Banner Life Privacy Policy

Your privacy is important to us.

(Effective Date: February 2, 2026)

Your privacy is important to us. At the Banner Life family of companies (Meiji Yasuda North America Holdings Incorporated, Banner Life Insurance Company, William Penn Life Insurance Company of New York, collectively “we”), we understand that the information you provide to us or that we collect about you is private. This privacy policy is provided to you so that you will understand what we, as a “data controller” or “business”, do with the personal information you provide to us and the measures we take to protect your privacy.

In essence, we collect information about you to provide you with life insurance and annuity products, to provide services to you, or to provide you with information about our products and services. Sometimes this information comes directly from you to us (either via our website, when you call us, or when you file a claim), and other times it comes to us indirectly, particularly through independent agents or financial advisors. We are also required to collect certain information to meet legal and regulatory requirements.

You may have certain rights with respect to this personal information as well, so we encourage you to read this Policy carefully, and to contact us if you have any questions.

This privacy policy does not apply to workforce members, such as employees, retirees, or contractors. If you are an employee or contractor of the Banner Life family of companies, please refer to our Employee Privacy Policy for information on how we process your personal information. This privacy policy also does not apply to information collected or controlled by a third party.

What type of information does the Banner Life family of companies collect and maintain?

As regulated insurance carriers, we are required by state laws and regulations to collect and maintain certain information about our customers. The information we collect also enables us to provide you with services and products that meet your individual needs and to provide you with the high level of customer care that you have come to expect from us.

The types of personal information we collect and share depend on the product or service you have with us or have requested information about. We typically collect information directly from you or through our independent agents and business partners (our “partners”). We may also collect personal information about you through your interactions with our website and other online systems. In addition, we may create records of personal information about you in the course of providing services or products to you, either directly or through our partners. We also collect information about you from third parties, including government agencies and our service providers. In all cases, we collect personal information about you in accordance with the principles outlined in this Policy and applicable law.

The table below provides more detailed information about the types of information we collect and why:

Information we collect	Why we collect it
When you apply for, inquire about, or obtain a product or service from us, we collect a range of identifiable information, which can vary depending on the circumstances, but may include your: name, address, telephone number, Social Security Number or other government identification, email address, financial information (such as employment and income history, banking relationships, assets and liabilities), financial account information, health information, demographic information, driving records, and information about your transactions with us (such as payment history and account balances).	This information is necessary to provide you with products, services, or information you requested or to take steps at your request prior to providing you with a product or service, for us to comply with a legal obligation, for us to carry out related business and operational activities, or for us to conduct market research to help us improve our services.
To the extent we engage in live quoting processes, we may collect from you a picture of yourself, from which we will draw inferences of your age, gender, and body mass index (BMI), and other indicia of insurability.	This information is required to provide you with our products and services. You will be asked to confirm the information, as we will not rely on the information gleaned from the photograph alone.
When you apply for, inquire about, or obtain a product or service from us, we may also obtain your credit history from consumer reporting agencies.	This information is necessary to provide you with products, services, or information you requested or to take steps at your request prior to providing you with a product or service.
If you are a beneficiary making a claim, we may require your name, address and proof of identity.	This information is necessary to confirm your eligibility as a beneficiary, and in order to administer the claim.
If you do business with one of our partners, we may collect personal information about you to allow us to identify and offer you products that may be of interest to you. This information may include your name, address, contact information, Social Security number or other government identification, financial information, demographic information, commercial information about your purchasing history, employment and professional information, and inferences based on this information regarding your preferences.	This data is used to offer products and services that may be of interest to you as permitted and subject to applicable law.
If you request or agree to receive electronic communications or mailings from us, we may collect your name, email, phone number, or physical address.	This information is necessary to send you the information you have requested.
If you partner with us or are interested in partnering with us, we may collect your name, address, telephone number, email address, and information about your agency.	This information is necessary to provide you with services, to provide you with information about our partner services, and to give you access to restricted parts of our web sites.

If you choose not to provide us with personal information or withdraw your consent to processing (where applicable), it may affect our ability to provide you with products or services you have requested.

Information We Automatically Collect
When you download, access, or use our Services, we automatically collect certain Personal Information from your device or browser. This may include information such as identifiers, device and location information, usage information, including any videos watched, transaction and account information, or call tracking information as described above. This includes information collected through technologies such as cookies, pixels, log files, web beacons, and other storage technologies (collectively, “Cookies and Similar Technologies”).

