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Privacy Policy

Online Privacy Policy for SBLIUSA.COM

 

Associated material: Opt-In and Opt-Out Forms, Initial and Annual Notices, Privacy Notices and Forms Used for Most Jurisdictions, and Individual Notice Forms for Vermont, New Mexico, North Dakota and California



PURPOSE
The purpose of this document is to establish SBLI USA and its affiliates (herein after "SBLI USA") policies regarding the collection, use, dissemination, disclosure, and protection of customer and former customer information.

POLICY AND PROCEDURE SCOPE
This document includes policies and procedures for collecting, using, disseminating, disclosing, and protecting customer and former customer information. It applies to all areas of SBLI USA. Similar versions of this policy are posted on the SBLI USA web site (SBLI USA.COM) and are sent to all consumers as required by law and to policyholders at least annually.

These policies and procedures may be revised from time to time to add, delete, or clarify certain points as deemed appropriate. The SBLI USA Compliance Officer has the responsibility for assuring compliance with these policies and procedures. Any deviations from this policy must be pre-approved by the Compliance Officer or his/her designee. Any questions regarding the content or application of this policy should be directed to the Compliance Officer or his/her designee.

The Internal Audit Department may periodically review the policy and related procedures and controls, and issue reports thereon to Management and the Audit Committee.

POLICY AND PROCEDURE DETAILS


1. General
1.1. Privacy is a great concern to SBLI USA and to most Internet users. We are very 
      aware and protective of the privacy concerns of our customers, former customers,
      consumers, and visitors to our web site.

1.2. We are committed to adhering to all applicable laws and regulations governing the
       privacy of information.



2. Information SBLI USA Gathers
2.1 SBLI USA only asks for information necessary to provide customers, consumers,
      and visitors to the SBLI USA web site with superior customer service and to 
      maintain and improve customer service.

2.2 SBLI USA does not collect any nonpublic personal information from a visitor to its
      web site without expressly requesting that the visitor provide the information. If a
      visitor is just browsing SBLI USA's web site, SBLI USA does not gather any
      personal information about the visitor whatsoever.

2.3 Subject to compliance with the applicable federal and state fair credit reporting laws, 
     SBLI USA may collect the following nonpublic personal financial information from
     customers, consumers, and visitors to the web site:
2.3.1 Information we receive on forms, whether received orally, in writing, or
        through our web site, such as name, address, email address, social
        security number, beneficiaries, age, income level and telephone number.

2.3.2 Information about customers, their transactions and experiences with SBLI 
        USA, our affiliates, or others, such as policy coverage, premium balances, 
        payment history and parties to the transactions, and

2.3.3 Information we receive from a consumer-reporting agency, such as credit
        worthiness and credit history, assets and income.

2.4 SBLI USA may also collect health information necessary to the underwriting process.

2.5 Any individual who has provided SBLI USA with personal information may request 
     a change or modification to that information in any of the ways described in Section
     4.5 below.

2.6 SBLI USA does not knowingly solicit, collect or maintain any personally identifiable
     information from children under the age of 13 on the Internet.



3. How Personal Information Is Used

3.1. SBLI USA uses customer information obtained orally, in writing, or from the web site
       for customer service (if requested).

3.2. The customer's contact information is used to contact them when necessary.
      (e.g.Responding to a customer's call or to help process a transaction that a
       customer initiated.)

3.3. Financial information that is collected is used to bill the customer for products and
       services if purchased.

3.4. Unique identifiers (such as social security numbers) are used to verify the
       individual's identity.

3.5. Demographic and profile information collected on the web site is used to tailor the
      visitor's experience at the site, displaying the content we think may be of interest to
      them, and displaying it according to their preferences.



4. Disclosure of Customer or Web Site Visitor Information

4.1. SBLI USA is permitted by law to share information about customers or web site 
       visitors when and if they become a customer or claimant, even without their
       authorization, with any third party if it is reasonably necessary to enable the party
       to perform services for SBLI USA, such as claims investigations, appraisals,
       actuarial or  research studies, or detection of fraud or illegal activities. These
       services or activities in most cases are required by insurance regulatory authorities,
       law enforcement agencies, or other governmental authorities to protect the
       customer's interests. For personal information that is not exempted by the laws,
       SBLI USA offers consumers an opt-in and/or opt-out provision depending on
       applicable state law, as described in Section 5.

4.2. Subject to any requirement that SBLI USA obtain prior consent to do so, SBLI 
      USA, in certain jurisdictions, may disclose nonpublic personal financial information
      about customers to the following types of affiliated or non-affiliated third parties:

4.2.1. Companies that perform marketing services on our behalf or other 
          financial institutions with which we may have a marketing agreement.

