Privacy Notice

Last Modified 03/01/2021

OVERVIEW

Your privacy is important to us.

We understand that the information you provide to us or that we collect about you is private and personal. This privacy policy is provided to you so that you will understand what information we collect about you, how we use and share the personal information we collect about you, including through our website, mobile application, and application for insurance products, the choices you have about our collection, use and sharing of your personal information, and the measures we take to protect your privacy. We follow these same practices for everyone, even if they are no longer our customer. This information is provided in addition to, and intended to be consistent with, our GLBA Privacy Notice.

DEFINITIONS

“We,” “our,” or “us” refers to Everly, Security Benefit Life Insurance Company, and their affiliates and authorized representatives.

“Personal information” refers to information that can reasonably be used on its own or with other information to identify, contact or locate you. For example, personal information includes your name, email address, phone number, date of birth, address, social security number, driver’s license number, credit card number, or other data which can be reasonably linked to you.

“Protected health information” is personal information that can reasonably be used to identify you and that relates to your past, present, or future physical or mental health or condition, the provision of health care to you, or the payment for that care. Protected health information also includes your genetic information as defined in Section 201 of the Genetic Information Nondiscrimination Act of 2008.

“Website” refers to www.EverlyLife.com and our online services, mobile services, and software.

INFORMATION WE COLLECT

We collect information from many sources to serve your needs. The types of personal information we collect, store and use depend on the product and service you apply for or obtain from us and your use of our website or mobile application.

We collect your personal information when you transact directly with us or one of our affiliates (for instance, when you visit our website or other online portal or mobile application, apply for an insurance product, call us, make a payment or withdrawal, or file a claim). We supplement the information we collect directly from you with outside records from third parties in order to enhance our ability to serve you, to tailor content to you, and to offer you additional content and marketing.

We collect, store and use personal information about you such as:

Personal identifiers: your name, postal address, email address, telephone number, governmental identification number such as social security number, passport number or military identification number, online identifier, Internet Protocol address, driver’s license number or similar identifiers, and the name and some identifiers about your spouse, children and beneficiaries.
Sensitive information protected by federal or state law: your age, gender, race, marital status, national origin, and ethnicity or disability.
Professional or employment information: your job title, job history, and income.
Financial information: your account numbers, credit and debit card numbers in combination with a security or access code, account balances, transaction history, credit and payment history, and assets and liabilities, including records of personal property ownership.
Educational information not publicly available: your level of education, schools attended, and degrees.
Medical and health information: your medical history, medical treatment and diagnosis by a health care professional.
Life, health and other insurance information: information about other insurance policies you may own.
Unique biometric information: fingerprints, retinal scans, photos used for facial recognition, genetic information, and voice signatures.
Geolocation data: data regarding your location, which we can gather from your device or online profile.
Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a website, online application or advertisement.
Information from consumer reporting agencies: information from consumer reporting agencies about your medical and health information, credit reports, criminal offenses and convictions, consuming histories or tendencies, and driving record and information from various anti-fraud databases related to you.
Inferences drawn from any of the above to create a profile of you: information about your consumer preferences, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

WHY WE COLLECT AND SHARE

We use and share your personal information, including protected health information, to provide you with an insurance quote, to administer your policies, to market our products to you, and for the following purposes:

To consider your application for insurance, assess and evaluate institutional risk and provide you with an insurance product, where applicable.
To administer your insurance product and maintain your account, including processing premium payment, processing claims, administering benefits and paying out withdrawals, surrenders and claims settlements, and encouraging customer engagement.
To provide account statements and other required documents.
To respond to court orders and legal investigations or as otherwise required or permitted by federal and state law.
To report to consumer reporting agencies.
To authorize, settle and clear the collection of amounts charged, debited or otherwise used to pay premium or receive payments and the audit of such information.
To prevent and detect security incidents, fraud, money laundering, unauthorized access, data destruction and other crimes.
To obtain reinsurance, or stop loss or excess loss insurance on our operations.
To improve our products and technology, carry out market research, perform data analytics, risk modeling and statistical analysis and for mergers and reorganizations.
For marketing and analytic purposes.

