Effective Date: January 1, 2021
This Privacy Notice (“Notice”) describes our practices for collecting, using and disclosing information that Clear Spring Life and Annuity Company (“Clear Spring Life,” “we,” “us,” or “our”) and our affiliates, including Clear Spring Life Marketing, LLC ("CSL Marketing"), may collect about you. This Notice applies to information we collect via Clear Spring Life websites or online services that display or link to this Notice (the “Services”). This Notice also applies to communications you may have with us
1. PERSONAL INFORMATION WE COLLECT
a. Personal Information We Collect Directly from You
We collect personal information from you when you use our Services and interact with us. The information we collect includes: any information you choose to provide us, such as first and last name, account name, address, Social Security number, contact information (e.g., telephone number) and any interest you may express in our products and services. In some circumstances, we may be required to collect information such as government-issued ID and proof of address. We may also collect information relating to:
- Records and copies of your correspondence (including email addresses and audio recordings of calls placed to our customer service representatives), if you contact us.
- Your responses to surveys, such as those that we might ask you to complete for research purposes.
- Details of potential transactions or transactions you carry out through us or financial products and services you purchase, including financial information.
b. Personal Information We Collect Automatically
c. Personal Information We Collect from Third Parties
We also collect information about you from third parties, which may include information from analytics and information providers. We may combine information we collect about you with information from third parties.
2. HOW WE USE YOUR INFORMATION
We use the information we gather to provide services to you, to respond to your inquiries, and for our business purposes. This includes:
- Authenticating your identity and/or your access to an account;
- Initiating, facilitating, processing, and/or executing transactions;
- Responding to your requests and questions;
- Communicating with you regarding your account or any Services you use;
- Performing creditworthiness, fraud prevention or other similar reviews;
- Evaluating applications;
- Comparing information for accuracy and verification purposes;
- Managing our business and protecting ourselves, you, other persons, and the Services;
- Providing a personalized experience and implementing your preferences;
- Better understanding our customers and how they use and interact with the Services;
- Complying with our policies and obligations, government orders, legal advice or legal process;
- Establishing, exercising or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;
- Resolving disputes, collecting fees, or troubleshooting problems; and
- Providing customer service to you or otherwise communicating with you.
We may also process your personal information to fulfill the purposes for which you provide it, or with your consent.
3. HOW WE SHARE INFORMATION
We may disclose the information we gather with our affiliates and third parties. For example, we may share information with:
- Service providers and/or data processors: We may share personal information with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, or provide customer support.
- Other parties to transactions: We may share information with the other participants to your transactions. This may include: nonaffiliated third parties who are assisting us by performing services or functions for us or on our behalf, such as agents, brokers, brokerage firms, and insurance agencies; and with your designee, including for the purpose of providing information regarding the status of a transaction.
- Other third parties:
- To comply with any legal, regulatory or contractual obligation, or with any legal or regulatory process (such as a valid court order or subpoena) or advice of counsel;
- To third parties to market our products or services to you, or to track the effectiveness of such marketing, including banks, insurance agencies and securities brokers or dealers, with whom we have written distribution or joint marketing agreements;
- To establish, exercise, or defend legal claims or our policies;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction;
- In connection with the purchase, sale, merger, consolidation or transfer of all or part of our business; or
- We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the personal information was collected.
We may also disclose data to fulfill the purposes for which you provide it, or with your consent.
4. YOUR CHOICES
If we engage in email marketing, we will provide you the option to opt out of such communications, as required by law. As of the Effective Date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.
We have implemented administrative, physical and technical safeguards designed to protect your personal information. However, we cannot guarantee the security or confidentiality of information you transmit to us or receive from us when using the Services.
6. CALIFORNIA PRIVACY PRACTICES AND YOUR CALIFORNIA RIGHTS
If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the California Consumer Privacy Act (“California Personal Information”). For such residents, the provisions of this section prevail over any conflicting provisions contained within this Notice.
We describe the categories of personal information that we collect in this Notice in the part titled, “Personal Information We Collect.” This information includes the following categories of California Personal Information that we may have collected about you within the last 12 months:
- Identifiers such as a real name, postal address, Internet Protocol address, email address, account name, telephone number, Social Security number, identifiers related to government-issued ID such as driver’s license number, passport number or state identification card number, or other similar identifiers.
- Personal information described in the California Customer Records statute. This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, the personal information listed in the preceding bullet point as “identifiers,” physical characteristics or description (e.g., information reflected in government-issued ID), insurance policy number, education, employment, employment history, details of transaction or potential transaction information such as bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California or federal law such as information related to age and gender.
- Commercial information, including records of personal property, financial products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, information regarding your interaction with sites, applications, or advertisements, or information related to your computer or mobile device such as type of browser and operating system.
- Audio recordings from calls placed to Clear Spring Life and our affiliates (e.g., customer service) and electronic information in the form of Internet or other electronic network activity information as described above.
- Professional or employment-related information (including business contact information), such as name, title, company name, physical address, email address, telephone number, and facsimile number.
- Inferences drawn from any of the information identified in this subdivision to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
For each of these categories, we obtain California Personal Information from a variety of sources. We describe the sources from which we collect California Personal Information in the part of our Notice titled “Personal Information We Collect.”
Within the last 12 months, we have not shared any California Personal Information identified in the categories above in exchange for monetary or other valuable consideration as a “sale” under California law.
Within the last 12 months, we have disclosed California Personal Information identified in the above categories to third parties for our business purposes. We describe the third parties with whom we share personal information and the reasons why we share personal information in the part of this Notice titled, “How We Share Information.”
We do not disclose personal information of individuals we know to be under the age of 16 to businesses or third parties for monetary or other valuable consideration as a “sale” under California law, without affirmative authorization.
Your California Rights
If you are a California resident, you have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response as permitted by applicable law.
- Right to Know. You may request that we disclose to you:
- the categories of California Personal Information we have collected about you;
- the categories of sources from which the California Personal Information is collected;
- our business or commercial purpose for collecting or selling California Personal Information;
- the categories of third parties with whom we share California Personal Information;
- the specific pieces of information we have collected about you;
- the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act; the categories of third parties to whom the California Personal Information was sold; and, for each type of those third parties, the category or categories of personal information we sold to them; and
- the categories of California Personal Information about you that we disclosed for a business purpose.
- Deletion Rights.You have the right to request that we delete California Personal Information about you which we have collected from you.
You may request to exercise these rights by:
We will not discriminate against you if you choose to exercise any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by:
- Denying you goods or services;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may require you to provide information to verify your identity in response to exercising requests of the above type, including but not limited to: full name, contract number, mailing address, and last four digits of Social Security number. We may limit our response to your exercise of the above rights as permitted by law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require your agent to provide proof that you gave your agent signed permission to submit the request. We may also require you to verify your own identity in response to a request by an agent and/or directly confirm that you provided the agent permission to submit a request, as permitted by law.
7. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to modify this Notice from time to time, and, we will notify you of changes to this Notice by revising this Notice and updating the Effective Date above.
8. CONTACT US
We take your privacy concerns seriously. If you have any questions about this Notice or if you believe that we have not complied with this Notice with respect to your personal information, you may call us at (800)990-7626 or write to email@example.com