Haven Life

Privacy Notice

Last Updated:
Effective Date:

At Haven Life Insurance Agency LLC (“Haven Life”) 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”).

We use the terms “we”, “our”, “us”, and similar to refer to Haven Life, Massachusetts Mutual Life Insurance Company (“MassMutual”), Haven Life product brands, and any affiliate companies and partners. We use the terms “you”, “your”, and similar terms to refer to the visitors to our Platforms. Other sites associated with MassMutual may contain separate Privacy Notices. For the Privacy Notices associated with MassMutual’s main website, see www.massmutual.com/legal/privacy.

For residents of California, please also refer to section 12, Supplemental Information for California Residents.

1. Information We Collect on Our Platforms

Information You Provide To Us

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 and/or its affiliates or subsidiaries. If you use any of the technology platforms of our parent company, including, without limitation, MassMutual’s websites, interactive features, applications, and social network pages, we will handle your information in accordance with MassMutual’s own privacy policies and practices.

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, Supplemental Information for California Residents.

Information We Collect Automatically

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. For example, we use session replay tools to record your interactions with the Platforms, such as how you move throughout our Platforms and engage with our webforms. 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), SDKs, embedded scripts, and other tracking technologies. Cookies may contain a cookie ID that we and third parties can use to track you and your device across digital properties over time. For example, cookies may be used to associate you with social networking sites like Facebook and Twitter and to 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), and to personalize advertising to you (by us and our third party partners), such as on social media sites and through other online and offline interactions. A pixel tag may tell your browser to get content from another server or send content to another server or third party.

To learn how you may be able to reduce the number of cookies you receive from us, or delete cookies that have already been installed in your browser’s cookie folder, or prevent tracking activities, please refer to your browser’s tools or help menu or other instructions related to your browser. Because an industry-standard Do-Not-Track protocol has not yet been established we do not currently honor “Do Not Track” signals sent by browsers. However, you may refuse to accept cookies in order to prevent tracking activities. If you do disable or opt out of receiving cookies, please be aware that some features and services on our Platforms may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Information That We May Have Collected in the Past Twelve (12) Months

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.

2. How We Use the Information We Collect

We use the information we collect about and from you for a variety of 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.

Does Haven Life Sell Personal Information?

Haven Life does not sell personal information, including the personal information of consumers under 16 years of age, and we have not done so for the 12-month period preceding the last revision date of this Privacy Notice.

3. Sharing of Information

Except as described in this Privacy Notice or in our customer privacy notices and other privacy notices, we will not provide any of your Personal Information to any third parties without your consent. We may also share your information as disclosed at the time you provide your information. Examples of how we share information include:

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.

Legal Disclosure. We may transfer and disclose your information to law enforcement, government agencies, and other third parties to comply with a legal obligation or when we believe in good faith that the law or a governmental authority requires such disclosure; to verify or enforce our Terms of Use or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to our Platforms or the public.

Aggregate Data. We may share aggregate data with third parties.

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.

4. Information We Receive from Third Parties

We may receive information about you from third parties such as consumer or other reporting agencies and medical or health care providers; through your interactions with our affiliated companies; from data brokers; and from lead generation or referral partners. In addition, if you are on another website and you opt-in to receive information from us. 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 (Meta) 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. Third parties (such as social media companies) may also 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.

5. Your Privacy Rights, Choice and Access

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. 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 privacy@havenlife.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, comply with our internal compliance and record retention policies, enforce our agreements, carry out legitimate business functions, and for any other purpose permitted by law. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook (Meta) 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.

6. Advertising; How to Opt-Out

We may use third party ad network providers to help present ads on the Platforms, as well as other service providers to evaluate and provide us with information about the use of the Platforms and viewing of our content. We do not share Personal Information with these providers (except as described in section 3 above or in other circumstances with your permission). Such providers may place and access cookies, pixel tags, or similar technologies on your Device to serve you ads or other content personalized to your interests which they infer from your browsing on the Platforms and other sites you have visited. In doing so, the provider collects or has access to information about you and your device such as your Usage Information. The use of cookies, pixel tags, or similar technologies by these providers is subject to their own privacy policies, not ours.

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 https://optout.networkadvertising.org/?c=1 and the Your Ad Choices Opt Out at https://youradchoices.com/control. Please note that even if you choose to opt out at the links above, you will still see advertising when you are browsing online. However, the advertisements you see may be less relevant to you and your interests.

California residents who wish to opt out of the sale or sharing of their personal information must follow the process described in section 12 below.

7. Children

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.

8. Security of Your Information

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.

9. Other Sites

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 Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Notice.

