GREAT AMERICAN INSURANCE GROUP PRIVACY POLICY

Last Updated: May 7, 2019

Great American Insurance Group (“Great American”) respects your privacy, and we strive to be transparent in how we collect and use your information. This Privacy Policy describes how Great American collects, uses, discloses, and protects your personal information.

  1. SCOPE

This Privacy Policy applies to all personal information Great American receives or collects from you and from other sources about you during the course of our business operations and insurance relationships, including personal information we receive or collect when you visit our website (www.gaig.com) or use our mobile applications (GAIG Annuity, GAIG Trucking, GAIG Equine Mortality, GreatAg Mobile, ELDQuoter, Adjuster Mobile, and Grower Mobile).

For purposes of this Privacy Policy, “Great American”, “we”, and “us” means (a) the Great American life insurance companies and operations, and (b) the Great American property and casualty insurance companies and operations, other than those identified in Section 11: Exclusions below.

  1. PERSONAL INFORMATION COLLECTED BY GREAT AMERICAN

Great American offers and administers a variety of annuity, life, and property and casualty insurance products and services. Depending on our relationship with you – policyholder, insured, claimant, annuity owner, certificate owner, beneficiary, producer (including brokers, agents, and advisors), business partner, vendor, or other person or entity – Great American may collect or receive the following information that may contain personal information:

  • Identity Information: First name; middle name or initial; last name; gender; genetic characteristics; date of birth; marital status; age; mother’s maiden name; identification number, such as social security or tax identification number; geolocation data; permanent residence; professional licenses and affiliations; contract or policy number; relationship to policyholder, insured, owner, annuitant, or claimant; date and cause of death, injury, or disability; identification of insured property (such as addresses or vehicle license plate numbers); and other similar information. In cases involving a trust, the date of the trust instrument, the state law that governs the trust, the identity of each grantor, the identity of each current trustee, whether the trust is revocable, whether conflicts of interest are present, and information related to the tax status of the trust.
  • Contact Information: Business and/or personal addresses, email addresses, telephone numbers, fax numbers, and other contact details.
  • Financial and Business Information: Financial statements; assets; liabilities; tax filings and other tax information; business operations information; payroll information; credit history; credit score; educational information; employment details; vehicle driving records; prior accident or loss history; status as a director, partner, or other ownership or management position; insurance coverage information; and any other business or financial information required to underwrite or support a claim under a property and casualty insurance policy or support the suitability determination of an annuity purchase.
  • Payment Information: Bank account information, credit or debit card information, wire transfer instructions, and other information necessary for Great American to make or receive payments.
  • Health Information: Medical history; past, current, and future physical, mental, or medical condition or treatment; medical procedures performed; health status, injury, or disability information; personal habits (for example, smoking or consumption of alcohol); prescription information; payment for medical treatment; and other similar health information.
  • Regulatory Information: Any personal information needed for Great American to comply with its obligations under applicable laws and regulations, including, without limitation, anti-money laundering, anti-bribery, insurance fraud, economic and trade sanctions, and other regulatory schemes. In the event Great American intends to obtain a consumer credit report about a U.S. individual, Great American will provide separate notice to the individual and, if required under the Fair Credit Reporting Act, obtain the individual’s consent prior to obtaining the consumer report. Similarly, Great American will obtain consent from any Canadian resident prior to obtaining a consumer credit report in accordance with applicable law in the province or territory in which the individual resides.
  • Website Usage Information: Great American’s website uses cookies and other automatic data collection technologies to collect certain information about visitors to our website, including IP address; details about your browser, operating system and device/hardware; general location (if available); webpages visited; and other logging information such as the date, time, and duration of your use of the website. Please refer to our Cookie Policy for additional information about Great American’s use of cookies and other automatic data collection technologies.
  1. HOW GREAT AMERICAN COLLECTS YOUR INFORMATION

Great American collects and receives the personal information described in Section 2: Personal Information Collected by Great American above from a variety of sources. We may receive personal information directly from you, through our website, software, and mobile applications, as well as from third parties such as producers, appraisers, adjustors, claims handlers, other insurance companies, reinsurers, vendors, service providers, consumer reporting agencies, account verification services, and other publicly-available sources of information.

