Client Privacy Policy

This Online Privacy Policy (“Policy”) is applicable to the websites of Global Atlantic Financial Group Limited and its subsidiaries, including Accordia Life and Annuity Company, Commonwealth Annuity and Life Insurance Company, First Allmerica Financial Life Insurance Company, Forethought Life Insurance Company, Forethought National Life Insurance Company and Global Atlantic Re Limited (collectively, the “Global Atlantic Companies”). The Policy applies to online visitors to this website and summarizes the actions we have taken to ensure the privacy and security of information you provide through the website. The term “website” as used in this Policy includes Internet websites and mobile applications of the Global Atlantic Companies.

If you are a customer of one of the Global Atlantic Companies, you will receive a separate notice that describes the privacy policy of the company in connection with its financial products and services.

By using this website, you agree to the terms of this Policy. You consent to the collection, use and disclosure of information you submit or that we may collect in the manner described in this Policy.

We collect information from you that you voluntarily give us through our website, by email or other electronic contact with us. Some of the information you provide to us may be personal information that can be identified with you, such as your name, street address, email address, telephone number and other contact information. We also collect information from you by asking you for specific information and by permitting you to communicate directly with us via email, text messaging, feedback forms, and online chats. You may be asked to provide information in order to enable you to make use of certain features of the website or to participate in a particular activity on the website. In such cases, you will be told when you are required to provide information to us. We will maintain all information we collect in accordance with this Policy.

As you navigate through our website, we may collect certain information without your providing the information. 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 that 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 site uses cookies and session cookies.

We also may use Google Analytics to help analyze how visitors use this website. 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 the Global Atlantic Companies. 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.

We will not associate any data gathered from this website with any of your personal information from any source unless you explicitly submit that information via a fill-in form on our website or when you access the financial services or products of one of the Global Atlantic Companies through our website.

We use the information you provide through the website to deliver responsive information and solutions in connection with retirement, life and pre-need products and services. We may also analyze certain types of information - but not your personally identifiable information - to determine trends and patterns. If you provide us with your email address and agree to allow us to contact you, we may use your email address for that purpose.

Except as otherwise stated, we may use your information to improve the content of our website, to customize the website to your preferences, to communicate information to you (if you have requested it), for our marketing and research purposes, and for the other purposes specified in this Policy. If you provide personally identifiable information through this website, we may combine such information with other information we collected unless we specify otherwise at the point of collection.

We do not sell or rent information about you to anyone. We may share your personally identifiable information with our affiliated companies. We also may share your personally identifiable information to select third parties located in the United States or in another country in certain circumstances. For example, we may share your information with third parties (1) to process or service a product or service you request or authorize, (2) so that a third party may perform services on our behalf, (3) when required by applicable laws, court orders, or government regulations, (4) with which we have joint marketing agreements, and (5) as otherwise permitted by law.

Third parties with whom we may share information about you may include, among others, independent contractors, insurance support organizations, insurance agents and brokers, health information management providers, third party administrators, reinsurance providers, credit reporting agencies, financial institutions for joint marketing purposes, courts and government agencies.

In addition, we may use all information acquired through this website that is not in personally identifiable form.

To protect your information from unauthorized access and use, we have adopted security measures that comply with applicable law and which are reasonably designed to protect the availability, confidentiality and integrity of the personal information of our customers. These include computer safeguards and secured files and buildings.

This website may contain links or references to websites of other companies. This Policy does not apply to the websites of those companies. We do not control those websites and are not responsible for their content or privacy practices.

From time to time we may through this website request information via surveys and contests. Participation in these surveys and contests is voluntary. You may choose whether or not to participate and therefore disclose specific information, which may include contact information (such as your name or address) and demographic information (such as your zip code or age). Your contact information will be used to notify winners and award prizes. Any survey information is used for purposes of monitoring or improving the use and satisfaction of this website and our marketing efforts in general.

We do not knowingly collect personal information from anyone under the age of 13 without obtaining consent from a parent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website at www.ftc.gov.

When we make changes to this Policy, we will update it and post it on this website with a new effective date.

This Online Privacy Policy is effective as of March 21, 2016.