Legal & General America Privacy Policy

Your privacy is important to us.

Your privacy is important to us. At Legal & General America (Banner Life Insurance Company, William Penn Life Insurance Company of New York, and Legal & General America Retirement Services, Banner’s retirement division), we understand that the information you provide to us or we collect about you is private. This privacy policy is provided to you so that you will understand what Legal & General America, as a “data controller” or “business”, does with the personal information you provide to us and the measures we take to protect your privacy.

In essence, we collect information about you to provide you with life insurance and annuity products, to provide services to you, or to provide you with information about our products and services. Sometimes this information comes directly from you to us (either via our website, when you call us or when you file a claim), and other times it come to us indirectly, particularly through independent agents or financial advisors.  We are also required to collect certain information to meet legal and regulatory requirements.

You may have certain rights with respect to this personal information as well, so we encourage you to read this Policy carefully, and to contact us if you have any questions.

If you are an employee or contractor of Legal & General America please refer to our Employee Privacy Policy for information on how we process your personal information.

What type of information does Legal & General America collect and maintain?

As regulated insurance carriers, the Legal & General America companies are required by state laws and regulations to collect and maintain certain information about our customers. The information we collect also enables us to provide you with services and products that meet your individual needs and to provide you with the high level of customer care that you have come to expect from Legal & General America.

The types of personal information we collect and share depend on the product or service you have with us or have requested information about. 
We typically collect information directly from you or through our independent agents and business partners (our “partners”). We may also collect personal information about you through your interactions with our web site and other online systems. In addition, we may create records of personal information about you in the course of providing services or products to you, either directly or through our partners. We also collect information about you from third-parties, including government agencies and our service providers. In all cases, we collect personal information about you in accordance with the principles outlined in this Policy and applicable law.

The table below provides more detailed information about the types of information we collect and why:

Information we collectWhy we collect itLawful basis
When you apply for, inquire about, or obtain a product or service from us, we collect a range of identifiable information, which can vary depending on the circumstances, but may include your: name, address, telephone number, Social Security Number or other government identification, email address, financial information (such as employment and income history, banking relationships, assets and liabilities), financial account information, health information, demographic information, driving records, and information about your transactions with us (such as payment history and account balances). This information is necessary to provide you with products, services, or information you requested or to take steps at your request prior to providing you with a product or service, for us to comply with a legal obligation, or for us to carry out related business and operational activities.Necessary for the performance of a contract or in order to take steps to enter into a contract; necessary to meet legal requirements; legitimate interest.
To the extent we engage in live quoting processes, we may collect from you a picture of yourself, from which we will draw inferences of your age, gender, and body mass index (BMI), and other indicia of insurability.This information is helpful in providing you with our products and services. You will be asked to confirm the information, as we will not rely on the information gleaned from the photograph alone. Consent
When you apply for, inquire about, or obtain a product or service from us, we may also obtain your credit history from consumer reporting agencies.This information is necessary to provide you with products, services, or information you requested or to take steps at your request prior to providing you with a product or service.Necessary for the performance of a contract or in order to take steps to enter into a contract; legitimate interest; consent.
If you are a beneficiary making a claim, we may require your name, address and proof of identity.This information is necessary to confirm your eligibility as a beneficiary, and in order to administer the claim.Necessary for the performance of a contract for which you may be the beneficiary.
If you do business with one of our partners, we may collect personal information about you to allow us to identify and offer you products that may be of interest to you. This information may include your name, address, contact information, Social Security number or other government identification, financial information, demographic information, commercial information about your purchasing history, employment and professional information, and inferences based on this information regarding your preferences.This data is used to offer products and services that may be of interest to you as permitted and subject to applicable law.Legitimate interest.
If you request or agree to receive electronic communications or mailings from us, we may collect your name, email, phone number, or physical address. This information is necessary to send you the information you have requested.Consent; legitimate interest.
If you partner with us or are interested in partnering with us, we may collect your name, address, telephone number, email address, and information about your agency.This information is necessary to provide you with services, to provide you with information about our partner services, and to give your access to restricted parts of our web sites. Necessary for the performance of a contract or in order to take steps to enter into a contract; legitimate interest.
If you apply for a job with us, we will collect your name, address, telephone number, Social Security Number or other government identification, email address, and employment and educational history.This data is necessary to determine whether to extend an offer of employment, or approve your application to represent us, as applicable. This data is also necessary to comply with our legal obligations.Necessary in order to take steps prior to entering into an employment agreement; Legitimate interest.
If you receive a conditional offer of employment from us, we may conduct a credit and/or criminal history check, in accordance with local law.This data is necessary to determine whether to confirm an employment offer or an application to represent us, as applicable.Consent; necessary to meet legal requirement; legitimate interest.
If you choose not to provide us with personal information, or withdraw your consent to processing (where applicable), it may affect our ability to provide you with products or services you have requested.

