Careers Site & Candidate Privacy Notice

Prudential Financial, Inc. and its affiliated entities (collectively “PFI”) value your trust and are committed to the responsible management, use and protection of personal information (defined below) (“Personal Information”). The purpose of this Notice is to provide information about the Personal Information we collect, use, transfer, safeguard, and disclose.

PFI operates in many different countries. Some of these countries have laws related to the collection, use and disclosure of the Personal Information of individuals, and PFI is committed to protecting the privacy of our potential associates in accordance with these regulations and industry best practices. This Careers Site & Candidate Privacy Notice (“Notice”) is applicable to information collected by PFI from or about you during your use of our Careers site (the “Careers Site”), as well to any Personal Information PFI collects about you in connection with a job application or our recruitment and pre-employment activities, whether online or offline.

Personal Information submitted elsewhere on PFI or affiliate websites will be used in accordance with the Online Privacy Statements applicable to those websites.

About This Notice

This Notice describes our practices regarding all the information that we collect in connection with your candidacy for a job or internship with PFI and our recruitment and pre-employment activities.

This Notice does not constitute an offer or promise of employment with respect to any employment position posted or described on the Careers Site. If we elect to make you an offer, Personal Information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any Personal Information that we collect may become part of your employee file and may be used for other employment/work-related purposes. You will be provided with a new Privacy Notice which sets out how we use your Personal Information in the course of your employment or engagement with us.

What Personal Information Do We Collect About You?

The types of Personal Information we collect about you depends on the requirements of the country in which the position is located and the location where the information is collected and stored, and not solely based on the country in which you reside. The term “Personal Information” (i.e., Personal Data or other similar terms as defined by applicable law) includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws.

We may collect the following types of information in relation to your application, recruitment, and pre-employment:

  • Contact information, such as first name, middle name, last name, address, telephone number, e-mail address, and other contact information (e.g., emergency contact);
  • Online account information, such as username and password to access the Careers Site, and application identifiers;
  • Professional information, such as CV, résumé, cover letter, previous work experience, skills, education information, work-related licenses and certification information, professional memberships, languages and other relevant skills, title of qualifications and awards, reason for leaving current role and how you heard about the position to which you applied or are applying, or any other information you elect to provide;
  • Employment preferences, including willingness and eligibility to relocate, desired salary, available start date;  Information from interview and phone screenings, including video and audio recordings; and
  • Sensitive Personal Information (where permitted and in accordance with applicable law and in certain instances only where you voluntarily provide such information), such as Government ID number (ex: Social Security number), driver’s license number, health and medial related data, race and ethnic origin, sexual orientation, citizenship or immigration status, criminal history and drug and alcohol test results and biometric data.

NOTE: We ask that you only submit the following information, which may qualify as Sensitive Personal Information under applicable law, where such information is specifically requested: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, and veteran status.

The provision of Personal Information, as described in this Notice, is partly a legal requirement and partly a requirement necessary to initiate a possible employment relationship with you. In general, you are required to provide the Personal Information, except in limited cases where we indicate that the provision of certain information is voluntary. Failure to provide Personal Information may prevent PFI from beginning an employment relationship with you. Any information you submit must be true, complete, and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action, including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate the rights of any third parties.

How Do We Collect Your Personal Information?

We generally collect Personal Information in the following ways:

  • Directly from You, through your activities and interaction during the employment application process.
  • Other Sources, including employment or recruitment agencies, employment referrals, background check providers, or other publicly available sources.
  • Information Collected Automatically, please read our Cookies & Similar Technologies Statement to learn how we collect information from you automatically when you use the Careers Site and how we use such information.

If you voluntarily provide us with any Personal Information about other individuals, such as your references and/or referrals, it is your responsibility to make sure you have their permission to disclose this information to us.

How Do We Use Your Personal Information?

