California Resident Privacy Notice

Effective July 1, 2024

FOR CALIFORNIA RESIDENTS

This Notice to California Residents (“CA Notice”) supplements the Unum Group Privacy Notice and serves to inform California residents of Colonial Life’s collection of their information (“Notice at Collection”) and their rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”) and to provide additional important information required by the CCPA.

Collection of Information
Sources of Information
Purposes of Collection of Information
Disclosure of Information
Your Consumer Rights
Exercising Your Rights
Contact Colonial Life for Additional Information

COLLECTION OF INFORMATION

In the preceding twelve (12) months, Colonial Life has collected the following categories of personal information from or about consumers using the application, website, or services to which this policy applies:

CATEGORY	EXAMPLES
Identifiers	Name, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Any categories of personal information described in subdivision (e) of Section 1798.80.	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. (Some personal information included in this category may overlap with other categories.)
Characteristics of protected classifications under California or federal law	Age; ancestry and national origin; gender identity or expression; genetic information; marital status; medical conditions; mental or physical disability; military or veteran status; pregnancy, childbirth, breastfeeding or related medical conditions; race; religion; sex and gender; sexual orientation.
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information	None.
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Geolocation data	IP Address.
Audio, electronic, visual, thermal, olfactory, or similar information	Voice recordings, CCTV, photographs, videos.
Professional or employment-related information	Occupation, title, employer, resume, or employment history.
Education information	Certificates; licenses; grades, disciplinary actions, or assessments.

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Customer profiles, product profiles, job candidate assessments.
Sensitive Personal Information	Personal Information collected regarding health.

Colonial Life will retain such information until: (1) it has met any legal obligations for retention; and (2) it is no longer necessary for the business purpose for which it was collected.

SOURCES OF INFORMATION

We may collect the personal information described above from the following sources:

Directly from consumers or indirectly from consumer interactions with our technologies, or our websites
From authorized agents or others on a consumers behalf (including employers)
Brokers/agents
Beneficiaries or other individuals associated with an insurance company
Government agencies or other regulatory bodies
Publicly available databases
Other parts of our organization, including our parent company, subsidiaries, and affiliates
Our service providers, such as payment processors, website hosting providers or third-party data companies
Other insurers
Consumer reporting agencies
Financial institutions

PURPOSES OF COLLECTION OF INFORMATION

We may use the personal information we collect for one or more of the following purposes:

Providing Colonial Life Products and Services: Providing services to consumers and our business customers, including the following activities: providing and servicing insurance policies and administering claims, data analysis, pricing, underwriting and audits, product enrollments, reinsurance, and providing Colonial Life's non-insurance services and products to consumers.
Legal and Regulatory Compliance. Meeting internal and regulatory compliance requirements, responding to regulatory exams, conducting internal and external audits, and to otherwise response to governmental or regulatory inquiries and related obligations.
Analytics and Development. Developing new products, enhancing, improving or modifying our services, identifying usage trends, conducting internal research for technological development and demonstration.
Marketing: Advertising and marketing, determining the effectiveness of our promotional campaigns, auditing related to counting ad impressions to unique visitors, verifying quality and positioning of ad impressions and related activity.
Securing and Protecting Systems. Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
Error Remediation: Debugging to identify and repair errors that impair existing intended functionality of our web site, mobile application, or services.
Employment. Maintaining information regarding Colonial Life's workforce and potential new hires including: processing an application for employment, including reviewing references, background checks, and related analysis of a candidates application; maintaining information about employees required by law or necessary to administer benefits or otherwise support employees.

DISCLOSURE OF INFORMATION

Disclosure for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information to the following entities for us to operate our business, and provide services to consumers and for our service providers or contractors to perform services for us:

CATEGORY	EXAMPLES	RECIPIENTS
Identifiers	Name postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Any categories of personal information described in subdivision E of Section 1798.80.	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. (Some personal information included here may overlap with other categories.)	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Characteristics of protected classifications under California or federal law	Age; ancestry and national origin; gender identity or expression; genetic information; marital status; medical conditions; mental or physical disability; military or veteran status; pregnancy, childbirth, breastfeeding or related medical conditions; race; religion; sex and gender; or sexual orientation.	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Biometric Information	Fingerprints, sleep, health, or exercise data.	Vendors who provide services to Colonial Life; Colonial Life affiliates.
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.	Vendors who provide services to Colonial Life; Colonial Life affiliates.
Geolocation data	IP Address.	Vendors who provide services to Colonial Life; Colonial Life affiliates.
Audio, electronic, visual, thermal, olfactory, or similar information	Voice recordings, CCTV, photographs, videos.	Vendors who provide services to Colonial Life; Colonial Life affiliates; governmental entities to the extent necessary to protect life or property or to assist in related investigations.
Professional or employment-related information	Occupation, title, resume, employer or employment history.	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Education information	Certificates; licenses; grades, disciplinary actions, or assessments.	Vendors who provide services to Colonial Life; brokers or agents; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Customer profiles, product profiles, job candidate assessments.	Vendors who provide services to Colonial Life; brokers or agents; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Sensitive Personal Information	Personal information collected regarding health.	Vendors who provide services to Colonial Life; parties to whom consumers have directed or authorized disclosure.

