Terms of use

OCTOBER 1, 2024

This Online Privacy Policy (“Policy”) describesthe types of information we collect about individuals oninvestorslife.com; investorslife.info;and any otherwebsitesor mobile applications, if any, published by Investors Life Insurance Company of North America or its’ insurance related affiliates, (collectively “we, “us” our “our”), that link to this Policy (collectively, the or our  “Websites”).We respect and value your concerns about privacy.

This Policyalso describes (i) how we may use theinformation we collect, (ii) who we may share it with, (iii) the choices available to you regarding our use of such information, (iv) the measures we take to safeguard information we collect on our Websites; and (v) how individuals can contact us about our privacy practices.

This Policy does not apply to information collected through any third-party websites or mobile services, including through any application or content (including advertising) that may link to or be accessible from or on the Websites or that you may submit through email, text or other electronic message, or offline.

Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By accessing or using the Websites, you agree to this Policy. If you do not agree with this Policy, please do not access or use the Websites.

California Customers

The California Consumer Privacy Act (CCPA) gives California residents certain privacy rights with respect to some of the Personal Information we collect.  Learn about our practices regarding he collection, use and disclosure of personal information about California residents who are covered by the California Consumer Privacy Act and California Privacy Rights Act, and how covered individuals can exercise their rights, here [insert link to California Privacy Policy].

DEFINITION OF PERSONAL INFORMATION

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you.Personal information is usually your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number. The specific definition of personal information varies from one jurisdiction to another.

Personal information does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

We use and disclosepersonal information we receive from our customers in accordance with the Investors Life Insurance Company of North America Privacy Notice [insert link to Privacy Notice], whether that information comes from the services we provide or any other means. The information contained in this Policy is in no way intended to amend, abridge, replace, contradict, change or otherwise affect the policies outlined in the Privacy Notice.

INFORMATION WE COLLECT

As part of our business, we may collect information about you in various ways, for example, in order to provide a product or service to you, maintain and service your account, policy or contract, improve our services, inform you of additional Investor’s Life Insurance Company of North America products or services that may be of interest to you. .We collect information you provide directly through our Websites. We also collect information through automated means. Both mechanisms are described in more detail below.

Information You Provide

The information we collect when you visit the Websitesmay include:

• Contact information. We ask for certain information from you if you choose to contact us through our Websites.  Depending on your reason for contacting us, we request information such as name, postal address, email address, telephone number, and business type or company affiliation.
• Personal Identifiers.Date of birth, gender, postal address, email address, telephone number, governmental identification number such as social security number, passport number, governmental identification number or military identification number, driver’s license number or similar identifiers, andin some cases the name and some identifiers information about your spouse or children, chosen annuitants,insureds, and beneficiaries. Professional or employment information: your job title, job history, income. If you become a policyholder, this information will be handled in accordance with our Privacy Notice.
• Sensitive information protected by federal or state law such as your age, gender, race, marital status.
• Life, health orother insurance information: information about other insurance policies you may own.
• Geolocational data/Internet or other electronic network activity information: If you share your location in your online profile, we will collect that information. We may also determine location by using other data from your online and mobile devices, internet or other electronic network activity information, browsing history, search history, and information about your interaction with a website, online application and advertisement.
• Access Credentials.Information you provide to create your online customer service account or producer account, and other account-related information (such as username and password, PIN, personal information, security questions and answers, social security number, date of birth andpolicy, contract or accountnumber). We will handle the personal information in your online customer service account in accordance with our Privacy Notice.
• Employment and Financial Information. Employment and occupation, demographic, income, and financial information.
• Banking Information.Information you submit in connection with electronic payments, such as bank account or other financial institutional information.
• Policy Administration.Information you submit in connection with reporting a claim on the Websites, or requesting an action related to your policy or contract, including policy or contract number/certificate number, contact information, social security number and date of birth of you, an annuitant, insured or beneficiary or information about a deceased, and cause of death. We may also collect personal information about you and information related to your request, when you make or withdraw a claim, update your bank information, surrender your policy or contract, request a withdrawal, update your address, update a beneficiary, or otherwise seek service of your policy or contract through our Websites.
• Job Applications.Information you submit in connection with a career opportunity at Investors Life Insurance Company of North America, or our affiliates, suchas contact information, information in your resume, and details about your current employment.
• Information contained in content you submit, such as through our “Contact Us” feature or user experience surveys.

• Internet or other electronic network activity information, browsing history, search history, and information about your interaction with a website, online application or advertisement.

Broadly speaking we use the collected information to respond to your inquiries or to deliver requested information or services.