HOW WE SHARE AND WITH WHOM

We share your information with the following entities:

Our affiliates: Except for protected health information, we disclose your personal information, including information about your transactions and experiences, with our affiliated companies in order to assist in the delivery of services to you and for marketing purposes.
Third parties providing services to us or on our behalf: We share your personal information with third parties that provide services to us or on our behalf, such as technical support, third party administration, marketing expertise and analysis, hosting services and website analytics (“service providers”). For example, we may allow third-party advertising cookies to be placed on your computer or mobile device when you visit our website. While it is possible that these entities retain any report they prepare and disclose your information to other persons, we contractually require any person or organization providing products or services on our behalf to protect our customer information and not use it except for the purpose for which they received it from us.
Joint marketing partners: We may share your personal information with companies in order to market our products and to provide a broader range of products and services to you.
Reinsurers: We disclose your personal information to our reinsurers in order to assist us in managing our business.
Consumer reporting agencies: We share your personal information with consumer reporting agencies during the underwriting process and at other times, as permitted or required by law.
Judicial, regulatory and law enforcement bodies and auditors/examiners: We may disclose your personal information to judicial, regulatory or law enforcement bodies and auditors and examiners, in order to:
Comply with applicable law, regulation, subpoena, governmental request or legal process;
Protect and defend our rights and those of our affiliates and service providers, including investigations of potential violations of our rights and where it is advisable for us to do so.
Detect, prevent or address fraud and other illegal activity, including security breaches.
Assess our compliance with industry standards and requirements, guaranty funds, insurance rate advisory organizations.
Nonaffiliated third parties: We may share your personal information, including credit score, motor vehicle record, and other non-health consumer report with nonaffiliated third parties for our or their marketing purposes.
Persons acting in a fiduciary or representative capacity or holding a legal or beneficial interest relating to the consumer: We may share your information with these individuals to the extent you consent to the disclosure or as permitted by law.
Others with your consent or as permitted or required by law: We may disclose your personal information with your consent or as otherwise permitted or required by law, including for research purposes (you will not be identified in any research report, materials allowing you to be identified will be returned or destroyed as soon as no longer needed, and any research organization must agree never to disclose your information unless that disclosure is otherwise permitted). We may also aggregate, de-identify, or otherwise strip data of all personally identifying characteristics and may share that aggregated and/or de-identified data with other companies, organizations or individuals.

We limit sharing some of your more sensitive information for marketing purposes. In the future, if we share this data with our affiliates for marketing purposes, we will provide you with the right to opt-out of such information sharing.

We do not collect, use, or share your protected health information unless you expressly authorize it or it is permitted or required by law. If you authorize a disclosure, you may revoke that authorization at any time in writing, except to the extent that we have already taken action on the information disclosed or if we are permitted by law to use the information to contest a claim. We will use and share any protected health information you permit us to receive only with persons acting on our behalf to perform our insurance functions and only for the purpose for which we received it, or as otherwise permitted or required by law.

Examples of instances in which we are permitted or required to collect, use, or share your protected health information without an authorization include:

As part of investigating, evaluating, adjusting, or settling a claim.
As part of a merger, acquisition, or other assumption of liability.
As necessary to investigate, evaluate, subrogate, or settle third party claims.
To perform insurance functions.
When required to meet our workers’ compensation obligations.
To a reinsurer, stop loss, or excess loss carrier for the purpose of underwriting, claims adjudication and conducting claim file audits.
When you give us the information directly or it is included in public sources such as a newspaper or public report.
To a federal, state, or local government authorities as required by law or for fraud reporting purposes.
To a state department of insurance performing an examination, investigation, or audit.
As ordered by a court.
To research organizations conducting scientific, medical, or public policy research (only as necessary to conduct the research and with additional measures to protect your privacy).

