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Services Agreement <br />Prudential Provided by Prudential Retirement <br />Insurance and Annuity Company <br />EXHIBIT B <br />Confidentiality, Privacy, and Information Security <br />A. Personal Information <br />"Personal Information" means information provided by or on behalf of the Plan, Plan Sponsor or Plan <br />Participants, or their agents to Prudential or its agents in the course of Prudential's performance of <br />the Services under this Agreement that: <br />a) identifies an individual (by name, signature, address, telephone number or other unique <br />identifier), or <br />b) can be used to identify or authenticate an individual. <br />Personal Information includes (i) an individual's government -issued identification number (including <br />social security number, driver's license number or state -issued identified number); and (ii) financial <br />account number in combination with any required security code, access code, personal identification <br />number or password, that would permit access to an individual's financial account. <br />B. Confidentiality <br />Prudential agrees to keep and maintain all Personal Information in strict confidence, using an <br />appropriate degree of care to avoid unauthorized use or disclosure. <br />Prudential may disclose Personal Information to its employees (individually an "Employee" and <br />collectively, "Employees") having a need to know this information in connection with the performance <br />of the Services for Plan Sponsor. Prudential may also disclose Personal Information to its affiliates <br />and its subcontractors having a need to know this information in connection with the performance of <br />Services for Plan Sponsor. Prudential shall instruct all Employees, affiliates and subcontractors of <br />their obligations under this Agreement. <br />If Prudential receives any order, demand, warrant, or any other document requesting or purporting to <br />compel the production of Personal Information under applicable law (including, for example, by oral <br />questions, interrogatories, requests for information or documents in legal proceedings, subpoenas, <br />civil investigative demands or other similar processes), Prudential shall notify Plan Sponsor in writing <br />(except to the extent otherwise prohibited by applicable law). <br />C. Destruction and Retention of Personal Information <br />Upon the earlier of (i) the completion of an engagement or termination of this Agreement; (ii) a <br />determination that it has no need for Personal Information; or (iii) at any time Plan Sponsor requests, <br />Prudential shall dispose of all records, electronic or otherwise regarding or including any Personal <br />Information that Prudential may then possess or control by destroying them pursuant to Prudential's <br />written policy governing records destruction. Notwithstanding the foregoing, Prudential will not be <br />obligated to destroy Personal Information (i) it is required by law or regulation to retain, but then only <br />for the time period required, (ii) is commingled with other information or documents of Prudential if it <br />would pose an administrative burden to destroy such Personal Information, or (iii) if the Personal <br />Information is contained in an archived computer system or back-up in accordance with its standard <br />security policy. Such Personal Information will be retained in accordance with the requirements of this <br />Agreement. <br />iD <br />