  1. HOW GREAT AMERICAN USES YOUR PERSONAL INFORMATION

Great American uses the personal information collected above for the following purposes:

  • Underwriting and Policy Issuance, Maintenance, and Renewal: In order to underwrite and issue, maintain, and renew annuity contracts and insurance policies, bonds, or warranty products, obtain reinsurance, and communicate important information to you throughout this process, Great American may collect, use and share (“process”) identity, contact, financial and business, health, and regulatory information about policyholders, insureds, producers, loss payees, enrollees, annuity owners, certificate owners, annuitants, participants, beneficiaries, trustees, legal representatives, reinsurers, underwriters, appraisers, actuaries, and other related persons or entities. We process this information to enter into and perform our contractual obligations to you and for our legitimate business purposes.
  • Claims Review and Approval: In order to process claims under an annuity contract, life insurance policy, or a property and casualty insurance policy, bond, or warranty contract and to communicate with you throughout this process, Great American may process identity, contact, financial and business, health, and regulatory information about claimants, policyholders, insureds, annuity owners, certificate owners, annuitants, beneficiaries, trustees, legal representatives, witnesses, loss payees, claims administrators, adjusters, agents, advisors, brokers, and other third parties. We process this information to perform our contractual obligations to you and for our legitimate business purposes.
  • Payment: In order to collect premium payments, collect purchase payments, collect reinsurance proceeds, purchase reinsurance, make annuity payments, process annuity withdrawals and loans, pay annuity death claims, pay insurance claims, pay third-party service providers and other payees, and make other business-related payments, Great American may process identity, contact, financial and business, payment, and regulatory information about policyholders, insureds, reinsurers, annuity owners, certificate owners, annuitants, beneficiaries, trustees, claimants, loss payees, appraisers, adjustors, third party administrators, professional advisors, service providers, vendors, and other payees. We process this information to perform our contractual obligations to you and for our legitimate business purposes.
  • Internal Operations: Great American may process identity, contact, financial and business, payment, health, regulatory, and website usage information for purposes of Great American’s internal business operations, including but not limited to marketing; servicing your account; improving our products and services; data security; financial, claim or other audits; quality assurance measures; resolving complaints; identifying and preventing fraud; managing commercial risk; complying with legal, regulatory, and contractual obligations; business continuity and disaster recovery; complying with internal policies and procedures; establishing and defending Great American’s legal rights; communicating important information regarding our policies, terms and conditions, and other administrative information; communicating with agents, advisors, brokers, policyholders, contract owners, certificate owners and beneficiaries; responding to requests for information; website personalization and optimization; as well as actuarial studies, analytics, and statistical modeling. We process this information to perform our contractual obligations to you, for our legitimate business purposes to provide and customize our products and services to you and to secure your information, and to comply with legal obligations and exercise any legal rights we may have.
  1. HOW GREAT AMERICAN SHARES YOUR PERSONAL INFORMATION

Great American may disclose your personal information to the following entities, as allowed by and in accordance with applicable law, for the purposes set forth in Section 4: How Great American Uses Your Information above:

  • Parents, Subsidiaries, and Affiliates: In connection with our business operations, to provide products and services, and to comply with applicable laws and regulations, Great American entities may share information with their parent companies, subsidiaries, and affiliates.
  • Professional Advisors: In order to comply with applicable laws and regulations, to obtain professional advice and services, and in connection with our business operations, Great American may disclose personal information to accountants, auditors, lawyers, bankers, insurers, and other professional advisors to Great American.
  • Insurance-Related Business Partners and Third Parties: In connection with our business operations and to provide products and services, Great American may share information with underwriters, actuaries, appraisers, brokers, agents, advisors, and loss adjusters; claims administrators; insurance support organizations; reinsurance providers; other insurance companies; financial institutions, such as banks; payment processors; securities firms; credit bureaus; consumer reporting agencies; and other third parties.
  • Other Vendors and Service Providers: In order to provide products and services and to support our business operations, Great American may share information with vendors and third party service providers such as IT vendors, developers, software providers, and website hosting providers; records management and data storage providers; data analytics companies; printing, advertising, marketing and market research companies; translators; and other third parties.
  • Legal and Regulatory: For the purpose of meeting our legal and regulatory obligations, or otherwise as allowed or required by law, Great American may share personal information with third parties such as federal, state, and local regulatory authorities, tax authorities, law enforcement, public, administrative, or judicial bodies, or other persons or entities in response to a legal process (such as a subpoena).
  • Authorized Representatives and Successors in Interest: Great American may share personal information with your agent, representative, attorney-in-fact, guardian, or conservator. If an interest in the annuity contract, life insurance policy, or property and casualty insurance policy is transferred, assigned, or otherwise passes to a new owner, assignee, or other successor, Great American may share personal information with that successor to the extent needed to confirm the successor’s interest. After your death, Great American may share personal information with your executor, administrator, or personal representative, your beneficiary, or other legally authorized successor to your interest in the annuity contract, life insurance policy, or property and casualty insurance policy.
  • Corporate Transaction: Great American may disclose your personal information to a third party in connection with a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Great American business, assets, or stock (including in connection with any insolvency event or similar proceedings).
  • Marketing: Great American may disclose your personal information to an affiliate or a third party marketing service provider in connection with the marketing efforts of Great American or its affiliates, which may include joint marketing arrangements with third parties. You may opt out of marketing emails at any time by following the instructions in our marketing communications or by contacting us using the information provided in Section 12: Questions and Contact Information below.
  1. CONSENT

There may be situations where Great American is required by law to obtain your consent in order to process or share your personal information. If you are asked to give your consent and have provided your consent, you may withdraw it at any time by contacting us using the information provided in Section 12: Questions and Contact Information below. Please note, however, that withdrawing your consent could impact our ability to provide you with the requested products and services.

