Appendix A
Privacy Information for California Residents
Last updated September 2025
This Appendix discusses how National Guardian Life Insurance Company (“we,” “us,” or “our”) collects personal information of California residents. This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix does not apply to personal information outside the scope of the CCPA, including without limitation:
• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Personal information collected, processed, sold, or disclosed pursuant to the Gramm-Leach-Bliley Act, and implementing regulations, or the California Financial Information Privacy Act.
• Personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living as set forth in the Fair Credit Reporting Act.
• Personal health information collected, processed, or disclosed pursuant to the Health Insurance Portability and Accountability Act.
1. National Guardian Life Insurance Company as a Service Provider
When we act as a service provider for our customers, we collect personal information on behalf of our customers subject to our contractual obligations. When we act as a service provider, we follow the instructions of our customer on how to process personal information on our customer’s behalf. The provisions of this Appendix do not apply to the personal information that we process on behalf of our business customers.
2. What Personal Information We Collect and How We Share it
The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we share such information. We will share personal information with parties to whom you have directed or authorized us to share with.
NGL does not collect or share personal information for targeted marketing purposes. NGL does not collect or share personal information to infer characteristics about a consumer.
Categories of Personal Information | Categories of Service Providers and Third Parties with whom Personal Information is Shared |
|---|---|
Identifiers. This may include a real name, alias, address, email address, phone number, Social Security number, driver’s license number, online identifier, IP address, account username and password, job title, or other similar identifiers. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; data analytics providers; prospective purchasers of our business; and outside auditors and lawyers. |
Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; and data analytics providers. |
Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; and data analytics providers. |
Other information you submit to us. This may include requests or communications you submit to us, including emails, ratings, or customer service call recording. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; prospective purchasers of our business; and outside auditors and lawyers. |
Research or survey information. This may include survey results, social media data, and other information about your participation in consumer research. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; prospective purchasers of our business; and outside auditors and lawyers. |
Inferences we draw about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in. | Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates and business partners; and data analytics providers. |
We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.
3. How We Use Personal Information
We may use personal information in the following ways:
• To provide you with information, products, or services;
• To improve our services and products;
• To secure and monitor our websites;
• For audit or research purposes;
• To resolve grievances;
• To find or prevent criminal activity, fraud, material misrepresentation or nondisclosure in connection with an insurance issue;
• To respond to requests from law enforcement or other government authorities as required by law; or
• For our own legal obligations and business needs.
4. Sale of Personal Information
CCPA defines a “sale” of personal information broadly to include more than exchanges for monetary purposes. A sale can include personal information shared with a third party for “valuable consideration,” or information shared with a third party (even if they are performing services on our behalf) if they are permitted to use the information for their own purposes.
We do not and have not sold any personal information in the previous 12 months. We do not sell and have no knowledge that We have sold the personal information of consumers under the age of 16.
5. Retention Guidelines
NGL may retain personal information: (a) for as long as is reasonably necessary and proportionate to the purpose for which it was collected, to complete a transaction with you, or for warranty purposes;
(b) used for security purposes, to prevent fraud, or to fix errors; (c) for internal purposes given our relationship with you or compatible with the context in which you provided the information; (e) or otherwise permitted or required by law. The list is not exhaustive.
6. California Residents’ Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.
a. Access to Specific Information and Data Portability Rights (“Right to Know”)
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You could request:
• The categories of personal information we collected about you;
• The categories of sources of the personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information; or
• The specific pieces of personal information we collected about you.
b. Deletion Request Rights (“Right to Deletion”)
You have the right to request that we delete some or all personal information that we have collected from you and retained, subject to some exceptions. Please see Retention Guidelines above.
c. Exercising Your Rights
You have the right to request that we delete some or all personal information that we have collected from you and retained, subject to some exceptions. Please see Retention Guidelines above.
To exercise your rights described above, please submit a verifiable consumer request to us by
either:
• Calling us at 800.988.0826.
• Request a form to be completed by writing to us at:
National Guardian Life Insurance Company
Mailing Address: 123 Town Square Place
PMB 748
Jersey City, NJ 07310
Only you, or a person or entity that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person aboutwhom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
d. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the date we received your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
e. Non-Discrimination
You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
7. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information provided above.