Talcott Resolution Life, Inc. and affiliated companies in the U.S, (collectively, “Talcott Resolution,” "we" or "our") own and administer life, annuity and other insurance products and provide risk and capital management services for the insurance industry. Our affiliated companies for purposes of this notice, subject to change, include:
If you are a policyholder, you will also receive a copy of our Consumer Privacy Notice at the start of our business relationship with you and periodically thereafter as required by law.
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|
|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.||
|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.||
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|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.||
|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 sensitive 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.||
|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.||
|Personal information concerning a consumer’s sex life or sexual orientation.||
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.”
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 state-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 Resolution.
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.
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. The data analytics providers may also use the aggregated and de-identified data they collect on our Site for their own business purposes.
Professional services. We engage accountants, actuaries, data analysts, lawyers, and other professionals to provide services that may involve access to personal information.
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.
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. Talcott Resolution does not disclose any directly identifying personal information to data analytics services. However, 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. In that case, the processing of personal information will be the sole responsibility of the service provider and subject to its privacy practices.
We and the third parties we partner with currently do respond to the "do not track" signal transmitted by some web browser to indicate a request to disable online tracking of a visitor to our Site.
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 Talcott Resolution, P.O. Box 14293, Lexington, KY 40512 and/or at 1-800-862-6668.
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.
Social media. Talcott Resolution 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 Resolution by means of that platform. To stop receiving this information from Talcott Resolution on a social media site, you must follow the procedure established by the website. For example, on LinkedIn, you must click "Unfollow" on Talcott Resolution's profile.
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 states where the legal age of majority is greater than 18 years of age, who then must meet the state's 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.".
If you are a resident of California, you may be entitled to the following rights:
Right to know. California consumers have the right to request any of the following information regarding personal information collected by Talcott Resolution about the consumer or the consumer’s household during the last twelve (12) months (“Right to Know”):
The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.”
Right to correct. California consumers have the right to request a business correct any mistakes in personal information about the consumer that the business has collected or update their preferences regarding the collection of personal information about the consumer; the business may not be able to accommodate the consumer’s request if it believes it would violate any law or legal requirement or cause the information to be incorrect; data solely retained for data backup purposes is generally excluded.
Right to delete. California consumers have the right to request a business delete any personal information about the consumer that the business has collected from the consumer, subject to a range of exclusions permitted by law (“Right to Delete”). For example, a business is not required to delete personal information if it is necessary to complete a transaction, is reasonably used for an ongoing business relationship, or is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.
Once we receive and verify your request, we will separately confirm your request and follow appropriate procedures to verify the identity and authority of the person submitting the request. If the Right to Delete request is confirmed and verified, we will delete (and direct our service providers to delete) the requested personal information from our records, unless an exclusion applies. If we are unable to fulfill all or part of your request, we will let you know why (for example, if we have a permitted reason to retain certain information if the identity of the requesting person cannot be verified).
The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.”
Right to limit the use of sensitive personal information. California consumers have the right to limit the use and disclosure of the sensitive personal information Talcott Resolution collects or maintains about them, to only those purposes necessary to provide our services (but we do not use sensitive personal information for any purpose that is not necessary to provide our services).
Designating an authorized agent. California consumers may designate an authorized agent to act on their behalf to submit a Right to Know or Right to Delete request, or (if applicable) a request to opt-out from the sale of their Personal Information. An authorized agent may be a natural person or a business entity registered with the Secretary of State. An authorized agent must also submit to Talcott Resolution written proof of their authorization to act on the consumer’s behalf.
How to make a verifiable California Consumer Request. California consumers may submit a request to exercise any of their rights described above using the following methods:
Please note that in order for us to verify certain requests we need to verify your identity and California residency by confirming information we have on file for you, including email address, phone number, full name, address, and other personal information. If you make a request on behalf of someone else, we will need to verify your authority to make that request. We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed.
How we respond to a California Consumer Request. We endeavor to confirm receipt of your Right to Know, Right to Correct, or Right to Delete request within ten (10) business days and may request additional information necessary to verify that you are permitted to make the request. We will respond to any verifiable consumer request within forty-five (45) calendar days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason why and the extension period in writing. We will use the email address or U.S. Postal address you provided to us when making the request.
If we cannot comply with all or part of your request, we will explain the reasons why. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information readily from one entity to another entity.
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.
Protection from discrimination. California consumers have a right not to receive discriminatory treatment by the business for exercising the privacy rights conferred by the California Consumer Privacy Act. As such, we will not discriminate against a California consumer for exercising any of the rights described in this section. This means that except as legally permitted we will not:
California “Shine the Light” Law. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes within the immediately preceding calendar year. We will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. Please send a request including evidence of residency in California to:
*This Consumer Privacy Notice is being provided on behalf of Talcott Resolution Life, Inc., and its subsidiaries, to the extent required by the Gramm-Leach-Bliley Act and implementing regulations. This includes American Maturity Life Insurance Company; Talcott Resolution International Life Reassurance Corporation; Talcott Resolution Life and Annuity Insurance Company; Talcott Resolution Life Insurance Company; Talcott Resolution Distribution Company, Inc.; and Talcott Resolution Comprehensive Employee Benefit Service Company.
