Table of Contents

Assurance Privacy Policy

Assurance is here to protect and improve the personal and financial health of all consumers.

When you use, access or interact with our services, you are agreeing to our Terms of Service and also consenting to our information practices disclosed and hyperlinked herein.

Definitions

• “Assurance” or “us” or “our” or “we” refers to Assurance IQ, LLC and its affiliates, not to our parent company Prudential Financial or any of its other subsidiaries.
• “Information practices” refers to the collection, use, disclosure, sale, share, and retention of personal information.
• “Privacy Policy” refers to this disclosure and our hyperlinked privacy disclosure incorporated by reference in their entirety.
• “Services” refers to information practices when you:
  • visit or interact with us on our websites (“Websites” or “Sites”)
  • apply for or obtain a product/service through us
  • receive or reply to email or other electronic communications from us or our partners
  • use our software applications (“Apps”) on or through computers and mobile devices
  • register for online access to your account
  • view or click on our ads or other Assurance online content
  • ask to receive information about our products or services
  • fill out an online survey or provide your feedback
  • interact with us on social media or websites and applications maintained by other parties
  • apply for employment with us
  • provide services to us or on behalf of us as an employee of a service provider, consultant, or other business relationship
• “Website” or “Site” means www.assurance.com and any other Internet sites operated by us, our online services, mobile services, and software.
• “You” and “your” means the user of our Websites and Services.

Scope

This Policy covers our information practices and your choices in connection with our Services.

Our Assurance U.S. Consumer Privacy Notice applies to our information practices in connection with seeking, applying, or obtaining a financial product or service pursuant to Gramm-Leach-Bliley Act (GLBA). Please review the U.S. Consumer Privacy Notice.

Our California Resident Privacy Disclosure, applies to the information practices subject to California Privacy Rights Act of 2020 (CPRA). Please review, the California Resident Privacy Disclosure.

This Policy does not cover the privacy practices of third parties or service providers that we do not own or control, nor of our parent company Prudential Financial or its other subsidiaries. Certain Services of Assurance affiliates may contain different privacy statements, which supplement this Policy.

We are not responsible for the information practices of third parties, including any third party operating a website or service to which our Services link. The inclusion of a link to a third-party feature does not imply endorsement of the linked website or service by us or by our affiliates. When you leave our Services or interact with a third-party feature, you should also read the applicable party's privacy policies and Terms of Service to make sure you understand their information practices.

In addition, we are not responsible for the information practices of other organizations, such as Facebook, Apple, Google, Microsoft, Bing, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose directly to other organizations or which you enable to be disclosed to other organizations as result of your device or browser preferences through or in connection with your use of the Apps or social media pages.

Our Services are intended for use by residents of the United States. They are not intended to subject Assurance to the laws or jurisdictions of any state, country or territory other than those of the United States.

Our Services are directed towards individuals able to shop, apply, or enroll in the financial service products we offer. Our Services are not directed at nor intended for unemancipated minors or children under the age of 16. We also do not knowingly collect personal information from minors.

When you visit our Careers Website we collect information you provide to us such as business and personal contact information, professional credentials and skills, educational and work history, and other information contained in a resume or application. We also may collect information from third parties such as educational institutions, former employers, and background check agencies. We use this information to communicate with you, facilitate our recruitment activities and process employment applications; examples include, evaluating a job candidate, interviewing a job candidate, and monitoring recruitment activities. We may also use this information to operate and improve the Services, and as otherwise necessary for compliance, fraud or malicious activity prevention, and safety purposes.

When you operate for or on behalf of Assurance in a contracted business relationship capacity, we collect information you provide us such as business and personal contact information to facilitate access to systems and platforms relevant to the nature and scope of the contracted work. We use this information in the context of employment. We also collect and store information about your activity on our systems and platforms to ensure compliance with our code of conduct and security standards.

How We Collect Information

Depending on your relationship with us, there are three primary ways we may collect information about you: (1) when you provide it to us, (2) through automated technologies, and (3) by asking others to provide it. We need to collect personal information to provide Services to you. If you do not provide the information requested, we may not be able to provide the Services.

We’ve broken down each of those three categories in further detail.

