Aflac Privacy Policy

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Effective Date: January 1, 2020

Welcome! Thank you for visiting an offering of Aflac Incorporated and the Aflac group of insurance companies, including American Family Life Assurance Company of Columbus, its wholly owned subsidiary, American Family Life Assurance Company of New York, and Continental American Insurance Company ("CAIC") and Tier One (the Aflac group of insurance companies are collectively, “Aflac,” “we,” “our” or “us”). The aforementioned Aflac companies are separate legal entities. To help inform you, we provide this policy explaining our information practices and the choices you can make about the collection and use of information you submit or we collect (1) online through our websites www.aflac.com, www.aflacgroup.com, www.aflacny.com, and https://phs.aflac.com/aflac.phs.app/account/login, our mobile websites, and other applications (the “Site”), and (2) our offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (“Offline Services”). The Site and Offline Services are collectively referred to in this policy as the “Services.” The Services are owned and operated by Aflac.

Contents & Summary

A table summarizing the contents of this privacy policy (“Privacy Policy”) appears below, followed by the policy in full. Should there be any discrepancy between the table and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Scope and consent

By using the Services, you expressly consent to our collection, use, disclosure, and retention of your personal information and other information as described in this Privacy Policy. Your use of the Services is also governed by the Terms of Use.

Information Collection

We collect the following information when you use these Services:

(a) Registration, Enrollment, and Account Information: When you create an account for the Services, you voluntarily give us personal information.

(b) Claims Information: You may give us your personal information when you submit, change or update a claim.

(c) Information to Respond to Your Requests: You may give us your personal information so we can respond to your requests for information, respond to and process applications, and send you newsletters and other communications.

(d) Social Media Information: When you sign in or engage with our Site through third-party social media sites, you agree to give us on-going access to your personal information.

(e) Video Information: We may collect analytical information about the videos you view on the Site. You consent to our collection of video viewing information on the Site and sharing this information with our affiliates and vendors.

(f) Survey Information: From time to time, we may ask you to complete surveys relating to your experiences with the Services. In connection with same, we may obtain your demographic information (e.g., city, state, account ID, date of birth).

(g) Information About Others: If you are an employer, Aflac broker or agent, you may submit applications or other information for your employees or clients. You confirm that you have obtained the required consent to submit this third party information to us.

(h) Information From Other Sources or Combined by Us: We may, on occasion, combine information from outside sources to customize your experience with the Services.

(i) Mobile Information: We may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, location or GPS/geo-location).

(j) Technical Usage Information: We use tracking technologies such as cookies and other similar technologies to measure usage. For more information about the use of cookies and similar technologies on our Site, please review our Cookies and Tracking Technologies Policy.

(k) Geolocation: By using the site, you expressly consent to our use of your geolocation to respond to your requests.

(l) Call Center Information: When you call our Call Center, we may collect your name, account ID and other information to assist you.

(m) Mobile Applications: When you download and use our mobile application(s), we may track and collect usage data to tell us what information has been accessed, viewed and/or downloaded to the application(s) based on your device number or other identifier.

Uses and Retention

We use information collected from you to provide our Services and contact you. Your information is retained for as long as we need it for our business and to provide you with the Services you request.

Disclosure

We may share your personal information and other information we collect with the following entities: (a) Aflac and the rest of our corporate family including company affiliates and subsidiaries; (b) our vendors and service providers; (c) other entities with your consent; (d) legal, regulatory and law enforcement authorities; (e) others if there is a change of control; (f) companies in the mobile app industry; (g) with others who visit our site if you share information on the Site; (h) others in accordance with state insurance and federal laws; and (i) others as required or permitted by law.

HIPAA Notice of Privacy Practices

Aflac is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule.

Your Choices

You can control how and when you want to receive notifications from Aflac by following instructions within the notices or contacting us as indicated in the Contact Us section below.

Cookies and Tracking Technologies

We and our service providers use tracking technologies (including cookies) to recognize you, protect your privacy, customize your experience on the Site, and target the content/advertising you see, including providing videos customized to your interests. You consent to our tracking of your video viewing through the Site or third party social media.

