Privacy Policy

Consumer Privacy Notice
Learn about our practices regarding the collection, use, disclosure, and protection of personal information we hold about current and former customers. (Exhibit 1)

Revised April 2, 2026

CONSUMER PRIVACY NOTICE

FACTS

WHAT DOES AXONIC INSURANCE DO WITH YOUR PERSONAL INFORMATION?

WHY?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

WHAT?

The types of personal information that we collect and share depend on the product or service you have with us. This information can include:

Personal data, such as name, social security number, email address, physical address, and date of birth

Demographic data, such as age, disability status, citizenship, and gender

Professional or employment data, such as income, and employment history

Financial data, such as banking information, assets/debts, credit card information, and investment preferences

Health data, such as medical history, medical questionnaires, treatments, health-related information, and habits

Biometric Information, such as voice signatures

Interaction data when you visit our websites or speak with our customer service team, such as IP address and location

Audiovisual information, such as video and call recordings.

When you are no longer our customer, we continue to share your information as described in this notice.

HOW?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Axonic Insurance chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information

Does Axonic Insurance share?

Can you limit this sharing?

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes – to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes – information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes – information about your creditworthiness

No

We don’t share

For our affiliates to market to you

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

 

TO LIMIT OUR SHARING

Call toll-free [INSERT NUMBER]

 

Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us during business hours at the toll-free number above to limit our sharing.

 

QUESTIONS?

If you have any questions about this notice, please contact us at:

 

Axonic Insurance Services

Privacy Department

520 Madison Avenue, 24th Floor

New York, New York 10022

 

[INSERT PHONE NUMBER] or email us at privacy@axonicinsurance.com

 

WHO WE ARE

Who is providing this notice?

Axonic Insurance, as referred to in this notice, means Axonic Insurance Services LLC and its affiliates and subsidiaries, including Axonic Annuity & Life Insurance Company

WHAT WE DO

How does Axonic Insurance protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secure files and buildings.

 

We regularly review our security standards, procedures, and technology to protect against unauthorized access to your personal information.

How does Axonic Insurance collect my personal information?

We collect your personal information, for example, when you:

 

Apply directly for a product or submit a claim,

Make deposits or withdrawals from your account, pay your premiums, or apply for a loan,

Interact with our information technology resources in the course of providing services or products to you.

 

We also collect your personal information from other companies, such as your insurance producer, broker, financial advisor and their respective firms, your employer or plan sponsor, consumer reporting agencies, government agencies, healthcare providers, data science providers, business partners, service providers and insurance support agencies such as MIB, Inc.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

 

Sharing for affiliates’ everyday business purposes information about your creditworthiness.

Affiliates from using your information to market to you.

Sharing for nonaffiliates to market to you.

Axonic Insurance does not engage in the above sharing practices.

 

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account – unless you tell us otherwise.

 

DEFINITIONS

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies. Axonic Insurance does not share with nonaffiliates so they can market to you.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Axonic Insurance does not jointly market.

 

OTHER IMPORTANT INFORMATION

If necessary, we disclose information when it is required by law. We may also disclose certain information to other entities to help us detect, prevent or report fraud or other crimes, including reports to regulatory or law enforcement agencies.

 

Axonic Insurance reserves the right to modify this notice. If there are material changes to this notice or in how we will use your personal information, we will use reasonable efforts to notify you either by providing a notice on Axonic Insurance’s website <<INSERT URL>> and/or, if deemed appropriate, by mail, email or similar direct communication. We encourage you to periodically review this notice.

 

For Vermont Residents Only: We will automatically limit sharing of your information.

For Nevada Residents Only: We are providing this notice pursuant to Nevada state law. If you prefer not to receive marketing calls from us, you may be placed on our internal do-not-call list by calling [TOLL FREE NUMBER]. For more information, you may contact our customer service department or the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; 702-486-3132; aginfo@ag.nv.gov.

