PRIVACY

Last Updated: May 25, 2018

Global Online Privacy Statement

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, 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, for example, publicly available databases
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 customer’s 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.

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 our affiliates for the purposes described in this Privacy Statement.
    A listing of our affiliates can be provided by email at pgimrealestate.privacy@pgim.com
  • 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, payment processing, order fulfillment, 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 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
  • Demographic information and other information provided by you that does not reveal a specific person’s identity.
  • 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, 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 email at pgimrealestate.privacy@pgim.com, or write to us at the following address: 7 Giralda Farms, Madison NJ 07490.

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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en]. 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 pgimrealestate.privacy@pgim.com.

Children’s Online Privacy

This website is not directed toward individuals under the age of thirteen (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 Real Estate, located at 7 Giralda Farms, Madison NJ 07490 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 contact us at by email at pgimrealestate.privacy@pgim.com, or write to us at the following address: 7 Giralda Farms, Madison NJ 07490

Additional Information Regarding the EEA You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.