10. Changes

We may update this Privacy Notice to reflect changes to our information practices. If we make any material retroactive changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Platforms. We encourage you to periodically review this page for the latest information on our privacy practices.

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.

12. Supplemental Information for California Residents

This section describes how we collect, use, disclose, and otherwise handle Personal Information that is subject to the California Consumer Privacy Act (“CCPA”) for individual consumers and website visitors. This section also describes the rights available to California residents with respect to their Personal Information that is subject to the CCPA. This section supplements (but does not replace) the sections above.

Importantly, this section does not apply to personal information that is exempt from the CCPA, such as data subject to the Fair Credit Reporting Act (“FCRA), the federal Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (collectively, “Exempt Financial Information”). Exempt Financial Information is subject to our [financial privacy notices available here]. This section also does not apply to other, non-financial Personal Information that is exempt from the CCPA, such as data subject to the Health Insurance Portability and Accountability Act (HIPAA), the California Confidentiality of Medical Information Act, or the Driver’s Privacy Protection Act of 1994.

Sources of Personal Information. We collect Personal Information about you from the following sources:

  1. Directly from you. We may collect Personal Information you provide to us directly, such as when you contact us through our Platforms, interact with us in person, sign up for offers or newsletters, or otherwise communicate with us.
  2. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Platforms. This may include information about how you use and interact with our Platforms or otherwise interact with us, information about your device, and internet usage information. For more information, see Cookies and Other Tracking Technologies below.
  3. From service providers who collect information on our behalf.
  4. From our affiliates and subsidiaries.
  5. From financial professionals (such as agents and brokers).
  6. From third parties, such as commercial business partners, data brokers, social media companies or other parties who interact with us.
  7. From publicly available sources. We may collect Persona Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this section, including third party sources, and use or disclose it for the purposes identified below.

Categories and Disclosures of Personal Information. We may disclose Personal Information to third parties, including the categories of recipients described below.

Although we do not “sell” Personal Information for money, we engage in routine practices involving third parties that could be considered a "sale" (meaning a disclosure of Personal Information to a third party for consideration) or “sharing” (meaning a disclosure of Personal Information to a third party for targeted advertising purposes), as defined under the CCPA. We do not knowingly sell or share Personal Information about minors under the age of 16.

Categories of Personal Information We Collect Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”
Identifiers, such as your name, email address, physical address, telephone snumber, and device identifiers.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Advertisers, ad platforms and networks, and social media platforms
  • Third parties whose cookies and tracking tools we use as described below in Cookies and Other Tracking Technologies
  • Commercial data partners to whom we make information available for their own marketing purposes
  • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services
Records about you, such as covered medical or health nformation, investments, estimated income, and other information that we obtain rom commercial data partners.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared
Characteristics of protected classifications under California or federal law, such as age (including birthdates), gender, and veteran status.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared
Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Advertisers, ad platforms and networks, and social media platforms
  • Third parties whose cookies and tracking tools we use as described below in Cookies and Other Tracking Technologies
  • Commercial data partners to whom we make information available for their own marketing purposes
  • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services
Internet or other electronic network activity information, about you, your device, and how you interact with the Platforms. Data elements may include browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), operating system, browser used, and other information about how you interact with our Platforms (such as pages on our Platforms that you have viewed).
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Advertisers, ad platforms and networks, and social media platforms
  • Third parties whose cookies and tracking tools we use as described below in Cookies and Other Tracking Technologies
  • Commercial data partners to whom we make information available for their own marketing purposes
  • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services
Geolocation data, such as your location as derived from your IP address.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Advertisers, ad platforms and networks, and social media platforms
  • Third parties whose cookies and tracking tools we use as described below in Cookies and Other Tracking Technologies
  • Commercial data partners to whom we make information available for their own marketing purposes
  • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services
Audio, visual, or other sensory information, such as photographs and audio/video recordings.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared
Professional or employment-related information, such as job title, organization and other professional information.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared
Education information.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared
Inferences drawn from any of the information we collect about your preferences or behavior.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Advertisers, ad platforms and networks, and social media platforms
  • Third parties whose cookies and tracking tools we use as described below in Cookies and Other Tracking Technologies
  • Commercial data partners to whom we make information available for their own marketing purposes
  • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services
Sensitive Personal Information, such as health information obtained from commercial data partners or inferred from your interactions with our Platforms.
  • Affiliates and subsidiaries
  • Professional consultants
  • Vendors necessary to complete transactions you request
  • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
  • Other entities in connection with a corporate transaction
  • Entities to which you have consented to the disclosure
  • Not sold or shared

The categories of recipients in the chart above are used to mean:

  1. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
  2. Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
  3. Vendors necessary to complete a transaction that you request, such as shipping companies.
  4. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use, Terms of Service and other agreements or policies, and to protect ours, our customers’, or third parties' safety, property, or rights.
  5. Other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.
  6. Entities to which you have consented to the disclosure.

