Privacy Information for California Residents

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:

  • Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act.
  • Personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living as set forth in the federal Fair Credit Reporting Act.
  • Personal health information collected, processed, or disclosed pursuant to the federal Health Insurance Portability and Accountability Act (“HIPAA”).
1. UFLIC as a Service Provider

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.

2. What Personal Information We Collect and How We Share it

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.
3. How We Use Personal Information

We may use personal information in the following ways:

  • To provide you with information, products, or services;
  • To improve our services and products;
  • To secure and monitor our websites;
  • For audit or research purposes;
  • To resolve grievances;
  • To find or prevent criminal activity, fraud, material misrepresentation or nondisclosure in connection with an insurance issue;
  • To respond to requests from law enforcement or other government authorities as required by law; or
  • For our own legal obligations and business needs.
4. Sale of Personal Information

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.

5. California Residents’ Rights and Choices

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.

  1. Access to Specific Information and Data Portability Rights (“Right to Know”)

    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:

    • The categories of personal information we collected about you;
    • The categories of sources of the personal information we collected about you;
    • Our business or commercial purpose for collecting that personal information;
    • The categories of third parties with whom we share that personal information; or
    • The specific pieces of personal information we collected about you.

    Our employees and employees of our business partners and service providers also do not have a Right to Know.

  2. Deletion Request Rights (“Right to Deletion”)

    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.

  3. Exercising Your Rights

    To exercise your rights described above, please submit a verifiable consumer request to us by either:

    • Calling us at 800-366-8354.
    • Request a form to be completed by you by writing to us at:
    Universal Fidelity Life Insurance Company
    13931 Quail Pointe Drive
    Oklahoma City, Oklahoma 73134

    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:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    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.

  4. Response Timing and Format

    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.

  5. Non-Discrimination

    You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services;
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
    • Provide you a different level or quality of goods or services; or
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Other California Privacy Rights

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.