Access and Review Options

You can review and edit your personal information by accessing your account on the Site or as otherwise indicated in the Contact Us section below.

California Privacy Rights

If you are a California resident, have the right to notice of the personal information we collect, the right to access such personal information, the right to delete some or all of the personal information we collect and the right to opt-out of the sale of your information, as applicable. These rights do not apply to the personal information we collect in order to provide you with financial and insurance products and services.

Third-Parties

We are not responsible for the privacy practices of third-party service providers or websites that are linked to or from our Site.

Security

We protect your personal information using security measures.

Children’s Privacy

Our Services are not intended for minors under the age of 18.

International Transfer

We store and process your personal information on our computers in the United States.

Notification Regarding Updates

You agree that we may notify you about material changes to this Privacy Policy by posting notices on this Site.

Contact Us

For more information about our privacy practices, go to our full Privacy Policy or send an email to privacyoffice@aflac.com. If you are a CAIC account or certificate holder, you may send an email to aflacgroupprivacyoffice@aflac.com.

Full Privacy Policy

Scope and Consent
When you use our Services, you are contracting with Aflac. By using the Services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.
Information We Collect
1. Registration, Enrollment, and Account Information:
  You can browse the Site without telling us who you are or revealing any personal information (e.g., name, username, password, PIN, email address, physical address, social security number, policy number, financial information, telephone number, mobile telephone number, text messages or email, health and medical information, audio, family and children’s information, date of birth, and photos) about yourself. If you register for an account with us, or enroll online or through a call center, you choose to give us your personal information and are not anonymous to us. When you register an account, enroll online or through a call center, create a profile, purchase Services, download a mobile application or otherwise apply for, request or engage with our Services on our Site or through another enrollment system, you may provide personal information. Personal information is only associated with your account/profile on the Site when you sign in as a registered user. Personal information is also collected via Offline Services when you provide it to us, such as applications submitted by you or on your behalf, information about your other transactions with us, and medical exams and tests you take in connection with your application or policy.
  
  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, internet protocol (IP) address, computer type, operating system name and version, device manufacturer and model, language, Internet browser type and version, and browser click-through and usage data. We may use this information for purposes such as analyzing the use of and interaction with our Site and Services, detecting fraud and diagnosing server problems.
  1. Career Information:
    The Aflac Careers sections of the Site give you the opportunity to create an “Application Account” to search and apply for jobs. To apply for a position, you will need to establish an “Application Account.” In order to do so, you will provide us with your email address, password, first and last name, physical address, phone numbers, and career data (e.g., work experience, education and certifications). Aflac is an equal opportunity employer. Your email and password will allow you to access your account later. You may choose to use third-party login credentials to establish and sign onto an Application Account. See the “Social Media Information” section below for more information on using third-party credentials to access the Site. Also, when you apply for a job or authorize us to obtain a consumer report (e.g., background check), we will collect personal and non-personal information (e.g., name, address, telephone number, resume, employment history, reference information, compensation, compensation history, education, social security number and so on).
    
    Visit our employment application information policies for more information regarding the types of employment application information we collect and how we treat it.
2. Claims Information:
  You may give us your personal information when you submit a claim, or when you make changes to, check on, or update your claim.
3. Information to Respond to Your Requests:
  You may give us your personal information so we can respond to your requests for information, review or process your application, and send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section headed “Your Choices” below.
4. Social Media Information:
  We may offer sign-in services that allow you to use third-party login credentials to access the Site. We also may offer Services that allow you to share information with third-party social media websites such as Facebook, Google, Twitter, and others.
  
