LifeCare Assurance Company ("LifeCare Assurance", "us", "we", or "our") knows that you care how information about you is used and shared.

This Privacy Policy informs you about how we collect, use protect, and disclose your information when you visit and otherwise use the LifeCare Assurance website at www.lifecareassurance.com ("Website"), or use any of the other services that we may make available to you (collectively, "Services"). This Privacy Policy also informs you about certain choices and rights you have associated with that data, and how you can manage the privacy of your Personal Information. Please note that this Privacy Policy does not govern the practices of third parties, including any partners, third party service or marketing providers, or other associated firms, even when those services are branded as, or provided on behalf of, LifeCare Assurance. Information collected from you by others, such as third party websites that you access through links on the Website, are governed by those entities' privacy policies. Please read such third party's privacy policies carefully.

LifeCare Assurance reserves the right to modify this Privacy Policy at any time in our sole discretion without notice.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) was enacted on June 28, 2018. The CCPA seeks to ensure California consumers have certain privacy rights.

CCPA Rights Request Webform or toll free at (888) 505-0397

To read more about the CCPA please visit California Legislative Information.

LifeCare is not in a position to provide customers with legal advice on their requirements under CCPA, and suggests that customers consult their legal counsel on how best to prepare for CCPA's implementation and enforcement.

Information We Collect

LifeCare Assurance may collect certain personal information about you in order to provide and improve our Services to you.

"Personal Information" means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It may also include other information that may be associated with your Personal Information, such as Generic Information (defined below), location, preferences or interests, if that information can be used to identify you, your household, or your device.

Personal Information: LifeCare Assurance, a third party administrator, may collect the following "Personal Information" about you when you use our Services: your name, mailing address, phone number, email address, Internet Protocol address ("IP address"), age, gender, and relevant medical information required to administer long term care insurance policies.

Personal Information Collected over the Last 12 Months

In addition to the Personal Information listed above, LifeCare Assurance has collected the following types of Personal Information from our customers and visitors over the last 12 months:

• First Name
• Last Name
• Address
• Phone Number
• Email Address
• Date of Birth
• Social Security Number
• Medical Records

Generic Information: This includes information that does not, by itself, identify you. Generic Information may include data that relates to Website pages viewed and their duration, your IP address information, your browser or operating system information, or other information that relates to your interaction with our Website. In some situations, Generic Information may be used or combined in a way that it identifies you. In those situations, such information will be treated like Personal Information.

Cookies & Tracking Data: The Website may use third party products and services to gather anonymous traffic statistics using cookies and web beacons. A cookie is a small piece of information stored on your device that helps websites and multiple servers recognize you. LifeCare Assurance and its third party service providers may also use other tracking technologies such as pixels, or transparent GIF files, for web site management and user tracking.

Some of the cookies we use are "strictly necessary" for the functionality of our Websites. Others improve the functionality of our Websites but are not strictly necessary. Some cookies help improve the performance of our Websites (such as by gathering analytic data), while others help provide targeted services to you (like ads that you may be interested in).

Examples of cookies we use include:

• Session Cookies. We use Session Cookies to operate our Services. Session cookies are temporary, and are automatically deleted once you close your Internet browser.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings. Preference cookies are first party cookies that remain on your computer or device until you delete them or they are otherwise removed upon expiration.
• Third Party Cookies. LifeCare Assurance permits third-party service providers, advertisers and other companies to use cookies or other similar technologies on our Website. These companies may collect your information, track your behavior on our Website, and gather information about your use of our Websites or Services and other online services over time and across different services. We are not responsible for the functioning of cookies and other technologies used and placed by third parties on your device.
• Pixel Tags, Web Beacons, and Transparent GIFs. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages.
• Other Technologies. We collect many different types of information from other technologies to improve the quality of our Website and the services we provide. For example, we may collect Usage Data and other information about the device you use to access our Website, your operating system and/or mobile device type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We may record the IP address of the device you use to connect to the Internet.

Your Cookie Choices

When it comes to how you want to use or allow cookies to be used on your devices, you are in control. You may set your browser or modify your device settings to block or refuse all cookies, to indicate when a cookie is being sent, or otherwise control what cookies your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete those cookies that are otherwise stored on your device. Please consult the instructions provided by your browser or mobile device manufacturer to find out how you can control the placement of and/or remove cookies or other technologies. Please note, however, that limiting or disabling the use of cookies and other technologies may impact or adversely affect your ability to perform certain transactions on, use certain functions of, and access certain content on our Website.

LifeCare Assurance transmits non-personally identifiable Generic Information about our Website visitors to third parties for the purpose of targeting advertisements on other sites. To do this, LifeCare Assurance uses web beacons in conjunction with cookie data. LifeCare Assurance may also use third party companies to provide advertising services and/or to collect certain information when you visit and interact with the Website. These third-party companies may collect and use non-personally identifiable Generic Information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visit to the Website and/or other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These third-party companies may use cookies and other technologies to recognize your browser to collect and record information about your web surfing activity including your activities on the Website. In addition to adjusting your browser or device's cookie settings, you can also opt-out of having non-Personal Information or cookies used to target ads to you by the party service providers. To opt out please Click Here.