1. Information You May Provide to Us

You may provide information to us in various ways, such as through online forms, over the phone, or other means offered through our Service. For example, on our Website we may ask you some basic questions in order to generate an insurance quote for you. The types of information you provide us fit into two categories.

• Personal Information is information that identifies you personally, such as your name, postal address, email address, telephone number, or other contact information.
• Non-Personal Information is information about you or your household that, on its own, doesn’t identify you personally, like gender, income, employment status, or products of interest. This also includes information that has been aggregated in a manner such that it no longer reveals your identity

When we combine Non-Personal Information with Personal Information, we treat it like Personal Information for as long as it is combined.

Unless specifically requested, we ask that you do not send us, and you do not disclose, any additional personal information (e.g., information related to government identifiers, racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) during the use of our Services.

If you disclose, to us or to our service providers, any personal information relating to other people in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

2. Information We May Automatically Collect

We may automatically collect certain information from your device or computer regarding how you access and interact with our Services. We call this Usage Information for purposes of this Privacy Policy. Usage Information is a critical part of how we improve your experience on our Websites and, more importantly, provide you with more personalized insights and recommendations, which is the core of what we aim to do at Assurance.

In some instances, we may combine Usage Information with Personal Information. If we do, we will treat the combined information as personal information as long as it is combined.

There are four types of Usage Information we may collect:

1. Device Information. We collect information about your device, such as your operating system, hardware model, application or browser type and version, browser configuration, IP Address, and unique identifiers associated with your device.

2. Activity Information. We automatically collect certain information in system logs or similar files about your use of our Services, how you interact with our Services and advertisements, and information about data or files that have been uploaded to our Services. This Information may include things like buttons you click and mouse movements, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Jump to our Tracking & Analytics Technologies section to learn more about cookies, pixels tags, and analytic technologies.

3. Information Used to Reidentify. We collect information to try to reidentify you across multiple browsing sessions and devices (for instance, connecting your current browsing session with a prior session).

4. Location Information. We may use certain information to estimate your location such as IP Address. We may also request location-enabled services on your device (which typically provide GPS or Wi-Fi access point details).

Note that you may choose to set your web browser to refuse, limit, or to alert you of certain information practices regarding Usage Information. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. If you do make such changes, please note that some parts of our Services, designed to combine digital guidance and human touch, may not function properly, and we may not be able to offer you a personalized experience.

3. Information Third Parties Provide to Us About You

To provide you with more personalized product recommendations, we collect information about you from third parties and from other sources, such as contracted parties, government data sources, public data sources, or an authorized proxy. For example, we may collect information from a third party to verify the address you provided, to help us understand your occupational background, to confirm you are not a bot, or to prevent entering fraudulent information. This also includes when you provide a third-party information and consent to share that information with us to help generate a personalized quote for you.

How We Use the Information We Collect

We use the information we collect from you and third parties to operate our Services, including to provide you with insurance quotes, communicate with you, and take steps to improve your experience. Such business and commercial purposes include:

• To provide personalized Services to you. We use the information we collect to provide Services to you in a personalized way including offering a quote, processing transactions, maintaining and servicing your account or policy, providing customer service. We also may collect information in our capacity as a service provider on behalf of a financial service providers (e.g., insurance carriers, financial institutions). Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. The information we collect gives us a more detailed picture of who you are so we can help you find the right product.
• To improve and debug our Services. We are constantly trying to improve our Services. The information we collect may be used to conduct internal research and analysis including data analytics, modeling, and recommendation Services. The information we collect also helps us improve the experience we provide to consumers, the intended functionality of our Services, and the way we match consumers to product recommendations in real time. For example, in some instances, we may use information you have provided, even if you have not completed the web flow, so that if you return to the Website this information will be pre-loaded for your convenience.
• To detect, investigate, and prevent fraud, misuse, or malicious activities. We respect your privacy and safety and therefore may use the information we collect to detect, investigate, prevent, or take action regarding incidents, threats, and misuse of natural persons, your information, or our systems. This includes suspected theft, fraud, malicious, deceptive or illegal activities, or violations of our policies. As a result, we may also use the information we collect to verify your identity.
• To communicate with you and advertise to you. Part of providing personalized service is quickly connecting you with real people who can help walk you through your Service options, communicating to you about potential topics of interest, marketing and advertising to you, and responding to your requests and inquiries. For example, if you provide your phone number and email and then consent to being contacted by us, we may call you to connect you with one of our licensed insurance agents. We may also text and email you information about how to contact us, personalized marketing messages, information about your shopping journey, offers, and other information pertinent to your financial services inquiry.
  • Opting Out of Further Communication. Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. If you’d prefer we do not contact you, please opt-out of further communications from us by requesting to be placed on our Do Not Call list, by replying “STOP” to our text messages, by unsubscribing to our email list, or by using our Communication Opt-Out form.
• As required by governing law and for legal reasons. We operate in a regulated industry and therefore reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, information related to your use of our Services as reasonably necessary to do any of the following: comply with applicable law; respond to complaints, legal actions or governmental requests; enforce our Terms of Service; protect our rights, privacy, safety, or property; or respond to other similar matters. We may also use third-party services to record your actions on our Websites to help meet our compliance and legal obligations.
• As part of a corporate change. We may use, disclose, and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.