  When you link your account or engage with our Site through third-party social media sites, you understand that you may be allowing us to have ongoing access to certain information stored on those social media sites (e.g., your public profile, friend list, people you follow or who follow you, your email address, birthday, work history, education history, interests, current city, religious and political views, website, personal description, and likes, and your friends’ birthdays, education histories, personal descriptions, and likes). We may receive certain information about you that is stored on social media sites if other users of those sites give us access to their profiles and you are one of their friends or connections depending upon your settings on those third-party social networking sites. We may also receive other information (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with our Site. The information we have access to from the third-party social media websites varies by website and is controlled by your privacy settings on that website and by your consent. The information that may be passed to analytics providers and advertising partners is via cookies and tracking technologies. Please see our Cookies and Tracking Technologies Policy page for information including your choices in relation to these technologies. By associating an account managed by a third party with your Aflac account and authorizing us to have access to this information, you agree that we may collect, use, and store information from these websites in accordance with this Privacy Policy.
5. Video Information:
  You agree that we may collect and share your video viewing with, or obtain information about your video viewing from, analytics service providers, advertising partners and third-party social media sites for two years or until you withdraw consent.
6. Survey Information:
  You agree that we may collect and share your demographic information (including city, state, and date of birth), claim number, policy holder or certificate holder information, to include your contact information, and other information you may provide to conduct policy holder or certificate holder surveys.
7. Information About Others:
  Employers, Aflac brokers and agents, and their designees may choose to submit applications for other people, either on the Site or through an affiliate or vendor of ours. The applications for Aflac products and services may contain the applicants’ personal information. By submitting information on behalf of someone else to us, you represent and confirm that you have obtained consent from them to do so.
8. Information From Other Sources or Combined by Us:
  The information about you that we collect may be combined with information we receive from other sources and from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law. If you are a policyholder or certificateholder of Aflac, personal information that you provide at Sites may be combined with certain other information we have collected about you through our policy application/administration procedures. In reviewing applications, policies, claims or performing our Services, we may collect additional information from you or others, such as from other insurance companies, consumer reporting agencies and credit bureaus as permitted by the Fair Credit Reporting Act, public records, public databases, government agencies, information clearinghouses and other third parties. In addition, you will have received a Privacy Notice from us explaining how we protect the privacy and security of information you provide and that is collected by Aflac (please see HIPAA Notice of Privacy Practices below in Section 5).
9. Mobile Information:
  We may collect additional information from you if you access our Site through a mobile device (e.g., your unique device identifier, location or GPS/geo-location).
10. Technical Usage Information:
  When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site (“usage information”). We use tracking technologies (including cookies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, and e-tags/cache browsers) to collect usage information.
  
  We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, pages viewed, including page response times, files downloaded, download errors, time spent on certain pages, page interaction information, applications used, browser type, the user’s Internet service provider (ISP), and the user’s computer operating system.
  
  Our goal is to collect and use only that information that we think is required for our legitimate business purposes, in order to better understand your interests and improve the Services. To learn more about how we use tracking technologies and cookies, see Section 7 of this Privacy Policy and also our full Cookies and Tracking Technologies Policy.
11. Geolocation Information:
  When you visit the Site, we may collect geo-location information to provide certain location-based services that you request (e.g., maps) or any of the reasons set forth in Section 3 of this Privacy Policy. We may disclose the geolocation data in the manner set forth in Section 4 of this Privacy Policy.
12. Call Center Information:
  When you contact our Call Center, we may collect your name, account ID and other information you provide so that we may assist you.
13. Mobile Applications:
  When you download and use our mobile application(s), we may track and collect usage data to tell us what information has been accessed, viewed and/or downloaded to the application(s) based on your device number or other identifier.
Uses and Retention
1. Provide Our Services:
  We use the information collected to (i) respond to your requests; (ii) allow you to manage your policies and claims; (iii) allow us to service your policies and manage your claims; (iv) give you information about your account; (v) provide customer service (e.g., to resolve disputes, problems with your account/profile or the Services); (vi) personalize your experience by providing information and content about Aflac products and services to you that we believe may be of interest to you; (vii) operate our promotions (e.g., provide you with entries to and information regarding our sweepstakes and contests); (viii) manage, administer and improve our operations and Services, including Services via employers, brokers, agents and enrollment systems; (ix) conduct surveys; (x) allow you to use our online technologies; and (xi) provide you with a safe, efficient, and customized experience.
2. Analyze and Aggregate Non-Personal Information:
  We use aggregate information about our users and non-personal information to administer, analyze and improve the Services and to analyze user behavior and prepare aggregated reports.
3. Prevent Fraud:
  We use information we collect to prevent, detect, mitigate and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Use.
4. Communicate With You:
  We use your information to contact you by U.S. mail, telephone, email, text message and other means to maintain the Services, your account, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications, to respond to requests related to recruiting brokers, agents and clients or contact you for other purposes authorized by law.
5. Mobile Data:
  When you access the Site on a mobile device or through a mobile application, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you with location-based services, such as an agent locator, search results and other personalized content.
  
