Privacy Statement
We value the privacy of our website visitors. This Privacy Statement describes the information Â鶹´«Ă˝ Holding Ltd. (together with its affiliates “Â鶹´«Ă˝,” “us,” “we,” or “our”) collects from athene.com and any other web properties (collectively “Websites”) hosted by Â鶹´«Ă˝ that link to this Privacy Statement. This Privacy Statement also describes how we use and share this information, and other related matters.
This Privacy Statement does not apply to information collected by any third parties, including through any application or content that may link to or be accessible from or on our Websites.
We want you to understand your privacy rights while on our Websites. If you do not agree with the terms outlined below, do not access the Â鶹´«Ă˝ Websites. By accessing our Websites, you agree to this Privacy Statement.
Information We Collect
We collect information you provide directly through our Websites. We also collect information through automated means. Both mechanisms are described in more detail below.
Information You Provide
The information we collect on or through our Websites may include:
- Contact Information – we ask for certain information from you if you choose to contact us through our Websites. Depending on your reason for contacting us, we request your name, address, email address, phone number, and business type and company affiliation.
- Personal Identifiers – we ask for a Social Security number, date of birth, or other information (“personal information”) that verifies your identity for ordinary business purposes.
- Access Credentials – we ask for a User ID and password when you create an account with either MyÂ鶹´«Ă˝ or Â鶹´«Ă˝ Connect.
- Newsletter – we ask for your email address if you choose to subscribe to our newsletter.
- Job Applications – we ask you to register an account and provide information, such as your name and email address, in order to apply for a job with Â鶹´«Ă˝. Once registered, you can share additional contact information, such as your name and address, and information about your employment and education background. You can also apply for a job by submitting your full LinkedIn profile to us.
Broadly speaking, we use this information to respond to inquiries or to deliver requested information or services. For more information, please see How We Use Your Information.
Information Collected Through Automated Means
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
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Traffic Data – When you visit and use our Websites, certain data may be captured, including: location data, logs, and other communication information that you access.
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Technical Data – When you visit and use our Websites, certain data may be captured, including: the IP address, operating system, duration of visit, pages viewed, and session ID you use to connect to the internet. This technical data is automatically recorded in our web server log files.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies) - A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
- Web Beacons - Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Â鶹´«Ă˝, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain service content and verifying system and server integrity).
We use information collected through automatic means to assess aggregate visitor volume and interest, assess how visitors use our Websites, and to enhance and improve our Websites. Our Websites do not respond to “Do Not Track” signals.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Websites and various content to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To process payments.
- To notify you about changes to our Websites or any products or services we offer or provide through those Websites.
- To maintain security and prevent or detect crime and fraud.
- For any other purpose with your consent.
We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Choices About How We Use and Disclose Your Information.
Parties with Whom We Share Information
We may share your information with: (i) our affiliates; (ii) contractors, service providers, analytics providers and other third parties we use to support our business and Websites; and (iii) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Â鶹´«Ă˝â€™s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
We may also disclose information about you to third parties where we have a legitimate purpose for doing so, including: (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to enforce our rights or agreements, prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
Choices About How We Use and Disclose Your Information
We strive to furnish you with choices regarding the personal information you provide to us. We do not respond to Do-Not-Track signals at this time; however, we have created mechanisms to provide you with the following control over your information:
- Tracking Technologies - You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
Google Services – We use Google Analytics, Google Tag Manager, and Google Dynamic Remarketing to collect and analyze information, such as how many users visit our websites, the pages visited, the duration of those visits, the pages from which visitors arrive and user demographics, and deliver advertising content on our Websites across the internet in a manner that is specifically directed toward the interests expressed by the visitors while on our Websites. For information about how Google Analytics collects and processes data, please . For more information about how Google Tag Manager collects and processes data, please . To opt out of having your information used by Google Analytics, please . To opt out of having Google use of cookies to serve ads based on your past visits to our Websites, please . For more information, please visit .
- Targeted Advertising - We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To opt out of receiving targeted ads (including ads served using non-cookie technologies) from members of the NAI, . To visit the Digital Advertising Alliance’s website and use its Consumer Choice tools, .
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Children’s Privacy
We do not knowingly collect and retain personal information from children under 13. If you believe that your child has provided their information to Â鶹´«Ă˝ without your permission, please contact us at the email address listed below so that we can identify and delete that information.