We and our partners, such as advertising networks, analytics providers, social media platforms, business partners and other service providers, may also use Cookies and Similar Technologies to collect information about your activities over time and across third-party websites, applications, and other online services (sometimes referred to as “behavioral tracking”). For more details about how we use these technologies work and your choices, please see the “Information About Cookies, Similar Technologies, and Do Not Track” section below.

We may also obtain Personal Information about you from third-party sources. These sources can include our service providers, business partners, analytics providers, advertising networks, social media platforms, data brokers, or publicly available sources.

Additional Disclosures Related to Collection, Use, and Disclosure of Personal Information for Residents of Certain U.S. States

The personal information about you that we collect includes information within the below categories of data. These categories also represent the categories of personal information that we have collected over the past 12 months. We do not necessarily collect all data listed in a particular category, nor do we collect all categories of data for all individuals. Note that the categories listed below are defined by California state law, but the disclosures below apply to residents of other US states. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect or disclose some information within that category. It does not necessarily mean that we collect or disclose all information listed in a particular category for all our customers, nor does it imply that California law applies to all the below categories of data.

We have also disclosed data in each of the following categories with our affiliates and service providers for our business purposes within the last 12 months, including for marketing purposes. We may receive requests for data from regulatory authorities, our auditors and/or our legal advisors. If requested from such parties, we would disclose your Personal Information as appropriate.

Category	Source	Purpose of processing
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	This information is collected directly from you, your agent, our partners, or our service providers.	This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services. If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, and organizing interviews.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, our service providers, or public records.	This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services. If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, and organizing interviews.
Characteristics of classes protected under federal or California law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.	This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. This data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services. If you are an applicant, this data is processed in connection with setting up an electronic job applicant HR file, managing your application, organizing interviews, and providing any necessary accessibility accommodations.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, our service providers, or public records.	This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. This data, as well as information regarding your purchasing tendencies obtained from our business partners, is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services.
Biometric information, which includes physiological, biological or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity.	To the extent we collect this information, it is collected directly from you, your agent, or our service providers, with your consent.	This data, to the extent we collect it, is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or for compliance management.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	This information is collected through the use of cookies and similar technologies.	This data is used for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
Geolocation data	This information is collected through the use of cookies and similar technologies.	This data is processed for marketing purposes, including offering you products that may interest you through both direct and partner advertising and to conduct market research to help us improve our services. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management.
Audio, electronic, visual, thermal, olfactory, or similar information	This information is collected directly from you, your agent, or our service providers.	This data (e.g. voice signatures for e-applications as well as recordings of customer service calls) is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account and to conduct market research to help us improve our services, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management.
Professional or employment-related information	This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.	This data is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims. It is also processed in order to help manage and administer your account and to conduct market research to help us improve our services, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management. If you are an applicant, this data is processed in connection with a number of our operational functions, including setting up an electronic job applicant HR file, managing your application, and organizing interviews.
Inferences drawn from any of the above categories of information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	This information is collected from consumer reporting agencies, our partners, or our service providers.	This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account and to conduct market research to help us improve our services, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.

In addition to the categories of Personal Information above, we also collect the following categories of sensitive personal information under various laws, including California law:

Category of Personal Information	Source of Personal Information	Purpose of Collection, Processing, and Disclosure
Characteristics of protected classifications under California or federal law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.	This data is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems.
Processing of biometric information for the purpose of uniquely identifying a consumer.	This information is collected directly from you.	This data, to the extent we collect it, is processed in connection with a number of our operational functions to provide you with services, including: policy issuance. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or for compliance management.
Personal information collected and analyzed concerning a consumer’s health.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.	This data, to the extent we collect it, is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.
Personal information collected and analyzed concerning a consumer’s health, sex life or sexual orientation.	This information is collected directly from you, your agent, consumer reporting agencies, our partners, or our service providers.	This data, to the extent we collect it, is processed in connection with a number of our operational functions to provide you with services, including: policy issuance.

International Users
This website is based and administered in the United States of America. The website is governed by the laws of the United States and is not directed at users based outside of the United States.