  We retain information as long as it is necessary and relevant for our operations, including servicing your account. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.
Disclosure

Information collected through the Services may be shared with:
1. The Aflac Corporate Family:
  We may share the information we collect about you with the Aflac corporate family, including our affiliates and subsidiaries (e.g., Aflac New York, Communicorp, Inc., Continental American Insurance Company, Empowered Benefits), as well as with third-party suppliers. The information may be disclosed to: (i) provide joint content and our services (e.g., registration, transactions, underwriting, setting rates, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our, or a third-party’s products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you communications, including marketing communications, and you will have the opportunity to opt-out in email communications or as otherwise explained in the Your Choices section of this Privacy Policy.
2. Service Providers and Other Third-Parties:
  We may disclose your information to service providers under contract who help with our business operations and Services (such as, but not limited to, call centers, application and benefit enrollment services, policyholder or certificateholder claims processors and adjustors, survey providers, fraud investigations, advertising, data enhancement, computer software and hardware, site analytics and operations). We require these third parties not to further disclose your personal information to any other third party or use it for any other purpose.
3. Other Entities with Your Consent:
  Other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). You may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third-parties, or parties working on their behalf, to implement your request.
4. Legal, Regulatory and Law Enforcement:
  Law enforcement, governmental agencies, or authorized third-parties, including but not limited to inspections, reviews, and in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Aflac user to legal liability. In this regard, we may share your information with third parties in response to a subpoena, court order, search warrant, other legal process and/or to others as required or permitted by law. In such events, we may disclose information relevant and necessary to the inspection, investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation. As appropriate, we also may disclose information to persons identified in our records who have a legal or legitimate interest in your policy, such as mortgagees, lessors or lienholders.
5. Change of Control – New Owners:
  We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.
6. Companies in The Mobile App Industry:
  If you access the Services through a mobile device, we may also share your information with carriers, operating systems and platforms.
7. Information You Share Through the Services:
  When you interact with our Site through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent or control further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.
8. Notices of Information We Share Pursuant to State and Federal Laws:
  Under various state laws and the Gramm-Leach-Bliley Act, insurers and agents must describe their information practices in addition to providing a HIPAA Notice of Privacy Practices.
  Aflac policyholders select your appropriate notice or form below:
  - All other states and Puerto Rico - English | Español
  - California - English | Español
  - Montana - English | Español
  - Affiliate Marketing Opt-Out Form - English | Español
  - Important Privacy Choices for Consumers (California Residents) - English | Español
  Aflac Group certificate holders select your appropriate notice or form below:
  - All other states and Puerto Rico - English | Español
  - California - English | Español
  - Montana - English | Español
  - Affiliate Marketing Opt-Out Form - English | Español
  - Important Privacy Choices for Consumers (California Residents) - English | Español
HIPAA Notice of Privacy Practices
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule provides individuals with the right to receive a notice that describes (1) how their individual health information, personal information and other protected health information (“PHI”) may be used and/or disclosed, (2) their privacy rights with respect to their PHI (including their right to access their PHI and other rights), and (3) Aflac’s obligations with respect to that information. Aflac is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule, in safeguarding PHI.

For its HIPAA-covered insurance policies, Aflac is federally mandated to send a notice (Notice of Privacy Practices) to its insureds and to post the notice on its website. You should be aware that your state law may provide additional access and amendment rights to you, which differ from those granted by HIPAA. If you would like additional information concerning the collection and disclosure of PHI and your rights under state law to access and amend such information, it will be furnished upon request. Please e-mail your request to privacyoffice@aflac.com. If you are a CAIC account or certificate holder, please email your request to aflacgroupprivacyoffice@aflac.com.

