Privacy Notice

Effective Date: February 2023

Nassau Financial Group, L.P., its subsidiaries and affiliates including Nassau Life and Annuity Company, Nassau Life and Annuity Insurance Company, Nassau Life Insurance Company, Nassau Life Insurance Company of Kansas and PHL Variable Insurance Company ("we," "us," or "our") are committed to protecting the personal information we collect from or about you. This Privacy Policy explains the personal information we collect, use, and disclose, including when you visit or use our website,, and the features and content available therein (the "Website"). The Privacy Policy does not apply to information collected through third-party websites that you may access through the Website. By using this Website, you acknowledge you understand the practices described in this Privacy Policy.

Information We Collect and How We Collect It

Depending on how you use the Website, we may collect personal information from or about you. "Personal information" includes any information that we collect about you that, alone or in combination with other information, can be used to identify you, such as a personal identifier, an identification number, online identifiers, or inferences about your preferences. Personal information does not include certain information, such as publicly available information or information that is anonymous or aggregated so that it cannot be used to identify individuals who use the Website. We explain below the categories of personal information we may collect.

  • Identifiers, such name, postal address, email address, social security number, driver’s license number, passport number, or other similar identifiers;
  • Professional or employment-related information, such as previous employment, work history, and professional license;
  • Education information, such as education or student records;
  • Characteristics of protected classifications, such as age, race, color, ancestry, national origin, marital status, religion, sex, veteran or military status, medical condition, and mental or physical disability, and other demographic data;
  • Commercial information, such as records of personal property;
  • Biometric information, such as fingerprint or retina from which an identifier template can be extracted;
  • Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with an internet website application;
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Inferences, such as using your personal information to create a profile about you reflecting your characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Some of the information we collect from or about you may be considered sensitive personal information under certain applicable laws.

How We Collect Your Information

We may collect your personal information in different ways and from different sources. The categories of sources from which we collect or receive personal information may include you, our affiliates, sponsors, business partners, government entities and other sources, publicly available sources, credit agencies or bureaus, service providers or other third parties. For example, we will collect and use personal information that you provide to us when you fill out forms on our Website, such as through the "Contact Us" page.

How We Use Your Information

We and service providers or other third parties may use the information we collect about you for various purposes, including:

  • To respond to your inquiry or request, or to communicate with you;
  • To provide you with the information or to fulfill your request, including subscribing to our podcast;
  • To send email communications and/or newsletters that may be of interest to you;
  • To analyze usage trends;
  • To improve, enhance, and repair the functionality of our Website; and
  • To enforce the Website Terms of Use.

In certain circumstances, we may aggregate and/or de-identify information for additional purposes.

How Your Information is Disclosed

We will disclose your personal information in different ways, consistent with the purposes for which we collected the information. These include the following circumstances:

  • To share information with service providers, contractors, and vendors that assist in operating our Website;
  • To share information with our corporate affiliates, sponsors, and business partners;
  • To comply with applicable laws or to respond to a lawful subpoena, court order, government request, or other legal process;
  • As a part of a corporate transaction, such as in connection with a merger, divestiture, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred;
  • To maintain the security and integrity of our Website;
  • To protect our interests, rights, safety, or property or those of others;
  • To produce relevant documents or information in connection with litigation, arbitration, mediation, government or internal investigations, or other legal or administrative proceedings; and
  • Any other disclosure with your consent.

Retention of Your Information

We may retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected. In some circumstances, we may retain personal information for longer periods of time as may be necessary to comply with legal or regulatory requirements.

Cookie Policy

We and third parties working on our behalf may also place, view, and/or use cookies and other electronic tools to collect information about your use of this Website. A cookie is a small text file placed on your computer. Cookies help us understand how our Website is being used and improve your user experience. personal information collected by cookies may include your device&rsqo;s IP address, browser type, operating system, computer platform, web pages viewed, and/or the date and time of your visit. We or third parties may use such information for certain purposes, including to support functions on this Website, to enhance your experience with this Website, or to analyze and compile the usage of this Website.

Most browsers include tools to manage or disable these technologies. You can visit the help function on most browsers to modify how your browser handles cookies. However, if you disable cookies, certain features of this Website may not function or function properly.

"Do Not Track" Signals. Some web browsers have "Do Not Track" or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Our Website does not currently respond to "Do Not Track" signals.

How Do We Secure Your Information?

We use reasonable administrative, physical, and technical safeguards designed to prevent unauthorized access, use, or disclosure of your personal information. Although we exercise reasonable care in providing secure transmission and storage of the personal information you provide to us through the Website, no method of transmission over the Internet, and no means of electronic storage, is absolutely secure. Accordingly, we cannot guarantee the absolute security of your personal information.

Links to Third-Party Websites

This Website may contain links to third-party websites. We do not control third-party websites and are not responsible for any information you may provide while on such third-party websites. Any information provided on such websites is governed by the privacy policies of the third-party websites and not this Privacy Policy. We encourage you to read the privacy policies on those websites before providing your information on such websites.

Children’s Privacy

This Website is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If you are under 13, you are prohibited from using or providing any information through this Website or any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will promptly delete that information.