California Residents

The personal information about you that we collect includes information within the below categories of data. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect or disclose some information within that category. It does not necessarily mean that we collect or disclose all information listed in a particular category for all our customers, nor does it imply that California law applies to all the below categories of data.

 

CategorySourcePurpose of processingDisclosed for a Business Purpose in last 12 months?Types of Third Parties Shared With

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

This information is collected directly from you, your agent, our partners, or our service providers.This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.
If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, and organizing interviews.
YesAffiliates and service providers.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.This information is collected directly from you, your agent, consumer reporting agencies, our partners, our service providers, or public records.

This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.

This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.
If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, and organizing interviews.

YesAffiliates and service providers.
Characteristics of classes protected under federal or California law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.
If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, organizing interviews, and providing any necessary accessibility accommodations.
YesAffiliates and service providers.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.This information is collected directly from you, your agent, consumer reporting agencies, our partners, our service providers, or public records.This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
This data, as well as information regarding your purchasing tendencies obtained from our business partners, is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.
YesAffiliates and service providers.
Biometric information, which includes physiological, biological or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. To the extent we collect this information, it is collected directly from you, your agent, or our service providers, with your consent.This data, to the extent we collect it, is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or for compliance management.
This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.
NoAffiliates and service providers.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.This information is collected through the use of cookies and similar technologies.

This data is used for marketing purposes, including offering you products that may interest you through both direct and partner advertising.

It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
YesAffiliates and service providers.
Geolocation dataThis information is collected through the use of cookies and similar technologies. This data is processed for marketing purposes, including offering you products that may interest you through both direct and partner advertising.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management.YesAffiliates and service providers.
Audio, electronic, visual, thermal, olfactory, or similar informationThis information is collected directly from you, your agent, or our service providers.This data (e.g. voice signatures for e-applications as well as recordings of customer service calls) is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management.YesAffiliates and service providers.
Professional or employment-related informationThis information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.

This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management.

If you are an applicant, this data is processed in connection with a number of our operational functions, including setting up an electronic job applicant HR file, managing your application, and organizing interviews.
YesAffiliates and service providers.
Inferences drawn from any of the above categories of information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesThis information is collected from consumer reporting agencies, our partners, or our service providers.This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.  It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.YesAffiliates and service providers

 

International Users
This website is based and administered in the United States of America. The website is governed by the laws of the United States and is not directed at users based outside of the United States.

Information about Cookies and Do Not Track

While you are on-line, your computer saves so-called “cookies.” These are small files that control how our website is displayed and operates. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our website more user-friendly, effective and secure.  Some cookies are even necessary to the functioning of our website.

What types of cookies do we use?
Third-party cookies belong to and are managed by other parties, such as Google Analytics or the other service providers indicated below. These cookies may be required to render certain forms, such as email list sign-up, or to allow for some advertising outside of our website.  In particular, Google Analytics allows us to understand how our media campaigns work and how you interact with our website in order to improve the user experience. 
Session cookies are temporary cookies that are used to remember you during the course of your visit to the website, and they expire when you close the web browser.

