Updated as of May 22, 2018
Global Online Privacy Statement
Jennison Associates LLC (“Jennison,” “we” or “us”) respects your privacy, and we are committed to protecting it. We provide this Global Online Privacy Statement (“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 Jennison.com and other websites operated by us from which you are accessing this Privacy Statement (the “Websites”).
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 Jennison representative contact you, when you fill out a 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 client’s requests.
- To respond to inquiries and fulfill requests from our clients, 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.
We will engage in these activities to manage our contractual relationship with our clients and/or to comply with a legal obligation.
- Providing our clients with our newsletter and/or other marketing materials and facilitating social sharing.
- To inform our clients 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 validate authorized signatories when concluding agreements and transactions;
- 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 clients, to comply with a legal obligation, and/or because we have a legitimate interest.
How We Disclose of 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 your client services representative or by emailing: firstname.lastname@example.org.
- 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.
- To intermediaries and counterparties with which we may have dealings.
- These can include other financial institutions, insurers, brokers and credit institutions,
- To client’s service providers or clients.
- For our clients, these can include your custodians, fund administrators or consultants.
- For client’s service providers, these can include our mutual clients.
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.
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
- App usage information
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you that does not reveal a person’s specific 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, pixel tags and other similar technologies; and through IP addresses. Please see our Cookies Statement 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 Privacy 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
Jennison 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.
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: email@example.com. We will respond to your request consistent with applicable law.
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 client 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).
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.
Personal information may be stored and processed in any country where Jennison 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 EUROPEAN ECONOMIC AREA (“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 firstname.lastname@example.org.
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.
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.
Jennison Associates LLC located at 466 Lexington Avenue, New York, NY 10017 is the company responsible for the collection, use, and disclosure of your Personal Information under this Privacy Statement.
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 https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
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.jennison.com (the “Website”) of JENNISON ASSOCIATES LLC. We may change this CST Policy at any time. Please take a look at the “LAST REVISED” legend at the top of this page to see when this CST Policy was last revised. Any changes in this CST Policy will become effective when we make the revised CST Policy available on or through the Site.
If you have any questions, please contact us by email at email@example.com, or write to us at the following address: Privacy Officer, Jennison Associates LLC, 466 Lexington Avenue, 19th Floor, New York, NY 10017.
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 also use technologies similar to cookies, such as Flash Local Shared Objects (also known as Flash cookies) or pixel tags.
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 party or
|Nlbi_858098||DDoS Attack Prevention||Session||3rd party|
|incap_ses_553_858098||DDoS Attack Prevention||Session||3rd party|
|visid_incap_858098||DDoS Attack Prevention||Persistent||3rd party|
|_utmvc||Filter for malicious requests||Persistent||3rd party|
|AWSALB||Amazon load balancer cookie||Persistent||1st party|
|PGIM_AWS||Required until cloud migration to AWS is stabilized||Session||1st party|
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. The Website does not have any Preference cookies.
Social Media Cookies. Social media cookies collect information about social media usage. This Website does not have any 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 party or
|_ga||Used to distinguish users||Persistent||3rd party
|_gid||Used to distinguish users||Persistent||3rd party
|_gat_pruISTracker||Used for performance analytics||Persistent||1st party|
|loadpop||Used to manage loads||Persistent||1st party|
|analyticsAuth||Used to distinguish users||Persistent||3rd party|
|gpv_pn||Used to captures the value of an analytics variable on the next page view.||Persistent||3rd party
|s_cc||Used to determine whether cookies are enabled in the browser||Session||3rd party
|s_dfa||Used for performance analytics||Persistent||3rd party
|s_fid||Used as a “Fallback’ visitor identifier.||Persistent||3rd party
|s_getNewRepeat||Used to determine whether a visitor is a new visitor or a repeat visitor, and||Persistent||3rd party
|s_ppvl||Used to record the portion of a page the user views||Session||3rd party
|Used to identify unique visitors, with an ID and timestamp||Persistent||3rd party|
|uuid||Used to track unique user sessions||Persistent||1st party|
|demdex||Used to assign a unique ID to a site visitor||Persistent||3rd party
(Adobe Audience Manager)
|dpm||Used to determine if other cookies can be set||Session||3rd party
(Adobe Audience Manager)
|Used to identify a unique visitor||Persistent||3rd party
|Used to identify a unique visitor||Persistent||3rd 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 party or
|bito||Used for targeted advertising||Persistent||3rd party|
|ck1||Used to identify the user for programmatic ads||Persistent||3rd party|
|iuuid||Used to distinguish cookies||Persistent||3rd party|
|Id||Used for targeted advertising||Persistent||3rd party|
|Rlas3||Used to collect anonymous data related to the user’s visits to the site||Persistent||3rd party|
|Rtn1-z||Used for targeted advertising||Persistent||3rd party|
|Used to determine if other cookies can be set||Persistent||3rd party|
|tuuid||Used for online ad network business||Persistent||
|tuuid_last_update||Used to identify the user for programmatic ads||Persistent||3rd party|
|1P-JAR||Used to customize ads on Google websites||Persistent||3rd party|
|IDE||Used for targeted advertising||Persistent||3rd party
|NID||Used to help customize ads on Google properties||Persistent||3rd party
|APISID||Used in conjunction with the Google+ 1 button to share information publicly||Persistent||3rd party
|SSID||Used in conjunction with the Google+ 1 button to share information publicly||Persistent||3rd party
|SAPISID||Used in conjunction with the Google+ 1 button to share information publicly||Persistent||3rd party
|HSID||Used in conjunction with the Google+ 1 button to share information publicly||Persistent||3rd party
|everest_g_2||Used to map clicks to other events on client’s website||Persistent||3rd party
|everest_session_v2||Used to map clicks to other events on client’s website||Session||3rd party
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 Site, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.
