Welcome to the Empower website.

Empower takes data privacy very seriously and is committed to protecting and respecting the privacy, security and integrity of your personal information. This policy sets out key information regarding Empower and how your personal information will be collected, used and protected. Please note that certain portions of this policy may, or may not, be applicable to you based on the services and products in which you are enrolled and applicable laws. This policy is supplemented by specific notices, set out in links within this policy, that provide additional information pertaining to your relationship with Empower or addressing the requirements of the jurisdiction in which you live. In this policy, the terms "Empower," "we" and "our" refer to each and all of the Empower family of companies listed at the end of this policy.

How we collect data

Empower collects personal information as required or permitted by law. Personal information (also referred to as personal data) means information that, when used alone or with other relevant data, personally identifies, or is capable of personally identifying you, either directly or indirectly, or as otherwise defined by law. Based on the services or products you receive from us, or other transactions initiated by you, your personal information may be collected from the following sources:

• From you when you communicate with us by email, by web (including online chat) or electronic communication on our websites, by correspondence, or by phone.
• Information you provide on our websites (such as information about your financial planning or retirement goals) and information from third party financial accounts you link to your Empower account (such as assets held, balance and account information).
• From you, or your representative, when you complete applications and forms for various products or services.
• From your plan sponsor (your employer or former employer) for a retirement plan in which you are or were eligible to participate in and for which Empower provides services (your data may be provided by your plan sponsor or its service providers, such as payroll providers, third-party administrators or advisors).
• From activity in your account (for example, data from the administration of your investments, balances, trades and elections).
• From your device when you browse websites or mobile applications (see website, cookies and web beacons sections below) and from tracking technologies in emails that we or our suppliers send to you.
• From Empower's suppliers, consumer and insurance reporting companies, data providers and other third parties as permitted by law.
• If you enroll in account aggregation services, we may also collect information from the accounts that you linked, as approved by you.
• We may have acquired your personal information if it is held by a business that we have acquired.
• From other sources to complete transactions initiated by you or your representative (for example, to transfer balances from another retirement account into a new retirement account).

We also collect your preferences when you elect to receive or opt-out of cookies, communications involving email, texting, or telephone calls; these preferences apply to Empower communications with you and are not shared with nor transferable to third parties.

How we use data

Empower uses your personal information to respond to your requests and inquiries and to provide you with services and products you receive from us. In the event you are enrolled in a retirement plan that is administered by Empower pursuant to a services agreement with the plan sponsor of your retirement plan (your employer or former employer), Empower will process your data to perform its services to the plan sponsor. If you contract directly with Empower or its affiliates for other services offered by Empower to individual customers, such as advisory services, financial products or financial wellness services, Empower will use your data to process transactions and perform its obligations in connection with such services. Empower will also use your data as permitted by law to make you aware of other financial products or services that may be of interest to you. Empower may use your data on an anonymized basis to conduct and publish aggregated research about the retirement or investment industries.

Empower will use your data for other purposes as permitted by law, including to protect your interests and ours in the detection, prevention and mitigation of fraud, to meet the requirements of applicable laws and regulations, to comply with requests of regulators with jurisdiction over our services, and for product development and delivery.

How we share data

We limit the information we share and the parties we share it with. What we share depends on the types of products or services you have procured and applicable law.

Further, personal information may be shared as necessary to effect, administer, or enforce a transaction you request or authorize, with your consent, at your direction, or as allowed by applicable law. For example:

• Retirement plans – If you are enrolled in a retirement plan offered by a plan sponsor (your employer or former employer), your personal information may be shared with the plan sponsor and with that plan sponsor’s third-party administrators, advisors, service providers, and other third parties as authorized or directed by the plan sponsor.
• Affiliate sharing – Certain personal information may be shared among our affiliates as permitted by law for their everyday business purposes and to make it easier to do business with us. Our affiliates are listed below in this policy and include, but are not limited to, our broker-dealer, our advisory service provider and our trust company.
• Nonaffiliated third parties – Your personal information may be shared with nonaffiliated third parties to provide services on our behalf. These third parties agree to maintain the confidentiality of the personal information and use it solely to provide their services to us.
• Health Information – Your health information will not be shared except as permitted or required by law.

