Online Privacy Statement
Effective Date: Oct. 1, 2020
This Online Privacy Statement (“Privacy Statement”) applies to this website or mobile application and the websites or mobile applications of American Financial Alliance Corporation (“AFA,” “we,” “us,” or “our”) that link to this Privacy Statement (each a “Site” and collectively, the “Sites”). We value your trust in us, especially when you share your personal information with us. We understand that the privacy and security of that personal information is important to you (collectively we call this information “data”). This Privacy Statement describes how Sites may collect, use, and share your data. By accessing our Site, you consent to this Privacy Statement and our
Terms of Use , including our collection, use, and sharing of your data and information, as described below. If you do not agree to the Terms of Use or our Privacy Policy, please exit our Site. If you have any questions regarding our policies or your use of our Site, please contact us at contact@MyAFA.com
Depending on how you interact with us, and which of our entities provide the products and services you chose (collectively “Product(s)”), your Product documentation and additional AFA and AFA entity privacy practices and disclosures may also be applicable.
What Data We Collect About You and How
Data We Collect Online
Data You Provide
We collect data that you provide to us at the Sites, through applications, online forms and calculators, and other communications. For example, we collect your data at the Sites when you:
• purchase or request a quote for a Product;
• register for, manage or update a Product;
• use our e-Billing services or manage your online account and investment options through the Site;
• use Site tools and resources that request your, your family’s or your beneficiary’s data;
• access other applications and services from this Site;
• make data available to us via social networking logins, such as Facebook or Twitter;
• participate in chats, web forums or other interactive sessions;
• subscribe to newsletters or provide feedback;
• conduct searches through the Site;
• share data about yourself with the Site, or authorize a third party to share such data about you with us; and/or
• request additional information.
This data may include, but is not limited to: name, address, telephone number, email address, date of birth, Product numbers, your profession, employment information, your IP address activity tracking from assistive technologies, geolocation data (to the extent provided by you or your device), data and/or information from mobile or wearable devices, or other similar technologies, and, where reasonably required to complete the request or transaction: health information, banking information, credit card number, Social Security number, driver’s license numbers and other data.
Data regarding your use of this Site may be collected and/or aggregated using automated means and Data Technologies as defined below. This data may include:
• your IP address, and the type of browser and operating system you use;
• date and time you access the Site and the pages you visit, and, if you link from or to another website, the address of that website;
• E-mail you open and links you click on within those E-mails;
• the duration of your use and the features and content you access; and/or
• data regarding your ISP or mobile carrier, and the type of handheld or mobile device that you use.
Data Technologies
Various technologies may be used to automatically collect information on the Site, such as cookies, web beacons and local shared objects. “Cookies” are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, connects web pages to web servers and their cookies. “Local shared objects,” sometimes known as Flash cookies, may be used to personalize your visit by storing your preferences or displaying content based upon what you have viewed on various websites. Anonymous advertising identifiers may be used on mobile devices and otherwise in a manner like cookies. We refer to these types of technologies generally as “Data Technologies,” which include today’s technologies and similar types of technologies as they evolve over time.
One or more Data Technologies may be used by us on this Site and other websites and mobile applications (including websites not operated by us). Third parties, who may have their own privacy policies, may also use Data Technologies to collect information on this or other websites.
When you download or use apps or mobile-optimized websites to access our Site or online services, we may receive information about your location and your mobile device, including a unique identifier for your device, device settings, analytical information about how you use your mobile device, and other information that may be stored on or accessed through your mobile device, including from apps not operated by us or from other devices connected to your mobile device. This information helps us provide you with location-based services, advertising, search results, and other personalized content. Most mobile devices allow you to turn off location services by accessing the device’s settings menu.
Publicly Posted Data
Data that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality is data that we or others may share or use in accordance with the law.
Data from Other Sources
We may also collect data about you from third-party sources, including from commercially available sources, such as credit reporting agencies, data brokers or other companies that collect or analyze information about consumers or users. Examples of data we receive from third-party sources include, but are not limited to: (1) credit history information from credit bureaus, which we use to help prevent and detect fraud and to offer certain credit or financial services to some customers; (2) demographic data from data brokers and other sources to help anticipate consumer trends and needs; (3) data provided from sources that you have authorized to share such data with us, either on our Site or via the third party applications, devices, websites, or other digital interfaces; and/or (4) other similar types of data.
