Everly Insurance Company Privacy Statement

Effective Date: 10/01/2024

Definitions

What types of information does Everly collect, store and use?

• 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, or ethnicity or disability. 
• Professional or employment information: your job title, job history, 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, assets and liabilities, including records of personal property ownership. 
• Educational information not publicly available: your level of education and schools attended, your 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 and genetic information and voice signatures 
• Geolocational data: If you share your location in your online profile, we will collect that information.  We may also determine location by using other data from your online and mobile devices.   
• Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a Website, online application and 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.

How do we use your Personal Information?

• 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; and 
• For marketing and analytic purposes.

How and when do we disclose your Personal Information to other parties?

• Our affiliates: We disclose your Personal Information, including information about your transactions and experiences, with other Everly affiliated companies in order to assist in the delivery of services to you. They may use your information for marketing purposes, except for California customers and as explained below. 
• Third parties providing services to us or on your 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”). We do not allow service providers to use our customer information for their own marketing or other purposes. 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 arrangements: We share your Personal Information with companies, such as broker-dealers and insurance producers/agents, 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. Persons acting in a fiduciary or representative capacity or holding a legal or beneficial interest relating to the consumer. 
• Consumer reporting agencies: We share your Personal Information with consumer reporting agencies during the underwriting process and at other times, as required by law. 
• Your health and medical information and related consumer reports: We do not share your Protected Health Information that we receive from any source, including consumer reporting agencies, with any of our affiliates or any other company, 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; and/or 
• 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 credit scores, motor vehicle records and other non-health consumer reports: We do not share this information with other Everly affiliated companies 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.   
• Judicial, regulatory and law enforcement bodies: We may disclose your Personal Information to judicial, regulatory or law enforcement bodies, including auditors and examiners hired by the state, in order to: 
• Comply with any 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 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, and our accountants, attorneys and auditors; and/or 
• 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. 

What are your rights over your Personal Information?

• 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. 

• 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.

Information Security

Children/Minors

Does this Website/mobile application include third party content and links to third party Websites/mobile apps?

Changes to this Privacy Policy

Our Cookie Policy

What are cookies? 

Why do we use cookies and other tracking technologies?

Cookies served through our Website and app

• 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 Website. We also partner with one or more third parties (such as advertisers and ad networks) to display advertising on our Website 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 Website 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
• . 

How can I control 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:  
• 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 cookies, visit 
• http://www.allaboutcookies.org/
• . 

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

What is personal information under the CCPA?

• 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 limit the use of your sensitive personal information; 
• The right to correct certain personal information we collect;  
• The right to delete some or all of the personal information we collect, subject to certain exceptions; and/or 
• The right to opt-out of our sale of your personal information, if we sell your personal information. 

• 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 

Purposes for which we use your data 

• 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. 

Children Under the Age of 16

EXERCISING YOUR RIGHTS UNDER CALIFORNIA’S PRIVACY LAW

Right to know and access 

• 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.

Right to correct

Right to delete

Right to non-discrimination if you exercise your consumer 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 

HOW TO SUBMIT A REQUEST TO EXERCISE YOUR RIGHTS

Authorized Agent 

• 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 

• 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.

• 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.

HOW WE WILL RESPOND TO YOUR REQUEST

Changes to This California Consumer Privacy Act Disclosure

How do I get answers to my privacy questions?

• Write us at: Everly Life Insurace Company
• Call us at: 
• 1-855-290-0529
• Email us at: 
• privacy.inquiry@everlylife.com