Online Privacy Statement

LAST UPDATED: MARCH 2020

Prudential (“we” or “us”) respects your privacy, and we are committed to protecting it. This Online Privacy Statement explains how we may collect, use, share and retain information about you and your choices.

This Online Privacy Statement describes our practices in connection with information we collect when you:

• Visit our websites (“Websites”)
• Receive or reply to email or other electronic communications from us
• View or click on our ads or other Prudential online content
• Interact with us on social media or websites and applications maintained by other parties
• Use our software applications (“Apps”) on or through computers and mobile devices

collectively referred to as “Online Services”. This Online Privacy Statement also covers when you indicate your choices in connection with the above.

Our Online Services are controlled and operated by Prudential from the United States and are intended for use by residents of the United States. They are not intended to subject Prudential to the laws or jurisdictions of any state, country or territory other than that of the United States. If you are using these Online Services from outside the United States, they may not necessarily be consistent with the laws and regulations of your home country.

Other websites and services of Prudential and its affiliates may contain different privacy statements, which supplement this Online Privacy Statement. You are advised to review the privacy statement of each Prudential Online Service.

How We Collect Information

Depending on your relationship with us, we may ask you to provide certain personal information about you and your dependents/beneficiaries in order to adequately provide services. For example, you may provide us with general identification and account information such as your name, telephone number, policy or account number, mailing address, email address, or date of birth when you:

• Apply for or obtain a Prudential product or service;
• Request that a Prudential representative contact you;
• Instruct us to perform a transaction;
• Fill out an online survey or form or participate in a promotion;
• Ask to receive information about our products or services;
• Register for online access to access your account; and/or
• Download, link to or use our mobile apps or those maintained by a third party

You may also provide us with your financial information and goals when you use certain services, features, and tools on our Online Services.

Unless specifically requested, we ask that you not send us, and you not disclose, any additional 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) through the use of the Online 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 Online Privacy Statement.

Additional Sources

We may also collect your personal information from other sources, such as publicly available databases, providers of demographic information, and social media platforms.

We also collect information through emails. From time to time, we may send you emails about our products and services. Prudential and third parties with which we contract may collect information regarding your interaction with these emails, including whether you opened the email, how long you viewed the email, and whether you opened any links in the email.

In addition, we collect “Other Information” about visitors to our Websites. Other Information we may 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 may also collect Other Information when you download and use an App. We may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

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.

Children

Our Online Services are not directed at nor intended for children under the age of 13. We also do not knowingly collect personal information from children under the age of 13. You can learn about children's privacy and the Children's Online Privacy Protection Act (COPPA) at the Federal Trade Commission's website at http://www.ftc.gov Opens in a new window.

Social Security Numbers

Prudential collects Social Security numbers in the course of its business activities. Prudential has a privacy policy that is designed to protect personal information, including Social Security numbers. This policy requires that Prudential have measures in place to keep all personal information about its customers and employees, and employees of our vendors and business partners, secure and confidential.

Retention Period

Prudential retains 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.

How We Use Information

We use personal information collected online for business purposes, to:

• Process applications and transactions;
• Verify your identity (such as when you access your account information);
• Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks
• Respond to your requests and communicating with you;
• Manage your preferences;
• Perform analytics concerning your use of our Online Services, including your responses to our emails and the pages and advertisements you view;
• To allow you to participate in contests, prize draws, or other similar promotions and to administer those activities;
• To resolve complaints and handle requests for data access, deletion, or correction;
• Provide you tailored content and marketing messages;
• Operate, evaluate and improve our business (including developing new products and services; improving existing products, services and Websites; performing data analytics; and performing accounting, auditing and other internal functions);
• Comply with and enforce applicable legal and regulatory requirements, legal process, contractual obligations and our policies;
• To establish and defend legal rights, protect our operations and pursue available remedies or limit our damages;
• Provide you with online financial tools
• Manage infrastructure and other business operations
• For any other purposes that we may specifically disclose at the time we collect your information.

How We Share Information

We may make personal information collected online available to:

• Prudential affiliates;
• A Prudential agent or an independent financial professional to provide you with a policy quotation or other information regarding insurance and financial service products;
• External service providers/vendors;
• Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Prudential businesses;
• Governmental or other public authorities, including law enforcement as permitted or required by law (e.g., regulators, law enforcement);
• Credit bureaus; and
• For participants of retirement or group insurance plans and/or policies, upon the request of your employer or plan sponsor, we may disclose information regarding your use of our Websites to your employer or plan sponsor or a subcontractor working for your employer or plan sponsor.

