WEBSITE PRIVACY STATEMENT

This Privacy Policy (this “Policy”) describes how 91制片厂 Company and its wholly owned subsidiaries, and Entrada Life Insurance Company with whom you are doing business (collectively, “91制片厂,” “we,” “us” or “our”), collect, use, share, and safeguard your personal information.

This Policy applies when you interact with us by visiting the 91制片厂 website (“www. american-equity.com”) and Eagle Life website (“www.eagle-lifeco.com”) or any client or agent portals on these websites; participate in our events, promotions, offerings or partner activities; or interact or communicate with us as part of our marketing practices or outreach. We offer a variety of products and services (collectively, the “Services”). As part of providing the Services, we collect and receive information in a variety of ways, including information on our websites, from our organizational customers and/or prospective customers, and from individuals that use the Services. 

For the purposes of this Policy, 91制片厂 is a controller (i.e., responsible party) of your personal information when we administer the Services directly on our own behalf. This Policy does not apply to certain information that is subject to insurance regulations, such as the Gramm Leach Bliley Act (“GLBA”). Please reference our Privacy Practices Notice here. to understand your rights governed under certain insurance regulations.

California Consumer Notice of Collection
This Notice of Collection is provided to all California consumers subject to this Privacy Policy. 

CATEGORIES OF INFORMATION WE MAY COLLECT

The types of personal information we collect about you depends on how you interact with us. “Personal information” refers to information that identifies, relates to, describes, or can be associated with you. Depending on the Services you use, the following are the categories and specific types of personal information that we may collect:

Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information, or other similar identifiers.

Government Identifiers, including driver’s license number and social security number (in certain instances may be considered sensitive personal information).

Demographic Information, including age, gender, race, ethnicity, certain limited health information, and household information, some of which may include characteristics of protected classifications under state or federal law.

Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.

Internet or Other Network Activity, including browsing or 91制片厂 history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.

Payment Information, including bank details and other financial information.

Sensitive Personal Information (where permitted and in accordance with applicable law), of the information listed above, social security number, racial or ethnic origin, and/or health information are also sensitive personal information.

The provision of the sensitive personal information listed above is voluntary.  In certain instances, we will not be able to process your request for our Services without the requested personal information. 

SOURCES OF PERSONAL INFORMATION 

We collect your personal information in the following ways, pursuant to applicable law:

Directly From You, when you use our Services, apply to be an agent, apply for an insurance product, register for online access, contact us, respond to a survey, sign up to receive emails and/or postal mailings.

Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our websites, use our mobile applications, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the “Cookies and Similar Tracking Technologies” section below.

From Third鈥慞arties, that we have partnered with, including third party providers, to provide you the Services that you have requested from us. 

Other Sources, including data analytics providers or publicly available sources.  

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information and sensitive Personal Information for the following business purposes (“Processing Purposes”) associated with our general business operations. We may collect your personal information:

Providing our Services

  • To provide you the Services, including insurance products.
  • To process your premium payments and send notifications to you related to your account.
  • To enable you to access and use our websites.

Communicating With You

  • To communicate with you and to respond to your requests, questions, comments, and other inquiries.
  • To understand what partner resources you use, if any, and to connect you to additional resources at your request.
  • To send marketing and promotional materials, including information relating to our products, Services, sales, or promotions or those of a third party.

Analytics and Administration of Website

  • To administer, maintain, evaluate, and improve our websites and Services, and to develop new products and services.
  • To conduct re91制片厂 and analytics related to our websites and Services, including combining any or all of the information that we collect or obtain.

Marketing and Promotional Purposes

  • We may use Personal Information for marketing and promotional purposes to show you advertisements.

Core Business Functions

  • To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
  • For other purposes with your consent, or as otherwise permitted or required by applicable law.

Legal Obligations

  • We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.

Security and Fraud Prevention

  • We use personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of 91制片厂 and our users, customers, employees, or others.

Use of Your Sensitive Personal Information

With regard to sensitive personal information, we only use your sensitive personal information to provide you with the requested products or services.

TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Policy, we may disclose information in the following situations, as permitted by applicable law:

  • Within 91制片厂. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies or subsidiaries, and other companies under common control) or joint ventures to which we are a party. 
  • Third Parties. With your consent, if required, we may disclose your information to independent insurance producers, marketing organizations, brokers/dealers, banks, reinsurers, third party administrators, or other insurance companies, in order to effect, administer or enforce transactions with us, or in connection with servicing your annuity contract.
  • Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.
  • Service Providers. We disclose information to service providers as necessary for them to assist us with our business operations and provide services to us, subject to appropriate confidentiality and data protection agreements. Among other things, service providers assist us with website hosting, data storage, data analytics, helping with addressing security, fixing errors, processing payments, providing identity verification services, providing technical support, sending communications, providing assessments, fulfilling user requests, and other activities related to the management of our business and services.
  • Government Entities or Regulators. We may disclose information for legal reasons as we believe to be necessary or appropriate to: (a) satisfy any applicable law, legal process, or proper governmental request; (b) enforce any agreement we may have entered into with you or your organization, including investigating any violations or asserting remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm (whether tangible or intangible) to the rights, property, or safety of 91制片厂, our users, or the public as required or permitted by law; and (e) establish or exercise our rights, defend against a legal claim, and investigate, prevent, or take action regarding possible illegal activities or a violation of our policies.
  • Business Transaction. We may disclose personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.
  • Sharing with Affiliates and Non-Affiliates for Marketing and Other Purposes.  We may share your information with affiliates and non-affiliates for marketing and other purposes.  Under certain circumstances, you may opt-out of such sharing with respect to certain data you have provided to us. Please refer to our Consumer Privacy Notice for information relating to the sharing of your personal information.
  • Social Media Platforms and Networks: Some of our websites have features such as, plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third party. The third party’s use of your information is not governed by this privacy policy. You may have the right to opt out of our use of these technologies, as further described in this Policy.
  • De-identified or Aggregate Information. We may aggregate and anonymize information you provide to us in such a way as to ensure it will no longer be identifiable to you. This data may be used for statistical, analytic, and administrative purposes, including analyzing our website traffic and trends, tailoring our Services, or conducting product analysis.  We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