Information about Cookies and Do Not Track

When you interact with our website, as well as when you interact with the websites or services of our partners, we may use a variety of technologies to automatically collect information. These include:

Cookies: Small text files placed on your device by your browser. Cookies allow us to recognize your browser, remember your preferences, keep you signed in, and understand how you use the Services. They may be set by us (first-party cookies) or by others (third-party cookies, such as for analytics or advertising).
Web beacons / pixel tags: Tiny graphics or snippets of code that link web pages or emails to our servers (and their cookies). They help us measure the effectiveness of campaigns, understand usage, and deliver content.
Advertising identifiers: Resettable identifiers provided by mobile operating systems (such as Apple’s Identifier for Advertisers (IDFA) or Google’s Advertising ID (AAID)). These work in a similar way to cookies and are used for advertising and analytics purposes.
Session replay technologies: Tools that may record how you interact with the Services (such as clicks, scrolling, and navigation) to help us diagnose issues, analyze usage, and improve your experience.
Local storage and similar technologies: Web browsers and apps may also use local storage (including HTML5 local storage and caches) and software development kits (“SDKs”) to save information directly on your device. These technologies are often used to remember settings, speed up performance, or support app functionality.
Device and browser fingerprinting: In some cases, we may use technical information about your browser, device, or network (such as fonts, screen resolution, or plug-ins) to help recognize your device for security, analytics, or advertising purposes.

These Cookies and Similar Technologies may be deployed by us directly, our business partners, or third-party analytics or advertising providers, either on our behalf or for their own purposes. They may be used to deliver information to you or about you and to connect information about you across different sources, websites, devices, and applications.

What types of cookies do we use?
While you are online, your computer saves so-called “cookies.” These are small files that control how our website is displayed and operates. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our website more user-friendly, effective, and secure. Some cookies are even necessary to the functioning of our website.

Third-party cookies belong to and are managed by other parties, such as Google Analytics or other service providers. These cookies may be required to render certain forms, such as email list sign-up, or to allow for some advertising outside of our website. In particular, Google Analytics allows us to understand how our media campaigns work and how you interact with our website in order to improve the user experience.

For detailed information regarding the cookies implemented by the Banner Life family of companies, please visit www.bannerlife.com. Utilize the cookie consent banner and select the ‘Manage Preferences’ button or click on the cookie icon located in the lower right corner of the page. This action will open a window that categorizes cookies. Detailed information about each cookie can be accessed by clicking on the 'View Cookies' links within the window. The cookies enabled may differ per session depending on the user's geographical location.

The Cookies we use generally fall into these categories:

Essential cookies
We may store cookies on your device if they are necessary to enable us to offer and provide our services. They are also required for you to navigate through the website and web application and benefit from all the available functions. These cookies cannot be switched off and are set for very basic options on the website, such as logging in, forms and set preferences such as timezone or languages.
Analytical cookies
These cookies are placed to aid us in understanding how you interact with the available options on the website, which parts you use the most, and how you engage with our services. This helps us create statistics of usage and the amount of time you spend on the website. These statistics will ultimately help us to improve our website and any services we offer on it.
Functional Cookies
These cookies are placed by us to help us to provide you with better functionality of the website and our services and to make them more personalized to you. They can also be placed by third-party providers you specifically consent to when you accept this cookie policy. You may block these cookies, but if you do, it may be that parts of the website do not function the way we intended.
Social Media Cookies
These cookies are set for social media services. They enable you to share parts of the website on social media with friends and networks.
Targeting or Advertising Cookies
These cookies are used to serve you with advertisements that may be relevant or of interest to you when you are browsing on the internet. They are mostly placed by third parties whenever you interact with their content on our website.

How are cookies used for targeted advertising purposes?
Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable us to understand and improve the delivery of ads to you and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.

Although we do not use cookies to create a profile of your browsing behavior on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal data that we collect to advertisers. You can choose not to enable off-site and third-party-informed advertising by adjusting your cookie settings. Doing so will not remove advertising from the pages you visit, but, instead, will result in the ads you see not being matched to your interests by any cookies you choose to delete or block.

How are third party cookies used?

For some of the functions within our websites we use third-party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third-party suppliers) may contain third-party cookies, and we encourage you to consult the privacy policies of these third-party vendors on their websites for information regarding their use of cookies.

Some of these technologies may interact with services provided by third parties, such as Google, Meta (Facebook), LinkedIn, Microsoft, and others.

These interactions can include:

Associating website activity with your accounts on these platforms (e.g., for advertising, analytics, or personalization).
Using browser identifiers or other device information to provide relevant content or ads.

We do not have control over how these third-party services collect, store, or use the data they receive. To understand and manage the information collected by these services, you should review the privacy settings and controls provided directly by the service providers:

Google: https://myaccount.google.com/privacy
Meta / Facebook: https://www.facebook.com/settings?tab=ads
LinkedIn: https://www.linkedin.com/psettings/
Microsoft / Bing: https://account.microsoft.com/privacy

You may adjust your preferences on those platforms to control how your information is used for personalized advertising and analytics.

