Last Updated: May 28, 2021
2. PERSONAL INFORMATION COLLECTED BY GREAT AMERICAN LIFE
Great American Life offers and administers a variety of annuity and life insurance products and services. Depending on our relationship with you – policyholder, insured, claimant, annuity owner, certificate owner, beneficiary, producer (including brokers, agents, and advisors), business partner, vendor, or other person or entity – Great American Life may collect or receive the following information that may contain personal information:
• Identity Information: First name; middle name or initial; last name; gender; genetic characteristics; date of birth; marital status; age; mother’s maiden name; identification number, such as social security or tax identification number; geolocation data; permanent residence; professional licenses and affiliations; contract or policy number; relationship to policyholder, insured, owner, annuitant, or claimant; date and cause of death, injury, or disability; and other similar information. In cases involving a trust, the date of the trust instrument, the state law that governs the trust, the identity of each grantor, the identity of each current trustee, whether the trust is revocable, whether conflicts of interest are present, and information related to the tax status of the trust.
• Contact Information: Business and/or personal addresses, email addresses, telephone numbers, fax numbers, and other contact details.
• Financial and Business Information: Financial statements; assets; liabilities; and tax information; credit history; credit score; educational information; status as a director, partner, or other ownership or management position; insurance coverage information; and any other financial information required to support the suitability determination of an annuity purchase.
• Payment Information: Bank account information, brokerage account information, wire transfer instructions, and other information necessary for Great American Life to make or receive payments.
• Health Information: Medical history; past, current, and future physical, mental, or medical condition or treatment; medical procedures performed; health status, injury, or disability information; personal habits (for example, smoking or consumption of alcohol); prescription information; payment for medical treatment; and other similar health information.
• Regulatory Information: Any personal information needed for Great American Life to comply with its obligations under applicable laws and regulations, including, without limitation, anti-money laundering, anti-bribery, insurance fraud, economic and trade sanctions, and other regulatory schemes. In the event Great American Life intends to obtain a consumer credit report about a U.S. individual, Great American Life will provide separate notice to the individual and, if required under the Fair Credit Reporting Act, obtain the individual’s consent prior to obtaining the consumer report.
3. HOW GREAT AMERICAN LIFE COLLECTS YOUR INFORMATION
Great American Life collects and receives the personal information described in Section 2: Personal Information Collected by Great American Life above from a variety of sources. We may receive personal information directly from you, through our website, software, and mobile applications, as well as from third parties such as producers, other insurance companies, vendors, service providers, consumer reporting agencies, account verification services, and other publicly-available sources of information.
4. HOW GREAT AMERICAN LIFE USES YOUR PERSONAL INFORMATION
Great American Life uses the personal information collected above for the following purposes:
• Underwriting, Policy Issuance and Maintenance: In order to underwrite, issue, and maintain annuity contracts and insurance policies, obtain reinsurance, and communicate important information to you throughout this process, Great American Life may collect, use and share (“process”) identity, contact, financial, health, and regulatory information about policyholders, insureds, producers, annuity owners, certificate owners, annuitants, beneficiaries, trustees, legal representatives, reinsurers, underwriters, actuaries, and other related persons or entities. We process this information to enter into and perform our contractual obligations to you and for our legitimate business purposes.
• Claims Review and Approval: In order to process claims under an annuity contract or life insurance policy and to communicate with you throughout this process, Great American Life may process identity, contact, financial and business, health, and regulatory information about claimants, policyholders, insureds, annuity owners, certificate owners, annuitants, beneficiaries, trustees, legal representatives, agents, advisors, brokers, and other third parties. We process this information to perform our contractual obligations to you and for our legitimate business purposes.
• Payment: In order to collect premium payments, collect purchase payments, collect reinsurance proceeds, purchase reinsurance, make annuity payments, process annuity withdrawals and loans, pay annuity and life death claims, pay third-party service providers and other payees, and make other business-related payments, Great American Life may process identity, contact, financial and business, payment, and regulatory information about policyholders, insureds, reinsurers, annuity owners, certificate owners, annuitants, beneficiaries, trustees, claimants, third party administrators, professional advisors, service providers, vendors, and other payees. We process this information to perform our contractual obligations to you and for our legitimate business purposes.
• Internal Operations: Great American Life may process identity, contact, financial and business, payment, health, regulatory, and website usage information for purposes of Great American Life’s internal business operations, including but not limited to marketing; servicing your account; improving our products and services; data security; financial, claim or other audits; quality assurance measures; resolving complaints; identifying and preventing fraud; complying with legal, regulatory, and contractual obligations; business continuity and disaster recovery; complying with internal policies and procedures; establishing and defending Great American Life’s legal rights; communicating important information regarding our policies, terms and conditions, and other administrative information; communicating with agents, advisors, brokers, policyholders, contract owners, certificate owners and beneficiaries; responding to requests for information and deletion; website personalization and optimization; as well as actuarial studies, analytics, and statistical modeling. We process this information to perform our contractual obligations to you, for our legitimate business purposes to provide and customize our products and services to you and to secure your information, and to comply with legal obligations and exercise any legal rights we may have.