We may also use personal information for any other purposes that we may specifically disclose at the time we collect your information.

Who We Share Information With

As a distributor of financial services products, we work with a number of partners to deliver the Services to help a consumer meet their financial needs, and therefore share information with those partners. Although we aim to directly meet all of our consumers’ needs, we also—with your permission—may sell the information you provide us to third parties, to market their financial products and services, and to select insurers, financial institutions, and their Agents who may make insurance, credit, and other offers.

The following is a general list of how we may share your information in connection with your use of our Services:

• Share information with our business and financial service partners (e.g., insurance carriers) to provide and improve our personalized Services.
• Share information with third-party service providers acting on our behalf.
• Share information with advertising networks, social media networks, and marketing affiliates to communicate to you about our Services. This includes joint marketing and communications about your consents and preferences.
• Share information to third-party partners, with your permission , to provide you or communicate to you about their products and services. These third parties may be other insurance agencies, insurance carriers, financial services providers, or other entities that facilitate the process of connecting customers with financial services providers. These third parties, or the entities they work with, may contact you based on the consent you have provided.
• As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.
• For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes as described above.

The table outlines who we may share your information with in connection with our Services:

Tracking & Analytics Technologies

We may use various technologies to collect and store information in connection with your use of our Services. These may include things like cookies, browser storage, web beacons, and other tracking technologies.

• Cookies. Cookies are a standard feature of our Services that allow us to store small amounts of data about your use of our Websites. A cookie is a small piece of information that a website can send to your browser. It acts as a tag that identifies your computer but may not identify you personally. Cookies store information such as web pages viewed, advertisements clicked, browser preferences, etc.
• Pixel Tags. Pixel tags, also known as clear GIF or web beacons, are placed on certain pages of our Websites. When you access our Services, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, for example, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous visit.

Assurance uses cookies and pixel tags to:

• provide better customer service
• analyze how visitors use and navigate our Services
• evaluate our advertisements on other websites
• identify areas which may need improvement
• enhance navigation and the functionality of our Services
• securely maintain a session for users accessing password-protected areas
• personalize aspects of your experience such as articles and education materials

We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.

You may also wish to refer to https://www.allaboutcookies.org/manage-cookies/index.html. If, however, if you do not accept cookies, you may experience some inconvenience in your use of the Services and you may not receive advertising or other offers from us that are relevant to your interests and needs.

We, or other parties we do business with, may place or recognize unique cookies or other technologies on your browser when you interact with our Websites to collect information about your use of our Services and your other online activities (over time and across different websites), and may use that information to serve interest-based advertisements and behavioral advertisements to you as you browse the Internet.

To learn more about this information and to learn how to opt out of it in desktop and mobile browsers on a particular device, please review the information below:

• To opt-out of such collection and use for online behavioral advertising by the Digital Advertising Alliance (DAA) participating companies in the United States, please visit: DAA Choices and DAA AppChoices.
• To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: NAI. Please note that even if you opt-out, you may still receive advertisements that are not customized based on your Activity Information.
• To opt-out of the sale/sharing of information for behavioral advertising, please visit: Global Privacy Control.

