Effective Date: June 1, 2020
This document discusses how Universal Fidelity Life Insurance Company (“UFLIC,” “we,” “us,” or “our”) collects personal information of California residents. This document applies solely to individuals who reside in the State of California (“consumers” or “you”). This document is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this document. This document does not apply to personal information outside the scope of the CCPA, including without limitation:
When we act as a service provider for our customers, we collect personal information on behalf of our customers subject to our contractual obligations. When we act as a service provider, we follow the instructions of our customer on how to process personal information on our customer’s behalf. The provisions of this document do not apply to the personal information that we process on behalf of our business customers.
The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we share such information. We will share personal information with parties to whom you have directed or authorized us to share with.
|Categories of Personal Information||Categories of Service Providers and Third Parties with whom Personal Information is Shared|
|Identifiers. This may include a real name, alias, address, email address, phone number, Social Security Number, driver’s license number, online identifier, IP address, account username and password, job title, or other similar identifiers.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; data analytics providers; prospective purchasers of our business; and outside auditors and lawyers.|
|Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; and data analytics providers.|
|Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; and data analytics providers.|
|Other information you submit to us. This may include requests or communications you submit to us, including emails, ratings, or customer service call recording.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; prospective purchasers of our business; and outside auditors and lawyers.|
|Research or survey information. This may include survey results, social media data, and other information about your participation in consumer research.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; prospective purchasers of our business; and outside auditors and lawyers.|
|Inferences we draw about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in.||Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; and data analytics providers.|
We may use personal information in the following ways:
CCPA defines a “sale” of personal information broadly to include more than exchanges for monetary purposes. A sale can include personal information shared with a third party for “valuable consideration,” or information shared with a third party (even if they are performing services on our behalf) if they are permitted to use the information for their own purposes. We do not and have not sold any personal information in the previous 12 months.
The CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You could request:
Our employees and employees of our business partners and service providers also do not have a Right to Know.
You have the right to request that we delete some or all of the personal information that we have collected from you and retained, subject to a number of exceptions. We are not required to delete personal information that is: (a) necessary to complete a transaction with you or for warranty or product recalls; (b) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (c) reasonable for us to use for internal purposes given our relationship with you; or (d) compatible with the context in which you provided the information. The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.
Our employees and employees of our business partners and service providers do not have a Right to Deletion.
To exercise your rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person or entity that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We may not be able to fulfill your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, we may request up to three pieces of personal information about you, and we reserve the right to take additional steps, as necessary, to verify your identity if we have reason to believe a request is fraudulent.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the date we received your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information provided above.