Privacy Policy

The Global Atlantic Financial Group, including its affiliates and subsidiaries, (hereinafter “Global Atlantic,” “us”, or “we”) is committed to protecting and safeguarding your privacy. This Privacy Policy describes how we collect and process personal information on individuals who access and use our websites and online platforms and on those individuals who are not otherwise customers of Global Atlantic. If you are an existing customer of Global Atlantic, please see our Global Atlantic Companies Privacy Notice, which provides additional information regarding how we will collect, retain, and share nonpublic personal information.

The nature, type, and scope of personal information that Global Atlantic collects and retains is based on the relationship we have with individuals, and the types of services we provide them. The following are examples of the personal information types, and other information that Global Atlantic collects as part of our routine business practices:

The Global Atlantic Website. Except for existing customers, the Global Atlantic website (www.globalatlantic.com), does not request that the user provide any type of personal or business contact information (e.g., names, telephone numbers, email addresses). The Global Atlantic website does collect and use cookie data and automated tracking tools (see below) in accordance with this Privacy Policy.

Online Accounts. Our existing customers, consumers, and other professionals may register and create an account to access and use our online platforms and portals.  During the account registration process, we will collect the following information: your title, name, company/business organization, address, and Social Security Number. We will collect and use this personal information in order to verify your identity and your relationship with Global Atlantic, and to establish, maintain, and administer your online account with us. We will retain and share this personal information in accordance with this Privacy Policy.

Social Media Platforms. Global Atlantic is engaged on social media platforms, and you may voluntarily choose to access these platforms, or otherwise follow our activities online. We will only collect the information that you voluntarily provide to us on these platforms, and such information is generally limited to names, online identifiers, email addresses, and other contact information. Please do not post any sensitive personal information, or other information that is considered private or confidential, on our publicly available social media platforms. Additionally, we offer the ability to sign into some of our services, such as our online accounts (see above), via Facebook Connect, which will authenticate your identity and provide you the option to share certain personal information with us (e.g., name and e-mail address) to pre-populate forms and documents. For more information about Facebook Connect, please see Facebook’s data policy and if you do not want data to be collected via Facebook Connect, please do not use the Facebook Connect function. Some of our social media platforms use cookie data and automated tracking tools (see below) in accordance with this Privacy Policy.

Inquiries & Communications. There may be other times that you provide Global Atlantic information about yourself or others. For example, if you communicate with Global Atlantic’s helpline or a sales representative, you may provide your personal information, such as contact data (e.g., name, address, telephone, email) and other personal information related to your communication (e.g., employer, consumer preferences, and interests). We will collect the personal information that we think is reasonably necessary to your inquiry or that is otherwise related to your communication. We will collect and retain such information in accordance with the purposes you provided it, and with our legitimate business interests.

Vendors and Suppliers. Global Atlantic may collect and process personal information concerning our vendors and suppliers, including their name, contact details, job title, bank account details and financial information (including credit/income history), transaction history, and communications. We process this information to facilitate routine and common business practices related to vendor management, contract and project development, payment and credit collection, legal compliance, accounting, litigation, and to defend our personnel, property, and interests. We generally collect this information directly from you, or from your employer. However, we reserve the right to collect general business information, such as performance reviews, from other third-parties.

As you navigate through the Global Atlantic website, we may automatically collect certain information. For example, we may collect your Internet Protocol (IP) address and the website pages you visited. An IP address is a number assigned to your computer by your Internet service provider which enables you to access the Internet. We may also place a “cookie” on your computer or other device you use to access our website. A cookie is a piece of information that is stored on the browser on your computer or access device that helps our website remember information about you and your preferences when you return to our website. “Session” cookies are temporary bits of information that are erased once you exit your browser window or turn your computer or access device off. Session cookies are used to improve navigation on our website and to collect aggregate statistical information. This website uses cookies and session cookies.

We also may use Google Analytics to help analyze how visitors use our websites. Google Analytics uses cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The anonymous information generated by the cookie about your use of the website (including your IP address) is transmitted to Google, and this information is solely used to evaluate visitors’ use of the website and to compile statistical reports on website activity for Global Atlantic. We will never use Google Analytics to track or to collect any personal information about you. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link an IP address with the identity of any person. By using a browser plugin provided by Google, you can opt-out of Google Analytics. You can learn more about Google’s privacy practices by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

We also use LinkedIn Analytics, which are a selection of metrics that capture the performance of the websites we operate on LinkedIn. Like other social media tools, LinkedIn Analytics measures and tracks user metrics, such as our followers and visitors, and their clicks, shares, and comments. For more information, see LinkedIn's privacy policy.

 

If you are an existing customer of Global Atlantic, we will collect, retain, and share your personal information in accordance with our Global Atlantic Companies Privacy Notice and the “Online Accounts” section of this Privacy Policy, provided you have registered to receive access to our online portals. For all the other individuals we collect personal information from, we will use and share your personal information in accordance with the following:

For website users, we may use your information to improve the content of our website and to customize the website to your preferences.

For consumer-related inquiries and communications, we use the information you provide to us to deliver responsive information and solutions in connection with retirement, as well as life and pre-need products and services.

We may share personal information that we collect to third-party service providers and nonaffiliated companies to support our legitimate business interests, assist in our ability to satisfy our contractual obligations, and perform other support or marketing services, such as data processing and mailings.

We may share personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Global Atlantic’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Global Atlantic would be among the assets transferred.

We may share personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Global Atlantic or others.

We may share personal information for any other purpose for which we have your consent, or to fulfill the purpose(s) for which you provide the information to us.

We do not sell or rent personal information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.

To protect your information from unauthorized access and use, we have adopted security measures that comply with applicable law, and are reasonably designed to protect the availability, confidentiality, and integrity of your personal information. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any electronic transmission of personal information (e.g., over the Internet) is at your own risk, and Global Atlantic is not responsible for circumvention of any privacy settings or security measures contained on its website. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user name and password to access our websites or online accounts, you are responsible for maintaining the security and confidentiality of those credentials. You must immediately contact us if you know, or have reason to suspect, that your user name or password to our website or online account has been compromised or otherwise subject to unauthorized access, use, or disclosure.

Global Atlantic is headquartered in the United States, and the information (including personal information) that we collect is most often stored, and retained, in the United States. If you are located outside of the United States, please be aware that information you submit will be transferred to the United States, and that the United States may not provide the same level of protections as the laws in your country of residence. By continuing to provide us such information you hereby consent to this transfer.

Global Atlantic retains your personal information for the time period reasonably necessary to satisfy the purpose it was collected for, or as long as necessary to comply with legal obligations, or for the establishment, exercise, or defense of a legal claim. Generally, we retain your personal information for the duration needed to complete, or facilitate, a contract, agreement, or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions, or in compliance with applicable laws.

We wish to remind you that this Privacy Policy applies to personal information that you provide to Global Atlantic, whether voluntarily or automatically when using our online services. It does not apply to any links to a third-party’s website and/or online services, such as third-party applications, that you may encounter when using use our website services. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third-parties. Please be aware that we are not responsible for the privacy practices of any third-parties.

Depending on the jurisdiction in which you reside, you may have the following rights with respect to the personal information we hold about you. If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below in the “Questions or Concerns” section. We may need to collect and process information about you solely for the purpose of responding and satisfying any such data request.

Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future.

California Privacy Rights. Pursuant to California’s “Shine the Light” law, California residents who provide personal information (as defined in the applicable statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. Global Atlantic does not, at any time, share your personal information with a third-party with whom we know, or have reason to believe, uses the personal information to undertake independent direct marketing. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents may have certain data privacy rights, such as the right to be notified about what personal information categories are collected about you, and our intended use and purpose for collecting your personal information. You have the right to request access to your personal information and, to the extent feasible, request that it be transmitted in certain forms and formats. You may have the right to request that we (and any applicable service provider) delete your personal information. You have the right to know whether we sell or disclose your personal information. For clarity purposes, Global Atlantic does not sell your personal information. Rather, we only disclose your personal information in accordance with this Privacy Policy. You have the right not to be subject to discrimination for asserting your rights under the CCPA. With limited exceptions, the CCPA does not apply to personal information collected, processed, sold, or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102), and its implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the California Financial Code).

Children’s Privacy. Our website is not directed to children under eighteen (18) years of age, and we do not intend to collect personal information from minors. By using this website, or otherwise engaging with Global Atlantic, you represent and warrant to Global Atlantic that you are over the age of eighteen (18).

Do Not Track. Some browsers have a “Do Not Track” feature, which permits you to inform websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. At this time, Global Atlantic’s website is not able to respond to “Do Not Track” browser requests.

The General Data Protection Regulation. If you are located in the European Union, you may have certain rights with respect to the personal information we have about you. To the extent permitted by applicable data protection laws, you may access the personal information we hold about you; request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted; and request that we provide your personal information in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time when we are relying on your consent for processing your personal information. You may object to our processing of your personal information where that processing is based on our legitimate business interest. You have the right to lodge a complaint with your competent data protection authority.

If you are a California resident and would like to submit a privacy request, as allowed under the California Consumer Privacy Act, you may make a request by phone or through our web form.

Phone: 800-903-1452. Please leave your name and phone number and your call will be returned by a member of our privacy team.
Request Form: CCPA-Request

With regard to any personal information that you provide Global Atlantic, regardless of whether that personal information relates to you or a third-party, you must ensure, on a continuing basis that (i) such personal information is accurate, relevant, and complete, (ii) you have the lawful basis to provide us with such personal information, and (iii) you have provided information related to this Privacy Policy to, and/or received consent from, any third party whose personal information you have provided us.

If you have any questions or concerns related to this Privacy Policy, or would like to exercise any of the rights set forth herein, please email us, with the Subject Line entitled, “Privacy Request” at privacy@gafg.com. You may also call us at (800) 903-1452. In the alternative, you can write to us at: Global Atlantic Financial Company, ATTN: Privacy Inquiry, 4 World Trade Center, 51st Floor, 150 Greenwich Street, New York, NY 10007.

This Privacy Policy was last updated on August 31, 2020. We may update this Privacy Policy from time to time, and we will, when required by law, notify you of such changes or updates. The updated policy will be posted on our website and your continued use of the website after we post a revised policy signifies your acceptance of the revised policy.

Privacy Policy

The Global Atlantic Financial Group, including its affiliates and subsidiaries, (hereinafter “Global Atlantic,” “us”, or “we”) is committed to protecting and safeguarding your privacy. This Privacy Policy describes how we collect and process personal information on individuals who access and use our websites and online platforms and on those individuals who are not otherwise customers of Global Atlantic. If you are an existing customer of Global Atlantic, please see our Global Atlantic Companies Privacy Notice, which provides additional information regarding how we will collect, retain, and share nonpublic personal information.

Personal Information We May Collect From You

The nature, type, and scope of personal information that Global Atlantic collects and retains is based on the relationship we have with individuals, and the types of services we provide them. The following are examples of the personal information types, and other information that Global Atlantic collects as part of our routine business practices:

The Global Atlantic Website. Except for existing customers, the Global Atlantic website (www.globalatlantic.com), does not request that the user provide any type of personal or business contact information (e.g., names, telephone numbers, email addresses). The Global Atlantic website does collect and use cookie data and automated tracking tools (see below) in accordance with this Privacy Policy.

Online Accounts. Our existing customers, consumers, and other professionals may register and create an account to access and use our online platforms and portals.  During the account registration process, we will collect the following information: your title, name, company/business organization, address, and Social Security Number. We will collect and use this personal information in order to  verify your identity and your relationship with Global Atlantic, and to establish, maintain, and administer your online account with us. We will retain and share this personal information in accordance with this Privacy Policy.

Social Media Platforms. Global Atlantic is engaged on social media platforms, and you may voluntarily choose to access these platforms, or otherwise follow our activities online. We will only collect the information that you voluntarily provide to us on these platforms, and such information is generally limited to names, online identifiers, email addresses, and other contact information. Please do not post any sensitive personal information, or other information that is considered private or confidential, on our publicly available social media platforms. Additionally, we offer the ability to sign into some of our services, such as our online accounts (see above), via Facebook Connect, which will authenticate your identity and provide you the option to share certain personal information with us (e.g., name and e-mail address) to pre-populate forms and documents. For more information about Facebook Connect, please see Facebook’s data policy and if you do not want data to be collected via Facebook Connect, please do not use the Facebook Connect function. Some of our social media platforms use cookie data and automated tracking tools (see below) in accordance with this Privacy Policy.

Inquiries & Communications. There may be other times that you provide Global Atlantic information about yourself or others. For example, if you communicate with Global Atlantic’s helpline or a sales representative, you may provide your personal information, such as contact data (e.g., name, address, telephone, email) and other personal information related to your communication (e.g., employer, consumer preferences, and interests). We will collect the personal information that we think is reasonably necessary to your inquiry or that is otherwise related to your communication. We will collect and retain such information in accordance with the purposes you provided it, and with our legitimate business interests.

Vendors and Suppliers. Global Atlantic may collect and process personal information concerning our vendors and suppliers, including their name, contact details, job title, bank account details and financial information (including credit/income history), transaction history, and communications. We process this information to facilitate routine and common business practices related to vendor management, contract and project development, payment and credit collection, legal compliance, accounting, litigation, and to defend our personnel, property, and interests. We generally collect this information directly from you, or from your employer. However, we reserve the right to collect general business information, such as performance reviews, from other third-parties.

Cookie Data and Automated Tracking Tools

As you navigate through the Global Atlantic website, we may automatically collect certain information. For example, we may collect your Internet Protocol (IP) address and the website pages you visited. An IP address is a number assigned to your computer by your Internet service provider which enables you to access the Internet. We may also place a “cookie” on your computer or other device you use to access our website. A cookie is a piece of information that is stored on the browser on your computer or access device that helps our website remember information about you and your preferences when you return to our website. “Session” cookies are temporary bits of information that are erased once you exit your browser window or turn your computer or access device off. Session cookies are used to improve navigation on our website and to collect aggregate statistical information. This website uses cookies and session cookies.

We also may use Google Analytics to help analyze how visitors use our websites. Google Analytics uses cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The anonymous information generated by the cookie about your use of the website (including your IP address) is transmitted to Google, and this information is solely used to evaluate visitors’ use of the website and to compile statistical reports on website activity for Global Atlantic. We will never use Google Analytics to track or to collect any personal information about you. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link an IP address with the identity of any person. By using a browser plugin provided by Google, you can opt-out of Google Analytics. You can learn more about Google’s privacy practices by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

We also use LinkedIn Analytics, which are a selection of metrics that capture the performance of the websites we operate on LinkedIn. Like other social media tools, LinkedIn Analytics measures and tracks user metrics, such as our followers and visitors, and their clicks, shares, and comments. For more information, see LinkedIn's privacy policy.

Use and Sharing of Your Information

If you are an existing customer of Global Atlantic, we will collect, retain, and share your personal information in accordance with our Global Atlantic Companies Privacy Notice and the “Online Accounts” section of this Privacy Policy, provided you have registered to receive access to our online portals. For all the other individuals we collect personal information from, we will use and share your personal information in accordance with the following:

For website users, we may use your information to improve the content of our website and to customize the website to your preferences.

For consumer-related inquiries and communications, we use the information you provide to us to deliver responsive information and solutions in connection with retirement, as well as life and pre-need products and services.

We may share personal information that we collect to third-party service providers and nonaffiliated companies to support our legitimate business interests, assist in our ability to satisfy our contractual obligations, and perform other support or marketing services, such as data processing and mailings.

We may share personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Global Atlantic’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Global Atlantic would be among the assets transferred.

We may share personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Global Atlantic or others.

We may share personal information for any other purpose for which we have your consent, or to fulfill the purpose(s) for which you provide the information to us.

We Do Not Sell Your Data

We do not sell or rent personal information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.

Protecting Personal Information

To protect your information from unauthorized access and use, we have adopted security measures that comply with applicable law, and are reasonably designed to protect the availability, confidentiality, and integrity of your personal information. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any electronic transmission of personal information (e.g., over the Internet) is at your own risk, and Global Atlantic is not responsible for circumvention of any privacy settings or security measures contained on its website. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user name and password to access our websites or online accounts, you are responsible for maintaining the security and confidentiality of those credentials. You must immediately contact us if you know, or have reason to suspect, that your user name or password to our website or online account has been compromised or otherwise subject to unauthorized access, use, or disclosure.

Information Stored in the United States

Global Atlantic is headquartered in the United States, and the information (including personal information) that we collect is most often stored, and retained, in the United States. If you are located outside of the United States, please be aware that information you submit will be transferred to the United States, and that the United States may not provide the same level of protections as the laws in your country of residence. By continuing to provide us such information you hereby consent to this transfer.

Retention of Personal Information

Global Atlantic retains your personal information for the time period reasonably necessary to satisfy the purpose it was collected for, or as long as necessary to comply with legal obligations, or for the establishment, exercise, or defense of a legal claim. Generally, we retain your personal information for the duration needed to complete, or facilitate, a contract, agreement, or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions, or in compliance with applicable laws.

Third-Party Websites

We wish to remind you that this Privacy Policy applies to personal information that you provide to Global Atlantic, whether voluntarily or automatically when using our online services. It does not apply to any links to a third-party’s website and/or online services, such as third-party applications, that you may encounter when using use our website services. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third-parties. Please be aware that we are not responsible for the privacy practices of any third-parties.

Your Rights and Responsibilities

Depending on the jurisdiction in which you reside, you may have the following rights with respect to the personal information we hold about you. If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below in the “Questions or Concerns” section. We may need to collect and process information about you solely for the purpose of responding and satisfying any such data request.

Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future.

California Privacy Rights. Pursuant to California’s “Shine the Light” law, California residents who provide personal information (as defined in the applicable statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. Global Atlantic does not, at any time, share your personal information with a third-party with whom we know, or have reason to believe, uses the personal information to undertake independent direct marketing. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents may have certain data privacy rights, such as the right to be notified about what personal information categories are collected about you, and our intended use and purpose for collecting your personal information. You have the right to request access to your personal information and, to the extent feasible, request that it be transmitted in certain forms and formats. You may have the right to request that we (and any applicable service provider) delete your personal information. You have the right to know whether we sell or disclose your personal information. For clarity purposes, Global Atlantic does not sell your personal information. Rather, we only disclose your personal information in accordance with this Privacy Policy. You have the right not to be subject to discrimination for asserting your rights under the CCPA. With limited exceptions, the CCPA does not apply to personal information collected, processed, sold, or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102), and its implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the California Financial Code).

Children’s Privacy. Our website is not directed to children under eighteen (18) years of age, and we do not intend to collect personal information from minors. By using this website, or otherwise engaging with Global Atlantic, you represent and warrant to Global Atlantic that you are over the age of eighteen (18).

Do Not Track. Some browsers have a “Do Not Track” feature, which permits you to inform websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. At this time, Global Atlantic’s website is not able to respond to “Do Not Track” browser requests.

The General Data Protection Regulation. If you are located in the European Union, you may have certain rights with respect to the personal information we have about you. To the extent permitted by applicable data protection laws, you may access the personal information we hold about you; request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted; and request that we provide your personal information in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time when we are relying on your consent for processing your personal information. You may object to our processing of your personal information where that processing is based on our legitimate business interest. You have the right to lodge a complaint with your competent data protection authority.

California Consumer Privacy Act Requests

If you are a California resident and would like to submit a privacy request, as allowed under the California Consumer Privacy Act, you may make a request by phone or through our web form.

Phone: 800-903-1452. Please leave your name and phone number and your call will be returned by a member of our privacy team.
Request Form: CCPA-Request

Your Responsibilities

With regard to any personal information that you provide Global Atlantic, regardless of whether that personal information relates to you or a third-party, you must ensure, on a continuing basis that (i) such personal information is accurate, relevant, and complete, (ii) you have the lawful basis to provide us with such personal information, and (iii) you have provided information related to this Privacy Policy to, and/or received consent from, any third party whose personal information you have provided us.

Questions or Concerns

If you have any questions or concerns related to this Privacy Policy, or would like to exercise any of the rights set forth herein, please email us, with the Subject Line entitled, “Privacy Request” at privacy@gafg.com. You may also call us at (800) 903-1452. In the alternative, you can write to us at: Global Atlantic Financial Company, ATTN: Privacy Inquiry, 4 World Trade Center, 51st Floor, 150 Greenwich Street, New York, NY 10007.

Last Updated

This Privacy Policy was last updated on August 31, 2020. We may update this Privacy Policy from time to time, and we will, when required by law, notify you of such changes or updates. The updated policy will be posted on our website and your continued use of the website after we post a revised policy signifies your acceptance of the revised policy.