For California Residents Only: We will not share your information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your policy. In addition, the California Consumer Privacy Act (CCPA) gives California residents certain privacy rights with respect to the limited non-public personal information we collect. These rights are:

    • The right to notice of the personal information we collect;
    • The right to know the categories, sources and specific pieces of personal information we have collected about you in the past 12 months, including our purpose for collecting the information and the categories of third parties with whom we share that personal information, subject to certain exceptions;
    • The right to delete some or all of the personal information we collect, subject to certain exceptions; and
    • The right to opt-out of our sale of your personal information, if we sell your personal information

CCPA rights are limited and do not apply to any of the non-public personal information that we have collected from you and about you in connection with providing you an insurance or financial product or service. We may share this information with our service providers for a business purpose. We do not sell personal information about current or former customers to any third parties. To exercise your rights under the CCPA please use our online form or email us at privacy@axonicinsurance.com.

 

Notice of Insurance Information Practices for Residents of Arizona, California, Connecticut, Georgia, Illinois, Maine, Massachusetts, Minnesota, Montana, Nevada, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oregon, Virginia and Wisconsin

We may collect personal information about you from persons other than you. In addition to information that you provide us on applications or in connection with insurance coverage we issue to you, we may collect personal information about you, such as your name, address, age, medical history, insurance history, driving records and other personal characteristics, from medical professionals, health facilities, employers, business associates, neighbors, other insurance companies, insurance support organizations (ISO) and consumer or other reporting agencies. Information obtained from a report prepared by an ISO may be retained by the ISO and disclosed to other persons. We may also disclose personal information about you, without your permission, to third parties that perform professional or insurance functions for us, other insurance companies to which you may have applied, insurance regulatory authorities, law enforcement, or other governmental authorities to the extent permitted or required by law.

 

You have the right to request a copy of the personal information that we have about you. If we receive such a request, we will provide you a copy of your requested personal information within 30 business days, as long as the information is reasonably locatable and retrievable. We may charge a reasonable fee to cover the costs incurred to provide you with copies of requested personal information.

 

You have the right to correct, amend or delete personal information we may have recorded about you. We will respond to your written request to correct, amend or delete personal information about you, within our possession, within 30 business days from the date your request is received.

 

If you wish to exercise your rights as provided in this notice, please contact us at privacy@axonicinsurance.com.

 

Online Privacy Policy
Learn about our practices regarding the collection, use, disclosure, and protection of personal information about individuals who visit our websites. (Exhibit 2)

Axonic Insurance Online Privacy Policy

Last Updated April 2, 2026

This Privacy Policy (“Policy”) applies to the operations of Axonic Insurance (“AXI”, “we,” “our,” or “us”) and describes our practices regarding information that we may receive from our individual customers and potential customers of our products (“Customers”) and from general visitors to the axonicinsurance.com website (“Website Visitors”). By using our website, completing an application form, or otherwise providing any information to AXI, you are consenting to the collection, use, and disclosure of your information in accordance with this Policy and, as applicable, the Consumer Privacy Notice available above (as further described below). For purposes of this Policy, personal information does not include de-identified or aggregated information that does not identify you.

Personal Information Collected from Customers

AXI offers various insurance products, and we collect personal information from Customers when they apply for and/or purchase products from us and in connection with other insurance-related transactions (collectively, “Insurance Personal Information”). Because all Insurance Personal Information is subject to the Gramm-Leach-Bliley Act, this Policy does not apply to any Insurance Personal Information collected on the website (e.g., information collected as part of an application form); rather, Insurance Personal Information is subject to our Consumer Privacy Notice.

Personal Information Collected from Website Visitors

We may collect certain personal information from our Website Visitors when they visit or browse the axonicinsurance.com website (such information, the “Website Information”), as described below. It is important to note that the types of personal information we collect will depend on each Website Visitor’s interaction with us.

What Information We Collect

We collect your contact information. For example, we may collect your name, telephone number, street or email address, and other personal identification information when you interact with the website, fill out a form to request information or submit information in connection with a career opportunity at AXI.

We collect device information and website usage information. When you visit the website, our servers may automatically collect information about your visit and your device. The information may include the date/time of your visit, your IP address, the webpages that you visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), or service(s) you arrived from, and other clickstream data.

