Talcott Financial Group, Ltd. and affiliated companies in Bermuda, the U.S., and Cayman Islands, (collectively known as “Talcott,” "we" or "our") issue, reinsure, and administer life, annuity, and other insurance products and offer risk assessment and other services for the insurance industry. Our affiliated companies for purposes of this notice, subject to change, include:
This Privacy Policy applies to each affiliated company unless it posts a different privacy policy on its own websites.
This Privacy Policy describes how Talcott collects, uses, and discloses personal information about individuals ("you" or "your") including:
We reserve the right to amend this Privacy Policy at any time in order to address future business or regulatory developments or changes in industry trends. If we materially alter these terms, we will post the revised Privacy Policy and effective date on the Site and provide other notification as required by law.
If you are a policyholder, you will also receive a copy of our Customer Privacy Notice at the start of our business relationship with you and periodically thereafter as required by law.
We use the term "personal information" in this Privacy Policy to refer to information that identifies, relates to, describes, or is reasonably capable of being associated, directly or indirectly, with you. The term personal information does not include, and this Privacy Policy does not restrict, our use or sharing of publicly available information or information that has been anonymized or otherwise modified so that that it cannot be reasonably used to identify you.
We may obtain personal information from or about you in various ways including, but not limited to, the following:
We may use your personal information to:
The personal information about you that we collect includes information within the below categories of data, depending on your interaction with the company. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below refer to the categories of personal information as defined under the CCPA. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all of our customers, or that the CCPA applies to the data (particularly in light of the CCPA’s exclusion for data regulated by the Federal Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), and the Health Insurance Portability and Accountability Act (HIPAA)). View our GLBA privacy notice.
For more information about third party access to your personal information, see the section titled, "When We Share Personal Information."
| Categories of personal information collected in past 12 months | Specific types of personal information collected in the past 12 months | Third party access for business purposes |
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| 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. |
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| 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, 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. |
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| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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| 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. |
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| 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. | Internet browsing history, search history, and interactions with our Site and the Annuities Logon page | Website analytics services |
| Audio, electronic, visual, or similar information. | Recordings of calls to our Call Center | IT and Other Service Providers |
In addition to the categories of information above, we may also collect the following categories of sensitive personal information:
| Categories of personal information collected in past 12 months | Specific types of personal information collected in the past 12 months | Third party access for business purposes |
|---|---|---|
| Social security, driver’s license, state Identification card, or passport number. |
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| 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. |
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| Personal information concerning a consumer’s sex life or sexual orientation. |
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| Health information. |
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Your personal information may be accessible or disclosed for business purposes to the categories of third parties described below. We do not, and do not intend to, sell your personal information for any purpose. We also do not share your personal information for cross-context behavioral advertising purposes, or for purposes unrelated to our business without allowing you to "opt-out" or "opt-in."
Each of these service providers and other third parties (except legal authorities) are permitted to use or disclose your personal information only on behalf of Talcott to support our business purposes or for any other purposes that you authorize.
Affiliated companies. We share personal information with our affiliated companies for everyday business purposes including the administration of insurance policies. We do not share personal information with affiliated companies for marketing purposes.
Investment professionals and registered representatives. We may work with your registered representatives and their associated brokers to facilitate communication with you and service your account. This is only done with your consent.
Third party administrators. We engage United States licensed third party administrators to manage premium charges and collections and to process, adjust, and settle claims on life, annuity, and health policies. They may also provide underwriting and renewal services. Our third party administrators are required to protect your personal information and are not permitted to use your personal information for any commercial purpose other than to provide these services on behalf of Talcott.
Information Technology and other business services providers. We engage third party vendors to support various administrative and technology operations. Examples include: data processing, hosting our website and Annuity Services Center; and providing information technology support, hosting, systems security, and data and records storage.
Payment processors. We may use third party payment services to process premium and claims payments. Your personal information as needed to process the transaction will be collected by the payment processor-not by us-and will be subject to the processor's privacy policy, rather than this Privacy Policy.
Risk management providers. We may disclose personal information to service providers who assist with fraud detection and prevention, identity verification, and protection of the rights, privacy, safety, and property of our customers, employees, and business.
Website usage analytics services. When you use our Site, online usage data about you and your activities are collected by third party data analytics services using cookies and similar technologies. We use this data to monitor the performance and security of our online services.
Professional services. We engage accountants, actuaries, data analysts, lawyers, and other professionals to provide services that may involve access to personal information.
Legal process and enforcement. We may disclose personal information to third parties to: enforce our agreements and rights; enforce the Terms of Use for our Site; comply with legal requirements; investigate, respond to and resolve claims or complaints; and respond to law enforcement, legal process, or a request for cooperation by a government entity.
Business transaction parties. We reserve the right to disclose or transfer your personal information, subject to appropriate confidentiality safeguards, in connection with a business transaction such as a financing, reorganization, merger, sale of a business unit, or change in corporate structure.
