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Online Privacy Statement

LAST UPDATED: May 2, 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 or 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.You can request a listing of our affiliates by contacting us at PPCMarketing@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    
- 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 at pricoa.privacy@pricoa.com. 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.

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 PPCMarketing@pgim.com or by following this link.

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
Pricoa Private Capital, located at 180 N. Stetson Avenue, Suite 5600, Chicago, IL  60601 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: PPCMarketing@pgim.com or Pricoa Private Capital, 180 N. Stetson Avenue, Suite 5200, Chicago, IL 60601.

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.

Cookies & Similar Technologies Statment

This Cookies & Similar Technologies Statement (“CST Statement”) describes the different types of cookies and similar technologies that are used on https://www.pricoaprivatecapital.com (the “Website”) of Pricoa Private Capital. 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.

If you have any questions, please contact us by email at PPCMarketing@pgim.com or write to us at the following address: Pricoa Private Capital 180 N. Stetson Avenue, Suite 5600, Chicago, IL  60601

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
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 and features

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 for you.

Social Media Cookies
Social media cookies collect information about social media usage

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 or 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 analyzes website traffic, but we do not examine this information in individually identifying information.

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. The Website does not have any Advertising cookies.

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 http://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

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.

How Do I Manage Cookies and Similar Technologies
Our site provides you with an option decline cookies if you chose to do so. You will be asked to make your selection the first you visit the site. Cookie preferences may be changed afterwards by selecting Cookie Settings from our footer.

You can also 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:    

Pricoa Private Capital (‘PPC’) is a trading name of PGIM, Inc. (‘PGIM’), the principal asset management business of Prudential Financial, Inc. ('PFI'), and it is also a trading name of PGIM Private Capital Limited and PGIM Private Capital (Ireland) Limited. In the United Kingdom, information is issued by PGIM Private Capital Limited with registered office: Grand Buildings, 1-3 Strand, Trafalgar Square, London, WC2N 5HR. PGIM Private Capital Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) of the United Kingdom (Firm Reference Number 172071) and registered in England No. 1331817. In the European Economic Area (“EEA”), information is issued by PGIM Private Capital (Ireland) Limited with registered office: Pramerica Drive, Letterkenny Business and Technology Park, Letterkenny, Co Donegal, F92 W8CY, Ireland. PGIM Private Capital (Ireland) Limited is authorised and regulated by the Central Bank of Ireland and registered in Ireland under company number 635793 operating on the basis of a European passport. In certain EEA countries, information is, where permitted, presented by PGIM Private Capital Limited in reliance of provisions, exemptions or licenses available to PGIM Private Capital Limited under temporary permission arrangements following the exit of the United Kingdom from the European Union. These materials are issued by PGIM Private Capital Limited and/or PGIM Private Capital (Ireland) Limited to persons who are professional clients as defined  under the rules of the FCA and/or to persons who are professional clients as defined in the relevant local implementation of Directive 2014/65/EU (MiFID II).