Our Websites may also use Google Analytics. Google Analytics uses cookies and similar technologies to collect information about how visitors use our Services. We use the information to compile reports and to help us improve the Services. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Our Websites may also use third-party analytics tools such as Verisk Analytics, ActiveProspect, Jornaya, LogRocket, Datadog, Microsoft Clarity, and Google Tag Manager to track page content and click/touch, movement, scroll, and keystroke activity.

How We Protect Your Information

We seek to use reasonable administrative, technical and physical safeguards, and other security measures to protect personal information within our organization from growing threats. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate personal information to us through the use of the Services. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the contact methods provided below.

How Long We Retain Information

Assurance retains personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

Updating Your Information

To update information about your Assurance account, you may use one of the following methods:

• Contact us at: 1 (844) 563-0386 TTY 711
• Contact us at: The telephone number associated with the particular online form
• Message us any time at: contactus@assurance.com
• For Medicare customers, you can access or create an online account at: my.assurance.com
• To modify the Agent of Record: contact the carrier associated with your application or policy

Changes to this Policy

This Privacy Policy is effective as of January 2023. We reserve the right to change this Privacy Policy at any time. We will note within the Privacy Policy when it was last updated. Any changes to this Privacy Policy will be effective as of the day they are posted. Use of our Services following these changes signifies acceptance of the revised Privacy Policy.

Contact Us

We appreciate you taking the time to read this. If you have questions regarding this policy or information practices at Assurance, you can email us at privacy@assurance.com

California Resident Privacy Disclosure

Assurance is here to protect and improve the personal and financial health of all consumers.

When you use, access or interact with our services, you are agreeing to our Terms of Service and also consenting to our information practices disclosed and hyperlinked herein.

Definitions

• “Assurance” or “us” or “our” or “we” refers to Assurance IQ, LLC and its affiliates, and not to our parent company Prudential Financial or any of its other subsidiaries.
• “California Resident Privacy Disclosure” or “Disclosure” refers to the combination of California Privacy Policy and California Privacy Notice at Collection.
• “Information practices” refers to the collection, use, disclosure, sale, share, and retention of personal information.
• “Personal Information” or “information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device.
• “You” and “your” means the California resident using our Websites and Services.

Other terms throughout this Disclosure, such as “share”, “sell”, and “sensitive personal information”, are referenced according to their definitions under the California Privacy Rights Act of 2020.

Scope

This Disclosure covers the online and offline information practices and your choices in connection with the California Consumer Privacy Act of 2018 as amended under the October 2022 draft revisions of California Privacy Rights Act of 2020 (referred to as “CPRA”).

Certain information is subject to certain state and federal privacy laws, like the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act (“HIPAA”). That information is not subject to CPRA and therefore, this Disclosure does not apply to information practices subject to such laws. For example, information practices in connection with requesting or obtaining our financial products and services for personal, family, or household purposes, or for long-term care, or individual health products.

This Disclosure does not include deidentified or aggregate consumer information (such as demographic-level data or data that can no longer be tied to a single identifiable individual), or information that is publicly available (such as information from public records).

Our Assurance U.S. Consumer Privacy Notice applies to our information practices in connection with seeking, applying, or obtaining a financial product or service pursuant to Gramm-Leach-Bliley Act (GLBA). Please review the U.S. Consumer Privacy Notice.

Our Assurance Privacy Policy applies to our information practices in connection with our Services. Please review the Assurance Privacy Policy.

This Disclosure does not cover the privacy practices of third parties or service providers that we do not own or control, nor of our parent company Prudential Financial or its other subsidiaries. Certain Services of Assurance affiliates may contain different privacy statements, which supplement this Policy.

We are not responsible for the information practices of third parties, including any third party operating a website or service to which our Services link. The inclusion of a link to a third-party feature does not imply endorsement of the linked website or service by us or by our affiliates. When you leave our Services or interact with a third-party feature, you should also read the applicable party’s privacy policies and Terms of Service to make sure you understand their information practices.

In addition, we are not responsible for the information practices of other organizations, such as Facebook, Apple, Google, Microsoft, Bing, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose directly to other organizations or which you enable to be disclosed to other organizations as a result of your device or browser preferences through or in connection with your use of the Apps or social media pages.

It applies solely to California residents and supplements other privacy policies and notices applicable to Assurance Websites and Services that you visit or use.

