Privacy Notice

Effective Date: March 1, 2024

This Privacy Notice is provided on behalf of Nassau Life Insurance Company, PHL Variable Insurance Company, Nassau Life and Annuity Company, Nassau Life Insurance Company of Kansas, Nassau Asset Management LLC and its subsidiaries (collectively, “Nassau” “we,” “our,” “us”).

This Privacy Notice refers only to the websites and applications that link to this Privacy Notice. You may also want to read our corporate privacy policy. Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to this Notice). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

We are not responsible for the content or information practices of any third-party websites to which the Services refer or link. We urge you to read their policies regarding their privacy practices.

Personal Login

Certain segments of the Services require a personal login to customize your experience and provide you information that is appropriate to your relationship with Nassau. Depending on where you are on the Services, we may collect some personal information (e.g., name, Social Security number, account number, e-mail address, postal address, company and phone number) about you to facilitate requested communications or facilitate transactions. We will assign you a username, and you will be asked to create your own password. If you forget your username and/or password, you may request assistance through the Services or by contacting a customer service representative at the following numbers:

• Annuities, Variable and Universal Life Insurance: 1-800-541-0171
• Term and Whole Life Insurance: 1-800-628-1936

What Information Does Nassau Collect?

We may obtain information about you when you choose to provide it to us and when we collect it from third parties. We may also collect certain information about your device or usage by automated means, including through technologies such as cookies, web server logs, and web beacons.

Some content or applications on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and devices and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information that You or Others Provide

You may choose to provide information to us in a number of ways, such as when you request a quote, apply for a policy, sign up for promotions or newsletters, purchase our products, register on the Services, post or provide content, or otherwise interact on the Services. The types of information you may provide to us include:

• Information we receive from you on applications or other forms or in order to provide you with a quote (such as name, address, city, state, ZIP code, email address, telephone number, gender, birth date, household information, marital status, information about beneficiaries, and education);
• Information about your transactions and relationships with us, our affiliated companies, and others (such as products or services purchased, account balances, your policy coverage, premiums, and payment history);
• Financial and payment information (such as social security number, net worth, assets, income, expenses, taxes, liabilities, payment card number, expiration date, account number, and billing address);
• Medical information (such as information about your health status or condition, payment for health care, etc.);
• Claim information (such as information you provide when completing beneficiary statements and trust forms);
• Product preferences, advertisement preferences, and other information about how you use the Services;
• Content you submit or post (such as photographs, videos, reviews, articles, comments, or any other information you provide to us or post);
• Employment information, including information you provide when you apply for employment opportunities with Nassau;
• Information we receive from you when you get appointed to sell Nassau Products, use our Nassau Agent mobile application, submit forms or applications, or order marketing materials, including contact information, social security number, date of birth, national producer number, CRD number, experience level, states in which you are appointed to sell, documents you upload, quotes, and service forms and applications you complete; and/or

Records and copies of your correspondence (including email addresses), if you contact us, including your policy number.

We also may collect information about you from third parties, such as:

• Information we receive from a consumer reporting agency (such as information about your creditworthiness and credit history);
• Information we receive from third parties in order to issue and service your policies (such as motor vehicle reports and medical information);
• Information we receive from third party social media sites (see How Does Nassau Share My Information? section below); and/or
• Information we receive from human resources software providers.

Information Collected Automatically

When you visit the Services or our online advertisements, utilize our services, open an email that we send you, or interact with social networking applications, we (and our third-party advertisers and/or service providers) may collect information about your usage or device by automated means. Some of the technologies we use to collect information automatically include:

• Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Some cookies may exist for only a single session and some are persistent for multiple sessions over time. We may use cookies that are managed by Nassau or by third parties (such as social media website cookies) for the purposes provided in this Privacy Notice, including for session management, authentication, user preference storage, Services performance and personalization, Services analytics, advertising (including affiliate marketing), content management, eCommerce, search, security, and social media integration.
• Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your usage of the Services.
• Web beacons, pixels, and analytics software: To control which web servers collect information described above, we may place tags on the Services or in emails called “web beacons” or “pixels.” These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behavior. These tools may also be used to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email, and any URL accessed through our email message. Such tools are also used in connection with online advertisements on the Services and on third-party websites to collect the same types of information with respect to individuals who click on advertisements.

Such technologies may permit collection of data elements such as demographic data, browser type, MAC address and other unique device information, operating system type and settings, domain, the address of the web page that linked you to the Service, IP address, pages visited, whether you have visited us before or are new to the Services, activities conducted on the page (such as search queries), and the day and time of your visit. This information may be correlated to other data that identifies you specifically.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information on your choices for opting out of behavioral tracking on the Services and other mechanisms that enable users to exercise choice about behavioral tracking, see Choices About How We Use and Disclose Your Information.