Data Retention
We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Privacy Statement or at the time of collection; (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements into which we have entered.
Confidentiality & Security
We use commercially reasonable security measures to protect any records containing personal information and limit the number of people who have access to such information. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. 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 Websites.
Your California Privacy Rights
California Consumer Privacy Policy
This Policy applies to individuals residing in California (referenced as “consumer,” “you,” or “your”) subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively referred to as “CCPA”). The purpose of this Policy is to provide consumers a description of your rights and our information practices and supplements any privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of Â鶹´«Ă˝.
Most of the personal information we collect is protected and governed by Gramm-Leach-Bliley Act (“GLBA”) and is therefore exempt from most CCPA obligations. As such, this Policy provides disclosures and information related to the limited personal information we may collect, process, or maintain subject to the CCPA.
Right to Know
California consumers have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information.
The below chart reflects the categories of personal information we have collected from California residents, the categories of sources from which the information was collected, the business or commercial purpose(s) for which the information was collected, and the categories of third parties with whom we disclosed that information.
| Personal Information Category set forth in Cal. Civ. Code § 1798.140 | Source(s) of Personal Information Collection | Business or Commercial Purpose(s) for Collection/Use | Third Parties, Service Providers, and Contractors Receiving Personal Information Category |
|---|---|---|---|
| Personal Identifiers, including 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. | Directly from you; Indirectly from you as you navigate our Websites; Third party source(s); Publicly available information; Recruiters and background check providers (for job applicants). | Provide services to you; Respond to questions; Provide you with information about our services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; Conduct hiring and/or other human resources activities (for job applicants and employees); For research, analysis, and product development; To evaluate or process a commercial transaction; As required by applicable law or government regulation. |
Our affiliates; Service providers; Business partners; Data analytics providers; Background check providers (for job applicants); Human resources providers (for employees). |
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California Customer Records personal information (Cal. Civ. Code § 1798.80(e)), including 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.
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Directly from you; Indirectly from you as you navigate our Websites; Third party source(s), Publicly available information; Recruiter and background check providers (for job applicants). | Provide services to you; Respond to questions; Provide you with information about our services; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; Conduct hiring and/or other human resources activities (for job applicants and employees); For research, analysis, and product development; To evaluate or process a commercial transaction; As required by applicable law or government regulation. |
Our affiliates; Service providers; Business partners; Data analytics providers; Background check providers (for job applicants); Human resources providers (for employees). |
| Characteristics of protected classifications under California law. | Directly from you; Third party source(s); Publicly available information; Recruiter and background check providers (for job applicants). | Provide services to you; Enhance customer experience; Conduct hiring and/or other human resources activities (for job applicants and employees); For research, analysis, and product development; To evaluate or process a commercial transaction; As required by applicable law or government regulation. |
Our affiliates; Service providers; Business partners; Background check providers (for job applicants); Human resources providers (for employees). |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Directly from you; Third party source(s). | Provide services to you; Enhance customer experience; To evaluate or process a commercial transaction; As required by applicable law or government regulation. |
Our affiliates; Service providers; Business partners. |
| Biometric information | We do not collect. | Not applicable. | Not applicable. |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information on interactions with an internet website, application, or advertisement. | Directly from you; Indirectly from you as you navigate our Websites; Third party source(s); Internet service providers. | Provide services to you; Enhance customer experience; Detect security incidents and protect against fraud or illegal activity; Identify and repair errors. |
Technology service providers; Data analytics providers. |
| Geolocation data | Indirectly from you; Devices you use to access our Websites; Data analytics providers. | Detect security incidents and protect against fraud or illegal activity; Identify and repair errors. | Technology service providers; Data analytics providers. |
| Sensory data including audio, electronic, visual, thermal, olfactory, or similar information. | We do not collect. | Not applicable. | Not applicable. |
| Professional or employment-related information | Directly from you; Third party source(s); Publicly available information. | Provide services to you; Enhance customer experience; Conduct hiring and/or other human resources activities (for job applicants and employees); For research, analysis, and product development; To evaluate or process a commercial transaction; As required by applicable law or government. |
Our affiliates; Service providers.