In this Privacy Policy we use the term "cookies" to refer to cookies, pixels, SDKs, JavaScript, device identifiers, and similar technologies that we (or third parties) may place on your web browser when you visit our Site. We do not use third party tracking cookies for purposes of online advertising.
Data collected using cookies. We use cookies to support some of the functionality and features of our Site and to track and measure visitor activities on our Site. The types of data collected when you visit our Site or use the Annuity Service Center may include, for example:
Third party data analytics services. We use third parties such as Google Analytics, to collect website usage data and provide usage and functionality reports to us. The analytics provider may monitor a user's interactions with our Site and combine this data with data from other websites monitored by the same service provider, and then use the combined data for its own business and commercial purposes. You can manage your consent at any time by making a request using one of the methods outlined below.
We have implemented a cookie “door” to ensure your cookie preferences are honored, and thus we do not sell or share your information derived from cookies for cross context behavioral advertising. We also have tools in place to better detect and honor requests made using the Global Privacy Control (“GPC”) signal as requests to opt-out of the sharing of personal information to the extent required by applicable law. If you wish to manage your cookie preferences, make a request using one of the methods outlined below.
Restricting online data collection. You can restrict how cookies are used to track and log data about your visits to our Site and other websites. If you restrict the use of cookies some of the services on our Site may not be fully functional.
These controls include:
We take commercially reasonable precautions to safeguard the personal information we collect, and we take measures to require third parties with whom we share personal information to use reasonable precautions to safeguard such information. Although we strive to protect your personal information in our control, we cannot completely guarantee the security of personal information you transmit electronically through our Site, by e-mail, or in other ways.
If you have any concern that your interaction with us is no longer secure (for example, if you are concerned that the security of any account you might have with us has been compromised), you should immediately notify us of the problem by contacting us at privacy@talcott.com
Policyholders should be aware that life insurance and annuity policies often remain in effect for many years and we will retain your personal information as necessary or appropriate to administer the policy, comply with our legal obligations, resolve any disputes, and enforce our agreements. To determine the appropriate retention period for personal information, we take into account the purposes for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. Based on those considerations, we will delete, remove personal information, or anonymize the information in accordance with applicable law.
Privacy practices of social media and third party websites. Our Site may contain links to social media platforms and other websites. If you use those links to access another internet location, you will leave the Talcott Site and this Privacy Policy will not apply to your use and personal information you provide at those third party locations. The personal information you provide will be collected by the third party website operator and controlled by its privacy policy. Links we provide on the Site to other internet locations are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked location or any security or data collection practices associated with those other websites. We encourage you to read the legal and privacy notices posted at those locations. We have no responsibility or liability for your access or use of, and the data collection and use practices of, third party platforms or websites.
Social media. Talcott may maintain a presence on social media platforms including LinkedIn. If you choose to "Like," "Follow," or take any similar action on a social media platform, you are providing your consent to receive information updates, including solicitations, from Talcott by means of that platform. To stop receiving this information from Talcott on a social media site, you must follow the procedure established by the website. For example, on LinkedIn, you must click "Unfollow" on Talcott's profile.
Talcott may engage third party administrators or other service providers that operate under United States laws and regulations. If you reside or are located in a different country, the data protection laws of that country may differ from the laws of the United States in the ways your personal information is protected. We want you to understand that when you provide your personal information to us, or engage in a transaction with us, you are giving your consent to (1) the transfer of your personal information outside of your country of residence, and (2) the processing of your information in accordance with the laws of the United States and the guidelines of this Privacy Policy.
If you are resident in the European Economic Area, the United Kingdom, or Switzerland, we will process your information in order to fulfill your requests and to otherwise pursue our legitimate business interests as described in this Privacy Policy. If you are resident in a country that provides specific rights regarding the processing or disposition of personal information, we will make commercially reasonable efforts to accommodate your request to exercise such rights.
Our Site is not intended for access and use by persons under the age of 18 (except in the case of legal residents of certain jurisdictions where the legal age of majority is greater than 18 years of age, who then must meet the applicable legal age of majority). Except with respect to policy beneficiary matters, we do not intentionally collect personal information from individuals who we have reason to believe are under the age of 18. If you become aware of any personal information we have collected from individuals under age 18, please contact us as explained in the section titled "How to Contact Us.".
We reserve the right to amend this Privacy Policy at any time in order to address future developments of Talcott, the Site or changes in industry or legal trends. If we materially alter the terms of this Privacy Policy, we will post the revised Privacy Policy on the Site and provide other notification as required by applicable law.
Any changes will become effective upon the posting of the revised Privacy Policy on the Site. You can determine when the Privacy Policy was last revised by referring to the "Effective Date" legend on the end of this Privacy Policy.
By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with any or all of the terms of our Privacy Policy as in effect at any time, you should not continue to use the Site.
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Effective Date: March 20, 2024
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