UPDATED AS OF: December 2, 2020
At Haven Life Insurance Agency LLC (“Haven Life”, “we”, “us”, or “our”) we are committed to maintaining your confidence and trust as it relates to the privacy of your information. Please read below and learn how we collect, protect, share and use your information as part of our technology platforms, including, without limitation, our websites, interactive features, applications, and social network pages (“Platforms”).
For residents of California, please also refer to section 12, Rights of California Residents.
We may collect Personal Information (information that can be used to identify you as an individual) such as your name, email, telephone number, home address, demographic information (such as zip code, age), payment information (such as account or credit card number), social security number, medical and health information, checking history, account balances. The types of Personal Information we collect may vary depending on your use of the features of the Platforms. We are a licensed insurance agency and a wholly owned subsidiary of Massachusetts Mutual Life Insurance Company (“MassMutual”), and we sell insurance issued by MassMutual. If you are or become a customer of our parent company, MassMutual, and use the Platforms to access account, contract or policy information, we will handle your information in accordance with MassMutual’s customer privacy notices.
For California residents, personal information is defined as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Under California Law, personal information does not include publicly available information or consumer information that is de-identified or aggregate consumer information. For more information, see Section 12 on Rights of California Residents.
Usage Information. Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used (“Usage Information”). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor content to a visitor’s interests.
Device Identifier. We automatically collect your IP address or other unique identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Platforms, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your interests, and gather broad demographic information for aggregate use.
Cookies; Pixel Tags. The technologies used on the Platforms to collect Usage Information, including Device Identifiers, include but are not limited to: cookies (data files placed on a Device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites. We, or our vendors, may place cookies or similar files on your Device for security purposes, to facilitate site navigation, to perform analytics, and personalize your experience while visiting our Platforms (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). A pixel tag may tell your browser to get content from another server.
In the past 12 months, we may have collected the following categories of personal information relating to consumers:
We collect personal information directly from consumers, through the use of analytics tools on our website, and from affiliated and nonaffiliated third parties, such as data brokers or data aggregators.
We use the information we collect about and from you for a variety of business purposes such as to respond to your questions and requests for services; operate, manage and maintain our business; provide you with access to certain areas and features of the Platforms such as certain products and services; purchase history; verify your identity; communicate with you about your account and activities on the Platforms and, in our discretion, changes to any of our policies; tailor content, advertisements, and offers we serve you; for our employment and vendor management purposes; conduct research and data analysis; conduct risk and security control monitoring; detect and prevent fraud; improve the Platforms; comply with law, legal process, internal policies and license obligations; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent. We may also collect your location based information for the purpose of providing you with certain services.
Third Parties Providing Services. We may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners) such as:
Business Transfers. We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
Information That We May Have Shared In the Past Twelve (12) Months. In the past 12 months, we may have disclosed the following categories of personal information to affiliated and nonaffiliated third party service providers for our business purposes:
Please note that any personal information consisting of medical or health information is only shared with third parties to perform business, professional or insurance functions on our behalf or as authorized by you.
We may receive information about you from third parties such as consumer or other reporting agencies and medical or health care providers; or through your interactions with our affiliated companies. In addition, if you are on another website and you opt-in to receive information from us, that website will submit to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Usage Information and Personal Information such as lists of your friends, “likes”, comments you have shared, groups and location. Services like Facebook Connect give you the option to post information about your activities on our Platform to your profile page to share with others within your network. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections’” web page, profile page, or similar page on a social networking or other third party website or interactive service. We may supplement the information we collect about you through the Platforms with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you.
You control the Personal Information that you provide to us on the Platforms, but some Personal Information is required by us in order for you to obtain services from us or for you to use the Platforms. If you choose not to provide us with your Personal Information on the Platforms, you may not be able to take advantage of some of the services we offer or use some functionality on the Platforms. Except as provided above in section 3, we will not share Personal Information collected on the Platforms with third parties without your consent. You may also direct us to stop sending you promotional emails by following the removal instructions in a communication you receive from us. Your opt-out request will be processed within 10 business days of the date on which we receive it.
If you wish to modify, verify, correct, or delete any of your Personal Information collected through the Platforms, you may edit your registered user information or contact us at the above address or email. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your online account or request that we no longer use your information to provide you services through the platform, contact firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, adhere to information retention and disposition guidelines, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.
If you do not want to receive the benefits of targeted advertising, you may opt-out of some network advertising programs that use your information by visiting the NAI Opt-Out page at http://networkadvertising.org/managing/opt_out.asp. Please note that even if you choose to remove your information, you will still see advertising when you are browsing online. However, the advertisements you see may be less relevant to you and your interests.
The Platforms are not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
We take information security seriously and use certain reasonable security measures to help protect your Personal Information. We apply physical, electronic, and procedural safeguards to protect your personal information from unauthorized access. We provide training to our employees on how to safeguard personal information and only authorized employees are permitted to access personal information, which may only be used for permitted business purposes. We contractually require service providers to protect your personal information and use it exclusively for the purpose of performing certain business functions on our behalf. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.
The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
The website is governed by and operated in, and in accordance with the laws of the United States. We make no representation that the website is governed by or operated in accordance with the laws of any other nation. By using the website, or providing us with any information, you (a) acknowledge that the website is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain additional privacy rights related to the personal information we collect about you. For the avoidance of doubt, the rights outlined in this section are only applicable to California residents. Generally, the CCPA provides you with the right to know about the personal information we collect about you and the right to have personal information we collect about you deleted in certain circumstances. The CCPA also provides you with the right to opt-out of the sale of personal information that has been collected about you. Please see below to learn more about your rights under the CCPA and to learn more about Haven Life’s CCPA privacy practices.
This section (“CCPA Privacy Rights”) applies solely to consumers who are residents of the State of California at the time of a request. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Terms used in this section, such as personal information, consumers, and service providers, have the same meaning as they are defined in the CCPA.
You may request and, subject to certain exemptions, we will provide:
You have the right to not receive discriminatory treatment by Haven Life for the exercise of your privacy rights under the CCPA. This means that we will not:
Beginning January 1st, 2020, if you are a California resident and would like to submit a CCPA request, you may contact us by phone toll-free at 855-744-2836, or by email at email@example.com.
After verifying your identity, we will respond to your request within forty-five (45) days. If additional time is required to process your request, we will communicate as such. If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that is not in conflict with applicable laws or exempt under the CCPA.
Only you, or a person you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That individual must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.
In order to verify your identity, we may request your:
We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third-party identity verification service.
We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.
We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.
If you have an account with Haven Life, we may instead verify your identity by communicating with you directly through your account center. You are not required to have an account with us to make a verifiable request.