At this time, we do not honor "do not track" signals from browsers. However, you may refuse or delete cookies. If you refuse or delete cookies, some of the functionality of the Services may be impaired. Please refer to your browser Help instructions to learn more about how to manage cookies and the use of similar technologies.

How Does Nassau Use My Information?

We use your information for the following purposes:

• Offering you products and services, deciding if you qualify for our products and services, and servicing your account;
• Establishing and verifying the identity and eligibility of users;
• Collecting and processing applications for employment;
• Opening, maintaining, administering, managing, and servicing users’ profiles, accounts or memberships;
• Processing, servicing or enforcing transactions (including credit or debit card transactions);
• Providing products, content, content suggestions, services, and support;
• Conducting special events, sweepstakes, surveys, programs, contests, and other offers (and communicating with you about such events);
• Analyzing and improving our products, services, or the Services (including developing new products and services; improving safety; managing our communications; analyzing our products; performing market research; performing data analytics; and performing accounting, auditing and other internal functions);
• Providing users with product, service, or Nassau updates;
• Marketing and advertising our products or services as well as products and services of third parties (such as affiliates, subsidiaries, and business partners);
• Responding to your inquiries or comments, or contacting you as necessary;
• Operating and communicating with you about or through external social networking platforms;
• Maintaining the security and integrity of our systems, including maintaining internal records;
• Conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
• As part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of Nassau’s assets;
• Fulfilling any other purpose for which you provide it;
• Carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us
• In any other way we may describe when you provide the information; and/or
• For any other purpose with your consent.

All information we collect may be aggregated and merged or enhanced with data from other sources, such as third parties or our mobile application. We may also collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Our legal bases for processing your information include:

• Your consent;
• Exercising our rights and performing our obligations in connection with entering into or performing under any contract we make with you;
• Compliance with our legal obligations; and/or
• Our legitimate interests that are not overridden by your interests or your fundamental rights and freedoms, like research and development, to market and promote the Services, and to protect our legal rights and interests.

How Does Nassau Share My Information?

We may disclose all of the information we collect (including your nonpublic personal financial information), as described in the Information that You or Others Provide section above, to both affiliated and non-affiliated third parties, such as:

• To companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements;
• To financial services providers, such as life insurers, automobile insurers, mortgage bankers, securities broker-dealers, and insurance agents;
• To non-financial companies, such as retailers, direct marketers, airlines, and publishers;
• To third parties who help us with our business functions, such as service providers or suppliers. Examples of these service providers include entities that process payments, help us moderate content posted on the Website, provide web hosting, technology, or analytics services, provide review platforms, provide mobile application platforms, provide web mapping platforms (please note that the Services may include Google Maps features and content- Google Maps may collect users’ IP address, latitude and longitude coordinates, and search terms; for more information, please visit Google’s privacy policy, available at: https://policies.google.com/privacy), provide human resources software, provide video sharing platforms (including Vimeo), provide social bookmarking services (please note that we may share information with AddThis, including for the purposes specified in the Oracle privacy policy, available at: https://www.oracle.com/legal/privacy/addthis-privacy-policy.html), provide video communication platforms, provide scheduling services, provide customer service and live chat support, or who assist with marketing functions;
• To third parties involved in servicing and administering products and services on your behalf such as:
• Your agent, broker or producer,
• Banks,
• Reinsurance companies,
• Firms that assist us in the servicing of your policies,
• Firms that assist in the printing or delivering of statements and notices, and/or
• To third parties for specific purposes permitted by law, such as:
• If necessary to protect the safety, property, or other rights of us, our customers, or employees,
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, or as otherwise required by law,
• To State or federal regulators,
• To auditors, and/or
• With your consent in certain circumstances.

We may also disclose your personal information:

• To enforce or apply our agreements with you;
• In the event we sell, transfer, or engage in another transaction involving all or a portion of our business or assets, or undertake another form of corporate change, including bankruptcy. Following such a sale, transfer, or transaction, or corporate change, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information; and/or
• For any other purpose disclosed by us when you provide the information.

We may also contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on the Services and our emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our and third-party marketing efforts.

What About External Social Media Platforms?

The Services may embed plugs-ins, widgets or other apps of various external social media platforms (including, for example, links to our to Facebook, Instagram, LinkedIn, Pinterest, X, and YouTube pages; for more information about YouTube’s collection of information, see Google’s privacy policy at: http://www.google.com/policies/privacy). When you encounter those embedded objects, your Internet browser may make a direct connection to the social media platform’s service and may share with the social media platforms information such as which portions of the Services you have visited, information about your public profile, or content you have posted.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have enabled mechanisms to provide you with the following control over your information:

• Tracking technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.
  