In order to access Aflac’s HIPAA Notice of Privacy Practices, please select from the appropriate options below:
Aflac policyholders:
- All states and Puerto Rico - English | Español
Aflac Group certificate holders:
- All states and Puerto Rico - English | Español
Your Choices

Aflac customers
If you are an Aflac customer, you can opt-out of notifications from Aflac by following instructions within the notices or emailing your opt-out request to privacyoffice@aflac.com. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account. You may also choose to opt-out from receiving marketing materials from us by calling 800.992.3522 or downloading and completing the Affiliate Marketing Opt-Out Form. California residents please download or complete the Important Privacy Choices for Consumers form. For more information, refer to “Opting Out of Information Sharing” in the GLBA Customer Privacy Policy. You can opt-out of receiving communications by expressing your preferences to us using one of the mechanisms described in the Contact Us section below.
CAIC customers
If you are an Aflac Group customer, you can opt-out of notifications from Aflac Group by following instructions within the notices or emailing your opt-out request to aflacgroupprivacyoffice@aflac.com. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account. You may also choose to opt-out from receiving marketing materials from Aflac Group by calling 800-433-3036 or downloading and completing the Affiliate Marketing Opt-Out Form. California residents please download or complete the Important Privacy Choices for Consumers form. For more information, refer to “Opting Out of Information Sharing” in the GLBA Customer Privacy Policy. You can opt-out of receiving communications by expressing your preferences to us using one of the mechanisms described in the Contact Us section below.
Cookies and Tracking Technologies
When you visit the Site, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your login status and viewing preferences from a previous use of our Site, for when you later return to the Site.

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
- We offer certain features that are available only through the use of tracking technologies.
- We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
- We use tracking technologies with your prior consent as obtained through your use of this Site.
- We encode and protect the tracking technologies that Aflac sets, so that only we can interpret the information stored in them.
- You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics.
- You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another service user, there may be a cookie placed by that web page.)
- We may target and track the videos you view on the Site. You consent to our tracking of your video viewing through the Site or third party social media for up to two years or as permitted by applicable law or until consent is withdrawn.
For more information about the use of cookies and similar technology on our Site, please review this Privacy Policy and our Cookies and Tracking Technologies Policy.
Accessing, Reviewing, and Changing Your Personal Information
Registered members or policyholders/certificate holders can review and change personal information at any time by accessing their accounts on the Site. You can also call 800.992.3522 to make changes to your personal information or your policy. You should promptly update your personal information if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, administer and manage our operations, comply with regulatory or legal requirements, or take other actions permitted by law. Likewise, if your membership is terminated or suspended, we may maintain some information to prevent re-registration.

Notice to California Residents

California Consumer Privacy Act (CCPA): The CCPA gives California residents certain privacy rights with respect to some of the personal information we collect. These rights are:

The right to notice of the personal information we collect
The right to know the categories, sources and specific pieces of personal information we have collected about you in the past 12 months, including our purpose for collecting the information and the categories of third parties with whom we share that personal information, subject to certain exceptions
The right to delete some or all of the personal information we collect, subject to certain exceptions
The right to opt-out of our sale of your personal information, if we sell your personal information

This section describes these rights, the steps you must take to exercise these rights, how we will verify your identity, and how we will respond to your requests.

Your rights under the CCPA are limited. These rights do not apply to publicly available information from government records, de-identified data or aggregated consumer information, and information we collect in order to provide you with a financial, health or life insurance product or service.

(a) Notice of Collection: We collect personal information about California residents from a variety of sources and use it for purposes related to our business. A full description of the purposes for which we collect the personal information of our consumers is provided in the section below the chart. The personal information we collect includes not only clear personal identifiers, but also any information that directly or indirectly can be associated with, or linked to, our consumers or their households. Below are the categories of personal information we may collect about our consumers, the sources of that information, the purposes for which we use personal information and the types of third parties with whom we have shared personal information in the past 12 months. We may collect similar information about your spouse, children, friends and beneficiaries.