HOW WE COLLECT INFORMATION

Whether we collect certain types of information and how we process it depends on how you use and access the Websites and our services. If you decide to register online with us, your browsing will no longer be anonymous to us. Some information is collected automatically through use of cookies and similar tracking technologies designed to help make your online experience more convenient.  We collect information about you in the following ways:

Directly From You

Some of the information we receive comes directly from you on applications, surveys or other forms you have completed, or from information you’ve chosen to disclose when you visit our Websites or other online portals.  For example, we collect information from you including personal information and usage data from you when you access the Websites to:

• File or check the status of a claim.
• Contact or chat with a customer service representative for help or information or otherwise voluntarily provide your information.
• Manage or make changes to your account or policy or contract information.
• Make a payment or withdrawal, request a surrender or file a claim.
• Apply for or purchase an Investors Life Insurance Company of North America product.

From Our Business Partners and Service Providers

Third parties that assist us with our business operations may also collect information (including personal information and usage data) about you through the Websites and share it with us. For example, we may also collect information about you indirectly (for instance, from and our service providers and data brokers, producers /agents, our affiliates, your financial advisers), and from other third parties such as consumer reporting agencies, government agencies. Our vendors may also collect and share information with us to help us detect and prevent fraud.  We may combine the information we collect from you with information from other sources and use the combined information as described in this Policy.

Automated Collection of Data and Tracking Technologies

When you use and interact with our Websites, we may use automatic data collection technologies, such as browser cookies, web beacons, device identifiers, server logs, and other technologies (“Tracking Technologies”) to collect certain information about your equipment, browsing actions and patterns, including:

• Traffic Data – When you visit and use our Websites, certain data may be captured, including location data, logs, and other communication information that you access.

• Technical Data – When you visit and use our Websitescertain data may be captured, including: the IP address, domain name, identifiers associated with your devices and operating system, duration of visit, pages viewed, and session ID you use to connect to the internet, web browser characteristics, language preferences, clickstream data, your interactions with our Websites (such as the web pages you visit, links you click and features you use), the pages that led or referred you to our Websites, dates and times of access to our Websites,. This technical data is automatically recorded in our web server log files.

We use Tracking Technologies to help improve your experience with the Websites. For example, Tracking Technologies help us remember users and make our services more relevant to you. This information is used to help us improve our service and better provide you with information you are interested in when you visit ourWebsites.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies)

When you connect with one of our Websites or mobile applications, we place a small text file, called a “cookie,” on your hard drive, as a means to identify you to our computers in the future. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies are not themselves personally identifiable but may be linked to personal information that you provide to us through your interaction with the Websites.

You can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. However, if you select this setting, you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org.

Web Beacons

Pages of our Websites and our e-mails may contain small electronic files known as web beacons(also known as clear gifs, pixel tags, and single-pixel gifs, or Internet tag), link web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use web beacons for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain service content and verifying system and server integrity).

These Tracking Technologies help us (1) properly identify your computer and remember your information so you will not have to re-enter it, (2) tailor the Websites around your preferences, (3) measure the usability and functionality of the Websites, (4) monitor the use of the Websitesto  continually improve the design and functionality to better serve you, (5) understand the effectiveness of our communications and ads, (6) generate meaningful usage statistics, such as how many visitors entered the Websites, how they interacted with the Websites and specific pages that were visited, and (7) otherwise manage and enhance the Websites.

We use information collected through automatic means to assess aggregate visitor volume and interest, assess how visitors use our Websites, and to enhance and improve our Websites. Our Websites do not respond to “Do Not Track” signals.For more information about Do-Not-Track, please visit www.allaboutdnt.com.  Please be aware that if you choose to disable cookies or other automated technologies, you may not be able to use all the features of our Services.

Third-Party Web Analytics Services

Through our Websites, we may obtain information about your online activities over time and across third-party websites, devices and other online services. On our Websites, we use third-party online analytics services, and the service providers that administer these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate, for example, use of our Websites, to diagnose technical issues and to serve ads.

Online Tracking And Interest-Based Advertising.

This website does not use Online Tracking and Interest Based Advertising to collect information about your online activities to provide you with advertising about products and services tailored to your individual interests.