YOUR CHOICES

You have certain rights over your personal information, including protected health information. Any choices will apply to everyone on a joint account. Generally, with exceptions, your rights include:

You can limit our sharing with our affiliates for their business purposes or our sharing your information with anyone (affiliates and non-affiliates) for marketing purposes by calling or emailing us at the number provided in the Contact Us section below, or if you live in Arizona, California, Maine, Massachusetts, Minnesota, Montana, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oregon, Vermont, and Virginia, by simply not opting-in to such sharing.

You can also limit our disclosure of your information if you tell us that disclosure to a specified individual would jeopardize your safety.

Limiting Disclosures.

You can limit our sharing with our affiliates for their business purposes or our sharing your information with anyone (affiliates and non-affiliates) for marketing purposes by calling or emailing us at the number provided in the Contact Us section below, or if you live in Arizona, California, Maine, Massachusetts, Minnesota, Montana, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oregon, Vermont, and Virginia, by simply not opting-in to such sharing.

You can also limit our disclosure of your information if you tell us that disclosure to a specified individual would jeopardize your safety.
Accessing Your Information. You have a right to see the personal information we hold about you. If you prefer, we can send a copy of this information to you via email. This request must be in writing to the email or postal address provided in the Contact Us section below.
Accounting of Disclosures. You have a right to a list of entities to whom we normally disclose personal information. This accounting does not include disclosures related to your payment or disclosures made to you or with your authorization and may also exclude other disclosures, such as for national security purposes. This request must be in writing to the email or postal address provided in the Contact Us section below.
Amending or Deleting Your Information. You have a right to correct or amend, incomplete or inaccurate personal information and to delete certain information in our possession. This request must be in writing to the email or postal address provided in the Contact Us section below.

Any such information that is corrected will be provided to any insurance support organization from whom we received the information, any person designated by you to whom we may have disclosed the information in the prior two years, and any insurance support organization that maintains the corrected information and systematically received that information within the preceding seven years.

If we deny your request to amend or delete your information, we will tell you why. You then have the right to submit to us a written statement of disagreement with our decision and we have the right to disagree with that statement. We will file your statement with the disputed information and provide a means by which anyone reviewing the disputed information will be aware of and have access to your statement. We will also provide your statement to the persons who would have received the amendment or notice of deletion if we had approved it.
Know Our Health Information Policies, Standards, and Procedures. You have a right to receive a copy of our Health Information Policies, Standards, and Procedures. To request it, please contact us using the information in the Contact Us section below.

Please note:

These rights do not extend to information relating to, or collected in connection with or in reasonable anticipation of a claim or civil or criminal proceeding.
We may sometimes charge a fee for the costs of producing, copying, and mailing your requested information. If we do, we will tell you the cost in advance.
Any requests to access, correct, amend or delete personal information will be answered within 20 business days.

For information regarding your ability to limit cookies, please see the Cookies section below.

INFORMATION SECURITY

We maintain technical, physical, and administrative security measures designed to protect the security of your personal information, including your Protected Health Information, against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. We require our affiliated companies and any companies that work for us to protect your information by implementing appropriate security policies and procedures. These measures are designed to provide a level of security appropriate to the risks of collecting, using and retaining your personal information.

CHILDREN’S PRIVACY

The Site is directed to adults. We do not offer products to, nor knowingly collect information from, minors under the age of 18. No one under the age of 18 should submit or post personal information through our online services. We may collect information regarding individuals under 18 years of age from their parents or legal guardians, but only as necessary to provide our products and services. If you believe we have collected information from someone under the age of 18, please contact us and we will promptly delete that information.

THIRD-PARTY PRACTICES

This website/mobile application may contain content or links to third-party sites that are not owned or controlled by us. We are not responsible for the data collection and privacy practices employed by any of these third parties or their websites and apps. These other websites or apps may associate their tracking technologies with you and independently collect information about you. You should exercise caution and review the third party privacy policies when you leave our website or our app.

CONTACT US

If you have any questions about this privacy policy or if you want to submit a request as described in previous sections of this policy, please contact us by one of the following methods:

By Email: privacy.inquiry@everlylife.com

By Phone: 1-855-290-0529

CHANGES

We reserve the right to change this privacy policy at any time, effective for information we already hold about you and any that we may receive in the future. If we make a material change to this privacy policy, we will post the revised privacy policy to the www.EverlyLife.com website as of the effective date of such changes and revise the last modified date accordingly.

