This Privacy Disclosure (“Disclosure”) describes how we process Personal Information about California Consumers who are MassMutual Financial Professionals, including agents and brokers (and prospective agents and brokers) who sell our policies or perform similar functions. This Disclosure does not apply to Personal Information collected about other types of individuals or Personal Information collected from you in different contexts. For example, if you interact with our commercial websites or job applicant websites, the CCPA Consumer Disclosure or privacy disclosure posted on that website will apply rather than this Privacy Disclosure.
Changes: We may update this Disclosure from time to time. Any updated Disclosure will be effective when posted. Please check this Disclosure periodically for updates. If required by law, we will contact you directly to provide you with an updated Disclosure.
We collect Personal Information about you from the following sources:
A. Directly from you. We may collect Personal Information you provide to us directly, such as when you contact us, interact with us in person at tradeshows, sign up for offers or newsletters, communicate with us, place or customize orders, or apply/register to be an agent or broker.
B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies. This may include information about how you use and interact with our websites where this Privacy Disclosure is posted or otherwise interact with us, including information from and about devices used to interact with us.
C. From third parties. We may collect Personal Information from third parties who operate independently, such as data brokers and social media companies.
D. From service providers who collect information on our behalf.
E. Affiliated companies and subsidiaries.
F. Your employer (if applicable)
G. From publicly available sources. We may collect Personal Information about you from publicly available sources, such as government sources and public profiles and websites.
We may combine information that we receive from the various sources described in this Disclosure, including third party sources, and use or disclose it for the purposes identified below.
The type of Personal Information we collect depends on how you interact with us. We may collect the following types of Personal Information:
A. Identifiers, such as your name, email address, physical address, telephone number, business contact information, account number, and device identifiers.
B. Records about you, such as signatures, financial information (including bank account details), and background check information (where permitted or required by law).
C. Protected class and demographic information, such as age (including birthdates) and gender.
D. Commercial information, such as policies you sell, information relating to your transactions, and information related to compliance and book of business reviews.
E. Internet or other electronic network activity information, about you, your device, and how you interact with us online. Data elements may include browsing history, search history, preference information (including marketing preferences), account settings (including any default preferences), operating system, browser used, and other information about how you interact with us online (such as website pages you viewed or your interactions with email communications).
F. Non-precise geolocation data, such as your location as derived from your IP address.
G. Audio, electronic, visual, or other sensory information, such as security camera footage on our premises, and other audio/video recordings (such as on calls and trainings).
H. Professional or employment-related information, such as job title, organization, professional licenses, credentials, professional specialty, professional affiliations, professional experience, references, performance and other evaluation information, compliance information, resumes, interview notes, and other professional information.
I. Education information.
J. Inferences drawn from any of the information we collect about your preferences and behavior.
K. Sensitive Personal Information, such as Social Security number, driver’s license number, or passport number; account log-in information; racial or ethnic origin, if you voluntarily provide it; and content of mail, email, and text messages sent using our systems or company-provided devices where we are not the intended recipient (such as messages that we host but are not sent to us). We may monitor the contents of such communications for compliance and legal purposes.
We may use Personal Information for the following purposes:
A. To provide you or your company/employer with products and services, such as communicating with you or providing you with information you request; providing assistance with marketing and selling our policies to others; processing or fulfilling transactions; verifying information, such as eligibility for certain programs or benefits; responding to requests, complaints, and inquiries; and otherwise facilitating your relationship with us.
B. For our internal business purposes, such as maintaining or servicing accounts; operating our business, including online services; maintaining internal business records; enforcing our policies and rules; managing Company assets and workforce; auditing; maintaining records on business activities, such as accounting, commercial, procurement, document management and other similar activities; offering trainings and maintaining records of trainings you participate in; budgeting; real estate management; IT administration of our technologies, network, and intranet; and IT security management and tasks.
C. For our internal research and business improvement purposes, such as verifying, maintaining, or improving our business; designing new products and services; and evaluating the effectiveness of our advertising or marketing efforts.