Use of Personal Information. We may use Personal Information for the following purposes:

  1. For our internal business purposes, such as operating our Platforms and customizing the content; maintaining internal business records, such as accounting, document management and other similar activities; enforcing our policies and rules; management reporting; auditing; IT administration of our network, intranet, and other technologies; and IT security management and tasks.
  2. For our internal research and business improvement purposes, such as verifying, maintaining, or improving the quality of our business (including our Platforms); evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
  3. For legal, safety, or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against the Company, its personnel, and its customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
  4. In connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets.
  5. For marketing and targeted advertising, such as marketing our business or that of our affiliates, business partners, or other third parties (for purposes of this paragraph alone, “we” or ”our” includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Information we collect to personalize advertising to you on our Platforms or third party sites and digital properties; to analyze interactions with our email communications or website areas viewed; to develop product, brand or services audiences (including by identifying you across devices/sites) to better target our advertising to you; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the information in the Contact Us section below.

We only use Sensitive Personal Information that is subject to the CCPA for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including xnonpersonalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

Cookies and Other Tracking Technologies. Our Platforms (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Platforms. This section contains additional information about:

A. Types of cookies and tracking technologies we use

Our Platforms and the third parties that we authorize may use the following tracking technologies:

B. Purposes for Using These Technologies

We and authorized third parties use these technologies for purposes including:

C. Personal Information Collected

These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Platforms (such as pages on our Platforms that you have viewed, including your specific mouse movements, page clicks, and other session replay information).

D. Disclosures of Personal Information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Platforms such as social media companies, advertising networks, companies that facilitate session replay recordings and analysis, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platforms.

E. Your Choices

Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Platforms’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. Some browsers have incorporated Do Not Track (“DNT”) preferences. We do not currently honor such signals.

Data Retention. Our Information Governance and Records Management Program establishes and maintains company policies and procedures governing the creation, retention, storage, and disposition of corporate records and information, provided that such information to be delete or destroyed is not subject to regulatory requirement to retain it or a legal hold. We retain corporate records for the minimum time period required by law or regulation and/or for a longer period of time consistent with business needs. We determine retention periods for corporate record information using both legal/regulatory citations and business requirements. Citations for retention periods are regularly reviewed by outside counsel and updated as necessary. CCPA rights request records are subject to a two year retention period as required by California law.

Privacy Rights. California residents may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

You may exercise a privacy rights request by emailing us at privacy@havenlife.com or by calling us at 855-744-2836.

You may exercise the Right to Opt-Out of Sale/Sharing by both submitting your email address and selecting the “Opted Out” option in our Preference Center. You may also call us at 855-744-2836 or email us at privacy@havenlife.com. More details about your right to opt out and options available to you is available in the Preference Center. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.

Verification: In order to process requests, we may need to obtain information to locate you in our records or verify your identity using reasonable methods. To exercise the Right to Opt Out of Sale/Sharing, you must provide your email address in our Preference Center so we can locate your information (if any) in our records. For all other rights, we will collect some or all of the following data elements: Name, Date of Birth, Email, Phone Number, and Address. In some cases, we may ask for more or different information if needed to verify you. We may also use a third party identify verification and fraud prevention service that will present you with additional knowledg

Authorized Agents: Authorized agents may exercise rights on behalf of consumers by submitting a request via our dedicated email address at privacy@havenlife.com and indicating that they are submitting the request as an agent. Agents should provide their own information to verify the agent’s identity, after which we will contact the agent with additional instructions to complete the consumer right submission process. We may require agents to demonstrate authority to act on behalf of a consumer by providing signed permission and may require consumers to directly verify their identity with us using the methods described above.

Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request. We will respond to Right to Opt Out of Sale/Sharing requests within 15 days.

Statistical Information About Responses to Requests

January – December 2023

CATEGORY RECEIVED COMPLIED WITH (WHOLE/IN PART) DENIED MEDIAN DAYS TO RESPOND
Requests To Know 0 0 0 N/A
Requests To Delete 1 1 0 31
Requests To Opt-Out 0 0 0 0

13. Contact Us

If you have any questions or concerns about this Privacy Notice, the practices of the Platforms, or your experiences with the Platforms, please contact us at 855-744-2836, or by email at privacy@havenlife.com.