5. HOW GREAT AMERICAN LIFE SHARES YOUR PERSONAL INFORMATION
Great American Life may disclose your personal information to the following entities, as allowed by and in accordance with applicable law, for the purposes set forth in Section 4: How Great American Life Uses Your Information above:
• Parents, Subsidiaries, and Affiliates: In connection with our business operations, to provide products and services, and to comply with applicable laws and regulations, Great American Life entities may share information with their parent companies, subsidiaries, and affiliates.
• Professional Advisors: In order to comply with applicable laws and regulations, to obtain professional advice and services, and in connection with our business operations, Great American Life may disclose personal information to accountants, auditors, lawyers, bankers, insurers, and other professional advisors to Great American Life.
• Insurance-Related Business Partners and Third Parties: In connection with our business operations and to provide products and services, Great American Life may share information with underwriters, actuaries, brokers, agents, and advisors; insurance support organizations; reinsurance providers; other insurance companies and third party administrators; financial institutions, such as banks; payment processors; securities firms; credit bureaus; consumer reporting agencies; and other third parties.
• Other Vendors and Service Providers: In order to provide products and services and to support our business operations, Great American Life may share information with vendors and third party service providers such as IT vendors, developers, software providers, and website hosting providers; records management and data storage providers; data analytics companies; printing, advertising, marketing and market research companies; translators; and other third parties.
• Legal and Regulatory: For the purpose of meeting our legal and regulatory obligations, or otherwise as allowed or required by law, Great American Life may share personal information with third parties such as federal, state, and local regulatory authorities, tax authorities, law enforcement, public, administrative, or judicial bodies, or other persons or entities in response to a legal process (such as a subpoena).
• Authorized Representatives and Successors in Interest: Great American Life may share personal information with your agent, advisor, representative, attorney-in-fact, guardian, or conservator. If an interest in an annuity contract or life insurance policy is transferred, assigned, or otherwise passes to a new owner, assignee, or other successor, Great American Life may share personal information with that successor to the extent needed to confirm the successor’s interest. After your death, Great American Life may share personal information with your executor, administrator, or personal representative, your beneficiary, or other legally authorized successor to your interest in the annuity contract or life insurance policy.
• Corporate Transaction: Great American Life may disclose your personal information to a third party in connection with a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Great American Life business, assets, or stock (including in connection with any insolvency event or similar proceedings).
• Marketing: Great American Life may disclose your personal information to an affiliate or a third party marketing service provider in connection with the marketing efforts of Great American Life or its affiliates, which may include joint marketing arrangements with third parties. Notwithstanding the foregoing, however, Great American Life will not share the opt-in or consent information of any individual who opts in to a short code text messaging program with any affiliates or third parties for the affiliate or third party’s marketing purposes. You may opt out of marketing emails at any time by following the instructions in our marketing communications or by contacting us using the information provided in Section 12: Questions and Contact Information below.
There may be situations where Great American Life is required by law to obtain your consent in order to process or share your personal information. If you are asked to give your consent and have provided your consent, you may withdraw it at any time by contacting us using the information provided in Section 12: Questions and Contact Information below. Please note, however, that withdrawing your consent could impact our ability to provide you with the requested products and services.
7. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
Great American Life strives to ensure the information we have is accurate and up-to-date. Please notify us if you believe an error has been made in the accuracy of the information Great American Life has about you, and we will correct it upon confirmation of the error and receipt of the correct information.
You may have additional rights with respect to your personal information depending on the laws of your jurisdiction.
If you wish to exercise one or more of your rights with respect to your personal information, please contact Great American Life using the information provided in Section 12: Questions and Contact Information below. Please understand that in order to protect your privacy and security, we will need to take reasonable steps to verify your identity before we can respond or comply with any request relating to your personal information. Great American Life will respond to your request as soon as practicable, but in any event within the legally required time.
8. DATA RETENTION AND INFORMATION SECURITY
Great American Life retains your personal information for as long as reasonable or necessary to fulfill the purposes for which the data was collected, meet its business requirements, and comply with applicable laws and regulations.
Great American Life is committed to protecting your personal information and has implemented physical, procedural, organizational, and technical safeguards, consistent with applicable law, intended to prevent loss, misuse, unauthorized access, disclosure, or modification of personal information under our control. If you have reason to believe that any of your personal information is no longer secure, please notify us using the information provided in Section 12: Questions and Contact Information below.
9. DATA TRANSFERS
10. OTHER GREAT AMERICAN LIFE NOTICES OF PRIVACY AND INFORMATION PRACTICES
The federal Gramm-Leach-Bliley Act and U.S. state privacy laws require Great American Life to provide the following notice of privacy and insurance information practices to its U.S. consumers:
• Great American Life Insurance Company, Annuity Investors Life Insurance Company and Manhattan National Life Insurance Company (collectively, “Great American Life”) Notice of Privacy and Insurance Information Practices: https://gaconnect.com/privacy/notice
Great American Life’s website is intended for individuals who are over the age of eighteen (18). We do not knowingly collect personal information through our website from children under the age of eighteen (18) and ask that they do not provide us with personal information through the website.
12. QUESTIONS AND CONTACT INFORMATION
Great American Life Insurance Company
Attention: Privacy Officer
301 E. Fourth Street
Cincinnati, OH 45202-4201
(800) 854-3649 (select 2)