Persistent cookies are used to remember your preferences within the website and remain on your desktop or mobile device even after you close your browser or restart your computer. We use these cookies to analyze user behavior to establish visit patterns so that we can improve our website functionality for you and others who visit our website. These cookies also allow us to serve you with targeted advertising and measure the effectiveness of our site functionality and advertising.

Social Media Cookies
We also embed Social Media Plugins, like Facebook, Instagram, and Snapchat, which also store cookies. These cookies allow our users to share information with the respective social network but also allow the network operator to identify the user and store information about the usage of the Website by the user in his/her profile. 

How are cookies used for targeted advertising purposes?
Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable us to understand and improve the delivery of ads to you, and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Although we do not use cookies to create a profile of your browsing behavior on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal data that we collect to advertisers. You can choose not to enable off-site and third-party-informed advertising by adjusting your cookie settings. Doing so will not remove advertising from the pages you visit, but, instead, will result in the ads you see not being matched to your interests by any cookies you choose to delete or block.

How are third party cookies used?
For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies, and we encourage you to consult the privacy policies of these third party vendors on their websites for information regarding their use of cookies.

 

CookieDescriptionMore details regarding the privacy practices of our partners
Microsoft (Bing.com)The two bing.com cookies we use are targeted advertising cookies, and they are: (i) MUID, which is stored for 1 year and is used by Microsoft as a unique identifier. The cookie is set by embedded Microsoft scripts. The purpose of this cookie is to synchronize the ID across many different Microsoft domains to enable user tracking; and (ii) MUIDB is also stored for 1 year and is used by Microsoft to carry out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

https://about.ads.microsoft.com/en-us/resources/policies/microsoft-advertising-click-measurement-description-of-methodology

 

https://privacy.microsoft.com/en-US/

FacebookFacebook is a targeted advertising cookie which helps you stay in touch with your network through their website/ mobile application. LGA makes it easier for you to share any content of interest on Facebook and sometimes, we may present you with some targeted advertisements on Facebook based on your engagement with our website(s). Based on the content you have engaged with on our websites, Facebook can use that information to enhance their own services, present you with targeted advertising, and track the performance of our advertising campaigns. Personal data gets deleted after 1 year.

https://en-gb.facebook.com/help/238318146535333?helpref=hc_global_nav

 

https://en-gb.facebook.com/help/568137493302217

 

https://www.facebook.com/policies/cookies/

Google AnalyticsWe use Google Analytics as a performance cookie to understand how our media campaigns work and how you interact with our website in order to improve the user experience. Personal data gets deleted between 1 minute and 2 years, depending on the type of analytic.

https://policies.google.com/privacy?hl=en

 

https://tools.google.com/dlpage/gaoptout

Google tracking cookies

(DoubleClick)
Google tracking cookies are targeted advertising cookies which enable us to understand if you complete certain actions on our website(s) after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our websites Google are is able to deliver some targeted adverts across other Google partner websites. Personal data gets deleted between 180-540 days.

https://policies.google.com/privacy?hl=en 

 

https://support.google.com/ads/answer/2662922?hl=en

Google AdSenseThe “_gcl_au” cookie is a targeted advertising cookie set by Google Adsense that is stored for 2 months. This specific cookie is used by Google Adsense for experimenting with advertisement efficiency across websites using their services.
https://policies.google.com/technologies/ads

https://policies.google.com/technologies/types
Google Tag ManagerThe “_dc_gtm_UA-######-##” cookie is a strictly necessary cookie that is held for one minute. This cookie is associated with sites using Google Tag Manager to load other scripts and code into a page. Where it is used it may be regarded as strictly necessary as without it, other scripts may not function correctly. The end of the name is a unique number which is also an identifier for an associated Google Analytics account.https://www.google.com/analytics/tag-manager/use-policy/

https://privacy.google.com/businesses/compliance/
InstagramInstagram helps you stay in touch with your network through their website/ mobile application. We make it easier for you to share any content of interest on Instagram and sometimes, we may present you with some targeted advertisements on Instagram based on your engagement with our website(s). Based on the content you have engaged with on our websites, Instagram can use that information to enhance their own services, present you with targeted advertising, and track the performance of our advertising campaigns. Personal data gets deleted after 1 year. https://help.instagram.com/519522125107875

https://www.facebook.com/policies/cookies/
lgamerica.comThe “ASP.NET_Sessionid” cookie is a strictly necessary cookie placed by Legal & General America as a general purpose platform session cookie, used by such sites written with Microsoft .NET based technologies, and usually used to maintain an anonymized user session by the server.  
LinkedInThe LinkedIn insight tag allows us to perform campaign reporting and unlock valuable insights about website visitors that may come via the campaigns we run on LinkedIn. Personal data gets deleted after 90 days.

