We may aggregate and anonymize Personal Data.
  • Any data anonymized will no longer be considered Personal Data and we may use it for any purpose.
• Accomplishing our business purposes.
  • For data analysis, for example, to improve the efficiency of our Services;
  • For audits to verify that our internal processes function as intended, and are compliant with legal, regulatory or contractual requirements;
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks, attempts to commit identity theft;
  • For developing new products and services;
  • For enhancing, improving, or modifying our current products and services;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • Determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • Operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies to meet our users’ interests;

We use this information to manage our contractual relationship with you, comply with a legal obligation, and/or because we have a legitimate interest.

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Data:

• To our affiliates for the purposes described in this Privacy Statement.
  • For a list of affiliates, please contact us at pgim.privacy@pgim.com. We share information with our affiliates either to fulfill our contractual obligation with you and/or because we have a legitimate interest to do so.
• To our third-party service providers who provide services.
  • This 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.
• By using this service, you may elect to disclose Personal Data.
  • On message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

OTHER USES AND DISCLOSURES

We also use and disclose your Personal Data if it would be 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 respond to requests from public and government authorities.
  • To respond to a request or to provide information we believe is necessary or appropriate
  • This can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • For example, when we receive law enforcement requests and orders or when we voluntarily share information.
• For other legal reasons.
  • To enforce our terms and conditions;
  • 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.
  • In addition, we have legitimate interest to disclose or transfer your 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).

OTHER DATA

“Other Data” is any data that does not reveal a person’s specific identity or does not directly relate to an identifiable individual. The Services collect Other Data such as:

• 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 that has been aggregated in a manner such that it no longer reveals your identity

We and our service providers may collect Other Data in a variety of ways, including Adobe Analytics, pixel tags, a browser or device; physical location; device fingerprinting; using cookies and other similar technologies; and through IP addresses. Please see our Cookie StatementCookies & Similar Technology Statement 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 Data as Personal Data under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Data as detailed in this Statement. In some instances, we may combine Other Data with Personal Data. If we do, we will treat the combined information as Personal Data if it is combined.

SECURITY OF YOUR PERSONAL DATA

We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

MARKETING COMMUNICATIONS

PGIM Ireland gives you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking on the unsubscribe link at the bottom of one of our marketing emails or by contacting us at: pgim.privacy@pgim.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

ACCESS, CHANGE, OR DELETE YOUR PERSONAL DATA

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Data, object to or opt out of the processing of Personal Data, or if you would like to request to receive a copy of your Personal Data for purposes of transmitting it to another company (in each case, to the extent these rights are 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:

PGIM Ireland Limited
IDA Business Park
c/o Michael Klaessy,
Letterkenny
Co Donegal
F92 FP83

We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Data you would like to have changed or whether you would like to have your Personal Data suppressed from our database. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping or other purposes.

RETENTION PERIOD

We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your 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 SERVICES

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 Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the Apps or our Social Media Pages

CHILDREN’S ONLINE PRIVACY

The Website is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from children under the age of 16.

CROSS-BORDER TRANSFER

p>Personal Information may be transferred to other countries (including countries other than where you are based that have a different data protection regime than is found in the country where you are based). In such circumstances, we will take appropriate steps to provide an adequate level of data protection within the meaning of applicable data protection law, including by implementing the EU Standard Contractual Clauses, the UK Addendum to the EU Standard Contractual Clauses, or any other appropriate safeguard based on jurisdiction where required. You can request a copy of the appropriate safeguards referenced in this section by contacting us.

A list of the affiliate companies that may jointly process your personal information is available in our securities disclosures including 10-K available here:

https://www.investor.prudential.com/financials/sec-filings/sec-filings-details/default.aspx?FilingId=15581928
and/or upon request (please refer to the Contacting Us section of this Notice).

ADDITIONAL INFORMATION REGARDING THE EAA

Some 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 your Personal Data. You may obtain a copy of these measures where applicable by contacting us at pgim.privacy@pgim.com.

SENSITIVE INFORMATION

Unless specifically requested, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., information related to any racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural’s persons sex life or sexual orientation) on or through the Services or otherwise to us.

EFFECTIVE DATE

The “Last Updated” legend at the top of this Privacy Statement indicates when this Privacy Statement was last revised. 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 become effective as of the day they are posted. Your use of the Services following these changes signifies acceptance of the revised Privacy Statement.

CONTACTING US

PGIM Ireland, a company incorporated and registered in Ireland with company registration number 319900 with its registered office at 6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland, is the company responsible for collection, use and disclosure of your Personal Data under this Privacy Statement.

If you have any questions or concerns about this Privacy Statement, please contact us using the following information:

Email: pgim.privacy@pgim.com
Mailing Address:
PGIM Ireland Limited
c/o Michael Klaessy,
IDA Business Park
Letterkenny
Co Donegal
F92 FP83

Because email communications are not always secure, please do not include other sensitive information in your emails to us. Thank you.

If you are located in the EEA, you have the right at all times to lodge a complaint with a Data Protection Authority for your country or region or in the place of the alleged misconduct.