Categories of Personal Information We collect	Sources of the Personal Information	Purposes for which We use Personal Information	Disclosed for a Business Purpose in the past 12 months?	Types of third parties with whom we have shared Personal Information in the past 12 months
Personal Identifiers: your name, alias, postal address, email address, unique personal identifier, online identifier, account name, Internet Protocol address, social security number, driver’s license number, passport number, or other similar identifiers.	- directly from you or from others on your behalf - insurance producer/agent - consumer reporting agencies - our service providers - our affiliates - government agencies - public records - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements.	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Additional personal identifiers: your signature, physical characteristics or description, insurance policy number, bank account, credit card and debit card number, or any other financial information, medical information, and health, life or other insurance information, including your claims history	- directly from you or from others on your behalf - insurance producer/ agent - consumer reporting agencies - our service providers - our affiliates - government agencies - public records - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Sensitive information protected by federal or state law: your age, gender, familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, and genetic information	- directly from you or from others on your behalf - insurance producer/ agent - consumer reporting agencies - our service providers - our affiliates - government agencies - public records - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Commercial information: records of your personal property, products or services you have purchased or considered, and other histories or tendencies to purchase or consume particular products and services	- directly from you or from others on your behalf - insurance producer/agent - consumer reporting agencies - our service providers - our affiliates - government agencies - public records - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Biometric information: physiological, biological or behavioral characteristics that can be used to identify you, such as fingerprints, retina scans, photos used for facial recognition and genetic information	- directly from you or from others on your behalf - insurance producer/agent - our affiliates - our service providers, with your consent - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a Web site, online application and advertisements	- directly from you or from others on your behalf - insurance producer/agent - our affiliates - our service providers - consumer reporting agencies - third parties - information clearinghouses - consumer data resellers - your social media sites - Internet service providers	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Geolocation data	- directly from you or from others on your behalf - insurance producer/agent - our affiliates - our service providers - our affiliates - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Sensory information: Audio, electronic, visual, thermal, olfactory or similar information, including voice signatures and recorded calls	- directly from you or from others on your behalf - insurance producer/ agent - our affiliates - our service providers - our affiliates - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Professional or employment-related information: such as your job title	- directly from you or from others on your behalf - insurance producer/agent - our affiliates - our service providers - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Educational information not publicly available: your level of education, schools attended, your degrees and disciplinary history	- directly from you or from others on your behalf - insurance producer/agent - our affiliates - our service providers - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interestrelating to you Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers
Inferences drawn from any of the above categories of information to create a profile about you: Information about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	- directly from you or from others on your behalf - our affiliates - insurance product/agents - our service providers - consumer reporting agencies - consumer data resellers - information clearinghouses - consumer data resellers - other insurers - your social media sites	We may use this data to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements	Yes	- Affiliates - Group policy sponsors, such as employers and affinity groups - Insurance producer/agents - Service providers - Reinsurers and other insurance companies - Joint marketing partners - Consumer reporting agencies - Government, judicial and law enforcement agencies and their agents - Industry self-regulatory bodies - Attorneys, accountants and auditors - Your fiduciary or legal representatives - Persons holding a legal or beneficial interest relating to you - Advertising networks - Data analytics providers - Social networks - Internet service providers - Consumer data resellers

Purposes for which we use your data: We may use each of the categories of personal information listed in the chart above for the following business purposes: (i) respond to your requests; (ii) allow us to offer and issue you an insurance policy and to manage your policies and claims; (iii) allow us to service your policies (iv) give you information and statements about your account; (v) provide customer service (e.g., to resolve disputes, problems with your account/profile or the services); (vi) personalize your experience by providing information and content about Aflac products and services to you that we believe may be of interest to you; (vii) operate our promotions (e.g., provide you with entries to and information regarding our sweepstakes and contests); (viii) manage, administer and improve our operations, technology and services, including services via employers, brokers, agents and enrollment systems; (ix) conduct surveys; (x) allow you to use our online technologies; (xi) provide you with a safe, efficient, and customized experience; (xii) meet our legal and compliance obligations, including defend legal claims, obtain audits, respond to court orders and in legal investigations; (xiv) detect security incidents; (xv) perform data analytics; (xvi) conduct institutional risk assessments, risk modeling and statistical analysis and for mergers and reorganizations; (xvii) obtain reinsurance; and (xviii) report to consumer reporting agencies.

