We collect different types of information for our business purposes from the following sources:

Information You Provide. We collect information that you provide to us through the Online Services, surveys, and other communications.  We may collect information from entities you have requested or authorized to provide information to us in connection with the purchase or maintenance of a Product.  For example, we may collect information through the Online Services when you:

• purchase or request a quote for a Product;
• register for, manage, or update a Product;
• use our e-Billing services or manage your online account and investment options through the Online Services;
• use Online Service tools, calculators, and other resources that request your, your family’s, or your beneficiary’s information;
• access other applications and services from the Online Services, such as when you apply for a job or use the Locate an Agent function;
• subscribe to newsletters or other communications from us;
• provide feedback, request information, or otherwise contact us through the Online Services;
• participate in social media platforms where WFG maintains a presence, such as Facebook, Twitter, and LinkedIn, or when you make information available to us and others via social media or via forums, blogs, email lists, chat rooms, or other similar technologies;
• participate in surveys, sweepstakes, or other promotions;
• conduct searches through the Online Services; and/or
• otherwise share information about yourself through the Online Services or authorize a third party to share such information about you with us

We may collect the following information, including as reasonably required to complete a request, provide a Product, support your efforts to obtain a Product from companies or insurers we may represent, or complete a transaction on your behalf: first and last name, home or other physical address, telephone number, email address, other identifiers that permit an individual to be contacted physically or online, date of birth, Product numbers, data about transactions with us or those we represent (such as account balances, coverages and benefits, and payment and claims history), education information, professional information, employment information, medical and health information, banking information, credit card number and other financial information, government identification (such as social security or other tax identification, driver’s license, or passport numbers), age, race, disability status, criminal history, marital status, gender, security credentials (such as passwords or voiceprints), and other information.

Information Collected Automatically. We may collect information automatically using data collection technology, such as cookies, web beacons, pixel tags, or other similar current and future technologies as they develop (the “Data Technology”).  We may have access to information automatically collected by Data Technologies across our websites and third-party websites and mobile applications, or as compiled by our Advertising Partners, described below.

When you use mobile devices to access our websites, we may receive information about your location and your mobile device. This may include a unique identifier for your device, device settings, analytical information about how you use your mobile device, and other information that may be stored on or accessed through your mobile device. In some cases, we may receive information from mobile applications not operated by us or from other devices connected to your mobile device.

Information collected automatically, including through Data Technologies, may include: your IP address and associated activity tracking; the type of browser and operating system you use; the date and time you access the Online Services; the address of websites you visit prior to or after visiting our Online Services; the number of times you access our Online Services; the pages viewed and features you access during your visit to our Online Services; responses to advertisements and promotions on the Online Services, other websites, and mobile applications; BOI emails you open and links you click within those emails; data regarding your internet service provider or mobile carrier geolocation data (to the extent provided by you or your device); inferences which we may gather relating to your preferences, attitudes, characteristics, or behaviors; and the type of handheld or mobile device that you use.

Notice of Monitoring of Services.  We and our third-party vendors and partners may monitor visits to our websites and mobile applications, including sessions of users.  This monitoring may log the details of your visits to our websites and mobile applications information, such as clicks, page visits, text entered, how long you spent on a page, what you viewed on a page, information you submit, communications and other details of your visits. The Data Technology described above (see “Information Collected Automatically”) may be used to collect and retain usage data for the purposes described in this Statement, including for marketing, analytics, and security purposes and to improve your experience on our websites and mobile applications.

Additionally, if you engage with chat functionalities that may be offered on our websites, your conversations via our chat functionalities may be retained by us and our vendors for our business purposes. This can include any interaction between you and our chat technologies, information you input into chats, and the conversations you have through our chat functionalities.

Information from Other Sources. We may collect information about you from third-party sources, including from individuals authorized to sell products or services on our behalf (including brokers and insurance agents) or on behalf of companies we represent, commercially available sources such as credit reporting agencies, data brokers or other companies that collect or analyze information about consumers or users.  Examples of information we receive from third-party sources include: (1) information from independent insurance agents when you seek to obtain insurance or other financial products; (2) credit history information from credit bureaus, which we may use to help prevent and detect fraud, and for other similar purposes; (3) demographic information from data brokers and other sources to help anticipate consumer trends and needs; (4) information provided from sources you have authorized to share information with us, either on our Online Services or via third-party applications, devices, websites, or other digital interfaces; and (5) other similar types of information.  We may also gather information from other third parties with their own privacy practices and policies.  We may combine information obtained from other sources with information we collect ourselves.

We may use information we collect to operate our business, including the following:

• for our everyday business purposes, such as establishing and administering Products, providing information you request and providing customer support;
• to evaluate your eligibility for Products;
• to communicate with companies we represent when you obtain or seek to obtain their products or services;
• for special events, programs, surveys, contests, sweepstakes, and other offers or promotions, some of which may have additional rules or provisions addressing how your information is used or shared;
• to price and develop new and existing Products or technology and analyze the effectiveness of Products, marketing trends, and websites;
• to maintain the quality or safety of Products or technology which we may own, control, or provide;
• to conduct internal research;
• to deliver content and marketing communications that we think may interest you, including ads or offers tailored to you based upon your browsing and usage history, both within these Online Services and on other websites and mobile applications;
• to provide retirement calculators, assessments, and other financial planning tools on the Online Services;
• to comply with the law, regulations, and other legal obligations;
• to properly verify your identity, prevent fraud, and enhance security;
• to audit and provide reporting relating to particular transactions and interactions, including online interactions you may have with us or others on our behalf;
• to allow you to utilize features and personalized content within our Online Services when you grant us access to information from your device (e.g., contact lists, geolocation, etc.), including location-based services;
• to contact you, including via telephone, text, or chat;
• for short-term, transient use including contextual customization of ads;
• to protect our rights and the rights of others; and/or;
• for other purposes, as permitted by law or to which you consent.