We will limit sharing of your information where appropriate and where legally required.

Transfer of Personal Information

For the purposes set out above we may transfer personal information to third parties located in other countries. For example, we may transfer Personal Information internationally to our group companies, service providers, business partners, and governmental or public authorities. By providing personal information and other information to us through the Online Services, you understand that Personal Information may be transferred from the United States to other countries unless otherwise restricted.

Understanding Cookies and Similar Technologies

We and our service providers may collect Other Information in a variety of other ways, including through a browser or device; using cookies, pixel tags or other similar technologies; and through IP addresses.

Cookies and Pixel Tags

Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your use of our Websites. A cookie is a small piece of information that a website can send to your browser and may then be stored on your computer's hard drive. It acts as an anonymous tag that identifies your computer, but not you personally. Cookies have the ability to store information about web pages viewed and the advertisements viewed or clicked. For registered customers, cookies can also save user information and screen preferences.

A pixel tag, also known as a clear GIF or web beacon, is an invisible tag placed on certain pages of our Websites but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.

Prudential uses cookies and pixel tags to provide better customer service, and to analyze how visitors use and navigate our Websites and identify areas which may need improvement. Cookies also help us enhance navigation and the functionality of our Websites, to securely maintain a session for existing clients accessing password-protected areas, and to personalize aspects of a visitor's experience.

We collect information from cookies and pixel tags to evaluate responses to surveys and our advertisements on other websites and to provide you with specific or relevant content such as articles and educational material when you visit our Websites. Some of our Websites use cookies to better serve you when you return to the website. For example, a cookie may remember your user ID to simplify your login to a password-protected page. Prudential may also use cookies, pixel tags, or other technologies to track your use of certain partner websites.

Analytics

We use Adobe Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Online 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 more about Adobe’s practices visiting their website at https://cross-device-privacy.adobe.com Opens in a new window.

Our websites may also use Google Analytics. Google Analytics uses cookies to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. You can learn about Google’s practices by visiting their website at https://support.google.com/analytics/answer/6004245 Opens in a new window.

Online Advertising

Prudential arranges for advertisements with links to Prudential Websites to be placed on third-party websites and web pages and may contract with other companies that use cookies, pixel tags, and other online technologies to collect information regarding your interaction with Prudential advertisements and your use of both Prudential and third-party websites. These other companies may also collect information about your online activities over time and across different websites. This information may be used to show you Prudential advertisements that may be of interest to you when you visit other websites.

For further information about this practice and to learn about your choices in connection with it, please visit. http://www.networkadvertising.org/managing/opt_out.asp Opens in a new window and http://www.aboutads.info/ Opens in a new windowor the Ad Choices link at the bottom of our Websites.

Each browser version works in a slightly different way, but you generally have the ability to accept all cookies, be notified before accepting a cookie, block or restrict cookies from certain sites, or reject all cookies. Because many websites use cookies to allow visitors to navigate easily, you may find that some websites or pages do not work well if you reject the cookies associated with them. At this time, Prudential does not respond to browser ‘do not track’ signals.

Linking to Third-Party Websites

This Online Privacy Statement does not apply to and does not address those websites or communications of third parties that have their own privacy statements or to websites of other companies or third parties that are linked to our Websites. We are not responsible for the privacy, information or 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. To learn about the privacy policy of another website, please refer to the privacy statement for that website.

Security

Prudential seeks to use reasonable administrative, technical and physical safeguards and other security measures to protect personal information within our organization. Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us through the use of the Online Services. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at Global.Privacy@prudential.com or 1-800-PRU-HELP (778-4357).

Updating Your Information

To access online information about your Prudential account, you may register for access through https://www.prudential.com/clientenroll. We may collect information that you voluntarily provide on this site. If you would prefer to provide us with this information offline, you may call the following for service:

• 1-800-PRU-HELP (778-4357)
• The telephone number associated with the particular online form or
• Your Prudential representative

Changes to this Online Privacy Statement

We may amend this Online Privacy Statement at any time. When we do, we will let you know by appropriate means such as by posting the revised statement on this page with a new “Last Updated” date. Changes to this Online Privacy Statement will become effective when posted unless indicated otherwise.

Contact Us

If you have any questions after reviewing this statement, please contact us at Global.Privacy@prudential.com or 1-800-PRU-HELP (778-4357).