We value your trust. We are committed to the responsible:
of your Personal Information.
In general, we collect Personal Information to:
We may obtain Personal Information from:
Based on the type of product or service You apply for or get from us, we may collect Personal Information. We may use this information to:
To serve You and service our business, we may share certain Personal Information with our affiliates and third-parties, including affiliates such as our insurance companies, our employee agents, our brokerage firms, and our administrators; and including third parties such as contractors, agents or administrators under contract to perform services on our behalf, with independent agents, brokerage firms, and insurance companies to serve you; and service providers to administer or investigate claims, to store Personal Information, market our products or services, or administer surveys.
We only transfer or disclose Personal Health Information with:
Your Personal Information may be maintained and processed by our affiliates and other third party service providers in the US or other jurisdictions. Third parties are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. For details on the manner in which our service providers treat your Personal Information, contact us as set forth below.
If your Personal Information is shared, stored and/or processed in foreign jurisdictions, your Personal Information may be subject to the foreign jurisdiction’s laws and available to its courts, regulatory agencies and law enforcement authorities.
With your consent or when allowed by law, we may use or share certain Personal Information with third parties who:
We will not sell or share your Personal Information with anyone for these optional purposes without offering You the opportunity to:
as required by law.
We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Talcott Resolution or as part of a corporate reorganization or other change in corporate control.
We may otherwise provide your Personal Information in response to a search warrant or other legally valid inquiry or order, in the case of a breach of an agreement or contravention of law, or as required or permitted by applicable Canadian, US or other law. We may also disclose Personal Information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
We have implemented technical, physical, and administrative safeguards designed to maintain:
Personal Information in our custody or control. We use these procedures to guard against unauthorized access, use, modification, and disclosure of such Personal Information.We:
We are committed to the use of accurate Personal Information. You may request access to your Personal Information and seek correction of any inaccurate Personal Information. However, such access may be limited where we are under legal restrictions on disclosure or need to protect our rights and those of other persons, such as:
We retain Personal Information for so long as is required to enable us to fulfill all of the purposes for which such information was collected and to meet our legal and contractual obligations.
For general information, information about our privacy practices, complaints, or written access requests, contact:Talcott Resolution (Canadian Operations)
Application means your request for our product or service.
Personal Health Information means health information such as:
Personal Information is information about an identifiable individual, such as:
Transaction means your business dealings with us, such as:
You means an individual who has given us Personal Information in conjunction with:
a financial product or service from us.
New York Insurance Law §2612 domestic violence law provides victims of domestic violence with important protections. Illinois Administrative Code Section 2028 provides similar protections for victims of actual or threatened violence, including domestic violence. A victim, the legal representative of the victim or, if a child is the covered person, the child’s parent or guardian may request to receive policy information at an alternate address, telephone number, or other method of contact.
Upon delivery of a valid order of protection or a reasonable request for confidentiality, the insurer is prohibited (for the duration of the order or request) from disclosing to the policyholder or other person the address, telephone number, or any other personally identifying information of the insured, of any person or entity providing health services to the insured, the nature of the health services provided, or any other information from which there is a reasonable basis to believe the forgoing information could be obtained.
If a child is a covered person, then the right established by this section may be asserted by the child’s parent or guardian. The full text of New York Insurance Law Section 2612 can be found on the New York State Legislature’s website. The full text of Illinois Administrative Code (Title 50: Insurance, Chapter I, Subchapter z, Part 2028) can be found on the Illinois General Assembly website.
Talcott Resolution Life has adopted procedures to maintain the confidentiality of, and to refrain from disclosing, the information protected by the above statutes. To submit a request to receive communications by alternative means or at alternative locations, or to revoke such a request, please contact Talcott Resolution Operations Compliance at the following address:Postal Address:
After a reasonable request has been received, a requester may revoke the prior request by submitting a written sworn statement revoking the request to Talcott Resolution Life at the address above.
For New York Residents:
For further information on domestic violence services, you may contact the NYS Domestic and Sexual Violence Hotline by the following
For Illinois Residents:
For further information on domestic violence services, you may contact the State of Illinois Domestic Violence Helpline by the following:
We value your trust, and we are committed to the responsible protection of your Social Security number ("SSN"). This notice applies to any SSN that we collect in the course of our business. We protect the confidentiality of SSNs, including by maintaining manual and electronic security procedures to guard against unauthorized access to SSNs. We also limit access to SSNs, including by only granting access to SSNs to our employees who use that information to perform their job-related duties. In addition, we do not disclose SSNs to third parties, except where required or permitted by law.
Effective Date: March 30, 2023