HOW WE USE YOUR INFORMATION

Depending on the type of information collected, we may use the information we collect about you or that youprovide to us through the Websites, including any personal information to:

• personalize your experience on the Websites;
• process an application for our products;
• create your account;
• determine your eligibility for our products and services;
• identify and authenticate your identity so you may use the Websites, or to enable online registration and access to your policy, contract, account or claims information.
• maintain, manage, service and administer our products and services;
• respond to inquiries and requests;
• conduct user experience surveys;
• connect you with an appropriate agent;
• for everyday business purposes, such astooperate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; analyzing our products and services; managing our communications; measuring the effectiveness of our ads; performing data analytics; and performing accounting, auditing and other internal functions;
• provide you with information that may be of interest;
• manage your preferences or privacy choices;
• provide you with online technical support;
• manage career opportunities, including for recruitment purposes (such as processing job applications);

• detectsecurity incidents, identifyand protectagainst malicious, deceptive, fraudulent, or illegal activity;
• perform debugging to identify and repair errors that impair existing intended functionality of our Websites;
• comply withand enforce applicable legal and regulatory requirements, audits and investigations relevant industry standards, contractual obligations and our policies, including this Online Privacy Policy and the Terms of Use [insert link to Terms of Use];
• as described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA) (for California residents);
• evaluate or conduct merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us about you is among the assets transferred; and
• for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you.  If you do not want us to use your information in this way, please see “Your Choices About How We Use and Disclose Your Information”.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share yourinformation with our (i) subsidiaries and affiliates, (ii)contractors, service providers, analytics providers and other third parties we use to support our business and the Websites; and (iii) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or a portion of our business or assets ; whether as a going concern orin the event of a bankruptcy, reorganization, dissolution or liquidation or similar proceeding.

Disclosures Required by Law and Disclosures to Help Protect the Security and Safety of Our Websites and Others

We may disclose any information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal or regulatorycompliance or reporting purposes, or to protect our legal rights or enforce our Terms of Use or any contest rules.

We also may disclose information about you to third parties where we have a legitimate purposes for doing so, including  (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities or insurance regulators; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or  (v) otherwise with your consent.

In Aggregated Form

We may share personal information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our Services.

YOUR CHOICESABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to furnish you with choices regarding the personal information you provide to us. We do not respond to Do-Not-Track signals at this time; however, we have created mechanisms to provide you with the following control over your information:

• Tracking Technologies –You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org.If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

• Targeted Advertising – We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To opt out of receiving targeted ads (including ads served using non-cookie technologies) from members of the NAI, click here. To visit the Digital Advertising Alliance’s website and use its Consumer Choice tools, click here.

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, update or correct your information, or submit a request, please contact us as specified below.

California residents may have additional personal information rights and choices. Please see the Privacy Policy [add link] for more information.

OTHER ONLINE SERVICES AND THIRD PARTY FEATURES

Our Websites mayprovide links to third-party websites and online services with which we have no affiliation (“Third-Party Services”) for your convenience and information and may include third-party features such as apps, tools, widgets and plug-ins. These services, websites, and third-party features may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of those parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties’ information practices. Because third party sites are not under our control, we cannot guarantee the quality, accuracy, or timeliness of any information contained on these sites. When you use a link to go from one of our Websites to another web site, this Online Privacy Policy is no longer in effect. Your browsing and interaction on any other web site is subject to the rules and policies of that site not to those of this Policy.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We use commercially reasonable security measures to secure our Websites and protect any records containing your personal information. We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Websites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure and limit the number of people who have access to such information.Nevertheless, transmission of information via the internet is not completely secure and we cannot guarantee the security of your information.  Any transmission of personal information is at your own risk. We are not responsible for any circumvention of any privacy settings or security measures contained on or within the Websites.

Additionally, we limit access to your personal information to those employees, agents and service providers who need access in order to offer and provide or administer our products or services to you. We instruct parties with access to your information that it is to be used only in accordance with the principles set forth in this Online Privacy Policy and applicable internal policies, and privacy laws and regulations.

The safety and security of your information also depends on you. As an added security measure, many features of the Websitesmay require you to create a username, personal password, personal identification number, and other forms of authorization involved in obtaining access to password protected or secure areas. You are responsible for keeping this information confidential.

In order to protect you and your information, we may suspend your use of any of theWebsites without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Websitesare restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

CHILDREN’S PRIVACY

The Websites are designed for a general audience and are not directed to children under the age of 13.  We do not knowingly collect and retain information from children under the age of 13. If you believe that a child under the age of 13 may have provided us withtheir information without your permission, please contact us at the email listed below so that we can identify and delete that information.

DATA RETENTION

We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Online Privacy Policy or at the time of collection; (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements into which we have entered.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (CCPA) and California Privacy Rights Act, give California residents certain privacy rights with respect to some of the personal information we collect.  California customers have the right to access and correct the personal information we have collected about them so that we can provide them with an insurance or financial product or service.