We collect other information. If you choose to access, visit, or use any third-party service(s) that may be integrated with or linked to AXI’s website (such as for payment processing, identification verification, or electronic signatures), we may receive personal information and other information about you and your computer, mobile, or other device that you have made available to those services, including information about your interactions with those services. Your decision to use third-party service(s) in connection with AXI is voluntary.

How We Collect Your Information

We collect information directly from you. You may provide information directly to AXI if you contact us through our website.

We collect information from you passively. We use tracking tools like cookies and web beacons to collect information from you passively. We do this on our website. We collect information about users over time when you use this website. This includes usage and browser information. Local device storage may also collect and store your personal identifiable information.

We collect information about you from third parties. We may receive information about you from third-party sites or services. We may also collect information from users of third-party sites who give us access to their profiles.

How We Use Your Information

We use information to contact you and respond to you. We may use your information to respond to your questions and requests. We may also use your information to provide you with the information you have requested. We may use your information to communicate with you, including about our new features, products, or services.

We use information to improve our website and products. We may use your information to improve our website and our products. We may use your information to help diagnose problems with our servers and to administer the website.

We use information for research and tracking purposes. We may use your information to gather broad demographic information, analyze trends, and track your movements around the website.

We use information for security purposes. We may use your information to detect security incidents; protect against malicious, deceptive, or illegal activity; and prosecute those responsible for that activity. We may also use your information to identify and repair errors that impair existing intended functionality.

We use information to comply with laws. We may use your information to comply with applicable laws and regulatory requirements.

How We Combine Information

We may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third-party sites. We combine information collected across devices, such as computers and mobile devices. We also combine information we get from third parties with information we already have. Such combined information will be handled in accordance with this Policy.

How We Share Your Information

We may share information with our parent company, subsidiaries, and affiliates for the business purposes described in this Policy.

We share information with our service providers. We may share your information with trusted service providers that are providing services to us and acting on our behalf, such as consultants, professional advisers (such as attorneys, accountants and auditors), payment processors, identification verification providers, and data analytics providers.

We share information with our business partners. For example, we may share information with third parties (such as financial professionals) when you enter your information into our website to provide products or services to you.

We may share information with any successor to all or part of our business. We may share information in connection with a merger, divestiture, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or other similar proceeding, in which personal information held by us is among the assets transferred.

We will share information to comply with the law or to protect ourselves. We may share information with government agencies, consumer reporting agencies, and other outside parties as permitted or required by applicable laws. For example, we will share information to respond to a court order or subpoena. We will share information if a government agency or investigatory body requests it. We may also share information if we are investigating potential fraud or as part of other legal proceedings, such as in connection with pending litigation.

We may share information for other reasons we may describe to you.

How We Use Cookies

A cookie is a small text file stored on your device by a website. When you visit our website, we use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to make your experience on our website more personal and interactive. Cookies can make a website more useful by allowing the site to personalize information for visitors and by storing information about user preferences on a particular site so that the user does not have to re-enter information each time he or she returns to the site. Cookies also allow us (including our analytics providers) to collect information about your visit, such as the pages you viewed on our website, the number of times you accessed our website, the amount of time you spent on our website, and other web traffic data. We also use first-party cookies to conduct analytics on our website, as described below. By continuing to use our website, you consent to our use of cookies as explained in this Policy. We may also use local device storage or tracking technologies, such as web beacons, web bugs, clear gifs, and similar technologies, for any lawful business purpose, including gathering and/or store information, delivering content, and administering services on the website.

Your Choices

While most browsers are automatically set up to accept cookies, you can adjust your browser settings to reject cookies or to have your computer warn you each time a cookie is being sent. Cookies are typically browser specific. If you use different browsers, you will have to define your preferences on each browser. You can delete all or some of these cookies from your computer by activating the “delete cookies” feature in your browser. If you have several browsers, you must reiterate the deletion request for each browser. If you use different devices, you will need to configure each device to suit your cookie preferences. Note that if you remove or reject our cookies, you may not be able to use certain features on the site.