How do I reject and delete cookies?
You may stop or restrict the placement of cookies and other tracking technologies, such as pixel tags. You do this by blocking them on your device or by removing them and adjusting preferences on your browser. This may vary from device to device and from browser to browser.

Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Once you correctly block cookies on your browser, parts of the website may become unavailable to you or may otherwise not function properly.

You may also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. By using our website without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device.

How to opt-out of third-party cookies and targeted ads.
To opt out of tracking analytics placed by Google, you can install the Google Analytics opt-out browser add-on here.

To understand and responsibly manage cookies that enable interested-based ads we strongly recommend that you go to the website of the Digital Advertising Alliance (DAA) or to the website of the Network Advertising Initiative (NAI).

To learn more, please visit https://youradchoices.com/. Many of our third-party service providers that serve interest-based advertisements to you across our services are members of the Network Advertising Initiative (NAI), or they follow the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You can choose to opt-out directly from these third parties by visiting their opt-out pages on the NAI website (https://thenai.org/opt-out/) and DAA website (http://www.aboutads.info/choices/). However, please note that if you “opt-out” you will keep seeing links and online advertisements; however, they will not be specifically targeted to you or tailored to your interests.

Do Not Track
Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our services do not currently respond to browser DNT signals. For more information on DNT, see https://allaboutdnt.com/.

Who do we share your personal information with, and why?

We may disclose your personal information to our affiliated companies, when required by law, or to our service providers for the purposes described above. For example, using service providers may be necessary for the administration and maintenance of our IT systems. We may also transfer information, including your personal information, to third parties as necessary to provide the products and services you request, such as underwriting your risk or assisting you in completing a transaction. We require our service providers to provide written assurances regarding the security and privacy protections they have in place to protect any personal information transferred to them, as well as their compliance with our security requirements and any applicable laws and regulations.

As allowed by law, we may from time to time share non-public personal financial information with a non-affiliated third party that performs services or functions on our behalf. These services or functions may include marketing of our own products and services; or financial products or services offered pursuant to a joint agreement between us and one or more financial institutions.

The third parties we may share your personal information with include:

independent agents and business partners;
third-party service providers;
regulatory authorities;
our auditors and legal advisors; and
relevant industry self-regulatory bodies (such as FINRA).

We do not intentionally sell your personal information, or intend to in the future, and we have contracts with our service providers to prohibit any sale of the personal information we provide them; but if you have any concerns that our third parties might be selling your information, please contact us.

We may share your information with our corporate affiliates (e.g., our parent company, sister companies, subsidiaries, joint ventures, or other companies under common ownership or control of our ultimate parent company). This sharing is done so that these affiliates can provide services to us, and may be necessary to provide you with services, products, or information you have requested or expressed an interest in.

Your information may only be transferred to another country for processing as permitted, and in compliance with, applicable law.

We may also share your personal information in connection with managing the proposed sale, restructuring, transfer or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organization.

Where do we keep your personal information and how long do we keep it?

We store personal information about you on computer systems operated by or under the supervision of the Banner Life family of companies, our affiliates, or our service providers. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws and regulations.

We generally retain policy or account related information for at least 7 years after expiration of the policy or the closing of an account, and we retain the underlying documentation for any unclaimed property for the reporting period plus at least 15 years. We retain recordings of calls into our call center for 3 years. Any hard copies we receive are imaged and then are securely shredded after 60 days. Any threats of or actual litigation or regulatory inquiries may extend these periods.

How is my personal information secured?

We maintain physical, electronic and procedural safeguards designed to protect your personal information and prevent unauthorized or accidental use, access or loss. We limit access to personal information about you to those who have a business need for such access. We use reasonable best efforts to require that any person or institution to which we disclose Personal Information will protect the confidentiality of that information and use the information only for the purposes for which we disclose the information to them. We have policies in place that regulate how our employees and contractors handle information about you. We limit access to our premises and to our computer networks, and take steps to safeguard against unauthorized access to such premises and networks.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

What are my rights?

You may have various rights with respect to the information we have about you depending on the particular information and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not be applicable to our relationship with you or certain information we have about you.

We may choose to offer these rights to you in the interest of transparency and as an enhanced service to our customers, even if we are not required to under applicable law.