Other disclosures of your data may include:

• To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.
• For institutional risk control, or for resolving customer disputes or inquiries.
• To persons acting in a fiduciary or representative capacity on your behalf.
• To provide information to persons assessing our compliance with industry standards, and our attorneys, accountants and auditors.
• To protect the confidentiality or security of our records pertaining to you, the service or product, or a specific transaction.
• To comply with federal, state, or local laws, rules, and other applicable legal requirements.
• To comply with a properly authorized civil, criminal or regulatory investigation or subpoena or summons by federal, state or local authorities, or to respond to judicial process or government regulatory authorities having jurisdiction over the financial institution for examination, compliance or other purposes as authorized by law.
• To a group policyholder to report claims experience or for an audit.
• In connection with a proposed or actual sale, merger, transfer or exchange of all or part of our business.
• To a government agency to determine your eligibility for benefits they may have to pay for.
• To a certificate holder or policyholder to provide information about the status of a transaction.
• To consumer and insurance reporting organizations (such as your credit, financial or health history; please note, these organizations may retain information provided by us and disclose it to others).
• For purposes otherwise permitted or required by law.

After your relationship with us ends, the terms of this policy shall continue to be applicable to your data as long as we retain your data.

Categories of data we collect

Depending on which Empower products or services you use, we may collect the following categories of personal information for the indicated business purpose(s) described in the chart below.

We share your personal information with the following categories of third parties set forth under "how we share data": service providers (including affiliates), vendors, auditors and applicable regulatory authorities. The categories of personal information we may share with such third parties may include: identifiers, personal information such as contact information and financial information, protected classification characteristics under state or federal law, commercial information, biometric information, internet or network activity, audio or visual data, employment-related information and inferences drawn from such categories of personal information.

Deidentified or pseudonymous data.

We maintain and use deidentified data in such a way that any information can no longer be linked to you or any device associated with you. After data has been deidentified, i) we maintain and use such deidentified data without attempting to reidentify the data or re-associate it with specific individuals; ii) we take reasonable measures to ensure that the information cannot be reassociated with you or your household; and iii) we have implemented technical and organizational safeguards as well as business processes designed to prohibit the reidentification of your information. Such data is used for research and benchmarking purposes. We contractually obligate all recipients of the deidentified data to comply with applicable laws pertaining to deidentification and we monitor compliance with any contractual commitments.

Children

Empower will not knowingly collect personal information from children under the age of 16 without seeking prior parental consent (if required by applicable law). We will only use or disclose personal information about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definitions of "child" or "children" may be slightly different as set forth in various applicable laws.

Security

We use physical, administrative and technical safeguards designed to protect the confidentiality, integrity and availability of your personal information. Any third-party service providers with whom we share your personal information agree to maintain the confidentiality and security of the personal information and use it solely to provide their services to us. In addition, Empower provides the Empower Security Guarantee to its customers and participants as described here.

Website use

When you access our websites or mobile applications, we or our third party suppliers use a variety of technologies, such as tags and web beacons, that automatically collect data (such as: without limitation, your device type, browser type, internet protocol address, operating system used, number of visits, average time spent on the site and pages viewed). This data is used to operate the websites more efficiently, maintain the security of your online session, improve our websites’ design and navigation, and perform online advertising (where permitted by law). If you have created an account with us, we may combine the data collected through the tracking systems described herein with other information we know about you, as permitted by law. We use this information internally to provide you with a better user experience and to offer you products and services that may be of interest to you.

Some of our websites include links or navigation to third-party sites. These third-party sites may include informational sites, sites providing financial wellness tools and services, or services offered to you solely by a third party, as further described in the disclosures provided on such sites.

