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Nassau Re Website Privacy Statement — Highlights

This Privacy Statement is provided on behalf of Nassau Life Insurance Company, PHL Variable Insurance Company, and Nassau Life and Annuity Company (“The Company,” “we,” “our,” “us”).

We know how much you value privacy, and we realize that you care about what happens to the information you provide to us through our website, mobile application, email, phone, text messaging, live events, and other sources (our “Website”).  This statement does not apply to third party sites.  We have provided highlights below regarding how we collect, use, and share your information.  Click here to see our full Privacy Statement. 

What Information Does The Company Collect?

We collect the following types of information:

  • Information we receive from you on applications or other forms or in order to provide you with a quote (such as name, address, city, state, ZIP code, email address, telephone number, birth date, household information, marital status, information about beneficiaries, and education) 
  • Information about your transactions and relationships with us, our affiliated companies, and others (such as products or services purchased, account balances, your policy coverage, premiums, and payment history)
  • Financial and payment information (such as social security number, net worth, assets, income, payment card number, expiration date, account number, and billing address)
  • Medical information (such as information about your health status or condition, payment for health care, etc.)
  • Product preferences, advertisement preferences, and other information about how you use our Website
  • Content you submit or post (such as photographs, videos, reviews, articles, comments, or any other information you provide to us or post)
  • Employment information
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Geolocation Information: We may also collect your precise location using GPS, cell tower, Bluetooth, or WiFi signals if you access our Website from a mobile device.  You may turn this feature off at any time in your device settings.

This information is collected from a variety of sources including information that you give us directly (for example during product purchases and when you post information on the Website), information that we receive from affiliates and other third party sources, and information automatically collected when you visit our Website (such as via cookies or web beacons).

Read more about the information we collect

How Does The Company Use My Information?

We use your information for the following purposes:

  • offering you products and services, deciding if you qualify for our products and services, and servicing your account
  • establishing and verifying the identity and eligibility of users;
  • opening, maintaining, administering, managing, and servicing users profiles, accounts or memberships;
  • processing, servicing or enforcing transactions (including credit or debit card transactions);
  • providing products, content, content suggestions, services, and support;
  • conducting special events, sweepstakes, surveys, programs, contests, and other offers (and communicating with you about such events); 
  • analyzing and improving our products, services, or Website (including developing new products and services; improving safety; managing our communications; analyzing our products; performing market research; performing data analytics; and performing accounting, auditing and other internal functions);
  • providing users with product, service, or company updates;
  • marketing and advertising our products or services as well as products and services of third parties (such as affiliates, subsidiaries, and business partners);
  • responding to your inquiries or comments, or contacting you as necessary;
  • operating and communicating with you about or through external social networking platforms
  • maintaining the security and integrity of our systems, including maintaining internal records;
  • conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
  • as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of The Company’s assets

All information we collect may be aggregated and merged or enhanced with data from other sources, such as third parties or our mobile application.

Read more about how we use your information.

How Does The Company Share My Information?

We share your information as follows:

  • With third party service providers or business partners who help us with our business functions and who help us service or process transactions
  • With affiliated companies and non-affiliated business partners for our or the third party’s marketing purposes
  • If necessary to protect the safety, property, or other rights of us, our users, or employees, or when required by law 
  • If the ownership or control of the Websites or its assets changes, we may transfer your information to the new owner

Read more about how we share your information.

Nassau Re Website Privacy Statement — Full Statement

This Privacy Statement is provided on behalf of Nassau Life Insurance Company, PHL Variable Insurance Company, and Nassau Life and Annuity Company (“The Company,” “we,” “our,” “us”).

We respect your concerns about privacy and values the relationship we have with you. This Privacy Statement describes the types of information we collect about you, how we use the information, with whom we share it, the choices available to you regarding our use of the information, and how you can contact us about our privacy practices.

1.  What Information Does This Privacy Statement Apply to?

This Privacy Statement applies to the collection, use, and disclosure of information from and about you by The Company on our website (www.nsre.com), through our mobile application, and through telephone communications, email communications, and other sources (collectively, our “Website”).  The Company’s mobile application will collect the same information identified in this Privacy Statement and that information will be used and shared as stated in this Privacy Statement.

This Privacy Statement does not apply to third party websites that may be accessible through hyperlinks on the Website, which have their own privacy statement that we encourage you to review.  Linking to a third party site does not mean that we endorse the site, any products or services described on the site, or any other material contained in a third party site.  To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.  Please review the privacy statement on those other websites to see how they handle your information.

If you choose to use our Website in any way, such as browsing or interacting, you agree with the terms of our current Privacy Statement as posted here. If you do not agree with this Privacy Statement, you should not use our Website.  We may update or modify this Privacy Statement from time to time at our sole discretion, and will note the date of last update on the top of this page.  We encourage you to visit this area frequently to stay informed, as your continued use of our Website following the posting of changes to these terms means that you consent to such changes.