  Google Analytics collects personal information through the Services, including through the use of cookies. For information about how Google Analytics collects and processes information, please visit: https://policies.google.com/technologies/partner-sites. To opt out of having your information used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
  
  Additionally, third parties, including Google (through, for example, our use of Google Analytics Advertising Features, including Dynamic Remarketing), may place and read cookies on your browser, or use web beacons to collect information in connection with ad serving on or through the Services, including for the purposes of showing our ads on sites across the Internet. Our partners will collect personal information for personalization of ads and may use first-party cookies or other first-party identifiers and third-party cookies and other third-party identifiers for personalized and non-personalized advertising and measurement. Ad serving may be based on users’ visits to the Services or other websites on the Internet, and your activity may be tracked over time and across websites. For information about how Google collects, shares, and uses data, please visit: https://policies.google.com/technologies/partner-sites. You can opt out of Google’s use of cookies or device identifiers by visiting the Google Ads Settings web page at: http://www.google.com/ads/preferences/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1. You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative (“NAI”) opt-out page or control the use of device identifiers by using your device’s settings.
  
  We use the Meta Pixel to analyze user activity on the Services for remarketing and behavioral targeting. The Meta Pixel is triggered when you perform certain activities on the Services, and aids us in displaying Facebook ads to Facebook or Instagram users who have visited the Services, or Facebook or Instagram users who share certain characteristics with visitors to the Services. Meta and other third parties may use cookies, web beacons, and other storage technologies to collect information from the Services and from other Internet websites and use that information for the purposes of targeting ads and providing measurement services. Meta may track your activity over time and across websites. For more information about the data Meta collects, please visit Meta’s privacy policy at: https://www.facebook.com/privacy/policy/. For specific information about Meta Pixel, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. For more information about ad targeting and exercising your choice to opt out of the collection and use of information for ad targeting, please visit: https://www.facebook.com/help/568137493302217, or http://optout.aboutads.info/?c=2&lang=EN.
  
  Microsoft collects or receives personal information from our users or us to provide Microsoft Advertising (including through individual end user tracking and data sharing with third parties for advertising and marketing purposes). For more information, please visit the Microsoft Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement.


• Promotional offers from Nassau: If you do not wish to have your information used by Nassau to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to corporate.compliance@nfg.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click “unsubscribe” in the relevant communication. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important service-related announcements, important information about your policy, state-required notices, and other non-marketing communications about your account or purchases that you have made.


• Targeted advertising: We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads (including ads served using non-cookie technologies) from members of the NAI on the NAI's website, available at: https://optout.networkadvertising.org/?c=1. You can also visit the Digital Advertising Alliance’s website, available at https://youradchoices.com/, to use its Consumer Choice Tools. Users in the European Union and United Kingdom ("UK") can visit the European Digital Advertising Alliance opt-out page, located at youronlinechoices.com.

California residents may have additional personal information rights and choices. Please see our Nassau Privacy Notice for California Residents for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: corporate.compliance@nfg.com. However, please know we do not currently sell data triggering that statutes opt-out requirements.

International Data Transfers

When you use the Services and provide information through the Services, we may transfer your information to a destination outside your jurisdiction, including to the United States. The United States has not received a finding of "adequacy" from the EU under Article 45 of the GDPR (or other analogous international data protection regulations, such as the UK GDPR). Nassau relies on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR in order to transfer personal information across international borders.

Individuals in the European Economic Area ("EEA") and the UK may request a copy of applicable Article 46 agreements by contacting us at:
Corporate Compliance, Nassau, One American Row, Hartford, CT 06013

Your Rights

To the extent required by law, Nassau provides you with:

• Reasonable access to the personal information collected through the Services;
• The ability to review, correct, export, and delete such personal information; and
• The ability to restrict processing of your personal information, or object to its processing.

When the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time, but this will not affect any processing we have already performed. If you withdraw your consent, refuse to provide certain information, or provide inaccurate information, you may not be able to access or utilize all of the features or content available on or through the Services, and we may not be able to fulfill your requests for products or information.

Please contact us using any of the methods identified in the Contact Information section below if you would like to exercise your individual rights. We may need to obtain or confirm certain personal information in order to accommodate your request. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Individuals in the EEA and UK: In addition to the above rights, you also have the right to lodge a complaint with a supervisory authority (EEA) or the Commissioner (UK) if you believe we have processed your personal information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern.

Is My Information Secure and How Long is it Retained?

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

We retain your information for as long as needed:

• To conduct business with you;
• As needed for the purposes outlined in this Privacy Notice; and
• As necessary to comply with our legal obligations, resolve disputes, and enforce any agreements.

Does Nassau Collect Information from Children?

Nassau does not intentionally collect information from children, as defined under applicable law, and children should not submit any information to us. If we become aware that a child has provided us with information, we will use reasonable efforts to delete the child’s information from our databases.

Correcting/Updating Your Information

Financial advisors: You may contact us online or call 1-800-541-0171 to change or review the information we maintain about you and your business with Nassau.