Tracking; Analytics Providers

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our website may not work. If you block or reject cookies, not all the tracking described here will stop. We work with third party analytics service providers, including but not limited to Google Analytics, to help us better understand how you use the website. For example, we use Google Analytics to learn more about the types of users that visit the website, how they use the website, and to help us improve the website. Google Analytics provides us with certain data regarding the demographics of the users that visit the website. To provide this service, Google Analytics may collect certain information about you from your computer, including through the use of cookies. Such information may include information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/ . Please note that Google and other third parties (including, for example, advertising networks and providers of external services, like web traffic analysis services) may also use cookies as a result of you visiting other websites that are not operated by us, over which we have no control.

We May Transfer Your Information

We may transfer your information to and from any state, province, country, or other governmental jurisdiction, and process it in the United States or elsewhere. We may maintain your information on servers and databases located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may be different and may not be as protective as your jurisdiction.

Information Security

The Internet is not 100% secure and there is always some risk in transmitting information over the Internet. Therefore, we cannot promise you that your use of our website will be completely safe. In addition, standard email communications are not secure. Therefore, you should not transmit any sensitive information to us through email. We encourage you to use caution when using the Internet.

Children and Parents

This website is not intended for use by children under the age of 13, and we do not knowingly collect information directly from children under the age of 13. If we discover that we have received information directly from a child under the age of 13, we will delete that information. If you are a parent or legal guardian and believe we have collected information directly from your child, you may contact us at privacy@axonicinsurance.com to request that such information be deleted.

Links to Third-Party Sites

Our website may contain third-party links, including third-party integrations, or offer a co-branded or third party-branded service. Through these links, third-party integrations, and co-branded or third party-branded services, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect, share, or use your information. Because AXI has no control over the privacy practices or content of these linked sites, we recommend that you carefully review the privacy policies of every third-party service that you visit or see, including those third parties you interact with through our website. Our website may also serve third-party content that contains their own cookies or tracking technologies. We do not control the use of those technologies.

Notification of Changes

We reserve the right in our sole discretion to change, modify, add, or delete portions of this Policy. We will provide notice of such changes only by posting the updated Notice on our website and changing the “Last Updated” date listed above, by posting a notice on the website or by sending you an email. We encourage you to review our Policy each time you visit our website to see if it has been updated since your last visit. Your continued use of the website following our notice of any such changes constitutes acceptance of those changes.

Contacting Us

If you have any questions about this Notice or our privacy practices, please contact us at privacy@axonicinsurance.com.

 

California Notice at Collection and Privacy Notice
Learn about our practices regarding the collection, use and disclosure of personal information about California residents who are covered by the California Consumer Privacy Act and California Privacy Rights Act, and how covered individuals can exercise their rights. (Exhibit 3)

California Consumer Privacy Disclosure

Last Updated On: April 2, 2026

Axonic Insurance provides this Privacy Disclosure (“Disclosure”) in light of the California Consumer Privacy Act of 2018 (the “CCPA”), as modified by the California Privacy Rights Act of 2020 (the “CPRA”), and supplements AXI’s Online Privacy Policy which can be found above. In this Disclosure, “we,” “us,” “our,” “Company,” and “AXI” refer to Axonic Insurance Services LLC and its subsidiaries. The purpose of the Disclosure is to inform you how we process Personal Information that we collect through our websites, portals, social media accounts, online advertisements, and online communications (collectively, our “Platforms”), through communications (such as mail or phone), at in-person meetings and events, and through other online and offline methods. This Disclosure also applies to personal information collected about California residents in the context of business-to-business relationships.

The Privacy Disclosures posted on this page do not apply to Personal Information that is exempt from the CCPA, such as data subject to the Fair Credit Reporting Act (“FCRA”), the federal Gramm-Leach-Bliley Act (“GLBA”), or the California Financial Information Privacy Act (collectively, “Exempt Financial Information”). For more information about how we collect, use and share Exempt Financial Information, please refer to our notices above. Additionally, these Disclosures do not apply to other, non-financial Personal Information exempt from the CCPA, such as data governed by the Health Insurance Portability and Accountability Act (HIPAA), the California Confidentiality of Medical Information Act, or the Driver’s Privacy Protection Act of 1994. Therefore, these Disclosures are not applicable to Personal Information collected in relation to our products and services for personal, family, or household purposes, including insurance products, investment products and services, or financial planning.