Disclosure through Sharing with Third Parties

We do not sell personal information of any consumers. We may use cookies and related tracking technologies such as web beacons, pixel tags, and flash objects (collectively “Cookies”) to collect information about consumer visits to our website and then share that information with third parties such as advertisers, social media platforms, and analytics companies to deliver advertisements to consumers. Information collected about a consumer on our website that is shared with third parties could be combined with other information that said consumer provided to them or that they’ve collected from said consumer’s use of their services.

SHARED WITH THIRD PARTIES

CATEGORY	EXAMPLES	THIRD PARTIES TO WHOM THIS INFORMATION HAS BEEN SHARED
Internet or other electronic network activity information	Including, but not limited to, call logs, text messages or emails (content), browsing history, search history, and information regarding a consumer’s interaction with an internet website application, data related to a user activity (browser visits), cookies, advertisements, or other similar technologies.	Vendors who provide services to Colonial Life
Geolocation data	Physical location or movements, geo-location data (IP Address).	Vendors who provide services to Colonial Life

YOUR CONSUMER RIGHTS

As a California Resident, you may have the following rights with respect to your personal information, subject to applicable exceptions under law:

Right to Know What Personal Information We Have Collected.	You have the right to know what personal information we have collected about you, including the categories of such information, the categories of sources of such information, the purpose for which we collected, sold, or shared the information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.
Right to Correct Inaccurate Personal Information.	You have the right to correct inaccurate information about you that we have collected and maintain.
Right to Request Deletion of Personal Information.	You have the right to delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
Right to Opt-Out of Selling or Sharing Personal Information.	You have the right to opt-out of selling or sharing your personal information. We do not sell your personal information, so no opt-out is necessary. We do share your personal information as described in this notice. You may opt out of such sharing as set forth in Section F, below.
Right to Limit Disclosure of Sensitive Personal Information	You have the right to limit the use or disclosure of your sensitive personal information to that use which is necessary to provide the goods or services you have requested or other uses permissible under Section 1798.121 of the CCPA. We do not use or disclose your sensitive personal information for any reason other than those permitted under Section 1798.121, so no request to limit is necessary to exercise this right.
Right of No Retaliation Following Opt-Out or Exercise of Other Rights.	You have a right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the CCPA.

EXERCISING YOUR RIGHTS

To exercise your right to opt-out of sharing your personal information, please click the following link to be directed to a web form to complete your request: Do Not Sell or Share My Personal Information.

To exercise any of your other rights available under the CCPA, please click the following link to be directed to a web form to complete your request: Individual Rights Request.

If you wish to exercise your rights under applicable law, but do not wish to do so through the links above, please contact us at privacy@unum.com or call 1-877-684-1241.

Before we fulfill any of your requests, we are required to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of asking a series of questions to verify your identity. We will not deny you services or discriminate against you because you exercise any of the consumer rights described in this section. We try to process requests within 45 days of receiving the request. If we need more time or additional information to fulfill your request, we will let you know that we need additional time and why.

Given the nature of Colonial Life's insurance operations, much of the information we collect from or about consumers is not subject to the CCPA including the rights identified above. For example, the vast majority of the personal information we collect and process about consumers is subject to the requirements of the Gramm-Leach-Bliley Act and/or the Health Insurance Portability and Accountability Act, exempting such personal information from application of the CCPA. Furthermore, the CCPA restricts the above-mentioned consumer rights in situations where a business may need to retain the information for business purposes, to complete transactions you have requested, to comply with legal obligations, or for other purposes as required or permitted by applicable law.

You have the right to use or designate an authorized agent to submit requests on your behalf. If an authorized agent submits a request to know or a request to delete on your behalf, we may require that you provide the authorized agent written permission to do so. To designate an authorized agent, please contact us at privacy@unum.com or call 1-877-684-1241. Colonial Life may request signed permission designating the authorized agent to submit the request or a properly executed power of attorney that describes you, your designated authorized agent, and the purpose of the designation. If you provide the authorized agent with signed permission, we request that you also verify your own identity with us directly and confirm that you provided the authorized agent permission to submit the request.

CONTACT COLONIAL LIFE FOR ADDITIONAL INFORMATION

Colonial Life is dedicated to ensuring that consumers understand their rights regarding the use of their personal information. If you have any questions about this CA Notice or any related policies or practices, please contact us at privacy@unum.com or call 1-877-684-1241.