(c) Your Right to Know and Access the Personal Information We Collected: You have the right to ask us to disclose certain personal information we have collected about you over the preceding 12 months, subject to certain exceptions:

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

Before we respond to your request to know and access, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described in the section below on “How We Will Verify Your Identity.”

(d) Your Right to Delete Your Personal Information We Collected: You have the right to ask us to delete the personal information that we have collected and retained about you, subject to certain exceptions. Before we respond to your request to delete, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described in the section below on “How We Will Verify Your Identity.”

Submitting a request to delete is a two-step process. After you submit a request to delete, we will ask you separately to confirm that you want all or some of your personal information deleted.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(e) Your Right to Opt-Out of Sale of Personal Information: We do not sell personal information about current or former customers to any third parties. States are increasingly adopting privacy regulations, however, that require businesses like Aflac to provide consumers with a process to opt-out of potential practices that might involve the sale of personal data. If you would like to record your preference that Aflac not sell your personal information, please click here: DO NOT SELL MY PERSONAL INFORMATION

(f) Your Ability to Opt-out of Third Party Cookies: We may allow third-party advertising cookies to be placed on your browser or mobile device when you visit our website. You may opt-out of third party cookies. As explained in our Cookies and Tracking Technologies Policy, we and our third-party service providers may use cookies to deliver content, including ads, relevant to your interests on our Site and third party sites based on how you interact with our advertisements or content. In addition, our Ad Network partners may deliver ads to you using cookies to uniquely distinguish your web browser and keep track of your browsing history in order to serve ads to you on your web browser. To opt-out of third party cookies, follow the instructions in our Cookies and Tracking Technology Policy.

(g) How to Exercise Your Rights:

Authorized Agent: You may designate an authorized agent to submit a request to know or a request to delete on your behalf. If that agent is not already authorized to access your account in your profile, please submit a notarized special power of attorney in writing that provides the authorized agent with permission to make a request to know or a request to delete on your behalf. We may also ask you to verify your identity directly with us. We will deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
We provide consumers with a web-link and a toll-free telephone number for submitting requests under the CCPA. You, or your authorized agent, may exercise your individual rights at any time by selecting your preferred method and following the instruction provided:
- Initiate an individual rights request to access or delete personal information by clicking here and completing the online form; or
- Initiate an individual rights request by calling our toll-free number 1-855-768-9730.
- Initiate an individual rights request not to sell my personal information by clicking DO NOT SELL MY PERSONAL INFOFORMATION and completing the online form;

We have created the online form above to provide you with a quick and easy way to exercise your rights.

You may also mail a request to Aflac at: Aflac Worldwide Headquarters
Attn: Privacy Office
1932 Wynnton Road
Columbus, GA 31999

Aflac Group
Attn: Privacy Office
Post Office Box 427
Columbia, SC 29202

Aflac is not required to respond to your requests for individual access requests and/or to provide (where applicable) your personal information more than twice within a 12-month period.
If we deny your request in whole or in part, we will provide you with an explanation or direct you to our general business practices for collecting personal data. Under no circumstances will we provide the requestor with a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account numbers, any health insurance or medical identification numbers, any account passwords, or any security questions and answers.
We will use reasonable security measures when transmitting information to a consumer.
In no event will Aflac discriminate against any consumer who exercises any of their privacy rights found under the CCPA. Unless permitted by law, we will not do any of the following to you if you exercise your CCPA rights:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

(h) How We Will Verify Your Identity: Only you, or an authorized agent, may submit a request to know or to delete your personal information. You may also make a request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

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. Making a verifiable consumer request does not require you to create an account with us. We will use the personal information you provide to us when submitting a consumer request only to verify the requestor's identity or authority to make the request.

