Supplemental Privacy Disclosure for Residents of Certain U.S. States

Supplemental Privacy Disclosure for Residents of Certain U.S. States

This Supplemental Disclosure describes the practices of the Prosperity Life Group companies, including S. USA Life Insurance Company, Inc., Shenandoah Life Insurance Company, and Prosperity Service Group, LLC (“we,” “us,” “our”) regarding the collection, use, and disclosure of Personal Information about residents of California, Colorado, and Oregon through both online and offline interactions with you and how you can exercise your privacy rights under each state’s comprehensive privacy legislation (collectively, “U.S. Privacy Laws”). For residents of California, Colorado, and Oregon, this Supplemental Disclosure provides additional details about our privacy practices related to your Personal Information, as required by the applicable U.S. State Privacy Laws in your state of residence. Some portions of this Supplemental Disclosure apply only to residents of particular states. In those instances, we have indicated the portion applies only to certain state residents.

Please note that this Supplemental Disclosure does not apply to individuals with whom we interact in an employment-related context or a business context in Colorado or Oregon. For our disclosures applicable to employees or job applicants in California, please see our Employee/Applicant Privacy Notice.

Definitions

  • “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  • “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
  • “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration.
  • “Third Party” means any non-affiliated person that is not a Vendor.
  • “Vendor” means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your Personal Information only as directed by us.

You may be familiar with different terms that are used to describe materially similar concepts in this section by the U.S. Privacy Laws in your state of residence. You can treat them as the same for the purpose of our Supplemental Disclosure. For example, we intend the term “Personal Information” here to have the same definition as “Personal Data” used in specific U.S. Privacy Laws.

Collection and Processing of Personal Information

In addition to the categories of Personal Information we described in the “Information Collection” section of our Online Privacy Policy, we also collect the following categories of Personal Information about you during the past 12 months:

  1. Audio, Electronic, Visual and Similar Information, such as call and video recordings.
  2. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. This category includes Sensitive Data Inferences, which are inferences made by us based on Personal Information, alone or in combination with other data, to indicate your Sensitive Personal Information.

We do not knowingly collect or process Personal Information of children under 13 years of age. If and when we do so, we comply with the Children’s Online Privacy Protection Act (“COPPA”). For more information, please see our Online Privacy Notice.

We have described the sources of collection as well as the purposes for processing (including collection and disclosing) Personal Information in our Online Privacy Notice. We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes.

Disclosure of Personal Information

We have described how we disclose all categories of Personal Information we collect in the “Disclosure of Personal Information” section of our Online Privacy Notice. We do not Sell or Share Personal Information to Third Parties.

Additionally, we do not have actual knowledge that we Sell or Share Personal Information of individuals who are under 16 years of age. We also do not process Personal Information for purposes of Profiling in furtherance of decisions that produce legal or similarly significant effects (which means a decision that results in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services).

Data Subject Rights

Residents who reside in states with U.S. Privacy Laws have the following rights regarding our collection and use of the Personal Information, subject to certain exceptions. Some data subject rights (i.e., rights to opt out of certain processing) are not applicable and are omitted because we do not Sell or Share, have not Sold or Shared your Personal Information, and do not collect or use your sensitive personal information in the past twelve months. Please read this section carefully as some rights vary by state.

You may contact us to exercise the data subject rights below by calling 1-866-787-2123 or by using the Contact Us form and submitting details regarding your request. You may also authorize an agent to make data subject requests on their behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. We will request certain personal information from you or the requestor in order to verify your identity, such as asking your agent to provide proof of signed permission from you, or ask you to confirm with us directly that you provided the agent with permission to submit the request. Such information will be used solely for that purpose. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

  • Right to Know: You have the right to know the following details about our privacy practice at or before the point of collection. We have provided such information in this Supplemental Disclosure. You may also have the right to obtain information about the following aspects of how we have handled particular personal information about you during the past twelve months:
  • The categories of Personal Information we have collected about you;
  • The sources of such information,
  • Our purposes in collecting, Selling, or Sharing such information, The business or commercial purpose for collecting, Selling, or Sharing Personal Information about you;
  • The categories of Personal Information about you that we disclosed and the categories of Third Parties to whom we disclosed such Personal Information;
  • The categories of Personal Information about you that we sold, shared, or used for targeted advertising purposes, and the Third Parties, if any, with which we Sold or Shared Personal Information;
  • If we collect Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and
  • The length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
    • Right to Deletion: You may have the right to request that we delete personal information that we collect from you and to instruct our service providers to do the same, except as required by law or regulation. 
    • Right to Correction: You may have the right to request correction of inaccurate personal information. 
    • Right to Access Specific Pieces of Personal Information and Data Portability: You may ask to obtain the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.

Non-Discrimination

We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

Appeals

For residents of Colorado and Oregon: To appeal our decision on your data subject requests, you may contact our Compliance Department through the contact methods described above. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

Changes to this Statement

This online privacy statement is effective as of March 11, 2024.  It may be changed from time to time. You may wish to visit this page periodically to review the most recent Online Privacy Statement.

Questions

If you have any questions about this Online Privacy Policy statement, please Contact Us or write to us at:

Compliance Department

Prosperity Life Group

P.O. Box 12847

Roanoke, VA 24029-2847