Changes: We may update this Disclosure from time to time. Any updated Disclosure will be effective when posted. Please check this Disclosure periodically for updates. If required by law, we will contact you directly to provide you with an updated Disclosure.

Sources of Personal Information

We collect Personal Information about you from the following sources:

Directly from you. We may collect Personal Information you provide to us directly, such as when you contact us through our Platforms, interact with us in person, sign up for offers or newsletters, or otherwise communicate with us.

Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Platforms. This may include information about how you use and interact with our Platforms or otherwise interact with us, information about your device, and internet usage information. For more information, see our Online Privacy Policy.

From service providers who collect information on our behalf.

From our affiliates and subsidiaries.

From financial professionals (our financial professionals, brokers, and other financial professionals who sell our policies or perform similar functions).

From third parties, such as commercial business partners, data brokers, social media companies or other independent parties who interact with us.

From publicly available sources. We may collect Personal Information about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Disclosure, including third party sources, and use or disclose it for the purposes identified below.

Types of Personal Information We Collect

We may collect the following types of Personal Information about you:

Identifiers, such as your name, email address, physical address, telephone number, and device identifiers.

Records about you, such as covered medical or health information, investments, estimated income, and other information that we obtain from commercial data partners.

Protected class and demographic information, such as age (including birthdates), gender, and veteran status.

Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other electronic network activity information about you, your device, and how you interact with the Platforms. Data elements may include browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), operating system, browser used, and other information about how you interact with our Platforms (such as pages on our Platforms that you have viewed).

Non-precise geolocation data, such as your location as derived from your IP address.

Audio, visual, or other sensory information, such as photographs and audio/video recordings.

Professional or employment-related information, such as job title, organization and other professional information.

Education information.

Inferences drawn from any of the information we collect about your preferences or behavior.

Sensitive Personal Information, such as health information obtained from commercial data partners or inferred from your interactions with our Platforms.

How We Use Personal Information

We may use Personal Information for the following purposes:

For our internal business purposes, such as operating our Platforms and customizing the content; maintaining internal business records, such as accounting, document management and other similar activities; enforcing our policies and rules; management reporting; auditing; IT administration of our network, intranet, and other technologies; and IT security management and tasks.

For our internal research and business improvement purposes, such as verifying, maintaining, or improving the quality of our business (including our Platforms); evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.

For legal, safety, or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against the Company, its personnel, and its customers; for the establishment, exercise or defense of legal claims; protecting Company, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.

In connection with a corporate transaction, such as if we acquire, sell or transfer all or a portion of our business or assets.

For marketing and targeted advertising, such as marketing our business or that of our affiliates, business partners, or other third parties (for purposes of this paragraph alone, “we” or” our” includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Information we collect to personalize advertising to you on our Platforms or third party sites and digital properties; to analyze interactions with our email communications or website areas viewed; to develop product, brand or services audiences (including by identifying you across devices/sites) to better target our advertising to you; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

How We Disclose Personal Information

We may disclose Personal Information to third parties, including the categories of recipients described below. Although we do not “sell” Personal Information for money, we engage in routine practices involving third parties that could be considered a "sale" (meaning a disclosure of Personal Information to a third party for consideration) or “sharing” (meaning a disclosure of Personal Information to a third party for targeted advertising purposes), as defined under the CCPA. We do not knowingly sell or share Personal Information about minors.

