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.
© 2018 Jennison Associates LLC
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