COOKIES AND SIMILAR TRACKING TECHNOLOGIES 

We use cookies and similar tracking technologies, including pixel tags or web beacons (collectively “cookies”), to collect certain information on our websites, through our Services. We also permit certain third parties to use cookies and similar tracking technologies to collect information about your use of our websites or Services. The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information (“Technical Data”); (b) information about when and how you access and use our websites or Services, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage (“Usage Data”); (c) information about the device you use to access the websites or Services, such as device type, device ID, and device/browser settings (“Device Information”); and (d) location of the device used to access the websites or Services derived from GPS or WiFi use (“Location Information”).

We differentiate between cookies that are essential for the technical features of the Services and optional analytics and advertising cookies.

Cookie Type

Description

Essential Cookies

These are cookies that the Services need in order to function, and that enable you to move around and use the Services and features. Without these essential cookies, the Services will not perform as smoothly for you as we would like them to and we may not be able to provide the Services or certain services or features you request. Examples of where these cookies are used include to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.

Analytics Cookies

Analytics cookies allow us to understand more about how many visitors we have to our Services, how many times they visit us, and how many times a user viewed specific pages within our Services. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Services multiple times, we cannot use them to find out details such as your name or address. We use Google Analytics. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at , or any other URL Google may provide from time to time.

 

YOUR CHOICES

You may be able to make the following choices regarding your personal information:
  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties.  You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive.  If you decide not to receive promotional emails, we may still send you service-related communications. 

Data Subject Rights

You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements under applicable law (i.e., your rights will vary depending on whether you are located in, for example, California). Specifically, you may have the following rights:

  • Access: You have the right to request access to the personal information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the personal information has been or will be disclosed, the sources of the personal information, retention, and transfers of personal information.
  • Correction: You have the right to request correction of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement. As noted above, you may also be able to correct your information in your account or profile.
  • Deletion: You have the right to request that we delete your personal information.
  • Data Portability: Under certain circumstances, you have the right to receive the personal information about you that you have provided to us, in a structured, commonly used, and machine-readable format.
  • Opt Out of the “Sale” or “Sharing” of Personal Information: We do not currently, nor have we in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising) your Personal Information. We do not knowingly sell or share the Personal Information of individuals under the age of 16.
  • Automated Processing: Under certain circumstances, you have the right to object to a significant decision based solely on automated processing (i.e., without human intervention) unless that decision is required or authorized by law. However, at this time, we do not use automated processing.
  • Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Policy, nor do we retaliate against individuals who exercise these rights.  
  • Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). We do not disclose Sensitive Personal Information for purposes other than those which cannot be limited under applicable law.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. In some cases, we may limit or deny your requests to access or delete your information. This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity.

Please note that we must be able to verify your identity to make sure you are the person about whom we have collected personal information or an authorized representative. Depending on the type of request, we may conduct the verification process by email or phone using information that matches our records. The information you must provide as part of the verification process may include: name, contact information (such as email address or phone number), relationship with us, and residency. We may also ask for additional information as needed based on your relationship with us. 

You may also designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must (1) provide that authorized agent written and signed permission to submit such request, and (2) verify your own identity directly with us.

To submit a request to exercise any such rights (if they apply to you), please contact us at 1-888-221-1234 or send an email to compliance@american-equity.com.

HOW WE PROTECT YOUR PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

HOW LONG WE RETAIN YOUR INFORMATION

We retain information about you and your use of our Services for as long as is needed to fulfill our legitimate business purposes outlined in this Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations.

CHILDREN’S PRIVACY 

Our Services are not intended for persons under 13 years of age. We do not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that we have collected personal information from persons under 13 through our Services, we will take appropriate steps to delete this information. 

THIRD PARTIES AND LINKS TO OTHER WEBSITES AND SERVICES

Our websites and Services may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed. 

COMMERCIALLY RECOGNIZED OPT OUT SIGNAL

91制片厂 will endeavor to recognize commercially recognized opt out signals (e.g., Global Privacy Control). Recognition of this signal will only take place with respect to the device and/or browser that communicates the signal.

CHANGES TO THIS PRIVACY POLICY 

We may update this Policy from time to time to reflect changes to our practices, technology, legal requirements, and other factors. When changes are made to this Policy, they will become effective immediately upon posting. You can check the date at the top of this page to see when this Policy was last revised. We encourage you to review this Policy periodically for the latest information on our information processing practices.

To the extent that our Policy changes in a material way, the Privacy Policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent (express or implied) to the new Privacy Policy where and as required by applicable law.

CONTACT INFORMATION

If you have any questions, comments, or complaints concerning our privacy practices, or, where required by law, if you would like to submit a request based on a right listed in this Policy, please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

91制片厂 Company
Attn: Compliance Department
P.O. Box 71216
Des Moines, IA 50325

EFFECTIVE DATE: January 17, 2025
LAST UPDATED: January 17, 2025