How We Collect Your Information

LifeCare Assurance collects your information in a few ways: there is information that you give us via email or other direct contact from you, information we obtain through your use of our Services, and information we obtain from third parties.

a. Information You Give Us

We collect information that you decide to share with us. At times, we may require you to provide certain information – including Personal Information – in order to fulfill your requests with us or provide you with certain Services. For instance, we will need to collect Personal Information in order to administer long term care insurance claims.

b. Information We Obtain When You Use Our Services

We collect certain information from you through your use of our Services, such as Website usage data and other Generic information. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).

We also may collect information through the use of cookie, pixel tags, or other technologies, as described above.

c. Information We Obtain from Other Sources / Third Parties

We may obtain information about you from third parties who help us provide our Services to you. For example, if you apply for a long term care policy from an insurer for whom we administer policies, we will obtain your medical records. Third party vendors assist us in obtaining such records.

The categories of third parties we receive Personal Information from include:

• Medical Record Suppliers
• Physicians
• Medical Facilities
• Nursing Homes
• Assisted Living Facilities
• Home Health Providers
• Attorneys
• Personal Representatives

How We Use Your Information

a. Business & Other Purposes for Collection

LifeCare Assurance collects, processes, and uses your information to provide the Services that LifeCare Assurance makes available to you. We therefore collect your information for a variety of reasons, including:

• To administer your long term care insurance policies, including but not limited to issuing policies, paying claims, providing customer service and support.
• To comply with any and all relevant state and federal law and regulations.
• You have otherwise given us permission to do so.
• To facilitate our business purposes in relation to the Services that we provide to you. These operational purposes may include but are not limited to:
• Undertaking tasks related to the operations of our Website;
• Maintenance and improvement of our Services, including the Website;
• Detecting security incidents; and
• Debugging our Services.
• The collection is otherwise related to providing our Services to you. For example, we may collect your information:
• To provide customer support to you, our customers, and visitors.
• To gather analysis or valuable information so that we can improve our Services.
• To monitor the usage of our Services.
• To prevent, detect, and address technical issues.
• To provide you with news (for instance, via our newsletter), special offers, marketing or promotional materials, and general information about other services, products which we believe may be of interest to you, unless you have opted not to receive such information. You may opt out of receiving any, or all, of these communications from us by contacting us at the contact information listed below, or by following the "unsubscribe" links in such email messages.
• We may also use "automatically collected" information and "cookies" information to:
• monitor and analyze the our effectiveness and third party marketing activities;
• monitor aggregate usage metrics such as total number of visitors, pages viewed, etc.

How We Disclose or Share Your Information

a. Why We Disclose Your Information

LifeCare Assurance may share customer Personal Information provided to us with third parties who provide services and products to LifeCare Assurance. Examples of ways in which your information may be used include, but are not limited to, the following:

• Policy application and claims administration – for instance, we may provide a third party vendor with some of your Personal Information to administer a claim.
• Marketing activities including direct mail and e-mail marketing efforts.
• Database cleaning and maintenance, and analysis.
• Customer experience enhancements.
• To investigate, protect against and help prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity involving or affecting LifeCare Assurance, our Services, and/or our customers. This may include disclosures to law enforcement, prosecutors, and other entities to investigate potential criminal activity and other civil violations. To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.

LifeCare Assurance also collects, stores, and uses aggregate data that do not contain Personal Information, such as demographics or statistical information. This aggregate data may be shared with and used by third parties to help LifeCare fulfill its obligations with its clients and reinsurance partners.

b. Categories of Third Parties that Receive Personal Information

We share or otherwise disclose individuals' personal information to the following categories of third parties:

• Service Providers: We employ third party service providers, companies, individuals, and agents to facilitate and help us provide our Services to you. Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. For instance, we will share your name and address with LifeCare Assurance's cloud services and information technology service providers that help us maintain our Website and other systems.
  These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Other LifeCare Assurance Entities: We may share or disclose your information to other entities in the LifeCare Assurance family.
• Marketers: We may also from time to time provide your information to marketing firms to help us provide information about our Services to you.

c. Categories of Personal Information Disclosed for Business Purposes

Additionally, we may share certain Personal Information related to our business purposes outlined above.

d. Categories of Personal Information Sold

LifeCare Assurance is not in the business of selling its customers' Personal Information to others. LifeCare Assurance does not and will not sell, rent or trade its customers' personal information to third parties.

Please note that a "sale" of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.

Data Retention

LifeCare Assurance will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws and regulations), resolve disputes and enforce our legal agreements and policies.

