Privacy Notice for California Residents
This Privacy Notice for California Residents (this “Notice”) has been adopted by PLICA in light of the California Consumer Privacy Act of 2018 (the “CCPA”), as modified by the California Privacy Rights Act of 2020 (the “CPRA”), and supplements PLICA’s Privacy Policy which can be found at https://www.puritanlifeinsurance.com/privacy-policy. In this Notice, “we,” “us,” “our,” “Company” and “PLICA” refer to Puritan Life Insurance Company of America.
Scope of the CCPA
This Notice applies solely to California residents. As discussed in detail below, the CCPA provides California residents the right to know what personal information PLICA collects, sells, or discloses; the right to access their personal information; the right to correct their personal information; the right to limit our use of their sensitive personal information; and the right to request deletion of their personal information.
Personal information is defined by the CCPA as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person (for example, name, address, telephone number, Social Security number, and driver’s license number). It does not include anonymized, de-identified, or aggregated information.
However, the CCPA does not apply to all types of personal information, including information that we already protect under other laws, including the federal Gramm-Leach-Bliley Act (“GLBA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”) and the California Financial Information Privacy Act (“CFIPA”).
Collection, Use and Disclosure of Personal Information
PLICA’s Privacy Policy explains the Company’s information collection policies. It covers the types of information PLICA collects, how that information is collected, and the sharing of that information.
In the past 12 months, we have collected the following categories of personal information relating to California residents. These categories are defined by California law. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals. In addition, as mentioned in the “Scope of the CCPA” section, personal information which is governed by HIPAA, CMIA, GLBA and/or CFIPA is exempted from the CCPA.
We have shared information in each of the following categories with our affiliates and service providers for our business purposes within the last 12 months. We may also receive requests for information from regulatory authorities, our auditors and/or our insurers and legal advisors. If requested from such parties, we would share your personal information as appropriate. In the event we are acquired by or merge with another company, or otherwise undergo a change of control, we may also share each of the below categories as part of that transaction.
| Category of Personal Information Collected | Source | Purpose of Collection, Processing, and Disclosure | Third Parties to which Personal Information has been Disclosed |
|---|---|---|---|
| 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 | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| 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, health insurance information | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims. Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Characteristics of protected classifications under California or federal 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 | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding the consumer’s interaction with an internet web site, application, or advertisement | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing functionality. Research and analysis purposes. Complying with a legal obligation. | Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Audio, electronic, visual, thermal, olfactory or similar information | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Professional or employment-related information | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Research and analysis purposes. Complying with a legal obligation. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Education information | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Research and analysis purposes. | The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Inferences (defined as “the derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data”) drawn from any of the information [defined as personal information under the CCPA] to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | From you directly, whether on our websites or in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From our service providers. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Research and analysis purposes. | Providing our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services. Analyzing and amending our products and services. Research and analysis purposes. |
| Category of Personal Information Collected | Sources | Purpose of Collection, Processing, and Disclosure | Third Parties to which Personal Information has been Disclosed |
|---|---|---|---|
| Social security, driver's license, state identification card, or passport number | From you directly, in person, in applications or in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | From you directly, in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Racial or ethnic origin, religious or philosophical beliefs, or union membership | From you directly, in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Health information | From you directly, in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Personal information concerning a consumer’s sex life or sexual orientation | From you directly, in person, or in applications or questionnaire responses you submit in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. From public records or published databases. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
| Citizenship or immigration status | From you directly, in person, in applications or in connection with one of our products or services or other business purposes. From others on your behalf, such as if you are a named beneficiary or associated with a product held by one of our customers. From our service providers. | We use all or a subset of the personal information in this category:
| The members of our affiliated group of companies insofar as reasonable to administer our company. Service providers that assist us in providing products and services to you, including the following activities:
Courts or governmental entities where there is a binding obligation, whether legal or otherwise. |
Retention of Personal Information
In general, we aim to keep personal information only for as long as necessary and only for the reason(s) we collected it. It may be necessary to keep personal information longer than our official retention periods for legal or regulatory reasons, including litigation. To support us in managing how long we hold personal information and our record management, we maintain a data retention policy which includes clear guidelines on retention and deletion.
We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:
- How long the record is needed to provide you with the products and services you request
- How long the record is needed to support and enhance our operational processes
- How long the record is needed to protect our rights and legal interests
- How long the record must be retained to comply with applicable laws and regulations
The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.
Personal Information of Minors
We do not knowingly collect personal information directly from individuals under 16 years of age. We may collect personal information regarding individuals under 16 years of age from their parents or legal guardians, but only as necessary to provide our services.
Your Rights Under the CCPA
The CCPA provides California residents with certain rights regarding their personal information. Below is a description of the rights the CCPA affords and how you may exercise those rights with PLICA. Please note, these rights do not apply to our employees .
Right to Access/Know
You have the right to request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, the categories of sources from which we collected your personal information, our business or commercial purpose for collecting your personal information, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for which we shared your personal information. You also have the right to know if we have sold or disclosed your personal information. Where possible, the information will be delivered in a readily usable format that allows you to transmit the information from one entity to another without any hindrance.
Right to Correct
You have the right to request we correct any mistakes in your personal information or update your preferences; we may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect; data solely retained for data backup purposes is generally excluded.
How to Submit a Request
You or a person we can validate as being authorized by you may make a verifiable consumer request to exercise your rights discussed here by contacting PLICA through one of the following methods:
- Filling out this online form
- Calling 1-888-474-9519 and pressing 5. Inform our customer service representative that you wish to submit a “Right to Access/Know” and/or a “Right to Correct” and/or a “Right to Request Deletion” request.
We understand the importance of protecting your personal information. This means that we will need to verify your identity in order to respond to your request. Therefore, we will ask you for certain information that will assist us in identifying who is making the request and confirm that the person making the request is really whom they say they are. If someone authorized by you makes a verifiable consumer request and provides a notarized copy of the authorization or an active power of attorney, we will provide the information. You may also make a verifiable consumer request on behalf of your minor child. The information provided to us to verify the request will be used solely for verification purposes and will not otherwise be maintained by PLICA. Making a verified consumer request does not require you to create an account with us. Unless we specifically notify you otherwise, we will respond to all requests for information under the CCPA within forty-five days of the date we receive the request.
In the case that we are not able to verify the identity of the requestor based on the information provided to us upon the initial request, we will request addition information to help us complete the verification. We cannot respond to your request or provide you with personal information if we cannot both verify your identity or authority to make the request and confirm that the personal information that we have relates to you.
The CCPA limits you and your authorized agents to submission of two Right to Know requests within a twelve-month period. Right to Know Requests only cover personal information that we have collected within the preceding twelve months.
Notification of Changes
We reserve the right in our sole discretion to change, modify, add, or delete portions of this Notice. We will provide notice of such changes only by posting the updated Notice on our website and changing the “Last Updated” date listed above, by posting a notice on the website or by sending you an email. We encourage you to review our Notice each time you visit our website to see if it has been updated since your last visit. Your continued use of the website following our notice of any such changes constitutes acceptance of those changes.
Contacting Us
If you have any questions about this Notice or our privacy practices, please contact us at 888-474-9519. You can also write us at: Compliance Team 7272 East Indian School Road, Suite 100 Scottsdale, Arizona 85251