Individual investors/policy and contract holders: If you have a concern about your personal or account information maintained by us, or want to correct, update, or confirm your information, please contact us online or call a service representative at 1-800-541-0171 Monday through Friday between 8:30 a.m. and 6 p.m. ET.

Changes to this Privacy Notice

It is our policy to post any changes we make to this Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you in accordance with applicable law. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Services and this Privacy Notice to check for any changes.

Contact Information

To ask questions or comment about this Privacy Notice and our privacy practices, contact us at:

Corporate Compliance, Nassau, One American Row, Hartford, CT 06013

or via email at: corporate.compliance@nfg.com

Nassau Privacy Notice For California Residents

This Privacy Notice is for our customers, users and website visitors who are California consumers, as defined below. This “California Privacy Notice” supplements the information contained in the Nassau Privacy Statement located here (the “Nassau Privacy Policy”), this privacy notice, and any privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of Nassau.

CCPA Rights For California Consumers

Right to Know

California residents have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.

The below chart reflects the categories of personal information we have collected from California residents during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also do not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

Right to Opt Out of Sharing for Cross-Context Behavioral Advertising

In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to affiliates; data analytics providers; advertising networks; financial services providers; life insurers; automobile insurers; mortgage bankers; securities broker-dealers; insurance agents; marketing providers; social networks; video sharing platforms; retailers; airlines; publishers; customer data platforms; mobile application platforms; web mapping platforms; social bookmarking services; video communication platforms; agents; brokers; producers; banks; reinsurance companies; and firms that assist us in the servicing of your policies for this purpose:

• Personal identifiers, such as unique personal identifier, online identifier, Internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; inference data; characteristics of protected classifications under California or federal law; commercial information; and professional or employment-related information.

If you would like to opt out of this sharing, you may exercise your right using our “Do Not Sell or Share My Personal Information” link, or by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, click here.

Right to Opt Out of Sale

While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include actives such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to affiliates; data analytics providers; advertising networks; financial services providers; life insurers; automobile insurers; mortgage bankers; securities broker-dealers; insurance agents; marketing providers; social networks; video sharing platforms; retailers; airlines; publishers; mobile application platforms; web mapping platforms; social bookmarking services; video communication platforms; customer data platforms; agents; brokers; producers; banks; reinsurance companies; and firms that assist us in the servicing of your policies in ways that could be considered a “sale” under California law:

• Personal identifiers, such as unique personal identifier, online identifier, Internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; inference data; characteristics of protected classifications under California or federal law; commercial information; and professional or employment-related information.

We disclosed these categories of information to these third parties in order to market and advertise our products and services; perform analytics; and to maintain, improve, upgrade, or enhance our products or services.

We have no actual knowledge of selling the personal information or the sensitive personal information or minors under 16 years of age.

California residents have the right to opt out of the “sale” of their personal or sensitive personal information.

If you would like to opt out of such disclosures, you may exercise your right using our “Do Not Sell or Share My Personal Information” link, or by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using.

Right to Access

You have the right to request the categories and specific pieces of personal information we have collected about you.

Right to Delete

If you are a California consumer, you may have the right to request that Nassau delete certain of your personal information that we have collected from you. However, this right to deletion does not apply to any of your personal information that is subject to an exception under the CCPA.

Right to Correct

If you are a California consumer, you may have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

Nassau will not discriminate against any California consumer who exercises any of the rights described above. Specifically, except as permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties; provide you with a different level of service or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Additionally, California’s Civil Code Section § 1798.83 permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share your personal information to third parties for direct marketing purposes. If you have any questions about this right or personal information we have collected about you, please contact corporate.compliance@nfg.com or 1-800-813-8180.

How To Submit A Request

If you are a California consumer and would like to exercise any of the CCPA rights identified above, you may submit a request by either completing a request on nfg.com, sending an email to corporate.compliance@nfg.com or by calling us at 1-800-813-8180.

Submitting A Request Through Your Authorized Agent

If you are a California consumer, you may have the option to designate an authorized agent to submit a request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. We may need to contact you directly to verify the request.

How We Verify Your Request

Where required by the CCPA, requesters will need to provide us with personal information in order to verify their identity. Making a verifiable consumer request does not require you to create an account with us.

To verify your identity, we will ask that you provide the following information when you submit your request:

• Name
• Address
• Date of Birth
• Email Address
• Policy Number (if applicable)

Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.

We will respond to your request within the timeframe mandated by the CCPA, and, in any case, within forty-five (45) calendar days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA or other applicable law. We will advise you within forty-five (45) calendar days after receiving your request if such an extension is necessary and why it is needed.

If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.

We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Contact For More Information

If you have any questions or concerns about this California Privacy Policy or our privacy practices, or to request this California Privacy Policy in another format, please contact corporate.compliance@nfg.com or 1-800-813-8180.