Effective Date: April 2023

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 online through 1) our website www.tolic.com, 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 Trans-Oceanic Life Insurance Company (TOLIC) and Trans-Oceanic Life Insurance Company of America (TOLICA).

Scope and Consent

When you use our Services, you are contracting with Trans-Oceanic Life Insurance Company (TOLIC), or with Trans-Oceanic Life Insurance Company of America (TOLICA). By using our Services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

Information We Collect

Registration, Enrollment, and Account Information:

You can browse the Site without telling us who you are or revealing any personal information about yourself (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). 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.

Career Information:

Our Careers section of the Site gives you the opportunity to create an “Application Account” to search and apply for jobs. TOLIC and TOLICA is an equal opportunity employer. In addition, when you apply for a job or authorize us to obtain reports about you (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).

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.

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 Notices of Information We Share Pursuant to State and Federal Laws.

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, friends list, people you follow or who follow you, your email address, birthday, work history, educational history, interests, current city, religious and political views, website, personal description, likes, your friends’ birthdays, educational 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 from your interaction with our Site (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.). 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 TOLIC/TOLICA 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.

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.

Survey Information:

You agree that we may collect and share your demographic information (including city, state, and date of birth), claim number, policyholder information, contact information, and other information you may provide to conduct policyholder surveys.

Information About Others:

Employers, benefit brokers and authorized representatives, 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 our 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.

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 that we have acquired in accordance with the law (e.g., demographic information, navigation information, and/or additional contact information). If you are a policyholder, 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 Us (please see Notices of Information We Share Pursuant to State and Federal Laws).

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).

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. We use tracking technologies including cookies, 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 to our Services, 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 the 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 our Privacy Policy and/or our Cookies and Tracking Technologies Policy.

Geo-location 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 geo-location data in the manner set forth in the Privacy Policy.

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.

Uses and Retention of Information

Provide Our Services:

We use the information collected to 1) respond to your requests; 2) allow you to manage your policies and claims; 3) allow us to service your policies and manage your claims; 4) give you information about your account; (5) provide customer service (e.g., to resolve disputes, problems with your account/profile or the Services); 6) personalize your experience by providing information and content about our products and services to you that we believe may be of interest to you; 7) operate our promotions; 8) manage, administer and improve our operations and Services, including Services via employers, brokers, agents, and enrollment systems; 9) conduct surveys; 10) allow you to use our online technologies; and 11), provide you with a safe, efficient, and customized experience.

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.

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.

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 and 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.

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 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:

Our Corporate Family:

We may share the information we collect about you with TOLIC/TOLICA’s corporate family, including our affiliates and third-party suppliers. The information may be disclosed to: 1) provide joint content and our services (e.g., registration, transactions, underwriting, setting rates, analytics and customer support); 2) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and 3) 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 Privacy Policy.

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 claims, processors and adjustors, survey providers, fraud investigations, advertising, 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.

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.

Legal, Regulatory and Law Enforcement:

Law enforcement, governmental agencies, or authorized third parties include but not limited to inspections, reviews, and those 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 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.

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.

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.

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.

Notices of Information We Share Pursuant to State and Federal Laws:

Under various state laws and the Gramm-Leach-Bliley Act, insurers and authorized representatives must describe their information practices in addition to providing a HIPAA Notice of Privacy Practices.

Select your appropriate notice or form below:

Florida and Puerto Rico – English | Español

Affiliate Marketing Opt-Out Form – 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) our obligations with respect to that information. TOLIC/TOLICA is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule, in safeguarding PHI.

For our HIPAA-covered insurance policies, TOLIC/TOLICA 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 customerservice@tolic.com

Your Choices

If you are a customer, you can opt-out of notifications from us by following instructions within the notices or emailing your opt-out request to customerservice@tolic.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 1.800.981.8662 or downloading and completing the Affiliate Marketing Opt-Out 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 we set, so that only we can interpret the information stored in them.

You may encounter tracking technologies and/or 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 can review and change personal information at any time by accessing their accounts on the Site. You can also call 1.800.981.8662 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.

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 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, you should log into your TOLIC/TOLICA 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 on our website, you may contact us online, or contact us as follows:

Physical Address TOLIC
121 O’Neill St.
San Juan, Puerto Rico 00918
1.787.620.2700

Mailing Address and Email Address TOLIC

P.O. Box 363467

San Juan, PR 00936-3467

customerservice@tolic.com

1.800.981.8662

Physical Address TOLIC OF AMERICA
8240 Exchange Drive

Suites Cloud 1

Orlando, FL 32809

1.407.664.1703

Mailing Address and Email Address TOLIC OF AMERICA

P.O. Box 691628

Orlando, FL 32809

customerservice@tolic.com

1.800.981.8662