Our Services are directed towards individuals able to shop, apply, or enroll in financial service products we offer. Our Services are not directed at children under the age of 16. We also do not knowingly collect, sell, or share personal information of children under the age of 16.

When you visit our Careers Website we collect information you provide to us such as business and personal contact information, professional credentials and skills, educational and work history, and other information contained in a resume or application. We also may collect information from third parties such as educational institutions, former employers, and background check agencies. We use this information to communicate with you, facilitate our recruitment activities and process employment applications; examples include, evaluating a job candidate, interviewing a job candidate, and monitoring recruitment activities. We may also use this information to operate and improve the Services, and as otherwise necessary for compliance, fraud or malicious activity prevention, and safety purposes

We may disclose information we collect about you with service providers and contractors to perform services on our behalf. Assurance does not knowingly sell or share your personal information with third-parties, nor do we use sensitive personal information for purposes other than those permissible under CPRA.

You may submit a request for the consumer rights described in Your Consumer Rights section by contacting us at askhr@assurance.com.

When you operate for or on behalf of Assurance in a contracted business relationship capacity, we collect information you provide us such as business and personal contact information to facilitate access to systems and platforms relevant to the nature and scope of the contracted work. We use this information in the context of employment. We also collect and store information about your activity on our systems and platforms to ensure compliance with our code of conduct and security standards.

We may disclose information we collect about you with other service providers and contractors to perform services on our behalf Assurance does not knowingly sell or share your personal information with third-parties, nor do we use sensitive personal information for purposes other than those permissible under CPRA.

You may submit a request for the consumer rights described in Your Consumer Rights section by contacting us at askhr@assurance.com.

Our Information Practices Regarding Personal Information

The specific Personal Information that we collect, use, disclose, sell, share, or retain about you will depend on your relationship and interactions with us.

Depending on your relationship with us, there are three primary ways we may collect information about you:

1. When you provide it to us. You may provide us information in various ways such as through online forms, over the phone, or other means offered through our Service like applications and interactions with our Website.

2. Through automated technologies. This includes information from your device or computer regarding how you access and interact with our Services. This is a critical part of how we improve your experience on our Websites and, more importantly, provide you with more personalized insights and recommendations, which is the core of what we aim to do at Assurance.

3. Through external parties. We may collect information about you from third-parties and other sources such as contracted parties, government data sources, and public data sources. This includes insurance companies, data brokers, companies that provide or sell lists of potential purchasers, other contracted service providers, government data sources, and public data sources, or an authorized proxy. This also includes when you provide a third-party information and consent to share that information with us to help generate a personalized quote for you.

The list below outlines the information we may have collected in the past 12 months. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals.

The categories of Personal Information collected include:

1. Personal Identifiers such as name, address, email address, online identifiers, IP address, and Social Security number;

2. Personal Data , such as contact information, health and financial information;

3. Protected Class Information under California or federal law, such as age, sex, marital status, veteran or military status;

4. Commercial/Transaction information such as transaction and account information;

5. Internet or other Electronic Network Activity information such as browsing history, interactions with our Websites, and click and mouse movements;

6. Geolocation Information such as device location;

7. Audio, Video, Electronic or Similar Information such as audio and electronic recording;

8. Professional/Employment Information such as title, work history, prior employer, and other information necessary for verifying employment eligibility;

9. Education Information such as school, degrees earned, and graduation data;

10. Inferences drawn from other Personal Information to create a profile/summary about, an individual’s preferences and characteristics; and

11. Sensitive Personal information, which is personal information that reveals certain personal identifiers such as:

1. social security, driver's license;

2. account log-in or financial information in combination with password, security code, or similar credentials;

3. race, ethnic origin; and

4. information collected and analyzed concerning one’s health.

Most of our information practices are in the context of providing financial products and services that are not subject to the CPRA. Some of our information practices are subject to CPRA such as marketing, advertising, and certain improvements to your experience and our Services.