For example, we may share the information that we collect about you to support our business, including the following: 

Affiliates and Service Providers. We may share information with our corporate entities and affiliates, service providers, data processors, third party contractors, payment processors, and others who perform services for us in connection with our Online Services or our businesses, to complete or confirm a transaction or series of transactions or to provide Products or services to you (e.g., reinsurers, health care professionals, credit agencies, or your representatives).  In some cases, as permitted by law, we may share information with our affiliates to market their products and services to you.

Other Entities. We may share information as part of a merger, acquisition, or other sale or transfer of all or part of our assets or business.  To the extent you apply for a Product online, we may share your information with all the entities you have authorized us to share information with or request information from in the application (e.g., to insurers we represent whose products or services you apply for or obtain, reinsurers, health care professionals, credit agencies, your representatives, etc.).

Government Entities, Regulators, and Law Enforcement. We may disclose information about you to third parties under certain circumstances, such as in connection with illegal activity performed by a user on the Online Services, or to respond to a subpoena, court order, or other legal process.  We may release information that we collect to law enforcement, government officials, insurance regulators, auditors, professional advisors, or third parties as required or permitted by law (including foreign laws applicable to us or our affiliates or service providers), to protect our rights and the rights of others, or in our discretion to prevent fraud, harm, or loss to you, ourselves, or others.

Social Media. We may include widgets, tool bars, or icons from social media providers on our Online Services that allow you to interact or share information with them, and these social media networks may collect information about your browsing on the pages of our Online Services.  Such collection may occur where the widgets, tool bars, or icons are visible, even when you do not click on or otherwise activate the widgets, tool bars, or icons.  The privacy policy of the relevant social media network controls the collection, use, and disclosure of all information collected by that social media network. 

Marketing, Analytics, and Advertising Partners. Third parties may collect personally identifiable information about your online activities over time and across different Websites when you use our Online Services. We may share information with marketing providers, analytics providers, and Advertising Partners.  “Advertising Partners” means advertising networks which deliver targeted advertisements to consumers, including advertisements with links to BOI websites, and which generate related statistics and metrics.  These Advertising Partners may utilize information collected through a variety of Data Technologies to provide advertising placement, customization, auditing, research, and reporting for us and other advertisers. See Your Communication Choices below for information about how to control the information collected, used, and shared using Data Technologies.

You may make certain choices about how we communicate with you.  For example, you may: elect not to provide your information; adjust your device or browsing settings to disable, prohibit, or turn off Data Technologies or geolocation or location services features; and adjust your device’s settings regarding the use of advertising identifiers.  (Please note that when you adjust settings or delete Data Technologies in one device or browser, those same settings or deletions may not be effective on other, different devices or browsers.)  If you choose to limit collection of your information in these ways, certain Online Service features may not function properly, or at all, and certain Products may not be available to you. As of the effective date above, we do not respond to Do Not Track signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites. If you do not want to receive marketing emails from us, you can follow the unsubscribe link provided in those emails.  However, please note that even if you opt out of receiving marketing emails, you may still receive certain communications from us relating to your use of our Products, notices of changes to this Privacy Policy or other terms or policies, or similar administrative, transactional, or educational messages. 

Accessing Your Information. If you create an online account, you can log in to that account to access all or some of the information you previously provided.  

Correcting Your Information. If you believe that information we maintain about you is inaccurate, subject to applicable law you may request that we correct or amend the information by contacting us as indicated in the Contact Us section below.  In many cases, you may also access your online account to correct your information.

Consumer Requests. Under certain privacy laws, including in Canada, you may have the right to make additional requests regarding your information (“Consumer Request(s)”), including requests for access to your personal information, for information about how it has been processed, and to withdraw your consent to our processing of your personal information.  If you have questions about Consumer Requests, please call our toll free number 929-209-3366, or contact us by email at consumerdatarequest@blueoak.com.

Requests by California Residents. If you are a California resident, you may have certain additional privacy rights such as the right to request access to your personal information or that we delete your personal information.  For example, under the California Consumer Privacy Act (“CCPA”), California residents may request to prohibit the “sale” or “sharing” (for cross-context behavioral marketing), of their personal information, as defined in the CCPA.  If you are a California resident and wish to make this request, please click this link:  Do Not Sell or Share My PI. For additional information, please click this link: CCPA. Also note that the CCPA does not apply to information subject to other privacy laws such as the Gramm-Leach-Bliley Act (“GLBA”), the Health Insurance Portability and Accountability Act (“HIPAA”), and the Fair Credit Report Act (“FCRA”). Therefore, information collected or used under such laws, such as information collected for financial or insurance products, is not subject to the CCPA

Requests by Canadian Residents. If you are a Canadian resident, you may have the right to make additional Consumer Requests, such as the right to correction, or the right to opt-out of the sale of your personal information.  If you wish to make a Consumer Request or have questions about Consumer Requests, please call our toll free number 929-209-3366, or contact us by email at consumerdatarequest@blueoak.com

Online Services are not directed to children under the age of 13. 

Personal information is maintained on our servers or those of our service providers and is accessible to our authorized employees, representatives and agents who require access for the purposes described in this Statement. BOI and our service providers may access, process, or store personal information outside of your country of residence. 

We use administrative, technical, and physical security measures designed to safeguard your information against loss, theft, unauthorized use, disclosure, or modification. Of course, despite these measures, no network or system is entirely secure, and we cannot guarantee the security of networks and systems we operate or that are operated on our behalf.

If you have any questions or comments about this Statement, please contact our Privacy Officer by email at Privacy@blueoak.com