Privacy Rights under GLBA and the Fair Credit Reporting Act
In general, to the extent we received, obtained, or generated information about you in connection with providing you with a financial service or product within the United States, your rights with respect to that information are generally governed by the Gramm-Leach-Bliley Act (GLBA). We provide GLBA specific privacy notices to our consumers and customers as required by the GLBA. These notices also address your rights, to the extent applicable, under the Fair Credit Reporting Act. For more information about your rights with respect to this information, including the right to opt-out of some sharing of your information with third parties, you can access our GLBA privacy notices through the following links:

Consumer Privacy Rights
Depending on your jurisdiction, to the extent we have collected information about you that is not governed by the GLBA, you may have the rights described below with respect to personal information about you. These rights may also apply to individuals in the European Economic Area, but only to the extent the European Union’s General Data Protection Regulation (GDPR) applies.

Subject to certain conditions and limitations and depending on your jurisdiction, you may have the following rights with respect to personal information about you:

Right to withdraw consent – Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Note this does not affect the lawfulness of processing based on consent before withdrawal. Under the GDPR, we would stop processing your Personal Information unless there is another lawful basis upon which we rely, in which case we would let you know.
Right of access – Depending on your jurisdiction, you may be entitled to:
- Know and request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties, or specific third parties, depending on your jurisdiction, to whom we share such information, as well as the categories of personal information shared.
- Know if we have sold or disclosed your personal information, including the categories of third parties, or specific third parties, to whom we have sold personal information and the categories of the personal information sold.
- Access any inferences derived from your personal information. Know whether we use or sell your personal information for the purpose of training large language models.
Right of data portability – In some instances, you may have the right to receive the information about you in a portable and readily usable format. Data solely retained for data backup purposes is generally excluded.
Right to correct/rectify – You may have the right to challenge the accuracy or completeness of personal data that we process about you, particularly credit related data. If it is found that personal data is inaccurate, you may be entitled to have the inaccurate data removed, corrected, or completed as appropriate. We may not be able to accommodate your request if we believe it would violate any law, any legal requirements, or cause the information to be incorrect. Information solely retained for data backup purposes is generally excluded.
Right to have personal data erased – Subject to certain conditions, you may be entitled to request that we delete personal information about you. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with life insurance or annuity products or where required to be retained for regulatory purposes. Data solely retained for data backup purposes is generally excluded.
Right to lodge a complaint with your attorney general – Without prejudice to any other administrative or judicial remedy you might have, you may have the right to lodge a complaint with your attorney general where you live if you believe that we have infringed applicable privacy or data protection requirements when processing personal information about you.

If you chose to exercise any of these rights, to the extent that they apply, US state law prohibits us from discriminating or retaliating against you on the basis of choosing to exercise your privacy rights.

Submitting Privacy Requests
Requests to exercise your privacy rights as noted above, to the extent applicable, may be made by on our website or by calling us to speak to a customer service representative.

Before providing information you request in accordance with your rights, we must be able to verify your identity. In order to verify your identity, you will need to submit information about yourself, including, to the extent applicable, providing your account login credentials or other account information, answers to security questions, your name, government identification number (which you previously submitted), date of birth, contact information, or other personal identifying information. We will match this information against information we have previously collected about you to verify your identity and your request. To the extent you maintain an account with us, we will require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, please submit a notarized special power of attorney.

Depending on your jurisdiction, we may maintain your rights requests for at least 2 years. This information will not be used for any other purpose except to review compliance processes; it will not be shared except as necessary to comply with a legal obligation.

Children and Minors
We do not knowingly collect personal information directly from individuals under 17 years of age. Our products and services are not intended for individuals under 17 years of age. No one under 17 years of age should submit or post personal information through our online services. We may collect personal information regarding individuals under 17 years of age from their parents or legal guardians, but only as necessary to provide our products and services. For benefit purposes, we may also collect information regarding individuals under 17 years of age from their grandparents, other relatives, or other interested parties.

Changes to this Policy
We reserve the right to change this privacy policy at any time in our sole discretion. If we make changes, we will post the revised policy here, so that you can see what information we gather, how we might use that information, and in what circumstances we may disclose it. When we modify the policy we will also modify the “Effective date” at the top of this policy. If our privacy policy changes in any material respect, we will notify you of such change as required by law.

Banner Life family of companies
This notice is provided by: Meiji Yasuda North America Holdings Incorporated, Banner Life Insurance Company, and William Penn Life Insurance Company of New York.