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| Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99). | Directly from you. | Conduct hiring and/or other human resources activities (for job applicants and employees). | Our affiliates; Service providers. |
| Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Directly from you; Third party source(s). | Provide services to you; Enhance customer experience; Conduct hiring and/or other human resources activities (for job applicants and employees); For research, analysis, and product development. |
Our affiliates; Service providers |
| Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140 | Sources from which Information was Collected | Purposes for Collection; Use | Third Parties, Service Providers, and Contractors Receiving Personal Information |
| Social security number, driver’s license number, state identification card, or passport number. | Directly from you; recruiter and background check providers (for job applicants). | Provide services to you; Detect security incidents and protect against fraud or illegal activity; Conduct hiring and/or other human resources activities (for job applicants and employees); To evaluate or process a commercial transaction; As required by applicable law or government regulation. |
Our affiliates; Service providers; Business partners; Background check providers (for job applicants); Human resources providers (for employees). |
| Account access credentials (user names, account numbers, or card numbers combined with required access code, security code or password to access an account). | Directly from you; Accounts you use to access our Websites. | Provide services to you; Detect security incidents and protect against fraud or illegal activity to evaluate or process a commercial transaction. | Not applicable. |
| Precise geolocation (location within a geographical area of a circle with a radius of 1850 feet or less). | We do not collect. | Not applicable. | Not applicable. |
| Racial or ethnic origin | We do not collect. | Not applicable. | Not applicable. |
| Religious or philosophical beliefs | We do not collect. | Not applicable. | Not applicable. |
| Union membership | We do not collect. | Not applicable. | Not applicable. |
| Genetic Data | We do not collect. | We do not collect. | Not applicable. |
| Mail, email, or text messages where the content is not directed to us. | From devices or accounts owned or controlled by us (for employees). | Detect security incidents and protect against fraud or illegal activity (for employees). | We do not share. |
| Unique identifying biometric information | We do not collect. | We do not collect. | Not applicable. |
| Personal information collected and analyzed concerning health. | We do not collect. | We do not collect. | Not applicable. |
| Personal information collected and analyzed concerning sex life, or sexual orientation. | We do not collect. | We do not collect. | Not applicable. |
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also do not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.
Right to Opt Out of Sharing for Cross-Context Behavioral Advertising
In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to affiliates, data analytics providers, service providers, business partners, and social networks:
- Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data.
If you would like to opt out of this sharing of your personal information, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal on your browser. To learn more about the GPC, . You may also contact us as set forth in the “Exercising Your Rights” section below.
Right to Opt Out of Sale
While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include activities such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to affiliates, data analytics providers, service providers, business partners, and social networks in ways that could be considered a “sale” under California law:
- Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data.
We disclosed these categories of information to these third parties in order to market and advertise our products and services; perform analytics; and for research, analysis, and product development.
We have no actual knowledge of selling personal information or sensitive personal information or minors under 16 years of age.
California residents have the right to opt out of the “sale” of their personal or sensitive personal information.
If you would like to opt out of such disclosures, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal on your browser. To learn more about the GPC, . You may also contact us as set forth in the “Exercising Your Rights” section below.
Right to Delete Personal Information
You have the right to request the deletion of your personal information, subject to certain exceptions.
Right to Correct Inaccurate Personal Information
You have the right to request the correction of any inaccurate personal information that we maintain about you.
Right to Access
You have the right to request the categories and specific pieces of personal information we have collected about you.
Right of Non-Retaliation and Non-Discrimination
You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. We do not retaliate or discriminate against you for exercising the privacy rights conferred to you under the CCPA.
Retention of Personal Information
We may retain personal information for the time period reasonably necessary to fulfill the purposes described in this Policy, or any other notice, unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.
Exercising Your Rights
To exercise your rights, you may submit a request online through our website or contact us at 888-266-8489. Requesters will need to provide us with personal information in order to verify their identity and residency, including name, address, and date of birth as well as answer a series of unique identity proofing questions. We use a third-party service to verify your identity and will compare the information you provide with our internal records. The personal information that we use to verify identity and residency will not be used for any other purpose.
You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. We may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.
Contact Information
For information about this Privacy Statement or our privacy practices, or if you would like to request that this notice be provided in an alternative format in order to accommodate a disability, please contact us at: legal-privacy@athene.com.