If you are a California resident, please see our California Privacy Policy, [insert link to California Privacy Policy] which provides additional details about how we handle your personal information and how you can exercise your rights under the California Consumer Privacy Act. To the extent provisions of this Privacy Policy conflict or are inconsistent with the provisions of our California Privacy Policy, the terms of our California Privacy Policy shall prevail.

Under California’s Shine the Light law, California residents who provide personal information in connection with purchasing products or services from us may request a disclosure of what Personal Information, if any, we have shared with other businesses for their own direct marketing purposes. Such a request may be made by sending an email message to [email protected]; with “Request for California Privacy Information” in the subject line. In response to such a request, we will provide information as required by California law for the previous calendar year concerning such other businesses and the categories of Personal Information, if any, that we have shared with them.

To the extent provisions of this Privacy Policy conflict or are inconsistent with the provisions of our California Privacy Policy, the terms of our California Privacy Policy shall prevail.

CHANGES TO THIS ONLINE PRIVACY POLICY

The effective date of this Online Privacy Policy is set forth above. We reserve the right to modify or supplement this Online Privacy Policy at any time. If we make any material change to our practices, we will update this Online Privacy Policy to include such changes.

CONTACT INFORMATION

To update your preferences, update or correct your information, submit a request, remove, or correct any personally identifying data you have supplied or to us ask us questions about this Online Privacy Policy, please contact us by email at: [email protected]; or phone us at: 1-877-263-0987.

California Notice at Collection and Privacy Notice
Effective October 1, 2024

Introduction
Investors Life Insurance Company of North America and our insurance related affiliates, (collectively “Investors Life Insurance Company of North America” or “we” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy for California Residents (this “Policy”).

This Policy applies to individuals residing in California (referenced as “consumer,” “you,” or “your”) subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively referred to as “CCPA”). This Policy does not apply to personal information collected pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations or the California Financial Information Privacy Act, certain insurance laws, or the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

The purpose of this Policy is to provide consumers a description of your rights and our information practices and supplements any privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of Investors Life Insurance Company of North America or any of its insurance related affiliates.

Most of the personal information we collect is protected and governed by Gramm-Leach-Bliley Act (“GLBA”) and is therefore exempt from most CCPA obligations. As such, this Policy provides disclosures and information related to the limited personal information we may collect, process, or maintain subject to the CCPA.

This Policy may change from time to time, and the current effective date is set forth at the top of this Policy. When possible, we will provide you with advance notice of our changes to this Policy, and we will not make retroactive changes that reduce your privacy rights unless we are legally required to do so.

We collect, useand disclosepersonal information we receive from you in accordance with our Online Privacy Policy, Terms of Use, and Privacy Notice at Collection for California Residents, whether that information comes from the products or services we provide, or any other means. The information contained in this Policy is in no way intended to amend, abridge, replace, contradict, change or otherwise affect the policies outlined in the notices and policies referenced herein.

Personal Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or a member of your household.
We may have collected the following categories of personal information directly from you or about you in the last twelve (12) months. We do not necessarily collect all examples of personal information listed in a particular category, nor do we collect all categories of personal information for all consumers.

Category	Examples
A. Identifiers	Name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information in California’s Customer Records Statute (Cal. Civ. Code § 1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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 (Some personal information included in this category may overlap with other categories.)
C. Characteristics of protected classes under California or federal law	Age, race, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information	Fingerprint and/or facial recognition templates.
F. Internet or other electronic network activity information	Browsing history, search history, interaction with web sites, applications, or advertisements.
G. Geolocation data	Geolocation data, such as device location.
H. Audio, electronic, visual, thermal, olfactory, or similar information	Voice recordings, CCTV, photographs, videos.
I. Professional or employment-related information	Salary, compensation, employment status, business titles, business ownership interests.
J. Education information	Certificates / Licenses, grades, disciplinary actions, assessments.
K. Inferences drawn from any of the information identified above	Inferences drawn to create a profile about, for example, an individual’s preferences, characteristics, predispositions, behavior, or abilities.
L. Sensitive Personal Information	Social Security number, 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, precise geolocation; racial or ethnic origin, citizenship, immigration status, religious or philosophical beliefs, or union membership, the processing of biometric information for the purpose of uniquely identifying a consumer, health information, sex life or sexual orientation.

We may have collected personal information about you from the following categories of sources:

• Directly from consumers (you provide us this information).
• Agents / Brokers / Representatives / Accountants / Financial Advisors.
• Indirectly from you, such as when you participate in a transaction or contractual arrangement.
• Other individual(s) associated with a policy or transaction.
• Consumers Reports/ Credit Reporting Agencies.
• Court orders or legally binding documents.
• Government agencies or regulators.
• Your financial institution.
• From your devices, such as when you visit or Websites and mobile applications.
• Our affiliates.
• Data service providers.