Cookies and web beacons

A cookie is a piece of information that is stored on your computer, tablet, phone or other device by your web browser. Web beacons (also known as clear gifs, web bugs or pixels) are small graphics with a unique identifier and are embedded invisibly on web pages. Empower and third party service providers we hire may use such cookies and web beacons (collectively referred to below as “cookies”) to track the online movements of users of our websites and mobile applications, and to collect other data such as IP address, type of device used, and browser information. Empower and its third party service providers use such data to customize your experience on our website and personalize our communications with you. With respect to emails that are sent to you, we or our service providers also use cookies and web beacons to determine when you receive and open our emails, whether you click any links in the email, and other information about the device from which you access the email, as permitted by law.

If you do not want to have cookies on your computer or device, you can use the link at the bottom of the webpage to that is titled “Do not sell or share my personal information” to access a cookie manager in which you may refuse or deny certain types of cookies. Additionally, you can use the settings or tools offered on your browser to delete cookies that have already been stored. If you refuse or delete cookies, you may notice an impact on your use of Empower’s (and its affiliates’) websites; for example, you may not be able to sign in and access your account without additional authentication, or we may not be able to recognize you, your device or your online preferences.

Do not track

Some web browsers have the ability to activate a “do not track” signal. At this time, Empower does not respond to “do not track” signals. You may however, disable certain tracking as discussed above (e.g., by disabling cookies).

Analytics

We use a tool called “Google Analytics” to collect information about your activity on our website or in mobile applications, or regarding your receipt and access to information in emails we send to you. Google Analytics collects information such as how often users visit our websites, what pages they visit when they do so, and what other sites they used to navigate to this site. For more information about how Google uses data, see the site “How Google uses information from sites or apps that use our services,” here.

Interest-based advertising and communications

Empower advertises its products and services on its websites and mobile applications and on websites not affiliated with Empower, and we contract with third-party advertisers to place those advertisements. Empower and its suppliers may also send you advertising and communications that are tailored to you or that provide you with products or services that may be of interest to you, based on information that we or that such third-party service providers have collected about you. Such advertising may include advertising on websites not affiliated with Empower, such as social media. Our third-party advertising providers might use information collected from cookies or beacons about your use of our websites to provide interest-based advertisements based on your online activity as permitted by applicable law. If you would like information about how to opt-out of such interest- based advertising, you may find more information through the Network Advertising Initiative here.

Vermont residents

We will not share information about your creditworthiness among Empower companies, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Modifications to our privacy policy

We may change our privacy practices from time to time as the need arises. When we do, we will post the revised notice to our website. If there are material changes, notice will be provided as permitted under applicable law including by electronic notice on our website and electronic delivery.

Requests, questions or complaints

To submit privacy-related questions, requests, or complaints, please call our toll-free number at 855-756-4738 or send us an email at privacymatters@empower.com. Please do not put any confidential or personal account information in an email request.

In addition, you may contact us by mail to the address below:

Empower
Attn: Chief Privacy Officer
8525 E Orchard Rd, 2T3
Greenwood Village, CO 80111
 

About us

The policy is applicable to the following family of companies and brands:

• Empower Retirement, LLC
• Empower Annuity Insurance Company of America
• Empower Life & Annuity Insurance Company of New York
• Empower Plan Services, LLC
• Empower Advisory Group, LLC
• Empower Financial Services, Inc.
• The Canada Life Assurance Company (US operations)
• Great-West Life & Annuity Insurance Company of South Carolina
• Empower Capital Management, LLC
• Empower Funds, Inc.
• Empower Trust Company, LLC.
• Empower Holdings, Inc.
• Empower Annuity Insurance Company
• TBG Insurance Services Corporation
• MC Insurance Agency Services, LLC
• Mullin TBG Insurance Agency Services, LLC
• COMOSA REIT Corp.

Certain services or applications provided by Empower affiliates, such as the Empower Personal Dashboard or Empower Advisory Services, are subject to separate privacy policies that are provided with those applications or services.

Rev. June 11, 2023