The information PFI collects will be used for PFI’s global personnel recruitment, management, and planning purposes. We use your Personal Information listed above for the following business purposes associated with recruitment and pre-employment activities:

Application, Recruitment and Workforce Managment:

  • To process your application and assess your capabilities and qualifications for a job.  
  • To administer company workforce, including recruiting and staffing activities.
  • To conduct security and background screens, to the extent permitted by applicable law.
  • To administer Artificial Intelligence tools throughout the recruitment and employment process in accordance with applicable law or other regulatory guidance.

Communication and Information Provision:

  • To provide you with information about job and internship opportunities and the application process.  
  • To communicate with you about your application.
  • To notify you about changes to the Careers Site or its services.  
  • To manage complaints, feedback, and queries.

Site and Service Management:

  • To provide any services available to you on the Careers Site and to monitor the operation and performance of the site and services.
  • To improve the quality of the Careers Site, the services, and our training.
  • To improve and ensure the security of the site and services.

Compliance and Legal Obligations:

  • To monitor and ensure compliance with applicable laws, regulatory requirements, and company procedures, including making workplace accommodations.
  • To provide an opportunity to self-identify for diversity purposes in accordance with applicable federal, state, and international reporting requirements.
  • To comply with corporate financial responsibilities, including audit requirements (both internal and external), accounting, and cost/budgeting analysis and control.
  • To respond to and comply with requests and legal demands from regulators or other authorities.
  • To enforce or apply the agreements concerning you (including agreements between you and us) or our policies.

Security and Risk Management:

  • To protect against fraud or other illegal activity or for risk management purposes.
  • To protect the legal rights, privacy, or safety of PFI, our employees, our candidates, and/or others, including those that visit our websites and other properties.

We only use your sensitive Personal Information to administer your possible employment (e.g., for workplace accommodations), to maintain sickness/medical leave information and records, for health and wellness purposes to comply with applicable health regulations, for equal opportunities monitoring, and for any other purposes that are necessary to allow us to comply with our statutory obligations.

Personal Information about you will be added to PFI’s international candidate database and will be used for the purposes of considering whether your qualifications are suitable for other employment positions available at PFI.

PFI may anonymize and/or aggregate your Personal Information and, to the extent permitted by applicable law, use and disclose such anonymized and/or aggregated information for any purpose.

Legal Basis for Processing Personal Information

Data protection law seeks to ensure that your Personal Information is fairly and lawfully used. Some countries require that we have a legal justification for using your Personal Information. To comply with the law, we need to tell you the legal justifications on which we rely for using your Personal Information, which may be based on where you are located. PFI relies on the legal justifications below to collect, use, transfer, and disclose (“Process”) Personal Information you submit through the Careers Site:

  • When Pursuing Legitimate Interests. We process Personal Information for our legitimate interests in conducting and managing our business as a global organization; for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within PFI and across the organization; and (3) to prevent fraud;
  • With Your Consent (or express/explicit consent for sensitive Personal Information). As permitted by applicable law and where appropriate provided that such consent is voluntary, you have the right to withdraw your consent at any time, and your consent meets applicable legal requirements of such consent;
  • When We Have Legal Obligations. We will process your Personal Information when we have a legal obligation to do so (e.g., responding to a legal process or enforceable government request) or for our own compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws;
  • To Perform a Contract with You. We will process your Personal Information when processing is necessary for the execution or performance of a contract with you. For the purposes of this Notice, such contract is a contract of employment; and
  • Protection of the Vital Interests of you or another individual.

Additional legal justifications may also be available in the country in which you are based, and we may also rely on these justifications from time to time.

Disclosure of Personal Information

We may disclose all categories of Personal Information listed above to the following parties:

