California Consumer Privacy Act Notice

Pan-American Life Insurance Company, Pan-American Assurance Company and Mutual Trust Life Insurance Company, a Pan-American Life Insurance Group Stock Company (collectively, “PALIG”) are committed to protecting your privacy and provide this Notice to California residents (“you”) in order to explain the categories of Personal Information that we collect, use, and disclose, and additional rights that may apply to you.

Under the California Consumer Privacy Act of 2018 (“CCPA”), “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Collection of Personal Information

PALIG may collect the following types of personal information from you:

Category	Examples
Identifiers	Name, contact information, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver's license number, passport number, among others.
Personal information, as defined in the California customer records law	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, or benefits information.
Characteristics of protected classifications under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.
Commercial information	Transaction information and purchase history, such as records of personal property, products or services purchased, obtained, or considered.
Biometric information	Fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar activities	Browsing history, search history, information on a consumer's interaction with our website, application, or advertisement.
Geolocation data	Physical location or movement about a particular individual or device.
Audio, electronic, visual and similar information	Call and video recordings.
Professional or employment-related information	Current or past job history or performance evaluations.
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, trends, and attitudes.

Obtaining Personal Information

Directly from you For example, when you fill out a form or post on our website, engage with us on social media or at events, or when contact us.
From our clients or other third parties For example, when your employer, insurance brokers or agents or credit organizations provide information about you.
Indirectly from you For example, when we and our service providers use cookies, third party tags, log files, to automatically collect information about the use of our Sites including. Such as unique device identifiers, IP address; collection date; web pages viewed; and email clicks or other actions taken. Further information about our use of cookies can be found in our Online Privacy Policy.

Use of information

We use your information to provide you a service, for example, to provide you a quote or create an account in our website.
To administer your policy, for example, to bill you, communicate with you or administer a claim.
To provide you newsletters or offer you new products.
To invite you to our events.
To manage your accounts with us.
To process your transactions and payments.
To provide you customer service.
To personalize our website and give you and experience relevant to your needs and interests.
To keep our website, products and services up to date, secure and accurate.
To perform identity verification.
For research, product development and benchmarking.
To respond to law enforcement requests, when applicable, and to comply with our internal policies and procedures.
To protect our business operations, secure our network and information technology, assets and services.
To prevent and detect fraud, unauthorized activities, unauthorized access and other misconduct.
To operate, manage, and maintain our business, perform accounting and audits.
To maintain records.
To enhance the ability of visitors to browse and load website content.

Disclosure of personal Information

Within PALIG. We may share your Personal Information with our controlled affiliates, subsidiaries and branches to serve you, as listed above.
With Third Parties. We may share your Personal Information with trusted third parties, who provide certain services to us, or who cooperate with us on projects; however, we do not rent, sell or otherwise disclose personal information with such third parties for their own direct marketing use.
With the Government or Public Authorities. We may share your Personal Information upon their request or when we choose to cooperate with such authorities pursuant to a legal matter or matter of safety.
With other users of social media when you choose to disclose information based on your actions (for example, by posting user content) or your privacy choices.
With your benefit plan’s plan sponsor or plan administrator to permit them to determine eligibility, qualification or confirmation of a promised incentive or reward to you.

Rights under CCPA

If you are a California resident, you are entitled to the following rights:

Receive an Initial Notice: to be notified at or before the point of collection of the categories of personal information collected and the purposes for which such categories are used.
Submit a Verifiable Request to Know: customers may request that we disclose the following information gathered about them in previous 12 months:
1. Categories of personal information we collected about you and the sources we used for such collection.
2. The specific Personal Information we collected about you.
3. The business or commercial purpose for collecting such Information.
4. The categories of Personal Information about you that we shared or disclosed.
5. The parties with who we shared your Personal Information

Once we receive and verify your request, PALIG is committed to deliver this information, free of charge, either by mail or electronically in a portable and, to the extent technically feasible, useable format.

California residents may exercise their right to Requests to Know up to twice every 12 months.

Submit a Verifiable Request to Delete Personal Information: you have the right to request us to delete Personal Information that we collected about you (subject to certain exceptions established by law). Once we receive and verify your request, we will strive to delete your personal information from our records, unless an exception applies. There may be instances when we cannot delete personal information because the personal information may be:

Necessary to complete a transaction or service you requested;
Needed for security purposes;
Needed to identify and repair system errors;
Needed for the exercise of free speech or exercise another right provided for by law;
Necessary to comply with the California Electronic Communications Privacy Act;
Necessary for internal business purposes; or
Needed to comply with laws or legal obligations.

Not Being Subject to Discrimination: you are protected against discrimination based on the exercise of your CCPA rights. Once you exercise your rights, we will not:

Deny you services.
Charge you different prices or rates, or impose penalties.
Provide you a different level or quality of services.

Submitting a Request to Know or to Delete Personal Information

To make the requests described above, please:

Email us: privacy@palig.com

Call us: 1-877-939-4550

Keep in mind that once we receive your request, we will contact you to request information that allows us to verify your identity and properly understand and evaluate your request. We will respond to your request consistent with applicable law.

Changes to this CCPA Notice

We may change or update this CCPA Notice from time to time. When we do, we will post the revised notice on this page with a new “Last Updated” date.

Right to Request Accessible Alternative Format

This notice has been designed to be accessible to people with disabilities. If you are having difficulty viewing or navigating the content on this notice, please email our team at adacompliance@palig.com with “Disabled Access” in the subject line. You can also reach us via phone by calling 1-877-939-4550.

Last Updated March 2022

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