  1. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

Great American strives to ensure the information we have is accurate and up-to-date. Please notify us if you believe an error has been made in the accuracy of the information Great American has about you, and we will correct it upon confirmation of the error and receipt of the correct information.

In addition, you may have additional rights with respect to your personal information, depending on the laws of your jurisdiction. For example, European Union data subjects may have a right of access, rectification, erasure, and/or portability of their personal information, as well as the right to object to certain processing activities by Great American. Singapore residents may have the right to access the personal data about that individual that is in the possession or control of GAIG, as well as the ways in which such personal data has been or may have been used or disclosed by Great American in the preceding 12 months.

If you wish to exercise one or more of your rights with respect to your personal information, please contact Great American using the information provided in Section 12: Questions and Contact Information below. Please understand that in order to protect your privacy and security, we will need to take reasonable steps to verify your identity before we can respond or comply with any request relating to your personal information. Great American will respond to your request as soon as practicable, but in any event within the legally required time.

  1. DATA RETENTION AND INFORMATION SECURITY

Great American retains your personal information for as long as reasonable or necessary to fulfill the purposes for which the data was collected, meet its business requirements, and comply with applicable laws and regulations.

Great American is committed to protecting your personal information and has implemented physical, procedural, organizational, and technical safeguards, consistent with applicable law, intended to prevent loss, misuse, unauthorized access, disclosure, or modification of personal information under our control. If you have reason to believe that any of your personal information is no longer secure, please notify us using the information provided in Section 12: Questions and Contact Information below.

  1. INTERNATIONAL OPERATIONS AND DATA TRANSFERS

In connection with the purposes described above, Great American may transfer personal information to persons and organizations that are located in other countries. Where permitted by applicable law, by providing your personal information to Great American, you understand and consent to the collection, use, processing, disclosure, and transfer of such information in the United States of America (“United States” or “U.S.”) and other countries or territories, which may not offer the same level of data protection as the country where you reside, in accordance with applicable law and the terms of this Privacy Policy. Further, please note that information collected through the use of this website and any communication you send to a gaig.com email address will be routed through the United States.

  1. OTHER GREAT AMERICAN NOTICES OF PRIVACY AND INFORMATION PRACTICES

The federal Gramm-Leach-Bliley Act and U.S. state privacy laws require Great American to provide the following notices of privacy and insurance information practices to its U.S. consumers:

  1. EXCLUSIONS FROM THIS PRIVACY POLICY

Great American Affiliates

Great American conducts business in the United States and internationally through subsidiaries, affiliates, and international divisions (“Affiliates”), which may have their own privacy policies. If you visit the website of, have a relationship with, or otherwise provide personal information to any Great American Affiliate listed below, please review that Affiliate’s privacy policy for information about how that Affiliate collects, uses, and discloses your personal information.

U.S. Affiliates:

Mexican Affiliates:

European Affiliates:

Other Exclusions

This Privacy Policy does not apply to information Great American receives and maintains about its job applicants, employees, directors, or independent contractors.

Great American’s website is intended for individuals who are over the age of eighteen (18). We do not knowingly collect personal information through our website from children under the age of eighteen (18) and ask that they do not provide us with personal information through the website.

Although our website may contain links to third party websites, this Privacy Policy does not apply to those third party websites. You should review the privacy policies associated with those third party websites to understand their privacy practices.

  1. QUESTIONS AND CONTACT INFORMATION

If you have any questions about the Privacy Policy or wish to exercise any legal rights with respect to your personal information, you may reach us by clicking the “Contact Us” button at the top of our website, or by mail, email, or phone at the following address:

U.S. Operations

Great American Insurance – Property and Casualty Group
301 E. Fourth Street
Cincinnati, Ohio 45202-4201
(800) 545-4269
clegal@gaig.com
Attention: General Counsel

Great American Insurance – Annuity Group
301 E. Fourth Street
Cincinnati, Ohio 45202-4201
(800) 854-3649 (select 3)
Attention: Privacy Officer

Canadian branch

Great American Insurance Company, Chief Agency
Scotia Plaza, 40 King Street West, Suite 2100
Toronto, Ontario Canada M5H3C2
Attention: Chief Agent

Singapore branch

Ian Lee
Director, Risk Management & Compliance
Ian.lee@sg.gaig.com
Telephone: +65 6804 6039
Fax: +65 6235 0302

  1. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be changed from time to time. We will post any changes we make to the Privacy Policy on our website. The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised. We encourage you to check this page periodically and to review any updates, and we will obtain your consent to any changes where required by applicable law.