2. What Information Does The Company Collect?

We may obtain information about you when you choose to provide it to us and when we collect it from third parties.  We may also collect certain information about your device or usage by automated means, including through technologies such as cookies, web server logs, and web beacons.

Information that You or Others Provide

You may choose to provide information to us in a number of ways, such as when you request a quote, apply for a policy, sign up for promotions or newsletters, purchase our products, register on the Website, post or provide content, or otherwise interact on the Website.  The types of information you may provide to us include:

  • Information we receive from you on applications or other forms or in order to provide you with a quote (such as name, address, city, state, ZIP code, email address, telephone number, birth date, household information, marital status, information about beneficiaries, and education) 
  • Information about your transactions and relationships with us, our affiliated companies, and others (such as products or services purchased, account balances, your policy coverage, premiums, and payment history)
  • Financial and payment information (such as social security number, net worth,assets, income, payment card number, expiration date, account number, and billing address)
  • Medical information (such as information about your health status or condition, payment for health care, etc.)
  • Product preferences, advertisement preferences, and other information about how you use our Website
  • Content you submit or post (such as photographs, videos, reviews, articles, comments, or any other information you provide to us or post)
  • Employment information
  • Records and copies of your correspondence (including email addresses), if you contact us.

If you provide us with information regarding another individual, we will assume that you have that person’s consent to give us his or her information.
We also may collect information about you from third parties, such as:

  • Information we receive from a consumer reporting agency (such as information about your creditworthiness and credit history)
  • Information we receive from third parties in order to issue and service your policies (such as motor vehicle reports and medical information);
  • Information we receive from third party social media sites (see section 5 below)

Information Collected Automatically

When you visit this Website or our online advertisements, utilize our services, open an email that we send you, or interact with social networking applications, we (and our third party advertisers and/or service providers) may collect information about your usage or device by automated means.  Some of the technologies we use to collect information automatically include:

  • Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Some cookies may exist for only a single session and some are persistent for multiple sessions over time.  We may use cookies that are managed by Nassau Re or by third parties (such as social media website cookies) for the purposes provided in this Privacy Statement, including for session management, authentication, user preference storage, Website performance and personalization, Website analytics, advertising (including affiliate marketing), content management, eCommerce, search, security, and social media integration. 
  • Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your Website usage.
  • Web beacons, pixels, and analytics software: To control which web servers collect information described above, we may place tags on our Website or in emails called “web beacons” or “pixels.” These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behavior.  These tools may also be used to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email, and any URL accessed through our email message.  Such tools are also used in connection with online advertisements on our Website and on third party websites to collect the same types of information with respect to individuals who click on advertisements.
  • Other: we may use other technology to collect information for the purposes described in this Privacy Statement.

Such technologies may permit collection of data elements such as demographic data, browser type, MAC address and other unique device information, operating system type and settings, domain, the address of the web page that linked you to our Website, IP address, pages visited, whether you have visited us before or are new to the Website, activities conducted on the page (such as search queries), and the day and time of your visit.  If you access our Websites from a mobile device, we may collect your precise location using GPS, cell tower, Bluetooth, or WiFi signals.  You may turn this feature off in your device settings at any time.  This information may be correlated to other data that identifies you specifically.

At this time, we do not honor “do not track” signals from website browsers.  However, you may refuse or delete cookies.  If you refuse or delete cookies, some of the functionality of our Websites may be impaired.  If you turn off cookies, Web beacon and other technologies will still detect visits to our Websites, but the information they generate cannot be associated with other non-identifiable cookie information and are disregarded. Please refer to your browser Help instructions to learn more about how to manage cookies and the use of similar technologies.

3. How Does The Company Use My Information?

We use your information for the following purposes:

  • offering you products and services, deciding if you qualify for our products and services, and servicing your account
  • establishing and verifying the identity and eligibility of users;
  • opening, maintaining, administering, managing, and servicing users profiles, accounts or memberships;
  • processing, servicing or enforcing transactions (including credit or debit card transactions);
  • providing products, content, content suggestions, services, and support;
  • conducting special events, sweepstakes, surveys, programs, contests, and other offers (and communicating with you about such events); 
  • analyzing and improving our products, services, or Website (including developing new products and services; improving safety; managing our communications; analyzing our products; performing market research; performing data analytics; and performing accounting, auditing and other internal functions);
  • providing users with product, service, or company updates;
  • marketing and advertising our products or services as well as products and services of third parties (such as affiliates, subsidiaries, and business partners);
  • responding to your inquiries or comments, or contacting you as necessary;
  • operating and communicating with you about or through external social networking platforms
  • maintaining the security and integrity of our systems, including maintaining internal records;
  • conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
  • as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of Nassau Re’s assets

All information we collect may be aggregated and merged or enhanced with data from other sources, such as third parties or our mobile application.  We may also collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

4. How Does The Company Share My Information?

We may disclose all of the information we collect (including your nonpublic personal financial information), as described in Section 2 above, to both affiliated and non-affiliated third parties, such as:

  • To companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements
  • To financial services providers, such as life insurers, automobile insurers, mortgage bankers, securities broker-dealers, and insurance agents
  • To non-financial companies, such as retailers, direct marketers, airlines, and publishers
  • To third parties who help us with our business functions, such as service providers or suppliers.  Examples of these service providers include entities that process credit card and other types of payments, help us moderate content posted on the Website, provide web hosting or analytics services, or who assist with marketing functions. 
  • To third parties involved in servicing and administering products and services on your behalf such as:
  • Your agent, broker or producer
  • Banks
  • Reinsurance companies
  • Firms that assist us in the servicing of your policies
  • Firms that assist in the printing or delivering of statements and notices
  • To other third parties for their own marketing purposes
  • To third parties for specific purposes permitted by law, such as:
    • If necessary to protect the safety, property, or other rights of us, our customers, or employees. 
    • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, or as otherwise required by law;
    • To State or federal regulators;
    • To auditors.
    • With your consent in certain circumstances.

We may disclose information about our customers and our former customers to these third parties for the purposes described above.

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law).  If you wish to opt out of disclosures to nonaffiliated third parties, you may opt out by sending us an email request to opt out to corporate.compliance@nsre.com or by calling us at 1-800-813-8180.  Note that you can only opt out of sharing your nonpublic personal financial information with non-affiliated third parties for certain purposes; you cannot opt out of sharing such information with non-affiliated third parties who are service providers to us, who engage in joint marketing efforts with us, who assist us with processing and servicing transactions, or as otherwise permitted by law.

We may also contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on our Websites and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our and third party marketing efforts

We reserve the right to transfer information we have about you in the event we sell, transfer, or engage in another transaction involving all or a portion of our business or assets, or undertake another form of corporate change, including bankruptcy.  Following such a sale, transfer, or transaction, or corporate change, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.

Your information may be stored in databases maintained by The Company (including local storage) or third parties, and may be disclosed to third parties for the purposes stated in this Privacy Statement, that are located within and outside the United States, including countries where privacy rules differ and may be less stringent than those of the country in which you reside.  If you visit our Websites from a country other than the United States, you consent to such cross-border transfers of personal data to the United States and to other countries around the world.

5.  What About External Social Media Platforms?

Our Websites’ web pages may embed plugs-ins, widgets or other apps of various external social media platforms.  When you encounter those embedded objects, your internet browser may make a direct connection to the social media platform’s service and may share with the social media platforms information such as which of our Websites you have visited, information about your public profile, or content you have posted.

6. Is My Information Secure?

The Company will take reasonable precautions to protect your information from loss, misuse or alteration.  For example, we have procedures in place that limit internal access to personal information to only those employees who need to access it in order to perform business services or market products on behalf of Nassau Re and our affiliates. We educate our employees on the importance of protecting the privacy and security of your information. We also maintain physical, electronic and procedural safeguards that comply with federal and state regulations to guard your personal information.

Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception.  As a result, we ask that you not send any confidential information to The Company via e-mail. If you do want to send us a secure and confidential message, log in to your account and use the form provided.

7. Does The Company Collect Information From Children?

The Company does not intentionally collect information from children under 13 years of age, and children under age 13 should not submit any information to us.  If we become aware that a child has provided us with information without parental consent, or a parent or guardian of a child contacts us through the contact information provided below, we will use reasonable efforts to delete the child’s information from our databases.

8.  What Choices Do I Have?

We want to communicate with you about our products and services and make content available to you, but only in the ways that you agree to hear from us.  You may “opt out” of certain sharing of your nonpublic personal financial information with non-affiliated third parties by sending us an email request to opt out to corporate.compliance@nsre.com or by calling us at 1-800-813-8180. 

You may also “opt-out,” or unsubscribe, from our newsletters, special offers or discounts, or other marketing communications by following the unsubscribe instructions in any e-mail or other communication you receive from us.  After doing so, you will not receive future promotional emails unless you open a new account, enter a contest, or sign up to receive newsletters or emails.  Please note that even after unsubscribing we may still disclose information as permitted or required by law including, but not limited to, service related announcements, important information about your policy, state required notices, and other non-marketing communications about your account or purchases that you have made.  Please allow up to 2 weeks to process your request.

We store data for as long as it is necessary to provide the products and services described in this Privacy Statement and for our internal business purposes.  If you would like us to delete information, you may contact us using the information below and we will take reasonable efforts to delete your information from our records, but may need to keep a copy for administrative purposes (such as documenting that a transaction occurred).

We also participate in interest-based or behavioral advertising.  This means that you may receive advertising on our website or other websites that are tailored to how you browse.

9. How Can I Contact Nassau Re?

The Company is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy.  If you have submitted information to us and you would like to have it deleted from our databases or corrected, or if you have any other questions or comments regarding our privacy practices, please email us at corporate.compliance@nsre.com for more information.

Effective Date:  November 8, 2017