COOKIES

Cookies are small data files that are placed on your computer or mobile device when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies are widely used by online service providers in order to make their websites or services work more efficiently, as well as to provide reporting information and to share information. Cookies that are set by the website owner or service provider (in this case, Everly and Security Benefit Life) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third-party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services.

We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our websites, applications (“apps”) and services to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us and the third parties we work with to track and target the interests of visitors to our websites and apps, and we refer to these as “performance” or “functionality” cookies. For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our websites and apps and to otherwise improve the functionality of the services we provide. We also enable third parties to serve cookies through our websites and apps and services for advertising, analytics, and other purposes. This is described in more detail below.

Our digital properties (i.e. website, apps) use a variety of cookies, including:

Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not work if you do block these cookies. These cookies do not store any personally identifiable information.
Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.
Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.
Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device.
Targeted online advertising. We have engaged one or more third party service providers to track and analyze both individualized usage and volume statistical information from interactions with our Websites. We also partner with one or more third parties (such as advertisers and ad networks) to display advertising on our Websites and/or to manage and serve advertising on other sites. These third parties use cookies, web beacons, pixel tags and similar tracking technologies to collect and use certain information about your online activities, either on our Websites and/or other sites or mobile apps, to infer your interests and deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests (“Interest Based Advertising”). For more information about this practice, visit: aboutads.info/choices
Our third-party service providers may also use cookies or web beacons to collect information about your visits to our Websites and/or other sites to measure and track the effectiveness of advertisements and our online marketing activities (for example, by collecting data on how many times you click on one of our ads). The information collected by these third parties does not include personal information that enables you to be specifically identified (e.g. by reference to your name or email address).
Among other cookies, we use Google Analytics. You can learn more about how those cookies work by visiting “How Google Uses Data When You Use Our Partners’ Sites or Apps,” located here.

You have the right to decide whether to accept or reject cookies.

Website Cookie Preference Tool: You can exercise preferences about what cookies are served on our Websites by visiting the TRUSTe preference center by visiting: preferences-mgr.truste.com
Browser Controls: You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Websites though your access to some functionality and areas of our Websites may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.
Disabling Most Interest Based Advertising: Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, visit: aboutads.info/choices or youronlinechoices.com
Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of Interest Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system.
Do Not Track Signals: Various third parties are developing ways for consumers to express their choice about the collection of the individual consumer’s online activities over time and across third-party websites or online services. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created. To find out more about “do not track,” please visit http://www.allaboutdnt.com.

To find out more about cookies, visit http://www.allaboutcookies.org/.

CALIFORNIA CONSUMERS

CCPA

California Residents: Your privacy rights under the California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) gives California residents certain privacy rights with respect to some of the personal information we collect. These rights are:

The right to notice of the personal information we collect
The right to know the categories, sources and specific pieces of personal information we have collected about you in the past 12 months, including our purpose for collecting the information and the categories of third parties with whom we share that personal information, subject to certain exceptions
The right to delete some or all of the personal information we collect, subject to certain exceptions
The right to opt-out of our sale of your personal information, if we sell your personal information

This section describes the steps you must take to exercise these rights, how we will verify your identity, and how we will respond to your requests.

Your rights under the CCPA are limited. In some cases, federal law protects certain classes of personal information that we collect, such as all the information we collect in order to provide you with financial and insurance products and services. Such personal information is excluded from the CCPA. Personal Information does not include:

Publicly available information from government records
De-identified data (where personally identifiable information has been removed) or aggregated consumer information (information provided in a summary format)
Information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.

Notice of Collection

We collect personal information about California residents from a variety of sources and use it for purposes related to our business. We may disclose personal information to our service providers in order to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements. A fuller description of the purposes for which we collect the personal information of our consumers is provided below.

