Effective Date: January 1, 2020

Introduction

We understand that you care about how information about you is collected, used and shared, and we appreciate the trust you place with us. At the core of our commitment to protect the financial well-being of you and the people that matter most in your life is a commitment to protect your privacy. Our policies and procedures are designed to protect personal information about you. This Privacy Policy (“Policy”) will help you understand how we collect, use, share and protect any personal information we have about you. 

In general, we collect and process personal information necessary to issue you insurance and financial service products (like your name, address, telephone number, payment information), to assist you if you need to file a claim or obtain a benefit (for example, your health information), or to provide you with information on our products or special offers. We also are required to collect and process certain personal information to meet legal and regulatory requirements (for example, to verify your identity). While we share your information with credit unions, our affiliates, service providers, and other businesses that we work with to provide our products and services (“Business Partners”), we do not sell your personal information, and we prohibit any sale of the personal information we share with our Business Partners. As described in more detail below, you may have rights with respect to the information we collect about you. We encourage you to read this Policy carefully, and to contact us if you have any questions.

When does this Policy apply?

This Policy applies to CMFG Life Insurance Company, MEMBERS Life Insurance Company, CUNA Brokerage Services, Inc., CUMIS Insurance Society, Inc., and TruStage Insurance Agency, LLC (“CUNA Mutual”). This Policy applies when we process personal information about our customers, our potential customers, applicants for jobs with CUNA Mutual, and visitors to our website(s). Whenever we collect personal information about you, we make decisions about how and why we process that personal information and, because of this, we are responsible for making sure it is used in accordance with applicable data protection and privacy laws.

If you are an employee or contractor of CUNA Mutual, please refer to our internal policies and procedures on how we process your personal information.

What types of personal information do we collect, where do we get it from, and why?

We typically collect personal information directly from you or from our Business Partners. We also may collect personal information about you through your interactions with our information technology resources, such as our website(s). In addition, we may create records of personal information about you in the course of providing services or products to you, either directly or through our Business Partners. We also may collect personal information about you from third parties, including government agencies and third parties who provide services to us. In all cases, we collect personal information about you in accordance with the principles outlined in this Policy and applicable law.

The following table provides more detailed information on the personal information we collect and why:

Information we collect

Why we collect it

If you apply for, inquire about, or obtain a service or product from us, we collect a range of identifiable personal information based on the particular product and circumstances, possibly including: name, address, contact information, Social Security number or other identifier, financial and account information, health information, biometric information, demographic information, commercial information about your previous interactions with us, and recordings of our calls with you.

This information is necessary for us to provide services or products you requested or to take steps enroll in those services or products, for us to comply with a legal obligation, or to carry out related business and operational activities.

If you do business with our Business Partners, we may collect personal information about you to allow us to identify and offer you products that may be of interest to you. This information may include your name, address, contact information, Social Security number or other identifier(s), financial information, demographic information, commercial information about your purchasing history, employment and professional information, and inferences based on this information regarding your preferences.

This information is used to offer products and services that may be of interest to you as permitted and subject to applicable law.

If you visit our website(s) or interact with our electronic communications, we collect your IP address as well as electronic activity information about your use and interaction with our website(s) or communications, and geolocation data.

You can find more information on how we collect information in the Cookies section of this Policy.

This information is necessary for us to ensure the security and functionality of our website(s) and related technology resources. This information is also used to offer products and services that may be of interest to you.

If you provide your email address to us or otherwise request or agree to receive electronic communications from us, we may collect your name, email address, phone number, or physical address.

Note that we may send you electronic communications based on your other interactions with CUNA Mutual and our Business Partners. You may unsubscribe at any time by clicking the unsubscribe link or by unsubscribing in your account settings.

This information is necessary to send you the communications and information you have requested.

If you use our online financial management calculators, we will collect personal financial information.

This information is necessary to provide you with financial planning advice and suitable products. This information is also used to offer products and services that may be of interest to you.

If you apply for a position with us, or apply to be our registered representative or agent, we will collect your name, address, telephone number, email address, employment and educational history, and other biographical and background information.

This information is necessary to determine whether to extend an offer of employment, or approve your application to represent us, as applicable. This information also is necessary to comply with our legal obligations.

Additional information for California residents

The personal information we collect about you includes information within the categories below. These categories are defined by California law and represent the personal information that we have collected about California residents, and how it has been shared, over the past 12 months. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals. We have shared information in each category with our affiliates and service providers for our business purposes within the last 12 months. We have not necessarily shared all information listed in a category. We also share information as described in our financial and insurance privacy notices.

Category

Sources

Purpose of processing

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

- from government agencies

This information is processed in connection with our operational functions, including for example policy issuance and account administration and management, risk and compliance management, human resources, and systems development. It is also processed to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

For job applicants, a subset of this information is used to process your application.

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

- from government agencies

This information is processed in connection with our operational functions, including for example policy issuance and account administration and management, risk and compliance management, human resources, and systems development. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

For job applicants, a subset of this information, including education history, is used to process your application.

Demographic information protected under federal or state law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

- from government agencies

This information is processed in connection with our operational functions as permitted by law, including for example policy issuance and account administration and management, risk and compliance management, product development, human resources, and systems development. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

This information is processed in connection with our operational functions, including for example policy issuance and account administration and management, human resources, and risk and compliance management. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

Biometric information, which includes physiological, biological or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our affiliates

- from our service providers

This information is processed in connection with policy issuance, human resources, and account administration and management. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

This information is processed in connection with policy issuance, account administration and management, and data analytics. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

Geolocation data

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

This information is processed in connection with policy issuance, account administration and management, and data analytics. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

Audio, electronic, visual, thermal, olfactory, or similar information

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

This information is processed in connection with our operational functions, including for example policy issuance and account administration and management, human resources, and risk and compliance management. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity.

If you call us, we may record the call for these purposes.

Professional or employment-related information

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

- from government agencies

This information is processed in connection with our operational functions, including for example policy issuance and account administration and management, human resources, and risk and compliance management. It is also processed in order to protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.

Inferences drawn from any of the above categories of information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We collect information in this category:

- directly from you or your interactions with our information technology resources

- from our Business Partners

- from records we have about you in the course of providing services or products

- from government agencies

This information is processed in connection with our operational functions, including for example policy and account administration and management, risk and compliance management, human resources, and product development. It is also processed in order to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for data analytics.

This information is also used for marketing purposes, including offering you products that may interest you through both direct and Business Partner marketing.


Cookies

When you visit our website(s), we use so-called “cookies” to make our website(s) more user-friendly, effective, and secure. A cookie is a small piece of data sent from a website and stored in a file on your browser. A cookie is useful for having the browser remember specific information across several pages or between visits to a website. In addition to cookies, we use scripting, which is code run on the website to collect information such as actions you’ve completed on our website or items you click on. We also use “pixels,” which are transparent image files sent from the website to your browser to help us record items like IP address and time. For the purposes of this Policy, we refer to all these technologies as “cookies.”

We do not store any sensitive information within your cookies. Our website(s) does not read any information stored in cookies given to you from other websites, except in rare cases where the other website is a provider of information or functionality within our website and that cookie is necessary to make our website function correctly.

Most of the cookies we use are “session cookies” which are automatically deleted as soon as you leave the site. Other cookies, so-called “persistent cookies,” remain on your computer until you delete them. Using these cookies allow us to enhance your experience in interacting with our website, such as by helping recognize your browser the next time you visit and loading previously viewed pages faster. We use cookies to offer you the best possible experience on our website.

We also use cookies to collect browsing information in order to improve your overall experience. We use this information to track website usage and compile statistics. This helps us improve the website, so you will find it more useful and informative, and enable customized promotions you may be interested in. We may use the combination of data we collect, such as browsing information and email address, to join known devices together and provide you personalized experiences on the device you are currently using. Impression data from cookies, which indicates who has seen advertisements about our products and services on our website or third-party websites, may be used to improve our marketing practices. If you are a current customer, have logged into your account, obtain a policy from our website or provide your email address, we may use analytics software to link data we collect, such as use of our website, opening emails we send you or contacting our customer service center via phone, back to you.

We may use browsing information we collect (including IP address, email address and data received from Google Analytics) to match with information received from third parties (including behavioral information and device identifiers) and policyholder information to learn more about an individual or a group. These actions help us analyze interactions with our website, improve marketing efforts, inform our strategic approach and improve your experience. We also may use this information to directly market our products and services, to the extent permitted by law. We may use third parties to perform these and other activities.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. Parts of our website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our website, please enable cookies within your browser.

We also enable cookies to be placed or accessed on your device by third party advertising networks. These kinds of persistent cookies remember the websites you visit, and that information is shared with other parties, such as advertisers. We may use third-party advertising networks to help us deliver tailored online ads to you. To learn more about opting-out of this type of interest-based advertising, please visit the Network Advertising Alliance (NAI) Consumer opt-out website.

Do Not Track

We do not currently support the capability to respond to web browser “do not track” signals.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of our website. This tool uses persistent cookies to allow us to see behavior information relating to visitor age, gender and interests. We may also use this data to create remarketing lists. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings.

You can opt out of Google Analytics without affecting how you visit our website. For more information on opting out of Google Analytics tracking, visit this Google page.

Mobile Marketing

If you enroll in a CUNA Mutual Group mobile program, you will have the opportunity to opt-in to receive notifications via text message. If you do opt in, we will collect your mobile phone number to send you text notifications. We will send you notifications only according to the terms and conditions of the mobile program you join and will not use the mobile phone number you register with the program for any other purpose without your consent. You may opt-out of receiving these notifications at any time and choosing to do so will not affect your ability to participate in CUNA Mutual Group offerings.

Who do we share your personal information with, and why?

We may disclose your personal information to our affiliated companies, when required by law, or with our service providers for the purposes described in this Policy and in accordance with our financial privacy notices. We may also share information, including your personal information, to third parties as necessary to provide the products and services you request, such as underwriting your risk or assisting you in completing a transaction.

The third parties we may share your personal information with include:

  • credit unions or strategic partners;
  • nonaffiliated service providers;
  • regulatory authorities;
  • our auditors and legal advisors;
  • relevant industry self-regulatory bodies; and
  • others, where permitted by law.

We do not sell your personal information, and we have contracts with our service providers to prohibit any sale of your personal information and to provide written assurances regarding the security and privacy protections they have in place to protect your personal information. We may share your personal information with your credit union and other nonaffiliated financial companies in order to offer you products and services that may interest you.

We may share your information with our corporate affiliates (companies related by common ownership or control) where permitted by law and as further described in our financial privacy notices. We share your information with affiliates so they can provide services to us and where necessary to provide you with services, products, or information you have requested or expressed an interest in.

In the event there is a change in the corporate structure of CUNA Mutual, such as, but not limited to, merger, consolidation, sale, liquidation, or transfer of substantial assets, CUNA Mutual may, in its sole discretion, transfer, sell or assign personal information we have about you to one or more affiliated or unaffiliated third parties.

Your information may only be transferred to another country for processing as permitted and in compliance with applicable law.

Where do we keep your personal information and how long do we keep it?

We store personal information about you on computer systems operated by us or our service providers. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws and regulations.

How is my personal information secured?

We maintain physical, technological and administrative safeguards to protect your personal information and prevent unauthorized or accidental use, access, or loss. We limit access to personal information about you to those who have a business need for such access. Individuals who process personal information on our Business Partner’s behalf generally may do so only in an authorized manner and are required to keep your information confidential. We have policies in place that regulate how our employees and contractors handle information about you. We limit access to our premises and to our computer networks and take steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security incident and will notify you consistent with applicable legal requirements.

Your Rights

You may have various rights with respect to your personal information depending on where you live, the information we have about you, and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not apply to our relationship with you or your personal information.

We may choose to extend these rights to you even if we are not required to under applicable law.

Privacy Rights under Financial and Insurance Privacy Laws

In general, to the extent we received, obtained, or generated information about you in connection with providing you with a financial service or product within the United States, your rights with respect to that information are governed by financial and insurance privacy laws, including the Gramm-Leach-Bliley Act (GLBA). We provide financial and insurance privacy notices to our consumers and customers as required by law, and these notices address your rights with respect to this information. For more information about these rights, including your right to opt-out of sharing your information with third parties, please see our financial and insurance privacy notices:

Privacy Rights under the California Consumer Privacy Act

For residents of California, to the extent we have collected information about you that is not governed by financial and insurance privacy laws, you may have rights to your personal information as described below:

  • Right to know – You may be entitled to request that we disclose to you personal information we have collected about you, the categories of sources from which we collected the information, the purposes of collecting the information, the categories of third parties with whom we have shared the information, and the categories of personal information that we have shared with third parties for a business purpose. In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing any of this information, we must be able to verify your identity.
  • Right to opt-out – We currently do not sell personal information to third parties, and therefore do not offer this option. We may share personal information about you with our Business Partners as permitted by law. Please see the “Who do we share your personal information with, and why?” portion of this policy for more information.
  • Right to deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with life insurance or annuity products or where required to be retained for regulatory purposes.

We do not discriminate against you if you choose to exercise these rights.

Submitting Privacy Requests

You can exercise your privacy rights by submitting requests to us to exercise those rights and by taking other steps that will limit how information about you is collected, used, and shared.

Unsubscribe from promotional emails

If you no longer wish to receive marketing or promotional emails from us, please click the unsubscribe or manage subscriptions link included in the footer of every promotional email we send, or contact us directly as provided in the “Contact Us” section of this policy.

Limit the use of cookies

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You can also disable your browser from accepting cookies and delete cookies that have previously been placed on your device. Disabling and deleting cookies is unique to each browser and device you use. Disabling and deleting cookies on one device will restrict the ability to tie that device to other devices you use. Instructions for deleting and disabling cookies are available from the providers of most widely used internet browsers. Parts of our website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our website, please enable cookies within your browser.

Opt-out of third-party advertising tracking

Several network advertising industry groups provide tools for consumers to opt-out of interest-based advertising. The Network Advertising Initiative (“NAI”) provides one such tool for opting out of this kind of advertising from its members, which may be accessed by visiting the Network Advertising Alliance (NAI) Consumer opt-out website. A similar tool is also available through the Digital Advertising Alliance’s (“DAA”) consumer choice tool, which may be accessed by visiting the DAA’s YourAdChoices website. As noted above, visitors to our website can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings. For more information on opting out of Google Analytics tracking, visit this Google page. You can also disable ad personalization and tracking within the settings of your device, browser and social media accounts. 

Opt-out of sharing with our financial joint marketing partners

If you prefer that we do not share your personal information for joint marketing purposes with your credit union or any other nonaffiliated financial company, you may, to the extent applicable, exercise your right to opt-out of such sharing. Please submit your request electronically to membersproducts.com/privacychoices or by calling this toll-free number – 800.834.2617 – to speak to a customer service representative.

Submit personal information requests under the CCPA

For residents of California, you may exercise your privacy rights under the CCPA by submitting a Personal Information Request by visiting privacy.cunamutual.com or by calling this toll-free number – 800.834.2617 – to speak to a customer service representative.

We must verify your identity before fulfilling your personal information request. To verify your identity, we will collect information from you, including, to the extent applicable, your name, government identification number, date of birth, contact information, your account information, answers to security questions, or other personal identifying information. We will match this information against information we have previously collected about you or against information available from consumer reports to verify your identity and to respond to your request. Information collected for purposes of verifying your request will only be used for verification and to respond to your personal information request.

If you maintain an account with us, we may require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, we require you to verify your identity with us directly before we provide any requested information to your approved agent.

Children and minors

We do not knowingly collect personal information directly from individuals under 17 years of age. Our services are not intended for individuals under 17 years of age. No one under 17 years of age should submit or post personal information through our services. We may collect personal information regarding individuals under 17 years of age from their parents or legal guardians, but only as necessary to provide our products and services. 

Linking to Third Parties

When you leave this website and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, we do not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by us.

Changes to this Policy

We reserve the right to change this Privacy Policy at any time in our sole discretion. If we make changes, we will post the revised policy here, so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our services after notice is provided, you accept and agree to this Privacy Policy as modified.

International Users

This website is based and administered in the United States of America. The website is governed by the laws of the United States and is not directed at users based outside of the United States.

Contact Us

If you have any questions about this Policy or your privacy rights, please contact us at:

Mail
CUNA Mutual Group 
P.O. Box 61
Waverly, IA 50677-0061

Telephone Number
800.834.2617

Email Address
privacychoicesmail@cunamutual.com