California Notice at Collection and Privacy Notice

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Effective: December, 2022

Last Updated: April, 2024

We respect your concerns about privacy. This California Notice at Collection and Privacy Notice (the “Privacy Notice”) describes the New York Life Family of Companies’* privacy practices with respect to personal information we collect or obtain about California residents that is covered by the California Consumer Privacy Act and California Privacy Rights Act (collectively, the “CCPA”).

This Privacy Notice does not apply to personal information collected in connection with obtaining or seeking to obtain a product or service from the New York Life Family of Companies. If you are a customer of the New York Life Family of Companies, an insured or beneficiary under a policy, or have sought to obtain a product or service from the New York Life Family of Companies, your personal information collected in those contexts is protected by others laws and our Customer Privacy Notice applies to you. Please note that this Privacy Notice does not apply to your personal information when it is protected by other laws, such as the Gramm-Leach-Bliley Act; the California Financial Information Protection Act; the Health Insurance Portability and Accountability Act; the Fair Credit Reporting Act; and/or the Driver's License Protection Act.

This Privacy Notice does apply to personal information collected about California residents outside of the contexts described in the paragraph above. This includes personal information collected about California residents visiting any New York Life Family of Companies websites (“Sites”) to the extent they are not obtaining or seeking to obtain a product or service from us, and personal information collected about California residents who have applied for a position with, or been recruited by, the New York Life Family of Companies. This Privacy Notice also applies to personal information collected about California residents in the context of business-to-business relationships.

When you visit any New York Life Family of Companies Sites, our Online Privacy Policy also applies.

Notice at Collection

When you visit our websites (“Sites”), cookies and similar technologies may collect the following categories of personal information about you:

We use the personal information listed in the chart above for various purposes, including to: provide you information about our products and services; respond to your inquiries and requests; conduct marketing and advertising; perform market research; perform data analytics; conduct user experience surveys; help enhance or improve our products and services; manage our recruiting efforts and career opportunities; protect against, identify and prevent fraud and other unlawful activity; and perform IT and administrative support functions.

We maintain record retention policies and procedures based on applicable law and business needs that determine how long we retain records, including those containing personal information.

The New York Life Family of Companies does not “sell” personal information (including the personal information of minors under the age of 16) as that term is defined in the CCPA. The CCPA has a separate definition for the term “sharing”, which includes disclosing or making available a consumer's personal information to a third party for cross-context behavioral advertising. The New York Life Family of Companies may “share” limited personal information with third parties, such as advertising technology partners and ad networks, for cross-context behavioral advertising when we engage such third parties to assist with our digital advertising efforts. These third parties use cookies and similar technologies to collect and store information to enable cross-contextual advertising. This includes information about your activities on our Sites (such as pages viewed and links clicked on), and your general geolocation, IP address, unique personal identifier, online identifier and similar identifiers to display advertising about our products and services that are tailored to your individual interests. Please refer to the section in the Privacy Notice below entitled “Sharing Personal Information With Third Parties and Your Right to Opt Out” to understand your right to opt out of this sharing and how to do so.

Privacy Notice

Sources and Categories of Personal Information We Collect

We may collect personal information through online and offline means directly from you and from other sources, such as public sources and third parties (such as data aggregators and recruiting agencies) who help facilitate our marketing, analytics and recruiting efforts. We may have collected the following personal information from consumers in the preceding 12 months:

Please note that although we collect certain categories of “sensitive personal information” as defined by the CCPA, when we collect such information it is subject to other laws and not the CCPA because it is collected in the context of an individual obtaining or seeking to obtain a product or service from the New York Life Family of Companies or in another context not subject to the CCPA. Regardless, such sensitive personal information is used and disclosed as necessary to provide products or services as reasonably expected by individuals who have sought to obtain or have received such products or services, or otherwise as permitted by the CCPA and is not subject to a right to limit its use and disclosure.

Business or Commercial Purposes for Collecting and Disclosing Personal Information

We use the personal information listed in the section above for various business or commercial purposes, including to: provide you information about our products and services; respond to your inquiries and requests; conduct marketing and advertising; perform market research; perform data analytics; conduct user experience surveys; help enhance or improve our products and services; manage our recruiting efforts and career opportunities; protect against, identify and prevent fraud and other unlawful activity; and perform IT and administrative support functions.

We may disclose your personal information to our subsidiaries and affiliates, and service providers, to assist us with any of the business and commercial purposes described in the paragraph above. The categories of personal information disclosed for a business or commercial purpose may include certain identifiers (such as name, postal address, email address, telephone number, IP address, unique personal identifier, online identifier and similar identifiers, and demographic information), internet or other electronic network activity information, professional or employment-related information, education information and inferences drawn from your personal information to understand your preferences. We do not authorize our service providers to use or disclose the information except as necessary to perform services or functions on our behalf, or to comply with legal requirements.