We may combine the data we collect from you and information from other sources.
How We May Use the Data We Collect
We may use data we collect for a variety of purposes, including, but not limited to, the following:
• for our everyday business purposes, such as establishing and administering your Product, providing information you request and providing customer support;
• to evaluate your eligibility for Products;
• to provide you with up to date information regarding the Site, your Products, including changes to terms and conditions and/or other administrative information;
• to price and develop new and existing Products or technology and analyze the effectiveness of Products, marketing trends, applications and websites to maintain the quality or safety of Products or technology which we may own, control, or provide;
• to conduct internal research;
• to develop and demonstrate technology;
• to deliver content and marketing communications that we think may interest you, including, ads or offers tailored to you based upon your browsing and usage history, both within this Site and on other websites and applications;
• to provide retirement calculators, assessments, and other financial planning tools on the Sites;
• to comply with the law, regulations and other legal obligations;
• to properly verify your identity, prevent fraud and/or enhance security;
• to audit and provide reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
• to allow you to utilize features within our Sites when you grant us access to information from your device (e.g., contact lists, geolocation, etc.);
• to provide you with location-based services, advertising, search results, and other personalized content;
• to contact you via telephone, text or chat;
• for short-term, transient use including contextual customization of ads; and/or
• for other purposes permitted by law or to which you consent.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any specific individual) for various business purposes, where permissible under applicable laws and regulations.
Social Media
We may include applications or widgets from social media providers on our Sites that allow you to interact or share data and/or information or content with them. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between this Site and social media networks such as Facebook, Twitter and others may allow the social media networks to collect data and/or information about your browsing on the pages of our Sites where the widgets are visible, even when you do not click on or otherwise activate the widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and the choices that they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all data and/or information transmitted to that network. For clarification purposes, the preceding sentence does not apply to social media icons. Social media icons, which are graphical interfaces that allow you to link directly to our social media pages,
do not collect your browsing activities (or any activities).
AFA participates in several social media platforms such as Facebook, Twitter, and LinkedIn, which allow their users to create, share and exchange content and information. Any data and/or information that you post on a social media platform is also subject to the privacy policies of that social media network. These platforms may share your data and/or information with us in identifiable or aggregated form. Your use of any AFA social media sites is also subject to the AFA Social Media Participation Guidelines.
Advertising Networks and Analytics
We may partner with advertising networks that deliver targeted advertisements to consumers, including advertisements with links to AFA websites, and generate related statistics and metrics. These ad networks may utilize data and/or information collected through a variety of Data Technologies to provide advertising placement, customization, auditing, research and reporting for us and other advertisers. This data and/or information collection takes place over time, both on this Site and on third-party websites and mobile applications and includes data and/or information such as number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites or apps, and responses to advertisements and promotions on the Sites and on sites and apps where we advertise. In some cases, we have access to the data and/or information gathered by the Data Technologies used by the ad networks on our Sites. This process allows us and third parties to deliver targeted advertising (online and offline), enhance marketing programs and help track the effectiveness of such efforts. Advertising networks, which may have their own privacy policies, determine how they use this data and/or information, including for purposes such as determining or predicting the characteristics and preferences of their advertising audiences and measuring the effectiveness of their advertising. As of the effective date set forth above, we do not respond to Do Not Track signals or other similar mechanisms.
We reserve the right to use third-party analytics services such as Google Analytics. These services may track details about your online activities over time and across different sites. These services help us to improve our Site and the products and services that we offer you. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities. If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance.
Data We Share
We may share your data with third parties and among AFA entities as permitted or required by law, or when you authorize us to do so. For example, we may share your data:
• with our corporate entities, for example, for their everyday business purposes, to provide services or to perform marketing;
• to the extent you apply for a Product online, to all of the entities you have authorized us to share data with or request data from in the application (e.g., your employer or plan sponsor, reinsurers, health care professionals, credit agencies, your representatives, etc.);
• with service providers who we engage to provide services offered through this Site or on our behalf, including providers who help us operate our business and fulfill orders;
• with marketing partners, including analytics companies and advertising networks who provide Data Technologies on our website; and/or
• with insurance regulators, law enforcement, governmental authorities, auditors, and other third parties in order to comply with our obligations or to protect our interests, property, or legal rights, or those of our customers or members of the public.
