Terms Of Use

Privacy Notice

Protecting your privacy is important to us. We want our customers to understand what nonpublic personal information we collect and how we use it. Nonpublic Personal Information is nonpublic information about you that we obtain in connection with providing a financial product or service to you, such as that described in the examples below.

WHY WE COLLECT YOUR INFORMATION

We gather nonpublic personal information about you and your accounts so that we can

(i) know who you are and thereby prevent unauthorized access to your information.

(ii) design, deliver and improve the products and services we offer and (iii) comply with the laws and regulations that govern us.

CONFIDENTIALITY AND SECURITY

We limit access to your nonpublic personal information to those of our employees and service providers who are involved in offering or administering the products or services that we offer. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.

WHAT INFORMATION WE COLLECT

We may collect the following types of nonpublic personal information about you:

Information about your identity. such as your name. address and social security number
Information about your transactions with us
Information we receive from you on applications, such as your beneficiaries or income
Information we receive from a consumer reporting agency after we obtain your consent to seek this information.

WHAT INFORMATION WE DISCLOSE

We are permitted by law to disclose nonpublic personal information about you to third parties in certain circumstances. For example. we may disclose nonpublic personal information about you to affiliated and nonaffiliated third parties to assist us in servicing your account with us (e.g., mailing of account related materials), to government entities (e.g., IRS for tax purposes) and in response to a subpoena or court order, judicial process or regulatory inquiry.

Phoenix Holding Incorporated

75 State Street, Boston, Massachusetts 02109

If you are a citizen or resident of the European Union (“EU”) or the European Economic Area (“EEA”), we will ensure appropriate safeguards are in place as required by applicable law to adequately protect your personal information if it is processed by third parties outside the EU and EEA, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission). Citizens of the EU or the EEA and residents of California have certain specific rights provided under the General Data Protection Regulation (“GDPR”) and the California Consumer Protection Act (“CCPA”), respectively. For personal data that we will collect about you, we hereby notify you that you have the following rights:

Delete Personal Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you) unless otherwise restricted by law or regulation.
Right to Rectification: You also have the right to ask us to change, update or fix your personal data in certain cases, particularly if it is inaccurate.
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data, a copy of personal data you provided and personal data disclosed to a third party. You may request your personal information up to 12 months preceding your request.
Non-Discrimination: You have the right not to be subject to discriminatory treatment from us as a result of the exercise of your privacy rights.

RIGHTS TO OPT OUT

You have the right to direct us to not disclose non-public information about you to nonaffiliated third parties if its disclosure is beyond rendering services to you. Limiting our disclosure of such information may limit the services we are able to provide to you. We will not share non-public information unless compelled to do so by order of a court or in response to a subpoena. To limit our sharing of your non-public information, please contact us at 617-443-9000.

MODIFICATIONS

We may amend this privacy notice at any time, and we will inform you of changes as required by law.

FORMER INVESTORS AND CLIENTS

We will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive. Should you have any questions regarding our Privacy Policy, please contact us at 617-443-9000.