Categories of Personal Information We Collect

Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

Categories of Third Parties to Whom Personal Information is Sold or Shared

Identifiers

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Advertisers, ad platforms and networks, and social media platforms
• Third parties whose cookies and tracking tools we use as described in our Online Privacy Policy
• Commercial data partners to whom we make information available for their own marketing purposes
• Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

Records about you

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Not sold or shared

Characteristics of protected classifications under California or federal law

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Not sold or shared

Commercial information

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Advertisers, ad platforms and networks, and social media platforms
• Third parties whose cookies and tracking tools we use as described in our Online Privacy Policy
• Commercial data partners to whom we make information available for their own marketing purposes
• Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

Internet or other electronic network activity

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Advertisers, ad platforms and networks, and social media platforms
• Third parties whose cookies and tracking tools we use as described in our Online Privacy Policy
• Commercial data partners to whom we make information available for their own marketing purposes
• Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

Geolocation data

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Advertisers, ad platforms and networks, and social media platforms
• Third parties whose cookies and tracking tools we use as described in our Online Privacy Policy
• Commercial data partners to whom we make information available for their own marketing purposes
• Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

Audio, visual, or other sensory information

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

Not sold or shared

Professional or employment-related information

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

Not sold or shared

Education information

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

Not sold or shared

Inferences

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

• Advertisers, ad platforms and networks, and social media platforms
• Third parties whose cookies and tracking tools we use as described in our Online Privacy Policy
• Commercial data partners to whom we make information available for their own marketing purposes
• Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

Sensitive Personal Information

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

Not sold or shared

The categories of recipients in the chart above are used to mean:

Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.

Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.

Vendors necessary to complete a transaction that you request, such as mail service companies.

Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with laws or legal requirements, to enforce or apply our Terms of Service and other agreements or policies and to protect Company, our customers’, or third parties' safety, property, or rights.

Other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.

Entities to which you have consented to the disclosure.

Data Retention

We maintain record retention policies and procedures based on applicable law and business needs that determine how long we retain records, including those containing Personal Information. CCPA rights request records are subject to a two-year retention period as required by California law.

Data Subject Rights

California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

    • Right to Know. You may request information about the categories of Personal Information we have collected about you; the categories of sources from which we collected Personal Information; the purposes for collecting, selling, or sharing the Personal Information; and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.
    • Right to Delete. You may request that we delete Personal Information that we have collected from you.
    • Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.
    • Right to Opt Out of Sale/Sharing. You may request to opt out from the sale or sharing of your Personal Information. We do not knowingly sell or share any Personal Information of minors under the age of 16.

You may exercise a Right to Know, Right to Delete, and Right to Correct, via the Personal Information Request Form

We do not offer the Right to Limit the use of Sensitive Personal Information because we only use such information for purposes that are permitted under California law. These purposes include providing requested services, ensuring security and integrity, short-term transient use, performing services on behalf of the business, and other uses authorized by the CCPA and its regulations.

You may exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing by visiting the Personal Information Deletion Form To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

If you need assistance submitting a request or have questions regarding this Disclosure or how the Company uses your Personal Information, please contact us privacy@axonicinsurance.com.

Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.

Verification: In order to process requests, we may need to obtain information to locate you in our records or verify your identity using reasonable methods. For Right to Know, Right to Delete, and Right to Correct, we will collect some or all of the following data elements: Name, Date of Birth, Email, Phone Number, and Address. We use a third-party identity verification and fraud prevention service to verify the information you provide on your rights request form, and which may present you with additional knowledge-based questions. When it comes to identity verification, our third party only tells us whether your identity passes verification, and we do not use this information for any other purpose. In some cases, we may ask for more or different information if needed to otherwise support your request such as in cases of authorized financial professionals. To exercise the Right to Opt Out of Sale/Sharing, you may be asked to provide and verify your email address.

Authorized Financial Professionals: Authorized financial professionals may exercise rights on behalf of consumers by submitting a rights request via privacy@axonicinsurance.com and indicating that they are submitting the request as an financial professional. Financial Professionals should provide their own information to verify the financial professional's identity, after which we will contact the financial professional with additional instructions to complete the consumer right submission process. We may require financial professionals to demonstrate authority to act on behalf of a consumer by providing signed permission and may require consumers to directly verify their identity with us using the methods described above.

Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time, in which case, we will notify you and may take up to 90 days total to respond to your request.

Contact Information

If you need assistance submitting a request or have questions regarding this Privacy Disclosure or how AXI uses your Personal Information, please contact us at privacy@axonicinsurance.com.

 

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