Please note that Products offered by certain AFA entities may be subject to additional privacy notices. Please contact us at the number listed on your Product statement if you have a unique privacy notice for your Product, and would like a copy of the applicable privacy notice. We will limit sharing of your data to the extent required and in accordance with these additional notices. We also reserve the right to share the information that we collect with our subsidiaries and affiliates and with any subsequent owner in the event of a merger, consolidation, sale of our assets, or other change in our business, including during the course of any due diligence process.
Your Choices
You are entitled to make certain choices about how we communicate with you.
• You may choose not to provide your data, even though that might impact your ability to register or receive a particular Product;
• If you do not want to receive marketing e-mail from us, you can follow the unsubscribe link provided in those e-mails;
• You have a few choices regarding certain Data Technologies. Most web browsers automatically accept cookies, but you can usually modify your browser’s setting to notify you of cookie placement or decline cookies if you prefer. You may also render some web beacons unusable by rejecting their associated cookies and disabling or deleting similar data and/or information used by browser add-ons, such as Flash cookies, or by changing the add-on's settings or opting out at the website of the technology provider. If you choose to decline cookies or other Data Technologies, however, please note that certain features of our Sites may not function properly or at all as a result;
• You may be able to adjust the use of advertising identifiers on mobile devices through the settings on your device. For online behavioral advertising opt outs from our Sites and on other sites to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Site or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt-out again;
• If you do not want us to use data revealing your location, you may be able to configure your browser settings, or change the location services setting on your mobile device, to prevent the sharing of that data. Please note that certain features may not function properly or at all as a result if you opt out. Also note that for browser-based location services opt outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Site or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt-out again; and/or
• If you have a Product with us, we will use and share any data that we collect from or about you in accordance with the consumer privacy notice applicable to that Product.
You may have additional rights under applicable laws. For more information, please see the Contact Information section below.
Linking to Third Party Sites
We may provide links to websites that are owned or operated by other companies. When you use a link to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should review the privacy policy, terms of use and security practices of the linked third-party website to understand how that site may use your data and/or information. AFA is not responsible for the privacy or security of these third-party sites, or the accuracy, completeness, or reliability of the information they provide.
Children’s Privacy Rights
Our sites and applications are intended for general audiences, and we do not knowingly seek or collect personal information from children under the age of majority in your jurisdiction. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected personal information from a child under age thirteen (13) without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any personal information from or about a child, please contact us at 1-833-718-1232.
Accessing Your Data
Access to data that we collect and maintain about you may be available to you. For example, if you created an online account, you could access that account to update the data you previously provided. Additionally, if you believe that data we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the data by contacting us as indicated in the Contact Information section below.
Protecting Your Data
We use commercially reasonable administrative, technical, and physical security measures designed to safeguard your data that is in our possession against loss, theft and unauthorized use, disclosure or modification. We process payments ourselves and also utilize a PCI-certified service provider to process credit card payments. We also expect our service providers to protect information in the same manner. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems we operate or that are operated on our behalf.
Connecticut and other states laws require any person or entity that collects Social Security numbers from their residents in the course of business to create a privacy protection policy and to publish or display it publicly.
It is the policy of AFA to protect the confidentiality of Social Security numbers in its possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to individuals and services at AFA that need access to such information for the purpose for which it was originally provided.
Users Outside of the United States
Our Website is operated in the United States and intended for users located in the United States. The privacy and data protection laws in the United States differ from those of other countries. If you are located outside of the United States, please be aware that the information that we collect will be transferred to and processed, stored, and used in the United States, and that by using our Website, you consent to such transfers and processing.
Disputes
Your visit and any dispute regarding privacy is subject to this Privacy Statement and the dispute resolution provisions of our Terms of Use.
Updates to this Privacy Statement
We reserve the right to make changes to this policy. Any changes to this policy will be posted. Material changes to this Privacy Statement will be effective once they are posted.
Contact Information
If you have any questions or comments about this Privacy Statement, or if you would like us to update data we have about you or your preferences, please contact us by e-mail at
contact@MyAFA.com or call our toll free number 1-833-718 1232
Effective Date: October 1, 2020