How We Use Personal Information
We may collect your personal information for the following business purposes:

• Performing business related services, including processing applications, claims, investments, transactions, and maintaining or servicing accounts.
• To consider your application for insurance, assess and evaluate institutional risk and provide you with an insurance product and services, where applicable.
• To administer your insurance product and maintain your account, respond to your product or service request, including processing premium payment, processing claims, administering benefits and paying out withdrawals, surrenders and claims settlements, and encouraging customer engagement.
• To provide account statements and other required documents.
• To respond to court orders and legal investigations or as otherwise required or permitted by federal and state law.
• To comply with legal requirements, regulatory matters, audits and investigations.
• To report to consumer reporting agencies.
• To authorize, settle and clear the collection of amounts charged, debited, or otherwise used to pay premium or receive payments and the audit of such information.
• To prevent and detect security incidents, fraud, money laundering, unauthorized access, data destruction and other crimes.
• To obtain reinsurance.
• To authenticate your identity.
• To provide you with materials that may be of interest, including marketing materials.
• For other everyday business purposes, such as product development and website administration.
• To establish or defend legal claims and allegations.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We will only use your sensitive personal information for limited permissible business purposes, including to:

• Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• Detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
• Resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
• Ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
• Perform services on behalf of the business, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the Service or device that is owned, manufactured by, manufactured for, or controlled by the business.
• For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.

Personal Information We Disclose
We may disclose (and may have disclosed during the last twelve (12) months) the following categories of personal information to the following categories of third parties for business purposes:

Category	Examples	Categories of third parties to whom the category of personal information has been disclosed
A. Identifiers	Name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Affiliates Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration; Your authorized representatives; Vendors who provide services to us; Insurance Brokers, Producersor Agents; Financial Institutions associated with your account; Other Companies associated your policy, transaction, or account; Our Reinsurance Partner(s); Regulators, government agencies or law enforcement; Parties where we have obtained your consent or authorization.
B. Personal information in California’s Customer Records Statute (Cal. Civ. Code § 1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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 healthinsurance information (Some personal information included in this category may overlap with other categories.)	Affiliates Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration; Your authorized representatives; Vendors who provide services to us; Insurance brokers or producers/agents; Financial Institutions associated with your account; Other Companies associated your policy, transaction, or account; Our Reinsurance Partner(s); Regulators, government agencies or law enforcement; Parties where we have obtained your consent or authorization.
C. Characteristics of protected classes under California or federal law	Age, race, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.	Your authorized representatives; Vendors who provide services to us; Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration; Insurance brokers or producers/agents; Financial Institutions associated with your account; Other Companies associated your policy, transaction, or account; Our Reinsurance Partner(s); Regulators, government agencies or law enforcement; Parties where we have obtained your consent or authorization.
D. Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Your authorized representatives; Vendors who provide services to us; Financial Institutions associated with your account; Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration Insurance brokers or producers/agents; Other Companies associated your policy, transaction, or account; Our Reinsurance Partner(s); Regulators, government agencies or law enforcement; Parties where we have obtained your consent or authorization.
E. Biometric information	Fingerprints and/or facial recognition templates.	Vendors who provide services to us, Regulators, government agencies or law enforcement, or Parties where Investors Life we have obtained your consent or authorization.
F. Internet or other electronic network activity information	Browsing history, search history, interaction with web sites, applications, or advertisements.	Vendors who provide services to us; Parties where we have obtained your consent or authorization.
G. Geolocation data	Geolocation data, such as device location.	Vendors who provide services to us’ Parties where we have obtained your consent or authorization.
H. Audio, electronic, visual, thermal, olfactory, or similar information	Voice recordings, photographs, videos.	Vendors who provide services to us; Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration; Regulators government agencies or law enforcement; Parties where we have obtained your consent or authorization.
I. Professional or employment-related information	Salary, compensation, employment status, business titles, business ownership interests.	Vendors who provide services to us; Regulators government agencies or law enforcement; Parties where we have obtained your consent or authorization.
J. Education information	Certificates / Licenses, grades, disciplinary actions, assessments.	Vendors who provide services to us; Regulators government agencies or law enforcement; Parties where we have obtained your consent or authorization.
K. Inferences drawn from any of the information identified above	Inferences drawn to create a profile about, for example, an individual reflecting their preferences, characteristics, predispositions, behavior, or abilities.	Vendors who provide services to us; Parties where we have obtained your consent or authorization.
L. Sensitive Personal Information	Social Security number, 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; precise geolocation; racial or ethnic origin, religious or philosophical; beliefs, or union membership; the processing of biometric information for the purpose of uniquely identifying a consumer; health information; sex life or sexual orientation.	Your authorized representatives; Vendors who provide services to us; Plan Sponsor/Group policy sponsors, such as employers /Policyholder’s Administrator for plan or policy administration; Insurance brokers or producers/agents; Financial Institutions associated with your account; Other Companies associated your policy, transaction, or account; Our Reinsurance Partner(s); Regulators government agencies or law enforcement; Parties where we have obtained your consent or authorization.

