California Employee, Applicant, and Agent Privacy Notices

Effective July 1, 2024.

This Notice to California Residents: Prospective or Current Colonial Life Employees, Independent Contractors, Agents, and Brokers (“Notice”) supplements the Colonial Life 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
Consumer Rights
Exercising 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 in their roles as prospective or current Colonial Life employees, independent contractors, or agents:

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, 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; 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	None.
Biometric Information	Fingerprints, facial recognition scans.
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.	Colonial Life may use inferences drawn from information collected about prospective or current employees, independent contractors, or agents to determine suitability for hiring, retention and/or promotion in accordance with applicable law.
Sensitive Personal Information	N/A. We do not collect sensitive personal information as that term has been defined under the CPRA. All information collected falls under the definition of personal information.

Colonial Life will retain the information it collects about prospective or current employees, independent contractors, or agents 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
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
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:

Colonial Life Business Operations. To assist in managing Colonial Life's day to day business operations, including management of relationships between independent agents, brokers, and Colonial Life.
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.
Securing and Protecting Systems: Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
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:

Disclosed for a Business Purpose
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; 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, medical information, or health insurance information. (Some personal information included in this category may overlap with other categories.)	Vendors who provide services to Colonial Life; 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; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.
Commercial information	None.
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.	Vendors who provide services to Colonial Life.
Geolocation data	IP Address.	Vendors who provide services to Colonial Life.
Audio, electronic, visual, thermal, olfactory, or similar information	Voice recordings, CCTV, photographs, videos.	Vendors who provide services to Colonial Life; 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; 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; regulators or government entities; parties to whom consumers have directed or authorized disclosure; Colonial Life affiliates.

No Selling or Sharing with Third Parties

We do not sell or share (as those terms are defined under the CCPA) any personal information of any prospective or current employees, independent contractors, agents, or brokers.

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 or share your personal information, so no opt-out is necessary.
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. However, we do not collect sensitive personal information about prospective or current employees, agents, independent contractors, or brokers, 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 any of your 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 link above, please contact us at privacy@unum.com or 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.

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 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 privacy Notice or any related policies or practices, please contact us at privacy@unum.com or 1-877-684-1241.