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:
© 2018 Jennison Associates LLC
Prudential Financial, Inc. of the United States is not affiliated with Prudential plc which is headquartered in the United Kingdom.
Jennison Associates is a registered investment advisor and a Prudential Financial company. Jennison Associates LLC has not been licensed or registered to provide investment services in any jurisdiction outside the United States. Certain investment vehicles are distributed or offered through Prudential Investment Management Services LLC (also a Prudential Financial Company) or other affiliated entities. Additionally, vehicles may not be registered or available for investment in all jurisdictions.
This web site is not intended as an offer or solicitation with respect to the purchase or sale of any security or other financial instrument or any investment management services. It does not constitute investment advice, should not be used as the basis for any investment decision, and does not purport to provide any legal, tax or accounting advice. This is for informational and educational purposes only and should not be construed as investment advice or an offer or solicitation in respect of any products or services to any persons who are prohibited from receiving such information under the laws applicable to their place of citizenship, domicile or residence.
Please remember that there are inherent risks involved with investing in the markets, and your investments may be worth more or less than your initial investment upon redemption. There is no guarantee that the investment managers’ objectives will be achieved. Further, there is no assurance that any strategies, methods, sectors, or any investment programs herein were or will prove to be profitable, or that any investment recommendations or decisions we make in the future will be profitable for any investor or client. Professional money management is not suitable for all investors.
For visitors domiciled in Canada: Jennison Associates LLC ("Jennison") has its principal place of business in the United States and is not registered in Canada and relies on the international adviser registration exemption in NI 31‐103 and is limited to providing services to "permitted clients."
In Australia, Jennison Associates LLC ("Jennison") has authorized the issue of this material for use solely by wholesale clients as defined in the Corporations Act of 2001. A registered investment adviser regulated by the SEC, Jennison is exempt from the need to hold an Australian financial services license (AFSL) for financial services provided to Australian wholesale clients on certain conditions. Financial services provided by Jennison are regulated by the SEC under the laws and regulatory requirements of the United States, which are different from the laws applying in Australia.
In Hong Kong, information is presented by representatives of PGIM (Hong Kong) Limited, a regulated entity with the Securities and Futures Commission in Hong Kong to professional investors as defined in Part 1 of Schedule 1 of the Securities and Futures Ordinance.
In Singapore, information is issued by PGIM (Singapore) Pte. Ltd. (“PGIM Singapore”), a Singapore investment manager that is licensed as a capital markets service license holder by the Monetary Authority of Singapore and an exempt financial adviser. These materials are issued by PGIM Singapore for the general information of “institutional investors” pursuant to Section 304 of the Securities and Futures Act, Chapter 289 of Singapore (the “SFA”) and “accredited investors” and other relevant persons in accordance with the conditions specified in Sections 305 of the SFA.
For information on other jurisdictions, please see our Terms and Conditions.
Links to third-party sites are intended for informational purposes only and should not be considered investment advice or recommendation to invest. These links do not constitute endorsement or confirm their accuracy, and we are not responsible for any third-party guidelines, security, or accuracy of information.
The risks associated with investing include but are not limited to: derivative securities, which may carry market, credit, and liquidity risks; short sales, which involve costs and the risk of potentially unlimited losses; leveraging, which may magnify losses; small/mid cap stocks which may be subject to more erratic market movements than large cap stocks; foreign securities, which are subject to currency fluctuation and political uncertainty; real estate, which poses certain risks related to overall and specific economic conditions as well as risks related to individual property, credit and interest-rate fluctuations; and mortgage-backed securities, which are subject to prepayment and extension risks.
Thematic and concentrated portfolios may not be suitable for all investors. Such portfolios are non-diversified, so a loss resulting from a particular security will have greater impact on the portfolio’s return. Fixed income investments are subject to interest rate risk, and their value will decline as interest rates rise.
Your investment objectives, risk tolerance, and liquidity needs must be reviewed before suitable programs can be recommended. Asset allocation and diversification strategies do not assure a profit or protect against loss in declining markets. Investors should consult with their attorney, accountant, and/or tax professional for advice concerning their particular situation.