https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy

 

https://www.linkedin.com/legal/cookie-policy

 

https://www.linkedin.com/help/lms/answer/65521/the-linkedin-insight-tag-overview?lang=en
PandoraWe embed advertisements within Pandora, that when a viewer clicks on it, they are brought to our website(s). Cookies on our website(s) from Pandora and its partners enable us to understand if you complete certain actions on our website(s) after you have seen or clicked through one of our adverts served via Pandora. Based on the content you have engaged with on our websites, Pandora and its partners can use that information to enhance their own services, present you with targeted advertising, and track the performance of our advertising campaigns. https://www.pandora.com/privacy
SessionCamThese cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Neither we nor SessionCam shares this data with anyone else.
Personal data gets deleted after one year. 

https://sessioncam.com/about-us/

 

https://help.sessioncam.com/hc/en-gb/articles/200812017-SessionCam-Cookies

SnapWe embed advertisements within Snap, that when a viewer clicks on it, they are brought to our website(s). Cookies on our website(s) from Snap and its partners enable us to understand if you complete certain actions on our website(s) after you have seen or clicked through one of our adverts served via Snap. Based on the content you have engaged with on our websites, Snap and its partners can use that information to enhance their own services, present you with targeted advertising, and track the performance of our advertising campaigns.https://www.snap.com/en-US/cookie-policy/
TaboolaDepending on the services provided, Taboola may utilize up to 12 persistent cookies and 3 session cookies, all generally used for targeting/advertising, but with the following specifications: (i) ___cfduid is a strictly necessary cookie associated with sites using CloudFlare, used to speed up page load times, and used to override any security restrictions based on the IP address the visitor is coming from; and (ii) Taboola_mk does not contain any user identification information, but is set if the visitor marks a specific event or content on the website, thereby allowing the website to retarget the specific visitor with similar content; and (iii) _sm_au_c, which is used to check if a user has been authenticated.

https://help.taboola.com/hc/en-us/articles/360004904154-Taboola-s-Trust-Center

 

https://help.taboola.com/hc/en-us/articles/115007287467-Advertising-Content-Policies-Overview

TwitterTwitter provides real time updates from across the globe on the latest trending stories, ideas and opinions from the Twitter accounts or hashtags that you choose to follow. We make it easier for you to share our website content over Twitter. At times, we may present you with some ads on Twitter based on your engagement with our website(s). Personal data gets deleted after 1 year.

https://twitter.com/en/privacy

 

https://help.twitter.com/en/rules-and-policies/twitter-cookies

 

https://support.twitter.com/articles/20170410

 

https://help.twitter.com/en/safety-and-security#ads-and-data-privacy

YouTubeWe embed videos or insert links to videos from YouTube on our website(s). As a result, when you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from YouTube.  Personal data gets deleted between 180-540 days.

https://policies.google.com/privacy?hl=en

 

https://support.google.com/ads/answer/2662922?hl=en-GB

How do I reject and delete cookies?
You can choose to reject or block all or specific types of cookies for our websites and/or the websites of any third party suppliers by changing your browser settings, or, in some cases, through the specific links above. Please note that most browsers automatically accept cookies. Therefore, if you do not wish cookies to be used, you may need to actively delete or block the cookies. If you reject the use of cookies, you will still be able to visit our website but some of the functions may not work correctly. 

You may also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. By using our website without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device.

Do Not Track
Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our services do not currently respond to browser DNT signals. For more information on DNT, see https://allaboutdnt.com/.