The personal information we collect includes not only clear personal identifiers, but also any information that directly or indirectly can be associated with, or linked to, our consumers or their households. Below are the categories of personal information we collect about our consumers, the sources of that information, the purposes for which we use personal information and the types of third parties with whom we have shared personal information in the past 12 months.

For more information on the purposes for which we use personal information, see the section below on “Purposes for which we use your data.”

Personal Information We Collect, Use and Share

Categories of the Personal Information We Collected:

Personal Identifiers: address, social security number, driver’s license number, passport number, or other similar identifiers your name, alias, phone number, postal address, email address, unique personal identifier, online identifier, account name, Internet Protocol. We may collect similar information about your spouse, children and beneficiaries.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners.

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in Past 12 Months:

Affiliates
Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Additional personal identifiers: your signature, physical characteristics or description, insurance policy number, bank account, credit card and debit card number, or any other financial information, medical information, and health, life or other insurance information, including your claims history.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Sensitive information protected by federal or state law: your age, gender, familial status, disability, sex, national origin, marital status, veteran status, medical condition, ancestry, source of income, and genetic information.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in Past 12 Months:

Affiliates
Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Commercial information: records of your personal property, products or services you have purchased or considered, and other histories or tendencies to purchase or consume particular products and services.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Biometric information: physiological, biological or behavioral characteristics that can be used to identify you, such as fingerprints, retina scans, photos used for facial recognition and genetic information.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Our affiliates

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Categories of the Personal Information We Collected:

Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a Web site, online application and advertisements.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Geolocation data

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Sensory information: Audio, electronic, visual, thermal, olfactory or similar information, including voice signatures and recorded calls.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Professional or employment-related information such as your job title, job history, income.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Educational information not publicly available: your level of education, schools attended, your degrees.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Categories of the Personal Information We Collected:

Inferences drawn from any of the above categories of information to create a profile about you: Information about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources of the Personal Information:

Directly from you or from others on your behalf
Insurance producer/agent
Consumer reporting agencies
Our service providers
Our affiliates
Government agencies
Public records
Consumer data resellers
Social platforms

Purpose for Which We Use Your Data:

Disclosed for a Business Purpose in Last 12 Months?

Yes

Types of Third Parties With Whom We Have Shared Personal Information in the Past 12 Months:

Group policy sponsors, such as employers and affinity groups
Insurance producer/agents
Service providers
Reinsurers and other insurance companies
Joint marketing partners
Consumer reporting agencies
Government, judicial and law enforcement agencies and their agents
Industry self-regulatory bodies
Attorneys, accountants and auditors
Your fiduciary or legal representatives
Persons holding a legal or beneficial interest relating to you
Data analytics providers
Social networks
Consumer data resellers

Purposes for which we use your data

We may use your data for the following business purposes:

To consider your application for insurance, assess and evaluate institutional risk and provide you with an insurance product and services, where applicable;
To administer your insurance product and maintain your account, including processing premium payment, processing claims, administering benefits and paying out withdrawals, surrenders and claims settlements, and encouraging customer engagement;
To provide account statements and other required documents;
To respond to court orders and legal investigations or as otherwise required or permitted by federal and state law;
To comply with legal requirements;
To report to consumer reporting agencies;
To authorize, settle and clear the collection of amounts charged, debited or otherwise used to pay premium or receive payments and the audit of such information;
To prevent and detect security incidents, fraud, money laundering, unauthorized access, data destruction and other crimes;
To obtain reinsurance, or stop loss or excess loss insurance on our operations;
To improve our products and technology, carry out market research, perform data analytics, risk modeling and statistical analysis and for mergers and reorganizations;
For marketing and analytic purposes.

YOUR RIGHTS UNDER CALIFORNIA’S PRIVACY LAW

Right to know

You have a right to ask us to disclose certain personal information that we have collected about you over the 12 months before we received your request. You, or your authorized agent, may ask us to disclose, subject to certain exceptions:

the categories of personal information we have collected;
the categories of sources for the personal information we collected about you;
the purposes for which we collected the personal information;
the categories of third parties with whom we have shared the personal information; and
the specific pieces of personal information that we have collected.