Privacy Notice for California Residents ("California Privacy Notice")

This "California Privacy Notice" supplements the information contained in our Privacy Policy and provides additional notice for California residents. The California Consumer Privacy Act, as amended, and its implementing regulations ("CCPA"), provide California residents with certain rights related to their personal information, and this California Privacy Notice describes how California residents can exercise those rights. The terms defined in the CCPA have the same meaning when used in this California Privacy Notice. This "California Privacy Notice" supplements the information contained in our Privacy Policy and provides additional notice for California residents. The California Consumer Privacy Act, as amended, and its implementing regulations ("CCPA"), provide California residents with certain rights related to their personal information, and this California Privacy Notice describes how California residents can exercise those rights. The terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

Categories of Personal Information Collected. In the past 12 months, we have collected the following categories of personal information: Internet or other electronic network activity information; geolocation data; and inferences.

To the extent any of the personal information we collect qualifies as sensitive personal information, we only use or disclose such information for limited purposes as permitted by the CCPA.

Personal Information Disclosed. In the past twelve (12) months, we have disclosed personal information for a business purpose to third parties, including:

  • With our affiliates and business partners to conduct research, analyze usage and effectiveness of the Website, or provide advertising and marketing services.
  • Other third parties for data storage, marketing services, or improvement and security of the Website.

Sharing or Selling Personal Information. We do not sell or share personal information of California consumers. We do not have actual knowledge that we sell or share personal information of California consumers under 16.

CCPA Rights for California Residents. California residents have the following rights under the CCPA. Please note that these rights are not absolute, and in certain cases we may decline your request or comply in a more limited way, in accordance with applicable laws.

  • Right to Know. You have the right to request that we provide you with the information we have collected and used in the past twelve (12) months. You may only make this request twice within a twelve (12)-month period.
  • Right to Delete. You have the right to request that we delete certain of your personal information that we have collected about you. However, this right does not apply to any of your personal information that is subject to an exception under the CCPA or otherwise not required by the CCPA.
  • Right to Correct. You 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.
  • Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the sale or sharing of your personal information. As indicated above, though, we do not sell or share the personal information of California residents.
  • Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use of your sensitive personal information. However, this right does not apply if sensitive personal information is used for limited purposes as recognized in the CCPA. As indicated above, we only use and disclose sensitive personal information for such limited purposes, and this right does not apply.

We will not discriminate or retaliate against any California resident for exercising any of the rights described above.

Additionally, California’s Civil Code Section § 1798.83 permits users of our Website 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 or 1-800-813-8180.

How to Submit a Request

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

Submitting a Request Through Your Authorized Agent

If you are a California resident, 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. If you would like to designate an agent, your agent must register as such with the California Secretary of State and submit a copy of this registration along with your consumer request to us. We may need to contact you directly to verify the request.

How We Verify Your Request

We cannot fulfill your request to provide you with, correct or delete your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. To verify your identity and to fulfill your request, and depending on your type of request or the information requested by you, we may ask that you provide certain information when you submit your request.

We will respond to your request within forty-five (45) calendar days. However, in certain circumstances, we may require additional time to process your request. 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. Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. 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.

Privacy Notice for EU and UK Residents ("GDPR Notice")

This "GDPR Notice" supplements the information contained in our Privacy Policy and provides additional notice for residents of the European Union and United Kingdom. The use of "personal information" in the Privacy Policy and GDPR Notice is equivalent to "personal data" as defined in the EU’s General Data Protection Regulation ("GDPR") and the UK’s Data Protection Act 2018 and associated statutes (collectively the "UK GDPR").

Legal Basis for Processing Your Personal Information. We rely on the following legal grounds to process your personal information:

  • Consent – Some of the personal information we collect is provided by you voluntarily, such as when you sign up to our podcasts or join our mailing list. You may withdraw your consent to such use by contacting us.
  • Legitimate interests – We may use your personal information for our legitimate interests, such as to improve our Website, when those interests are not outweighed by your privacy interests.
  • Compliance with legal obligations – We may use your personal information to comply with legal obligations.

GDPR Data Subject Rights. If you are a resident of the EU or UK, you may have certain rights under relevant laws regarding your personal information:

  • Right to access;
  • Right to correct;
  • Right to delete; and
  • Right to restrict or object to processing.

Likewise, if you are a resident of the EU or UK, you have the right to complain to a Data Protection Authority in the country in which you are located if you believe that your personal information has been collected or used in violation of relevant privacy laws.

International Transfers of Personal Information

We are based in the United States, and the Website is designed for users in, and operated by us from, the United States. If you reside outside the United States and use our Website or otherwise provide information to us, you acknowledge that your information will be transferred to and processed in the United States for the purposes described in this Privacy Policy. The United States may provide different levels of privacy protection than the country in which you are located or from which you are visiting our Website or using our Website.

Marketing Communications

We may send email marketing correspondence to you about our Website. To unsubscribe from these communications, please follow the unsubscribe instructions contained in the emails or contact us using the contact information below.

Modifications to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time by posting the revised version on this Website and updating the last modified date. We encourage you to review the Privacy Policy whenever you access this Website or otherwise interact with us to stay informed about our privacy practices.

Questions Regarding this Privacy Policy

If you have questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at please contact or 1-800-813-8180.

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