We may use Personal Information relating to California Residents for one or more of the following business and commercial purposes:

• To provide personalized Services to you. We use the information we collect to provide Services to you in a personalized way including offering a quote, processing transactions, maintaining and servicing your account or policy, and providing customer service. We also may collect information in our capacity as a service provider on behalf of financial service providers (e.g., insurance carriers, financial institutions). Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. The information we collect gives us a more detailed picture of who you are so we can help you find the right product.
• To improve and debug our Services. We are constantly trying to improve our Services. The information we collect may be used to conduct internal research and analysis including data analytics, modeling, and recommendation Services. The information we collect also helps us improve the experience we provide to consumers, the intended functionality of our Services, and the way we match consumers to product recommendations in real time. For example, in some instances, we may use information you have provided, even if you have not completed the web flow, so that if you return to the Website this information will be pre-loaded for your convenience.
• To detect, investigate, and prevent fraud, misuse, or malicious activities. We respect your privacy and safety and therefore may use the information we collect to detect, investigate, prevent, or take action regarding incidents, threats, and misuse of your natural persons, your information, or our systems. This includes suspected theft, fraud, malicious, deceptive or illegal activities, or violations of our policies. As a result, we may also use the information we collect to verify your identity.
• To communicate with you and advertise to you. Part of providing personalized service is quickly connecting you with real people who can help walk you through your Service options, communicating to you about potential topics of interest, marketing and advertising to you, and responding to your requests and inquiries. For example, if you provide your phone number and email and then consent to being contacted by us, we may call you to connect you with one of our licensed insurance agents. We may also text and email you information about how to contact us, personalized marketing messages, information about your shopping journey, offers, and other information pertinent to your financial services inquiry.
• As required by governing law and for legal reasons. We operate in a regulated industry and therefore reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, information related to your use of our Services as reasonably necessary to do any of the following: comply with applicable law; respond to complaints, legal actions or governmental requests; enforce our Terms of Service; protect our rights, privacy, safety, or property; or respond to other similar matters. We may also use third-party services to record your actions on our Websites to help meet our compliance and legal obligations.
• As part of a corporate change. We may use, disclose, and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.

Assurance does not knowingly use, share, or disclose Sensitive Personal Information as defined in CPRA for purposes other than those permitted under CPRA.

We work with a number of partners to deliver financial products and services and therefore share information with those partners.

The following list represents: (i) who we may sell, share for cross-context behavioral advertising, or disclose with; and (ii) the purposes in connection with your use of our Services:

• Disclose information with our business and financial service partners to provide and improve our personalized Services. This includes business partners such as software and internet service providers, communication services, data brokers, data analytic providers, marketing companies, fraud prevention services; and financial service partners such as insurance carriers and agencies, financial service providers, and payment processors.
• Disclose information with third-party service providers acting on our behalf. This includes, insurance agencies, Agents and financial professionals, legal and compliance service providers, and process outsourcing companies.
• Sell or Share information with advertising networks, social media networks, and marketing affiliates. We sell and share your information with these parties to communicate to you about our Services, including joint marketing, behavioral advertising, and search engine optimization. In most cases this information is de-identified or aggregated to protect the personal information of our consumers. We also share information with these parties to communicate your consents and preferences.
• Sell information to third-party partners, with your permission, to provide you or communicate to you about their products and services. Although we aim to directly meet all our consumers’ needs, we also—with your permission—may sell and share, information you provide us, to select third parties, to market their financial products and services, and to select insurers, financial institutions, and their Agents who may make insurance, credit, and other offers. These third parties, or the entities they work with, may contact you based on the consent you have provided. We also share information with these parties to communicate your consents and preferences.
• Disclose information to a third party as part of a Corporate Change. We may disclose and transfer information about you to a third party such as our parent company, Prudential Financial, or its partners as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.
• Disclose information to a third-party for legal reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes as described above.

The table below outlines the categories of Personal Information related to Assurance’s sale, share, and disclosure practices in the past 12 months that may be subject to CPRA.

Assurance retains personal information in compliance with our records retention policies and for as long as needed based on the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• Length of time we have an ongoing relationship with you and provide you with the products and services requests;
• Whether there is a legal obligation we are subject to
• If there is a contractual obligation we are subject to; and
• Whether retention is advisable in light of our legal position.

Your Consumer Rights

California residents interacting with Assurance have certain consumer rights. These rights are limited to the personal information subject to CPRA and do not apply with respect to information that we collect about you in connection with providing financial products or services for personal, family, or household purposes or for long-term care or individual health products. That information is governed under certain state and federal laws defined in the Scope section of this Disclosure.