Before we respond to your request to know, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described below.

Right to delete

You have the right to ask us to delete some or all of the personal information we have collected or maintained about you, subject to certain exceptions.

Before we respond to your request to delete personal information, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described below.

Right to non-discrimination if you exercise your consumer rights

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not do any of the following to you if you exercise your CCPA rights:

Deny you goods or services
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
Provide you a different level or quality of goods or services
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Ability to opt-out of third-party cookies

We do not sell personal information about current or former customers to any third parties. We may allow thirdparty advertising cookies to be placed on your browser or mobile device when you visit our website. You may opt-out of third-party cookies. For more information on third party cookies and for instructions on how you can opt-out of third party cookies, go to the section of our Privacy Policy that describes our Cookie Policy.

HOW TO SUBMIT A REQUEST TO EXERCISE YOUR RIGHTS

Authorized Agent

You may designate an authorized agent to submit a request to know or a request to delete on your behalf.

If that agent is not already authorized to access your account in your profile, please submit a notice in writing that provides the authorized agent with permission to make a request to know or a request to delete on your behalf. We may also ask you to verify your identity directly with us.

We will deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Request to know: You or your authorized agent may submit a request to know by calling this toll-free number – 1-855-290-0529 – to speak to a customer service representative.

If we deny your request in whole or in part, we will provide you with an explanation or direct you to our general business practices for collecting personal data. Under no circumstances will we provide the requestor with a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account numbers, any health insurance or medical identification numbers, any account passwords, or any security questions and answers. If you maintain a password-protected account with us, we may comply with your request to know by using a secure self-service portal for you to use to access, view and receive a portable copy of your personal information. We will use reasonable security measures when transmitting information to a consumer.

Request to delete: You or your authorized agent may submit a request to delete all or some of your personal information by calling this toll-free number – 1-855-290-0529 – to speak to a customer service representative.

Submitting a request to delete is a two-step process. After you submit a request to delete, we will ask you separately to confirm that you want all or some of your personal information deleted.

Once we receive your verified request to delete and confirm your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless the information is subject to other laws or we need the information to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
Debug products to identify and repair errors that impair existing intended functionality
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
Comply with a legal obligation
Make other internal and lawful uses of that information that are compatible with the context in which you provided

HOW WE WILL VERIFY YOUR IDENTITY

Only you, or an authorized agent, may submit a request to know or to delete your personal information. You may also make a request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use the personal information you provide to us when submitting a consumer request only to verify the requestor’s identity or authority to make the request.

Policy/Contract owners who have a web-access account: if you have a web-based account with us that has a password, we will verify your identity using our existing authentication process. We may require you to correctly match at least two data points we have previously collected about you. We will match this information against information we have previously collected about you to verify your identity and your request. If we are unable to verify your identity as part of your request, we will not honor your request.

Policy/Contract owner who do not have a web-access account: If you do not have a web-access account with us, we will require the following information to verify your identity:

For requests to know categories of personal information: We will require you to correctly match at least two data points we have previously collected about you.
For requests to know specific pieces of personal information we have collected in the past 12 months: We will require you to correctly match at least three data points we have previously collected about you. We may also require you to sign a declaration under penalty of perjury that the requestor is the consumer whose personal information is being requested.
For requests to delete: We will require you to correctly match at least two or three data points we have previously collected about you, depending on the sensitivity of the personal information you are requesting. We may also require you to sign a declaration under penalty of perjury that the requestor is the consumer whose personal information is being requested.

Data we may request to verify your identity: When we request additional information from you to verify your identity, we may request other account information, answers to security questions, your name, government identification number, date of birth, contact information, or other personal identifying information.

HOW WE WILL RESPOND TO YOUR REQUEST

We intend to confirm receipt of your request within 10 business days and to respond to a verified request within 45 calendar days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will provide a written response to you via your account portal. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of a verified request from you. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know the specific pieces of information we have collected, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

For more information, contact us at:

Email: privacy.inquiry@everlylife.com

Phone: 1-855-290-0529

LI-10000-262021-03-01