We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Sharing Personal Information With Third Parties and Your Right to Opt Out

The New York Life Family of Companies does not “sell” personal information (including the personal information of minors under the age of 16) as that term is defined in the CCPA.

The CCPA has a separate definition for the term “sharing”, which includes disclosing or making available a consumer's personal information to a third party for cross-context behavioral advertising. The New York Life Family of Companies may “share” limited personal information with third parties, such as advertising technology partners and ad networks, for cross-context behavioral advertising when we engage such third parties to assist with our digital advertising efforts. These third parties use cookies and similar technologies to collect and store information to enable cross-contextual advertising. This includes information about your activities on our Sites (such as pages viewed and links clicked on), and your general geolocation, IP address, unique personal identifier, online identifier and similar identifiers to display advertising about our products and services that are tailored to your individual interests. You may see these ads for our products and services when you visit other websites. Pursuant to the CCPA, you have the right to request that we stop sharing your personal information with third parties as described above.

You can read more about your right to opt out of such sharing and submit your opt-out preference for Newyorklife.com by scrolling down to the footer of this Site and clicking the link titled “Your California Privacy Choices” or “Do Not Sell or Share My Personal Information”, depending on the Site. Please note that if you were redirected to this page from one of our Sites other than Newyorklife.com, you can opt out on the Site you came from by clicking the link on that Site, if available, titled “Your California Privacy Choices” or “Do Not Sell or Share My Personal Information”, depending on the Site. You can also opt out by using the opt-out preference signal on your browser, which we process in a frictionless manner. The opt-out preference signal will apply to your browser. Note that after you opt out, you might still see advertisements from the New York Life Family of Companies that are unrelated to us sharing your personal information with third parties. Please also note that your opt-out will apply only to the New York Life Family of Companies Site you are opting out on (unless you use the opt-out preference signal on your browser). If you clear your cache and cookies on your browser, your opt-out will no longer be effective and you will need to opt out again.

Additional Rights Under the CCPA and How to Exercise Them

If you are a California resident whose personal information is covered by the CCPA and this Privacy Notice, you may have certain rights under the CCPA as listed below. We will comply with your request in accordance with, and to the extent permissible under, applicable law.

The Right to Know

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

• The categories and specific pieces of personal information we have collected about you;
• The categories of sources from which your personal information was collected;
• Whether we have shared or sold your personal information (we do not sell personal information as that term is defined in the CCPA);
• The business or commercial purpose for collecting, sharing or selling your personal information (we do not sell personal information as that term is defined in the CCPA); and
• The categories of third parties with whom we have disclosed your personal information.

Deletion

You have the right to request that we and our service providers delete any personal information which we have collected from you, subject to certain exceptions. We and our service providers will not delete your personal information if it is necessary or permissible for us or our service providers to maintain the personal information pursuant to the CCPA or other applicable law.

Correction

You have the right to request that we and our service providers correct inaccurate personal information that we maintain about you. Depending on the circumstances, we may require you to provide documentation supporting your request to correct your personal information. Pursuant to the CCPA, if you request correction of your personal information, we may delete such personal information as an alternative to correcting the information if deletion does not negatively impact you or you consent to the deletion. We and our service providers will not correct your personal information if it is necessary or permissible for us or our service providers to not correct the personal information pursuant to the CCPA or other applicable law.

How to Exercise Your Rights

You can exercise your rights listed above, or reach out to us with questions or concerns about our privacy notices and practices, by calling us at (800) 225-5695 or clicking here. Note that, pursuant to the CCPA, you will not receive discriminatory treatment from us if you choose to exercise any of your CCPA rights, and you have the right not to be retaliated against for the exercise of your CCPA rights.

When you submit a CCPA Right to Know, Deletion, or Correction request, we will ask you to provide certain verification information, such as your relationship to New York Life, name, phone number, postal address, email address, and date of birth. This information will be used to help us detect potential fraud, verify your identity, and fulfill and respond to your request. Upon receiving a CCPA request, we may call you using the phone number you provide to request additional information (such as your Social Security Number if you are requesting to know the specific pieces of personal information we have collected about you) to further verify your identity and answer a few authentication questions required by the third-party identity verification service we use to assist in this process. We will not store or use this information for any other purpose..

If you decide to designate an authorized agent (other than through power of attorney) to submit a CCPA request on your behalf, we require that you provide the authorized agent written permission to do so and verify your own identity through the process described in the paragraph above. We also require the authorized agent to submit proof that you have authorized them to act on your behalf.

*The New York Life Family of Companies (also referred to as "we," "our," or "us" throughout this Privacy Notice) currently includes the following affiliates and funds: