Privacy Policy And Notice For California Residents

This Privacy Policy and Notice applies to personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 (CCPA). 

This Privacy Policy and Notice does not apply to personal information collected pursuant to:

  • the federal Gramm-Leach-Bliley Act and its implementing regulations;
  • the California Financial Information Privacy Act; or
  • certain medical and health information covered by the Health Insurance Portability and Accountability Act (HIPAA).

Your privacy is important to Sun Life.  We are committed to maintaining the privacy and security of your personal information.

Personal Information We Collect

Sun Life* collects information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).  We have collected in the past 12 months and may continue to collect these categories of your personal information:

Personal Information We Collect
Category of Personal Information Examples of Personal Information Collected

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers.

Personal information categories listed in the California Customer Records statute

A 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, or any other financial, medical, or health insurance information.

*Some personal information included in this category may overlap with other categories.

Characteristics of protected classifications under California or federal law

Race, color, age (40 years and older), ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information

Physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, voice recordings, gait patterns or rhythms, and sleep, health, or exercise information.

Internet or other electronic network activity information

Information regarding a consumer’s interaction with our Internet Web sites, applications, or advertisements.

Geolocation data

Physical location and/or movements determined by means of digital information processed via the Internet.

Sensory data

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

Professional or employment-related information

Current and/or past employment history including performance evaluations.

Non-public education information (as defined in the Family Educational Rights and Privacy Act)

Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, or student disciplinary records.

Inferences drawn from other personal information

Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources of Personal Information

We generally obtain your personal information from one or more of these categories of sources:

  • Directly from You
  • Employers/Benefits Administrators
  • Brokers/Agents
  • Service Providers
  • Our Website and Related Applications
  • Other Third Parties (these may include, but are not limited to, third party administrators, healthcare providers, authorized representatives, vendors, social media sites, consumer reporting agencies, and regulatory agencies)

Uses of Personal Information

Sun Life does not sell your personal information. We may use the above categories of personal information for these commercial or business purposes:

  • To provide the products and services you and/or your employer have requested
  • To create, maintain, and service your accounts
  • To help us develop financial products and services and inform you about them
  • For internal business purposes, including but not limited to audit, risk management, security, and quality control purposes
  • As described to you when collecting your personal information or as otherwise set forth in the California Consumer Privacy Act
  • To obtain reinsurance
  • To collect and display personal testimonials of our satisfied clients. With the client’s consent, we may publish a testimonial for advertising, publicity, promotional, or educational purposes, including in print, television, radio, online, within a multimedia presentation, or on social media
  • To comply with federal, state or local laws, respond to a subpoena, or comply with an inquiry by a governmental agency or regulator
  • For any other legally permissible purpose related to the products or services we provide

Once we obtain your personal information, we do not further disclose it except as permitted or required by law. We may share your information within Sun Life for the above purposes. We also may disclose your information to third parties that perform services on our behalf. If we disclose your information to third parties, we require them to protect the privacy of your information. We permit them to use and disclose your information only for the purpose(s) for which we provided it.

Third Parties with Whom Personal Information is Disclosed

We have disclosed in the past 12 months and may continue to disclose the above categories of your personal information for the above commercial or business purposes within the Sun Life group of companies and to these categories of third parties:

  • Service providers that help us conduct our business and perform services on our behalf
  • Brokers/agents
  • Employers/Benefits Administrators and their service providers
  • Reinsurers
  • Government agencies, regulatory authorities and other third parties as required by law
  • You and your authorized representative(s)

Your Privacy Rights

How to Exercise Your Rights and/or Obtain Further Information

To submit a request to access or delete your personal information, you or your authorized agent must fill out the appropriate request form. You can obtain the necessary request form on our website at www.sunlife.com/us. Select Find a Form and locate the Miscellaneous forms section. You can also obtain the necessary request form by contacting us at:

Phone: 1-888-444-2045
Address: One Sun Life Executive Park, Wellesley Hills, MA 02481
Email: Mypersonaldatarequest@sunlife.com

Once completed, you or your authorized agent should return the request form to us using one of the methods noted on the form.  If an authorized agent makes an access or deletion request on your behalf, you must give the authorized agent signed permission to do so.  We will require a copy of the signed permission that you gave the agent to submit the request (if applicable, we may instead require proof that you have granted your authorized agent power of attorney pursuant to California probate law).  Upon receipt of your completed form, we will use the information on the form to verify your identity.  If necessary, we will contact you if we need more information to verify your identity.  Sun Life may not be able to complete your request if we cannot verify your identity, your authorized agent’s identity, or your signed authorized agent permission.

If you have more questions, or for any accessibility issues including how to access this document in an alternative format, please contact us using one of the methods noted above.  You can also visit our website at www.sunlife.com/us to learn more about how Sun Life protects your privacy.  Click on the privacy link at the bottom of that web page for further information.

Access to Your Personal Information

You have the right to request that we disclose to you:

  • Categories of personal information we have collected about you;
  • Categories of sources from which we collect your personal information;
  • Business or commercial purposes for collecting or selling your personal information;
  • Categories of third parties with whom we share your personal information; and
  • Specific pieces of personal information we have collected about you.

You may make up to two requests in any 12 month period. You also have the right to opt out of the sale of your personal information and/or to request that we disclose to you:

  • Categories of your personal information that we have sold, and
  • Categories of third parties to whom we sold your personal information, by category or categories of personal information for each third party to whom we sold your personal information.

However, we do not sell your personal information as noted above.

Access to Categories of Personal Information We Have Disclosed for a Business Purpose

You have the right to request that we disclose to you the categories of your personal information that we have disclosed about you for a business purpose.

Deletion

You have the right to request that we delete your personal information. We will promptly consider all deletion requests. However, California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it. An example includes when we need to retain your personal information to process an insurance claim you filed. We will notify you of any denial of your deletion request and the reason for such denial.

Nondiscrimination

We will not discriminate against you because you have chosen to exercise any of your privacy rights listed above.

For a printable version of our CCPA Privacy Policy and Notice:

Last updated: July 1, 2020

*This Privacy Policy and Notice is provided by Sun Life Assurance Company of Canada, and affiliated companies Sun Life and Health Insurance Company (U.S.), Independence Life and Annuity Company, Professional Insurance Company, and UDC Dental California, Inc.