4.2.2. Financial service providers such as life insurers, property and casualty 
         insurers, banks, mortgage bankers, mortgage agencies and brokers, and 
         other mortgage related companies, securities broker-dealers, insurance 
         agents, brokers, third party administrators, and any non-financial services 
         companies or non-profit organization. We share this information in the 
         normal course of business for marketing purposes.

4.2.3. SBLI USA may also disclose nonpublic personal information to affiliated 
         or non-affiliated third parties as required or permitted by law.

4.2.4. In no event will SBLI USA disclose nonpublic personal financial information 
         about former customers to any affiliated or non-affiliated third party.

4.2.5 SBLI USA may also be compelled or directed by a court, law enforcement
         or government agency to comply with a search warrant, court order, or
         subpoena to disclose nonpublic personally identifiable information.

4.3. Nonpublic health information about customers will not be disclosed to affiliated or 
      non-affiliated third parties other than for underwriting purposes, claim handling
      or reinsurance to allow for the proper transaction of our business or disclosures
       required by law or legal process.

4.4. If at some point in the future we change our information collection and 
     dissemination practices, we will notify policyholders in writing of any change. 
     Policyholders will be able to "opt-out" of this change prior to the effective date of 
     the change, in compliance with all laws and regulations.

4.5. Any individual who has provided SBLI USA with personal information, either verbally 
      or through the SBLI USA web site, may request a change or modification to that 
      information in any of the following ways:

4.5.1 E-mail SBLI USA Customer Care at customercare@sbliusa.com.

4.5.2 Dial 1-877-SBLI -USA and speak with the SBLI USA Customer Care Group.

4.5.3 Mail a letter to the Company.

         SBLI USA Life Insurance Company, Inc.
         100 W. 33rd Street
         Suite 1007
         New York, NY 10001-2914

4.6. Upon written request, SBLI USA will make the nonpublic personal financial 
       information it has about a customer available for his review. If a customer notifies
       us that any such information is incorrect, we will correct our records if we agree. 
       If we do not agree, the customer may provide us with a written statement 
       disputing the accuracy of the information. We will include the customer's written
       statement in any future disclosure of the information to third parties.

4.7. Also upon written request, SBLI USA will provide customers with a more
       detailed notice concerning their privacy rights under the state laws applicable to
       the customer.



5. Opt-In and Opt-Out Provisions

5.1. Depending on the jurisdiction, SBLI USA provides the choice to "opt-in and/or opt-
      out" of having personally identifiable information used for secondary marketing 
      purposes, including telemarketing lists used for phone solicitations and lists used
      for mail offers, depending on state law. Customers may also request that their
      nonpublic personal financial information not be disclosed to affiliated and
      nonaffiliated entities.

5.2. If two or more customers jointly obtain an insurance product or service, any of the
       joint customers may exercise the opt-in and/or opt-out option.

5.3. Web site visitors are provided the ability to opt-in and/or opt-out of having their
       information shared at each point on the web site where personally identifiable 
       information is collected.

5.4. Customers and web site visitors can communicate their opt-in and/or opt-out
       preference in the following ways:

5.4.1 E-mail SBLI USA Customer Care at customercare@sbliusa.com.

5.4.2 Dial 1-877-SBLI -USA and speak with the SBLI USA Customer 
        Care Group.

5.4.3 Mail a letter to the Company.

         SBLI USA Life Insurance Company, Inc.
         100 W. 33rd Street
         Suite 1007
         New York, NY 10001-2914

5.4.4 Complete and return the Opt-In and/or Opt-Out Notice provided annually
        to every policyholder.

5.5. When SBLI USA receives an opt-in or opt-out notice, it is processed by SBLI USA
       who enters the opt-in or opt-out option(s) selected into the "client record" screen
       in LSP. The opt-in and/or opt-out form is maintained by SBLI USA for storage and
       will ultimately be scanned into the Optika system and indexed to the customer's
       policy file as a permanent record.

5.5.1 SBLI USA Call Center staff enter opt-in and opt-out information
        into LSP for information taken from customers over the
        telephone.The Customer Service Department spost-checks
        this data daily to ensure accuracy.

5.6. When lists of SBLI USA's customers are used or given to others for marketing 
        purposes, customers who have not opted in or opted out, depending, on the
        jurisdiction are excluded, according to the type of opt-in and opt-out selected and
        the type of marketing being done.



6. Computer Privacy and Security

6.1. With regard to web site security, SBLI USA.COM uses a secure server and 
       security protocol to safeguard the information provided by visitors during the
       information gathering and information delivery processes.