We will require the following information to verify your identity:

For requests made online: We will require you to upload a photo identification card (passport, driving license) so that we can correctly match it with data we have previously collected about you. We will also require you to attest that you are the person you claim to be.
For requests made by phone: In order to submit your request over the phone, you must have a valid phone number and a valid email address.
For requests made by mail: You must submit proof of your identity.
Additional data we may request to verify your identity: When we request additional information from you to verify your identity, we may request other account information, answers to security questions, your name, government identification number, date of birth, contact information, or other personal identifying information.

(i) How We Will Respond to Your Request: We intend to confirm receipt of your request within 10 days and to respond to a verified request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of a verified request from you. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know the specific pieces of information we have collected, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

(j) Residents of the State of California may request a list of categories of all third-parties with whom our Site has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at privacyoffice@aflac.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

(k) How We Respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Aflac responds to “Do Not Track” browser settings. Aflac does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Third-Parties
Our Site may contain links to other third-party websites, or they may provide services on our Sites. We are not responsible for the privacy practices or the content of these third-parties. Please refer to the privacy policies of these third-party sites to learn how they collect and use your information.
Security
We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures designed to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third parties. Also, as a reminder, the Internet and email generally are not often/always secure, and they should not be used for sending sensitive personal information, such as your SSN, birthdate or financial information. Emails also can be intercepted and/or read by unintended recipients. If you choose to communicate with us by email, then in order to contact us in a more secure manner, and if applicable, log into your Aflac account on the Site, which has additional safeguards in place.
Children's Privacy
The Site is a general audience site and it is not directed to minors under the age of 18. We do not knowingly collect personal information via our Services from users in this age group.
International Transfer
Our computer systems are currently based in the United States, and your personal information may be processed in the U.S., where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create an account/profile, you consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Privacy Policy.
Notification Regarding Updates

From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates.
Contact Us

If your questions are not answered online through this Policy or website, you may contact us online, or contact us as follows:

Physical Address

Aflac Worldwide Headquarters
1932 Wynnton Road
Columbus, Georgia 31999
800.992.3522

Aflac Group
1600 Williams St.
Columbia, South Carolina 29201
800.433.3036

Mailing and Email Address

Aflac Worldwide Headquarters
Attn: Privacy Office
1932 Wynnton Road
Columbus, Georgia 31999
800.992.3522
privacyoffice@aflac.com

Aflac Group
Attn: Privacy Office
Post Office Box 84075
Columbus, GA 31993
800.433.3036
aflacgroupprivacyoffice@aflac.com

^* Continental American Insurance Company (Aflac Group), a proud member of the Aflac group of insurers, is a wholly-owned subsidiary of Aflac Incorporated and underwrites group coverage. Continental American Insurance Company (Aflac Group) is not licensed to solicit business in New York, Guam, Puerto Rico, or the Virgin Islands. For groups sitused in California, coverage is underwritten by Continental American Insurance Company (Aflac Group). For groups sitused in New York, coverage is underwritten by American Family Life Assurance Company of New York.

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Individual Policies:
Coverage underwritten by American Family Life Assurance Company of Columbus. In New York, coverage underwritten by American Family Life Assurance Company of New York. Direct to Consumer individual coverage underwritten by Tier One Insurance Company.

Aflac Worldwide Headquarters | Columbus, GA

Aflac Group Policies:
Continental American Insurance Company (CAIC), a proud member of the Aflac family of insurers, is a wholly-owned subsidiary of Aflac Incorporated and underwrites group coverage. CAIC is not licensed to solicit business in New York, Guam, Puerto Rico, or the Virgin Islands. For groups sitused in California, group coverage is underwritten by Continental American Life Insurance Company. For groups sitused in New York, coverage is underwritten by American Family Life Assurance Company of New York.

Aflac Group | Columbia, SC

“Aflac” may include American Family Life Assurance Company of Columbus, American Family Life Assurance Company of New York, Continental American Insurance Company (marketed as “Aflac Group”), Tier One Insurance Company, and any other affiliated companies (collectively, “Aflac”), as applicable to the entity from whom you receive insurance services.

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