Transfer of Data

LifeCare Assurance's Services are offered to individuals in the United States of America and its Territories. While our Website is available for anyone who is interested in LifeCare Assurance, we do not sell or make available any products, goods, or other services to individuals outside of the United States, including the European Union. Your information, including Personal Information, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it here. If you are located in the European Union, you should be aware that U.S. data protection laws are not deemed to be as adequate as those in the European Union. Your submission of such information represents your agreement to that transfer.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, and destruction, we cannot guarantee its absolute security. By using or Website and Services, you acknowledge that there are data security and privacy limitations inherent to the use of the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and LifeCare Assurance, or between you and other related entities, cannot be guaranteed. We cannot ensure or warrant the security of any information you transmit to us or that we store, and you do so at your own risk.

Our Policy on "Do Not Track" Signals under the California Online Protection Act ("CalOPPA")

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

We do not track consumers' online activities over time and across third-party Web sites or online services.

Third parties may collect data that relates to you. We cannot control third parties' responses to do-not-track signals or other such mechanisms. Third parties' use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

Your California Privacy Rights

California residents are afforded certain rights related to their information under state law. LifeCare Assurance aims to take reasonable steps to allow California residents to correct, amend, delete or limit the use of your Personal Information, and exercise other rights available under applicable law. LifeCare Assurance informs you that, where applicable under relevant law, individuals may be entitled to the following:

• Right to Access / Disclosure: to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the collection or processing.
• Disclosure of Direct Marketers: to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes. Please see the "Direct Marketers Disclosure" section below for more information.
• Collecting, Selling, Sharing, or Disclosing Personal Information: upon receipt of a verifiable request, to obtain a list of:
• The specific pieces of your Personal Information LifeCare Assurance holds;
• The categories of Personal Information collected about you, sold to third parties, or disclosed to third parties for business purposes;
• The categories of Personal Information sold within the last 12 months;
• The categories of sources from which Personal Information is collected;
• The business or commercial purpose for collecting or selling Personal Information; and
• The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.
• Right to Opt-Out of the Sale of Personal Information: California residents have the right under the California Consumer Privacy Act ("CCPA") to opt-out of the sale of their Personal Information under certain circumstances. As noted elsewhere, however, LifeCare Assurance does not sell individuals' Personal Information.
• Right to Deletion / "Right to be Forgotten": to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
• Right to Data Portability: to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
• Right to Non-Discrimination: As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.

Please contact us at the information in "Contact Us" Section below in relation to exercising these rights. Note that we may ask you to verify your identity before responding to such requests.

Direct Marketers Disclosures

If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

1. the categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
2. the names and addresses of the third parties that received the information; and
3. if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include "California Privacy Rights Request" in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.

Note that responsive information may be provided in a standardized format that is not specific to you.

Links to Other Sites

LifeCare Assurance's Website may include links to other web sites that are not operated by us. Please note that this Privacy Policy does not apply to those third party websites that may be linked to our Website. This Privacy Policy does not govern the practices of third parties, including our partners, third party service providers, and/or advertisers, even when those services are branded as, or provided on behalf of, LifeCare Assurance. LifeCare Assurance is not responsible for and does not control the security or privacy when you visit those sites. LifeCare Assurance encourages you to visit the privacy notices governing those sites.

Children's Privacy

All of our Services, including our Website, are intended for adult audiences, and are not meant to address anyone under the age of 18 ("Children"). As such, Children under 18 may not use our Website. If you are under 18, do not attempt to register for or use any of our Services, including our Website, and do not provide us any Personal Information about yourself.

We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take steps to remove that information from our servers.

Updates to this Privacy Policy

From time to time, LifeCare Assurance may modify this Privacy Policy. LifeCare Assurance will notify you of any material changes to its Privacy Policy by posting those changes on this page and updating the Privacy Policy modification date above. LifeCare Assurance encourages you periodically to check back to this page for any updates.

Submitting a Verifiable Request to LifeCare Assurance

As mentioned above, California residents have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. LifeCare Assurance will respond to an individual's "verifiable request" to exercise his or her rights under such laws – that is, where LifeCare Assurance has received a request purporting to be from a particular individual, and LifeCare Assurance has been able to verify the individual's identity. The need to verify an individual's identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf.

You may submit a verifiable request via our email address, mailing address, or toll-free number, listed in the "Contact Us" section below, or as otherwise provided on our Website (if such means are available). LifeCare Assurance will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, your address, your account information, and any other information deemed necessary by LifeCare Assurance to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you.

We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a "verifiable request."

Under California law a consumer can appoint an "authorized agent" to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer's information. Because the security and privacy of your information is paramount, we will ask that you identify and provide permission in writing for such persons to act as your authorized agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.

How to Contact Us

If you have questions about this privacy statement, the practices of this site or your dealings with this site, please contact LifeCare Assurance:

• By email: ccpa@lifecareassurance.com
• By telephone: (888) 505-0397
• By mail: P.O. Box 4243, Woodland Hills, CA 91365-4243

Difficulty Accessing Our Privacy Policy?

Individuals with disabilities who are unable to usefully access our privacy policy online may contact us at the above-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format.