Who do we share your personal information with, and why?
We may disclose your personal information to our affiliated companies, when required by law, or to our service providers for the purposes described above. For example, using service providers may be necessary for the administration and maintenance of our IT systems. We may also transfer information, including your personal information, to third parties as necessary to provide the products and services you request, such as underwriting your risk or assisting you in completing a transaction. We require our service providers to provide written assurances regarding the security and privacy protections they have in place to protect any personal information transferred to them, as well as their compliance with our security requirements and any applicable laws and regulations.

As allowed by law, we may from time to time share non-public personal financial information with a non-affiliated third party that performs services or functions on our behalf. These services or functions may include marketing of our own products and services; or financial products or services offered pursuant to a joint agreement between us and one or more financial institutions.

The third parties we may share your personal information with include:

  • independent agents and business partners;
  • third-party service providers;
  • regulatory authorities; 
  • our auditors and legal advisors; and
  • relevant industry self-regulatory bodies (such as FINRA). 

We do not intentionally sell your personal information, or intend to in the future, and we have contracts with our service providers to prohibit any sale of the personal information we provide them; but if you have any concerns that our third parties might be selling your information, please contact us.  
We may share your information with our corporate affiliates (e.g., our parent company, sister companies, subsidiaries, joint ventures, or other companies under common ownership or control of our ultimate parent company). This sharing is done so that these affiliates can provide services to us, and may be necessary to provide you with services, products, or information you have requested or expressed an interest in.

Your information may only be transferred to another country for processing as permitted, and in compliance with, applicable law.

We may also share your personal information in connection with managing the proposed sale, restructuring, transfer or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organization.

Where do we keep your personal information and how long do we keep it?
We store personal information about you on computer systems operated by or under the supervision of Legal & General America, our affiliates, or our service providers. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws and regulations. 

We generally retain policy or account related information for at least 7 years after expiration of the policy or the closing of an account, and we retain the underlying documentation for any unclaimed property for the reporting period plus at least 15 years. We retain recordings of calls into our call center for 3 years.Any hard copies we receive are imaged and then are securely shredded after 60 days. Any threats of or actual litigation or regulatory inquiries may extend these periods.

How is my personal information secured?
We maintain physical, electronic and procedural safeguards to protect your personal information and prevent unauthorized or accidental use, access or loss. We limit access to personal information about you to those who have a business need for such access. Individuals who process personal information on our, our affiliates, or our partner’s behalf, may do so only in an authorized manner and are required to keep your information confidential. We have policies in place that regulate how our employees and contractors handle information about you. We limit access to our premises and to our computer networks, and take steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach consistent with applicable legal requirements.

Who has access to life insurance policy customer information?
The information that you provide to us is used for company purposes only. Our employees, independent agents of Legal & General America, and service providers have access to your information, and are authorized to review it, only for the purposes of carrying out their official duties and responsibilities. Our employees, independent agents, and service providers are required to keep customer information confidential.

Who has access to annuity customer information?
The information that is provided to us is used for company purposes only. Our employees and service providers have access to your information, and are authorized to review it, only for the purposes of carrying out their official duties and responsibilities. Our employees and service providers are required to keep customer information confidential.

What are my rights?
You may have various rights with respect to the information we have about you depending on the particular information and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not be applicable to our relationship with you or certain information we have about you. 

We may choose to offer these rights to you in the interest of transparency and as an enhanced service to our customers, even if we are not required to under applicable law. 

Privacy Rights under GLBA and the Fair Credit Reporting Act
In general, to the extent we received, obtained, or generated information about you in connection with providing you with a financial service or product within the United States, your rights with respect to that information are generally governed by the Gramm-Leach-Bliley Act (GLBA).   We provide GLBA specific privacy notices to our consumers and customers as required by the GLBA. These notices also address your rights, to the extent applicable, under the Fair Credit Reporting Act. For more information about your rights with respect to this information, including the right to opt-out of some sharing of your information with third parties, you can access our GLBA privacy notices through the following links:

Privacy Rights under the California Consumer Privacy Act or the General Data Protection Regulation
For residents of California, to the extent we have collected information about you that is not governed by the GLBA, you may have the rights described below with respect to personal information about you. These rights may also apply to individuals in the European Economic Area, but only to the extent the European Union’s General Data Protection Regulation (GDPR) applies. 