Nonetheless, you have the right to be free from unlawful discrimination or retaliation for exercising your rights under CPRA.

Generally, you can submit a request by contacting us at 1-(844)-311-6099 Monday through Friday between 9:00am EST – 8:00pm EST.

Request to Know: You may request to know what personal information we have collected since January 1, 2022, that is subject to CPRA. This includes the:

• categories of personal information;
• the categories of sources from which the personal information was collected;
• the business or commercial purpose for collecting, selling, or sharing personal information;
• the categories of third parties to whom Assurance disclosed personal information; and
• the specific pieces of certain personal information Assurance has collected.

Please note that to protect the privacy of our consumers, we will never disclose specific pieces of Sensitive Personal Information (as defined above in the Categories of Personal Information collected).

Request to Delete: You may request that we delete personal information we have collected that is subject to CPRA.

You can submit either of these requests through the following:

• Contact us at: 1-(844)-311-6099
• Visit us online at: assurance.com/california-data-request

Once you submit your request, we will review the information you submitted in the Form in comparison to the information we have in our systems to verify your identity and relationship with us.

In some cases, we may contact you to request additional information to verify the request, or to notify you that it will take more than 45 days to respond. In that case, we will respond within 90 days of receiving your request.

You can expect a response from data-request@assurance.com.

You may request that we correct inaccurate information maintained about you. Assurance supports this for all consumers, not just California residents.

You can submit this request through the following:

• California residents may contact us at: 1-(844)-311-6099
• All other consumers may contact us at: 1-(844)-563-0386 TTY 711
• Message us at: contactus@assurance.com

Once you submit your request, we will review and verify your identity, relationship with us, and the accuracy of the information submitted for the change. We may deny a request to correct if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances

You may request that we no longer sell or share for cross-contextual behavioral advertising (data sharing that exists to provide more targeted advertising across websites and over time).

You can submit this request through the following:

• Visit us online at: assurance.com/california-opt-out
• Set your browser or device settings to send an opt-out preference signal known as the Global Privacy Control (“Global Privacy Signal”). To learn more about the GPC and download browsers and extensions that will notify us of your privacy preferences, visit: https://globalprivacycontrol.org/

When processing a Global Privacy Signal, we honor the request with respect to the information collected on that device during your session. As a result, we may not be able to tie a browser or device-based preference signal request to all Personal Information we have about you.

Assurance will not call or email you for authentication or verification related to this request.

A California resident may authorize an agent to make a CPRA rights request on behalf of the California resident. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us at 1-(844)-311-6099 or submitting the applicable request Form provided above.

In general, if an authorized agent makes a request on behalf of a California resident, we may:

1. verify that the authorized agent is registered with the California Secretary of State to conduct business in California;

2. require that the California resident provide the authorized agent with written permission signed by the California resident authorizing the agent to make the request on the individual’s behalf (“Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.);

3. verify the identity of the California resident as we would if the California resident were making the request directly; or

4. obtain verification from the California resident that the individual gave the authorized agent permission to make the request.

We may decline to honor your request, in full or part, for certain reasons such as:

• the information is subject to certain state and federal laws outside the scope of the CPRA rights requests such as GLBA or HIPAA;
• we cannot identify you within our systems;
• we cannot confirm that the Personal Information that we maintain relates to you;
• we cannot verify your identity or verify that you have the authority to make a request on behalf of another individual (this is specific to access, deletion, and correction requests);
• we are required to retain the information under record retention requirements or compliance with other legal obligations; and
• disclosure of personal information would adversely affect the rights and freedoms of another consumer.

Changes to this Disclosure

This Disclosure is effective as of January 2023. We reserve the right to change this Disclosure at any time. We will note when it was last updated. Any changes will be effective as of the day they are posted. Use of our Services following these changes signifies acceptance.

Contact Us

We appreciate you taking the time to read this. If you have questions regarding this disclosure or information practices at Assurance, you can email us at privacy@assurance.com.

Consumer Rights Annual Transparency Report

Our annual transparency report shows the number of data requests we receive and how long it takes us to fulfill those requests. This report does not contain personal information, and providing it is a requirement under the CPRA. Assurance will publish this report by July 1st of each calendar year.