Last revised: July 1, 2023

Introduction

Our privacy commitments are fundamental to the way we run our business. Unless otherwise noted or governed by law, these commitments apply to everyone who has a relationship with us - including customers, partners, and website visitors. ELCO Mutual Life and Annuity (“ELCO”) is committed to providing you with the best overall experience in all of our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy. We have assessed all aspects of our business and optimized the amount of data we collect to find the right balance between data sharing and service.

Purpose.  The purpose of this Privacy Policy is to describe how ELCO collects, uses and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.elcomutual.com  (collectively referred to herein as the “Site”). Please read carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please Contact Us or contact us using one of the methods described at the end of this Privacy Policy.

Our Privacy Policy explains:

• Information That We Collect 
• Access to Your Information and Choices
• Security of Your Information
• Consent to Processing of Personal Data in United States
• Changes to Our Privacy Policy
• Questions and How Contact Us

Scope; Third Party Sites.  This Privacy Policy applies only to information we collect at and through the Site. Our Site may also contain links to third party sites that are not owned or controlled by ELCO. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information. 

Other Privacy Policies.  For information about how we collect, use and share your financial information, please refer to our Privacy Notice.

Terms of Use.  Please note that your use of our Site is also subject to our Terms of Use.

Information That We Collect

Information You Provide to Us

We collect personal information you provide to us, for example when you use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. “Personal data”, “personal information”, or "PII" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly — in particular, by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

“Special Categories of Personal Data” pertains to personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and the processing of data concerning health or sexual orientation.

“Sensitive personal data” either indicates “special categories” (see above) or is personal data of which the sensitivity level has been assessed and classified, indicating potential severe impact on an individual when confidentiality of such data is breached.

Personal Information may include:

• Name
• Address
• Social Security Number
• Email address
• Telephone number
• Agent and Policy Owner Numbers
• Financial account numbers of Agents and Policy Owners
• Salary or other personal financial information
• Content you submit to us including blog posts, feedback, comments, photos etc.
• Purchase History
• Internet or similar network activity
• Professional or employment-related information
• Inferences drawn from other personal information

Information We Collect Automatically Through Your Use of our Site

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on how your online activity.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A "cookie" is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to our websites. Cookies may store unique identifiers, user preferences and other information. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)

No Information from Children Under Age 18

If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, please Contact Us  or call us at (800) 321-3526. 

How We Use and Share Your Information

To Provide Products, Services, and Information.  We collect information from you in order to provide information that you request from us; send you promotional materials or advertisements about our products and services, as well as new features and offerings; administer surveys, sweepstakes, promotions and contests; and to provide interest-based targeted advertising to you.

Sharing with Third Parties.  We will not rent or sell your Personal Data to others but may disclose personal data with third-party vendors and service providers that work with us. We will only share personal data to these vendors and service providers to help us provide a product or service to you. Examples of third parties we work with are call center operators, shippers, servicers, information processors, financial institutions, independent insurance agents and independent marketing organizations. These third parties only have access to personal data necessary for them to complete their service.

Additional examples of “categories of third parties”:

• Affiliates within our family of companies;
• Service providers and vendors who provide services such as data analytics, payment processing, order fulfillment, customer service, auditing, marketing services, and IT services;
• Third party security providers to help us prevent and detect fraud, security or technical issues, or illegal activity;
• Marketing partners;
• Our trusted third-party service providers and affiliates who provide a service to us or assist us with providing our products and services;
• Our auditors, consultants, accountants, attorneys, and others providing advice to us;
• Payment processors;
• Any other person or entity we reasonably think is customary, necessary, or advisable for the business purposes disclosed in our Privacy Policy or to whom we are obliged by applicable law or regulation to make the disclosure; and
• Any other party where we have obtained your consent or authorization.

Advertising.  We may use how you browse and shop to show you ads for ELCO or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned or operated by ELCO.

We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites Our Site recognizes if your browser sends a “do not track” signal or similar global privacy control mechanism to indicate you do not wish to be tracked or receive interest-based ads. You can also opt-out from the tracking of your online activity when visiting our Site by clicking opt-out on the banner that appears upon entering the Site. You can opt-out of receiving interest-based ads from us. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Your Consent.  In addition to the sharing described elsewhere in this Privacy Policy, we will share personal information with companies, organizations, or individuals outside of ELCO when we have your consent to do so.

Legal Proceedings.  We will share personal information with third-party companies, organizations or individuals outside of ELCO if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security, or technical issues; and
• Protect against harm to the rights, property, or safety of ELCO, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control.  If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third-party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

Access to Your Information and Choices

You have the right to access and limit the use and disclosure of your personal data. If you would like to express your point of view, challenge an explanation of data use, or otherwise obtain further information, you can contact Contact Us or call us at (800) 321-3526. If at any time after registering for information, your personal information changes, notify us and we will update your contact information. Please note, at any time, if you desire to obtain or transfer your information, we will provide you with your personal data in a structured and commonly used electronic format. You can opt-out of receiving marketing and promotional emails from ELCO by contact us by emailing us at compliance@elcomutual.com, calling us at (800) 321-3526 and mailing us at 916 Sherwood Drive, Lake Bluff, IL, 60044.

ELCO does not sell information of its consumers or agents except to service and grow the business relationship you have with us. For this reason, you do not need to “opt-out” or “opt-in” as you may have done with other financial companies because we do not sell your information.

Security of Your Information

We use industry standard physical, technical, and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

Not Intended For EU Residents. Consent to Processing of Personal Data in United States

This Site is not targeted to or intended for residents of the European Union. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Residents of California

The information below applies to residents of the State of California. ELCO regularly reviews its Privacy Policy and ensures that we process your information in a manner that in compliance with applicable regulations. The California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA) defines categories of personal information as the following:

ELCO obtains the categories of personal information listed above from the following categories of sources:

• Directly from you or someone on your behalf
• Healthcare professional or firm
• Financial service professional or firm
• Publicly available records
• Family member, dependent or beneficiary
• Other third parties (e.g., consumer reporting agency, credit reporting agency, staffing agency, companies that provide services to us)

 ELCO may disclose all categories of personal information as necessary or appropriate with the following categories of third parties:

• Consultants and contractors (e.g., external auditors)
• Financial services professionals
• Software service providers
• Attorneys and other legal professionals
• Cloud service providers
• Regulatory agencies
• Third party administrators

 You may request that ELCO delete personal information that we have collected and retained. Once we receive and confirm the request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We will not discriminate against you for exercising any of your rights. Please see the You May Request Your Information section above for more information on how to submit a deletion request.

Please be aware that certain legal and regulatory requirements require us to retain your personal information for specific periods of time which may impact our ability to honor your deletion request. We retain personal information in our server logs, our databases, and our records for as long as necessary to provide our services. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations and to resolve disputes or defend against legal claims. For these reasons, if your policy/contract is currently in force, we are unable to process a deletion request as the information is required to service our relationship with you. Likewise, if your policy/contract is not in force, we must retain the information for a period of time after the termination or application denial date of the policy/contract.

Changes to Our Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Questions and How to Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, email us at compliance@elcomutual.com, call us at (800) 321-3526, or contact us by US postal mail at the following address:

ELCO Mutual Life and Annuity

916 Sherwood Drive

Lake Bluff, IL 60044