6.2. The site uses industry standard encryption technology and protocol to
       secure user sessions with the web site. Specifically, pages where customer
       information is input or displayed are secured by this technology. This state-of-
       the-art technology encrypts customer information to prevent third parties from
       reading the information while it is in transit over the Internet.

6.3. SBLI USA.COM handles all visitor and customer information in a highly
       secure manner. Access by SBLI USA personnel to the web site server is highly 
       restricted, and we enforce adherence to the highest ethical standards in performing
       our jobs and conducting the business of SBLI USA, and in support of the SBLI 
       USA.COM site.

6.4. SBLI USA restricts access to nonpublic personal information about customers
       to only authorized employees and agents who need to know that information to
       provide products or services requested.

6.5. SBLI USA maintains security practices, physical, electronic, and procedural
       safeguards that comply with federal and state regulations to guard all nonpublic
       personal information.

6.6. SBLI USA stores the HTTP conversation between a visitor's browser and its
       web servers. This information is used to generate reports that are used to
       continually improve our visitor's online experience.  Click here for details on 
       the information exchanged between a visitor's browser and our web servers.

6.7.  There are a number of ways a visitor can explicitly provide and consent to
       SBLIUSA.COM's collection of personal information:

        6.7.1   The site may require visitors to provide contact information (such as name
                   and email address), unique identifiers (such as social security number or
                   policy number), health information and demographic information (such as
                   zip code, age or income level).

        6.7.2  When providing information to begin the purchase of a product or service,
                   our site requires you to provide personal information in order to provide
                   you with accurate insurance product rate(s) and product suggestions. 
                  When you request rates, SBLI USA always asks for your state of
                   residence.

        6.7.3  SBLI USA tracks and stores standard http requests as a means to provide
                  better services to our visitors and to monitor web site utilization.

6.8.    "Cookies" are small pieces of information sent by a web site that are stored in a
          file on a user's hard drive. SBLI USA.COM places a session ID "cookie" on a 
          visitor's computer so that the web server can track individual user session 
          variables. The site uses session variables in the majority of its pages. The
          cookie "expires" whenever the visitor closes his or her web browser. 

         6.8.1.   Some of our business partners (e.g., tracking utilities) use cookies on 
                    our site. We have no access to or control over these cookies.

         6.8.2.   As is true of most Web sites, we gather certain information automatically 
                     and store it in log files. This information includes internet protocol (IP) 
                     addresses, browser type, internet service provider (ISP), referring/exit 
                     pages, operating system, date/time stamp, and clickstream data.

                     We use this information, which does not identify individual users, to 
                     analyze trends, to administer the site, to track users' movements 
                     around the site and to gather demographic information about our 
                     user base as a whole. 

                     We do not link this automatically-collected data to personally identifiable 
                     information.

                      We use a third-party tracking service that uses cookies to track 
                      non-personally identifiable information about visitors to our site in the 
                      aggregate.

6.9.   The SBLI USA web site contains links to other web sites. SBLI USA is not
         responsible for the practices or the content of such web sites.

6.10. SBLI USA conducts privacy training periodically for its CSRs and others 
         who have access to SBLI USA's customer information. Topics covered include 
         federal and state privacy laws, SBLI USA's privacy and confidentiality policies 
         and practices, and the implications of not adhering to the laws and regulations.
         The Company has also prepared a CD presentation on privacy that is used in the 
         training sessions.

6.11. Non-SBLI USA Site Links: SBLIUSA.COM contains links to other web sites.
         SBLI USA is not responsible for the practices or the content of such web sites.
         SBLI USA encourages you to read the privacy statements of these linked sites 
         because their privacy statements may differ from ours.



Management relies on the following procedures and controls to ensure the policies herein are being followed:

1. Authority Controls

1.1. Only authorized individuals are permitted access to customer nonpublic personal
        information.



2. Accounting Controls - N/A.


3. Monitoring Controls

3.1. Supervisors oversee all work relating to the collection, use, dissemination and
       protection of customer information.
3.2. The Internal Audit Department may periodically performs independent audits of
       these policies and procedures and submits reports thereon to management.
3.3. Weekly staff meetings are held to review progress, problems, etc.
3.4. All laws and regulations are monitored regularly, and internal policies and
       procedures are updated and changed as necessary to ensure compliance.



4. Safeguarding Controls

4.1. Customer information is protected against unauthorized access (see Sec. 6.4).
4.2. Internal reviews are periodically performed to ensure these policies and
       procedures are being followed.



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