  • Within PFI - PFI may disclose Personal Information to affiliates that are involved in evaluating candidates for a given position. Prudential Financial, Inc. will remain responsible for Personal Information that is jointly used with affiliates. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.
  • Public and Governmental Authorities - We may be obligated to disclose your Personal Information to entities that regulate or have jurisdiction over PFI such as regulatory authorities, public bodies, judicial bodies, or law enforcement agencies; by a court order; under the discovery process in litigation, investigations, and prosecutions; or in response to requests from, or if required by, government agencies and/or regulators and/or any other person having appropriate legal authority or justification for receipt of the same. PFI may also disclose Personal Information voluntarily to cooperate with law enforcement agencies or any of the above bodies, including but not limited to matters of national security, criminal charges, civil claims or as may otherwise be permitted by applicable law.
  • Service Providers - PFI may disclose Personal Information to third parties who provide services such as recruiting assistance, background check processing, payroll, pension scheme, benefits providers; human resources services, performance management, IT systems suppliers and support; third parties assisting with equity compensation programs, or other service providers. Those third parties will be required to protect Personal Information.
  • Professional Advisors - PFI may need to make certain Personal Information available to other parties such as tax advisers, legal advisers, investigators, accountants, financial advisers, auditors, lawyers and other outside professional advisors in all of the countries in which PFI operates. PFI will remain responsible for the Personal Information collected.
  • Corporate Transaction - PFI may disclose 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).
  • Business Partners - As necessary in connection with business operations, limited Personal Information may be disclosed to certain business partners and their service providers in order to effectuate and manage business partnerships, as well as provide coordinated and consolidated services to you.
  • Other Disclosures with Your Consent - We may ask if you would like us to disclose your Personal Information with other unaffiliated third parties who are not described elsewhere in this Notice.

Personal Information may be transferred to other countries (including countries other than where you are based that have a different data protection regime than is found in the country where you are based). In such circumstances, we will take appropriate steps to provide an adequate level of data protection within the meaning of applicable data protection law, including by implementing the EU Standard Contractual Clauses, the UK Addendum to the EU Standard Contractual Clauses, LGPD Standard Contractual Clauses, or any other appropriate safeguard based on jurisdiction where required. You can request a copy of the appropriate safeguards referenced in this section by contacting us.

A list of the affiliate companies that may jointly process your Personal Information is available at our securities disclosures including 10-K available here, and/or upon request (please refer to the ‘Contact Us’ section at the end of this Notice).

How Long Do We Retain Your Personal Information?

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Notice unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; and (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). We may also retain your information for the purpose of considering whether your skills are suitable for other opportunities. If you do not wish us to do this, please contact GlobalHRDataMgt@prudential.com. We may remove Personal Information for inactive accounts from our records, subject to any applicable legal or regulatory obligations. Furthermore, PFI may delete Personal Information about you (including your CV/résumé) from our records at any time for any reason. Therefore, please retain your own copy of the Personal Information provided to us.

Your Rights

You may have specific rights under applicable data protection laws with respect to your Personal Information in certain circumstances and depending on your jurisdiction, which are described below. If you have privacy questions or would like to exercise your applicable privacy rights, please refer to the ‘Contact Us’ section below.

  • Right of Access - You may have the right to request a copy of the Personal Information held about you.
  • Right to Correct/Rectify - You may be entitled to have any inaccurate or incomplete Personal Information held about you corrected or amended.
  • Right to Erasure/Deletion - You may have the right to have your Personal Information erased (also referred to as the right to be forgotten) where, for example, retaining your Personal Information is no longer necessary in relation to the recruitment and pre-employment purpose for which it was originally collected/processed, or where you have withdrawn consent, subject to there being no overriding legal basis or requirement related to retention for continuing to hold your Personal Information.
  • Right to be Informed - You may have the right to know what Personal Information relating to you is held and processed by us. On receipt of a written request from you, we will provide information relating to the type of Personal Information held, the purposes for which the Personal Information is held or processed and to whom the information is disclosed.
  • Right to restrict processing - You are entitled at any time to request in writing to discontinue or ‘block’ the processing of your Personal Information where, for example, you believe your Personal Information is not accurate. Your request should clearly state the reason for your request, and we will respond to your request within a reasonable timeframe detailing whether we are able to comply with the request or the extent to which we are able to comply.
  • Right to Object – We are committed to the legitimate privacy interests of all candidates, employees, and previous employees and do not use Personal Information collected and processed in the context of your employment relationship for profiling purposes. If at any point in time you do not believe this to be the case you are entitled to object in writing, clearly stating the reasons for your objection. We will seek to make reasonable accommodations in response to your objection where appropriate and as required.
  • Rights in Relation to Automated Decision Making - Under certain limited circumstances, you may have the right to object to or opt-out of a significant decision based solely on automated processing (i.e., without human intervention), unless that decision is required or authorized by law.
  • Right to Data Portability – We can provide you with your Personal Information in a structured, commonly used, machine readable form which provides the ability to move, copy or transfer your Personal Information.
  • Right of Non-discrimination/Retaliation – We do not discriminate against individuals who exercise any of their rights described in this Notice, nor do we retaliate against individuals who exercise their rights.
  • Right to Anonymization - You may have the right to have unnecessary, excessive, or non-compliant Personal Information anonymized, blocked, or erased.
  • Right to Withdraw Consent – You may have the right to withdraw consent for the processing of Personal Information, where applicable.