D. For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against the Company, its personnel, and its customers; for the establishment, exercise or defense of legal claims; protecting Company, your, our customers’, and other third parties’ safety (including managing spread of communicable diseases), property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
E. In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.
F. For marketing, such as marketing our business or that of our affiliates, business partners, or other third parties to you (for purposes of this paragraph alone, “we’” or “our” includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Information we collect to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars, to show you personalized ads on our website or our business partner’s websites, to analyze emails sent and content viewed by customers, to identify visitors across devices and sites, to identify (lookalike) audiences (including by identifying you across devices and sites) to better target our advertising to you. We may use and disclose your personal information to promote MassMutual’s business, such as publicly disclosing the names, photographs, and work contact information of Financial Professionals who attend MassMutual events via social media, through public relations materials and communications, reputation and business-development efforts, branding, at events, and directly to business customers.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
We may disclose Personal Information to third parties, including the categories of recipients described below. Although we do not “sell” Personal Information for money, we engage in routine practices involving third parties that could be considered a "sale" (meaning a disclosure of Personal Information to a third party for consideration) or “sharing” (meaning a disclosure of Personal Information to a third party for targeted advertising purposes), as defined under the CCPA. We do not knowingly sell or share Personal Information about minors.
| Categories of Personal Information We Collect | Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose | Categories of Third Parties to Whom Personal Information is Sold* or Shared* |
|---|---|---|
| Identifiers (Section 2.A) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Records about you (Section 2.B) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Not sold or shared |
| Characteristics of protected classifications under California or federal law (Section 2.C) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Not sold or shared |
| Commercial information (Section 2.D) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Internet or other electronic network activity (Section 2.E) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Geolocation data (Section 2.F) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Audio, visual, or other sensory information (Section 2.G) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | Not sold or shared |
| Professional or employment-related information (Section 2.H) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Education information (Section 2.I) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | Not sold or shared |
| Inferences (Section 2.J) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | • Advertisers, ad platforms and networks, and social media platforms • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies) • Commercial data partners to whom we make information available for their own marketing purposes • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services |
| Sensitive Personal Information (Section 2.K) | • Affiliates and subsidiaries • Professional consultants • Vendors necessary to complete transactions you request • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes • Other entities in connection with a corporate transaction • Entities to which you have consented to the disclosure | Not sold or shared |
The categories of recipients in the chart above are used to mean:
G. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
H. Benefits services providers, such as companies that provide health and insurance benefits.
I. Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
J. Vendors necessary to complete a transaction that you request, such as shipping companies.
K. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use, Terms of Service and other agreements or policies, and to protect the Company , our customers’, or third parties' safety, property, or rights.
L. Other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.
M. Entities to which you have consented to the disclosure.
Our Platforms (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Platforms. This section contains additional information about:
Our Platforms and the third parties that we authorize may use the following tracking technologies:
We and authorized third parties use these technologies for purposes including:
These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Platforms (such as pages on our Platforms that you have viewed).
We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Platforms, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platforms.
Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.
You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Platforms’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. We do not currently honor such signals.
Our Information Governance and Records Management Program establishes and maintains company policies and procedures governing the creation, retention, storage, and disposition of corporate records and information, provided that such information to be deleted or destroyed is not subject to regulatory requirement to retain it or a legal hold. We retain corporate records for the minimum time period required by law or regulation and/or for a longer period of time consistent with business needs. We determine retention periods for corporate record information using both legal/regulatory citations and business requirements. Citations for retention periods are regularly reviewed by outside counsel and updated as necessary. CCPA rights request records are subject to a two year retention period as required by California law.
California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:
You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing via our webform.
You may exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing by visiting our Preference Center. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.
Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.
Verification: In order to process requests, we may need to obtain information locate you in our records or verify your identity using reasonable methods. For Right to Know, Right to Delete, Right to Correct, and Right to Limit Processing of Sensitive Personal Information, we will collect some or all of the following data elements: Name, Date of Birth, Email, Phone Number, and Address. We use a third party identity verification and fraud prevention service to verify the information you provide on your rights request form and which may present you with additional knowledge-based questions. When it comes to identity verification, our third party only tells us whether your identity passes verification and we do not use this information for any other purpose. In some cases, we may ask for more or different information if needed to otherwise support you request such as in cases of authorized agents. To exercise the Right to Opt Out of Sale/Sharing, you may be asked to provide and verify your email address.
Authorized Agents: Authorized agents may exercise rights on behalf of workforce members who are Financial Professionals by submitting a request via our online webform and indicating that they are submitting the request as an agent. Agents should provide their own information to verify the agent’s identity, after which we will contact the agent with additional instructions to complete the consumer right submission process. We may require agents to demonstrate authority to act on behalf of a consumer by providing signed permission and may require consumers to directly verify their identity with us using the methods described above.
Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request. We will respond to Right to Limit Sensitive Personal Information Processing and Opt Out of Sale/Sharing requests within 15 days.
If you need assistance submitting a request or have questions regarding this Disclosure or how the Company uses your Personal Information, please contact us at 1-877-777-9154 or email us at privacyrequest@massmutual.com