We do not sell or share your personal information, including your sensitive personal information, to non-service provider third parties. We do not sell or share personal information of minors under 16 years of age.

Your Rights Under the CCPA/CPRA
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

Right toKnow	You have the right to request the following information relating to the personal information we have collected about you and disclosed about you: The categories of personal information we have collected about you; The categories of sources from which the personal information was collected; The business or commercial purposes for collecting, selling, or sharing the personal information; The categories of third parties with whom the business shares personal information; The categories of personal information sold, and for each category identified, the categories of third parties to whom it sold that particular category of personal information; and The categories of personal information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.
Right to Access (Right to Know Specific Pieces of Information) / Portability	You have the right to access and obtain a copy of the specific pieces of personal information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.
Right to Correct	You have the right to request that we correct your inaccurate personal information maintained by us.
Right toRequest Deletion	You have the right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.
Right to Opt Out of Sharing for Cross-Context Behavioral Advertising	In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to affiliates, data analytics providers, service providers, business partners, and social networks: Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data. If you would like to opt out of this sharing of your personal information, you may do by contacting us as set forth in the “Exercising Your Rights” section below.
Right to Opt Out of DataSales or Sharing	The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting/cross contextual advertising. While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include activities such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to affiliates, data analytics providers, service providers, business partners, and social networks in ways that could be considered a “sale” under California law: Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data. We disclosed these categories of information to these third parties in order to market and advertise our products and services; perform analytics; and for research, analysis, and product development. We have no actual knowledge of selling personal information or sensitive personal information or minors under 16 years of age. California residents have the right to opt out of the “sale” of their personal or sensitive personal information. If you would like to opt out of such disclosures, you may do so by contacting us as set forth in the “Exercising Your Rights” section below.
Right of Non-Retaliation and Non-Discrimination	You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. We do not retaliate or discriminate against you for exercising the privacy rights conferred to you under the CCPA.
California’s“Shine the Light” Law	California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures.

Retention of Personal Information
We may retain personal information for the time period reasonably necessary for the purpose set out in our policies, for as long as an account or relationship with  us is active, as needed to provide services to our customers, or to comply with our internal policiesunless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.

HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS
To exercise your California Privacy Rights:
To exercise your California Privacy rights you may submit a requestby emailing us at [email protected] or contact 1-877-263-0987. Requesters will need to provide us with personal information in order to verify their identity and residency, including name, address, and date of birth as well as answer a series of unique identity proofing questions.  We’ll compare the information you provide with that maintained by us.

How we verify your request
Only you, or someone legally authorized 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. Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We cannot respond to 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. The personal information that we use to verify identity, and residency will not be used for any other purpose.

How to Designate an Authorized Agent
You may designate a third party (“Authorized Agent”) to act on your behalf when exercising your rights under CCPA/CPRA. You must provide us written consent, including the effective date, the name of the Authorized Agent and your signature, giving permission to the Authorized Agent to act on your behalf. You must also verify your identity in accordance with this Policy. A validly executed power of attorney may be provided to us in lieu of written permission. We may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

Your Authorized Agent designation is valid for the 12-month period preceding the date the document was signed and is only valid for the purposes stated herein.

Changes
We may change this Notice from time to time. When we make changes to this Notice, we will post the updated Notice on the Privacy pages of our website and mobile app with a new “Last Updated” date. Any changes will become effective when we post the updated Notice. Your use of the website or mobile app following these changes means that you accept the updated Notice.

Contact Us
If you have questions about this Policy, please contact us at:
Phone: 1-877-263-0987
Website: investorslife.com
Email: [email protected]

Privacy Notice

October 1, 2024

Consumers regularly trust Investors Life Insurance Company of North America with their nonpublic personal information (“PersonalInformation”). We respect the privacy of your Personal Information and take our responsibility to appropriately treat and protect your Personal Information seriously. This notice explains what Personal Information we collect, how we collect it and how we protect it.Please read this notice carefully to understand what we do.

Who We Are
Who is providing this notice?	This Notice is provided by Investors Life Insurance Company of North America.

Why are you receiving this notice?

Financial companies (including insurance companies) choose how they share your Personal Information. We are required by federal law to provide this notice when we start our relationship with you. You’ll also receive it annually so long as you have a policy, contract, or other type of account with us. Federal law gives consumers the right to limit some but not all sharing. These laws also require us to tell how we collect, share and protect your Personal Information.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing.

DEFINITIONS
Affiliates	Companies related by common ownership or control. They can be financial and non-financial companies.Our insurance related affiliates include Arcus General Agency LLC, and Arcus Holdings, Inc.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Investors Life does not share with nonaffiliates so they can market to you.

Reasons we can share your personal information?	Does Investors Life share	Can you limit this sharing
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes— to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We don’t share
For our affiliates’ everyday business purposes — information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes — information about your creditworthiness	No	We don’t share
For our affiliates to market to you	No	We don’t share
For nonaffiliates to market to you	No	We don’t share

QUESTIONS

Investors Life Insurance Company of North America, PO Box 758653, Topeka KS 66675-8645 [email protected] 1-877-263-0987

Summary of Investors Life Insurance Company of North America’s Privacy Notice	We collect Personal Information about you from your application, our transactions with you and from third parties as permitted by law. We do not share your Personal Information with nonaffiliated third parties other than as necessary to service your policy or claim. When we disclose your Personal Information to third parties to perform services for us, we require that they protect the Personal Information and use it only for the purpose it was disclosed. We do not sell your Personal Information to third parties. We maintain physical, electronic and procedural safeguards to protect your Personal Information
What Types of Personal Information DoWe Collect?	The types of Personal Information we may collect, and share may include: Contact information such as your name and address,email address, telephone number, and other contact information. Sensitive information protected by federal or state law such as your age, gender, race, marital status. Life, health  or other insurance information: information about other insurance policies you may own. Employment and occupation, demographic, income, and financial information. Social Security Number and date of birth. Transaction and claim history. Geolocational data: If you share your location in your online profile, we will collect that information.  We may also determine location by using other data from your online and mobile devices. Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a website, online application and advertisement. Consumer reports from consumer reporting agencies. Video and audio recordings. Account value and payment history. Information you submit in connection with reporting a claim on the Websites, or requesting an action related to your Policy, including Policy Number/Certificate Number, contact information.
How WeCollect Personal Information	We collect your Personal Informationin various ways such as when you: Provide information to us on applications and other forms. When you provide information over the phone. When you visit or enter personal details on our websites. Through other transactions with you, such as when you pay premiums, file claims, or make withdrawals. We also collect your Personal Information from others such as related companies, or third parties such as credit bureaus consumer reporting agencies, or data providers.
How WeUse YourPersonal Information	We may use your Personal Information only as permitted by law and as necessary to conduct business. We use your Personal Information for various business purposes, including for example: Normal everyday business purposes, such as providing services to you and administering your account, contract or policy, or processing payments, transactions, surrenders, withdrawals and claims. To authenticate your identity. To offer you other Investors Life Insurance Company of North America products. To perform other business, professional, or insurance functions as permitted by law. To operate, evaluate and improve our business (including enhancing existing products or developing new products and services) Managing our communications To protect against fraud; and comply with legal requirements. To evaluate or conduct merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us about you is among the assets transferred; and For any other purpose with your consent.
Who We Can Share Your Personal Information With	We may share your Personal Information, including information about your transactions and experiences, with: Our affiliates Non-affiliated companies that perform services for us or on our behalf for our everyday business purposes, such as providing services to you, and maintaining and administering your contract or policy. Agents, brokers and others who provide our products and services Contractors, attorneys and other third-party service providers we use to support our business. Courts and government agencies in response to court orders or legal investigations, or as required by law. State insurance departments or other governmental authorities; or Persons as ordered by subpoena, warrant or other court order. We may also share consumer report information among affiliated companies, which may include information about you from credit reports and certain information that we receive from you and from consumer reporting agencies or other third parties. Unless you agree otherwise, we do not share your Personal Information with non-affiliated companies for them to market their products or services to you. We may tell you about a product or service that other companies offer and, if you respond, that company will know that we selected you to receive the information.
Limiting Information That Can Be Shared “Opting Out”	Federal laws give you the right to limit only: Sharing for affiliates’ everyday business purposes-information about your creditworthiness Affiliates from using your Persona Information to mare to you Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing If you prefer that we do not disclose personal information about you to our affiliates or non-affiliated third parties –other than as required or permitted by law without your consent – you may direct us not to make those disclosures by completing the attached Mail-In Opt Out Notice form below and returning it, or mailing a letter, to the address provided. It takes 30 days to start the opt out process. If you have previously sent us an opt out request, there is no need to do so again unless we change our policy. If we change our policy, we will notify you in writing and you will be given another chance to opt out at that time. If your Investors Life Insurance Company of North America policy, contract or account is jointly owned with one or more other people, you can opt out for one or all of them.
How We Safeguard Personal Information	Investors Life Insurance Company of North America protects your Personal Information by: Maintaining physical, electronic and procedural safeguards to keep your Personal Information secure. Training employees to safeguard Personal Information and limiting access to people who need it to perform their job functions. Contractually requiring business partners that we share your Personal Information with to safeguard it and use it only for the purpose for which it was shared.
Your Rights	You have the right to know what Personal Information we have about you, to request a correction and to receive a copy upon request. You may be eligible under applicable law to make requests in relation to information we have about you. Please note that your request may be denied in whole or in part if your jurisdiction does not provide you an applicable right. If you would like to know what Personal Information Investors Life Insurance Company of North America has,that is personal to you as an individual, you may submit a request for access to that information by mailing your request to the address in the contact us section below. Your request must describe the records you are seeking. If we can reasonably locate and retrieve the requested records, your Personal Information will be provided in accordance with applicable laws. We may not be able to provide information if it is privileged or relates to investigations, claims, litigation, or similar or related matters. We may charge a reasonable fee to cover the costs in providing this record. If you believe that our records contain incorrect information that is personal to you as an individual, or if you want to request that we delete your information, you may request corrections, changes or deletion by mailing your request to the address in the contact us section below.  We will respond to you within 30 days of receiving your request. If your request cannot be granted, we will send you a notice explaining why the request will not be completed. You have the right to file a statement telling us what you think is correct or why you believe your information should be deleted and the reasons why you disagree with our determination. If you ask us to, we will notify persons with whom we have shared your Personal Information of the change or your statement. With any subsequent sharing of Personal Information, we will include a copy of your statement.
Contact Us:	Requests must be emailed to us at [email protected]. Because of its legal nature, Personal Information obtained when settling claims or defending lawsuits need not be shared with you. This Notice applies to prospective, current and former customers of the following Investors Life Insurance Company of North America Companies. If you are no longer our customer, we may continue to share your personal information as described in this Privacy Notice. If you have any questions or concerns about this Privacy Notice, please contact us at1-877-263-0987or email us at [email protected].
Other important information
NOTICE OF INFORMATION PRACTICES For residents of Arizona, California, Connecticut, Georgia, Illinois, Maine, Massachusetts, Minnesota, Montana, New Jersey, Nevada, North Carolina, Ohio, Oregon, and Virgina. These states require insurers and agents to describe their information practices in addition to providing a Privacy Notice.  The two notices are very similar, but in general our information practices include the following:  Investors Life Insurance Company of North America may obtain information about you and any other persons applying for insurance.  Some of this information will come from you and some may come from other sources.  That information and any other information collected by us may in some circumstances be disclosed to third parties such as agents, affiliates, service providers and others without your specific consent.  In some cases, we may need your direct authorization before sharing that information. Residents have the right to access to correct and, in some cases, to delete (if incorrect) the information collected about them, except information that relates to a claim or to a civil or criminal proceeding.  If you are refused coverage or if your application is postponed, you may also have the right to receive the specific reason in writing. To exercise your rights or if you wish to have a more detailed explanation of our information practices required by your state, please submit a written request at [email protected];
STATE-SPECIFIC DISCLOSURES Customer Person Information will be collected, used, and stored as required by applicable federal privacy laws. If the Customer’s state laws provide more protection of the customer’s Personal Information than federal privacy laws, Investors Life Insurance Company will protect the customer’s Personal Information as required by such state law. YOUR AUTHORIZATION REQUIRED Arizona, California, Maine, Massachusetts, Minnesota, Montana, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oregon, and Virgina. We will not share your personal information with non-affiliated third parties (or in certain circumstances, our affiliates) other than our agents and service providers unless you authorize us to share it or the law otherwise permits us to share it.  You have the right to authorize or not authorize this sharing of Personal Information. FOR VERMONT CUSTOMERS We will not disclose information about your creditworthiness to our affiliates and will not disclose your Personal Information, financial information, credit report or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.  Additional information concerning our privacy policies can be found at investorslife.com or call us at 1-877-263-0987.
ADDITIONAL RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may give California residents certain privacy rights with respect to the limited non-public Personal Information we collect.  To learn how to exercise your rights under the CCPA or if you wish to see a more detailed explanation of your rights, please visit our website at: investorslife.com.