Subject to certain conditions and limitations, you may have the following rights with respect to personal information about you:
Right of access – You may be entitled to request that we disclose to you personal information we have collected about you, the categories of sources from which the information was collected, the purposes of collecting the information, the categories of third parties we have shared the information with, and the categories of personal information that have been shared with third parties for a business purpose. Data solely retained for data backup purposes is generally excluded.

Right of data portability – In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing this information, we must be able to verify your identity. Data solely retained for data backup purposes is generally excluded.

Rights in relation to inaccurate personal or incomplete data – You may have the right to challenge the accuracy or completeness of personal data that we process about you, particularly credit related data or data that is subject to the GDPR. If it is found that personal data is inaccurate, you may be entitled to have the inaccurate data removed, corrected, or completed, as appropriate.

Right to have personal data erased – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting information, we must be able to verify your identity.  We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with life insurance or annuity products or where required to be retained for regulatory purposes.  Data solely retained for data backup purposes is generally excluded.

Without prejudice to any other administrative or judicial remedy you might have, you may have the right to lodge a complaint with regulators where you live if you believe that we have infringed applicable privacy or data protection requirements when processing personal information about you.

If you chose to exercise any of these rights, to the extent that they apply, U.S. state law prohibits us from discriminating against you on the basis of choosing to exercise your privacy rights. We may, however, charge a different rate or provide a different level of service to the extent permitted by law.   

Privacy Rights under GDPR
The following additional rights may also apply to individuals in the European Economic Area, but only to the extent the GDPR applies:
Right to object to or restrict our data processing – Subject to certain conditions, you may have the right to object to or ask us to restrict the processing of personal data about you. This right will generally only apply if our processing is based solely on our legitimate interests and not some other basis. Objections must be based on grounds relating to your particular situation.

Right to withdrawal of consent – Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent, we will stop processing your personal information for that purpose, unless it is necessary for us to continue processing your information based on another lawful basis. Your withdrawal of your consent won’t impact any of our processing of information about you prior to withdrawing your consent.  The withdrawal of your consent may prevent us from processing any request made by you or offering insurance coverage or services or impede our ability to pay a claim.

Submitting Privacy Requests
Requests to exercise your privacy rights as noted above, to the extent applicable, may be made by at [website] or by calling us  to speak to a customer service representative.

Before providing information you request in accordance with your rights, we must be able to verify your identity. In order to verify your identity, you will need submit information about yourself, including, to the extent applicable, providing your account login credentials or other account information, answers to security questions, your name, government identification number (which you previously submitted), date of birth, contact information, or other personal identifying information. We will match this information against information we have previously collected about you to verify your identity and your request. To the extent you maintain an account with us, we will require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, please submit a notarized special power of attorney.

Children and Minors
We do not knowingly collect personal information directly from individuals under 17 years of age.  Our products and services are not intended for individuals under 17 years of age. No one under 17 years of age should submit or post personal information through our online services.  We may collect personal information regarding individuals under 17 years of age from their parents or legal guardians, but only as necessary to provide our products and services.  For benefit purposes, we may also collect information regarding individuals under 17 years of age from their grandparents, other relatives, or other interested parties.

Changes to this Policy
We reserve the right to change this privacy policy at any time in our sole discretion. If we make changes, we will post the revised policy here, so that you can see what information we gather, how we might use that information, and in what circumstances we may disclose it. When we modify the policy we will also modify the “Effective date” at the top of this policy. If our privacy policy changes in any material respect, we will notify you of such change as required by law.

Legal & General America Affiliates
This notice is provided by: Legal & General America, Banner Life Insurance Company, and William Penn Life Insurance Company of New York.

 

Contact us if you have any questions about your privacy