Please note that certain Personal Information may be exempt from these rights pursuant to local data protection laws.

How Do We Protect Your Personal Information?

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of your concern by contacting us in accordance with the “Contact Us” section below.

Please do not send sensitive information to us via email. It is your sole responsibility to use the appropriate level of care whenever you communicate with us.

PFI hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any Personal Information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered, or destroyed or not timely delivered to our Careers Site.

Additional Notes and Disclosures

Diversity

PFI is an equal opportunity employer, which means we offer equal treatment to all candidates. PFI does not discriminate, either directly or indirectly, on the grounds of race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information in any area of recruitment. In some countries we ask for information on the ethnic origin, gender, and disability of our candidates for the purpose of monitoring equal opportunity. If you have a disability and would like to indicate as part of your application any relevant effects of your disability and any adjustment which you consider should reasonably be made to the process to assist your application, you are encouraged to disclose this during the application process.

Current Personnel of PFI

If you currently work for one of PFI’s business units, you must be eligible to apply for a different position within PFI. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

Changes to This Notice

We reserve the right to amend this Notice at any time to address future developments within PFI, changes in industry or legal trends. We will provide the revised Notice to you in compliance with applicable law. You can determine the effective date of this Notice by referring to the “Effective Date” legend on the bottom of this Notice.

Contact Us

If you have questions or concerns about PFI’s privacy practices or to exercise any of your rights and choices as described in this Notice, you can use the options described below:

Please include your contact information and a detailed description of your privacy request or privacy concern. For your protection, we may need to verify your identity before implementing your request and we may only implement requests with respect to the information associated with the email address that you use to send us your request. We will respond to your request as soon as reasonably practicable.

You may also have the right under local data protection laws to lodge a complaint with a Data Protection Authority for your country or region or in the place of the alleged misconduct.

Additional Information Regarding Other Jurisdictions

UK and EEA

  • The contact information for our data protection officer (DPO) in Germany is as follows: Jochen Geck VIVACIS Consulting GmbH Horexstraße 1 | ALTER GÜTERBAHNHOF D – 61352 Bad Homburg, Telephone: +49 160 938 492 30, Email: jochen.geck@vivacis.de
  • You may lodge a complaint with an EU/EEA or the UK data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities in the EU/EEA is available at: (http://ec.europa.eu/newsroom/article29/itemdetail.cfm?item_id=612080) and information regarding lodging a complaint with the UK ICO can be found here: (https://ico.org.uk/make-a-complaint).

California

In addition to this Notice and the contents herein, if you are a California candidate, please refer to the California Resident Statement, available on the Prudential (https://www.prudential.com/links/privacy-center) and PGIM (https://www.pgim.com/terms-use/privacy-center) privacy centers, for more information on our privacy practices, including the categories of Personal Information we collect, the purposes for that collection, and our retention practices.

Brazil

In addition to this Notice and the contents herein, if you are a Prudential of Brazil candidate, please refer to the Privacy Center

<https://www.prudential.com.br/privacidade>, for more information on our privacy practices.

The contact information for our data protection officer (DPO) in Brazil is as follows: Sabrina Calixto, e-mail: dpo.brasil@prudential.com

Acknowledgement

I acknowledge and agree that I have received a copy of this Notice, and completely read and understand this Notice, its contents, and its requirements.

Effective Date: April 2025