Privacy Policies

The Penn Mutual Life Insurance Company and its subsidiaries and affiliates (“Penn Mutual”, “we”, “our”, or “us”) respects and is committed to protecting your privacy. That is why we have adopted this Privacy Notice to inform you on how and for what purposes we are collecting, processing, and using your Personal Information (as defined herein). We pledge that we will take reasonable measures to ensure that your Personal Information and Usage Information (as defined herein) will only be used in ways that comply with this Privacy Notice.

This Privacy Notice applies to any web page, mobile application, blog, third party social media site, email list, onsite electronic data collection, generic information, and Personal Information collected and/or owned by us, including but not limited to the Penn Mutual website located at www.pennmutual.com. This Privacy Notice is in effect no matter the method of collection (such as by insurance application, mail, facsimile, sign-up/sign-in page, survey, or some other promotion), including collection through our website and any online feature, product, service, and/or program we offer (collectively, the “Web Properties”).

Notwithstanding the foregoing, this Privacy Notice does not apply to any other web page, mobile application, blog, social media site, generic information, or Personal Information collected and/or owned by anyone other than us. We are not responsible or liable for the content, privacy policies, or practices of such third parties.

Your use of the Web Properties is also governed by the Terms of Use located here.

Penn Mutual and any third party that we hire for the purpose of administering, operating, hosting, configuring, designing, maintaining, and providing internal support for our Web Properties may collect two types of information when you visit the Web Properties: personal information and usage information:

Personal Information: The types of information that Penn Mutual collects may include, among other things, the following categories of information (collectively, “Personal Information”):

• contact information (such as your name, location, address, zip code, phone number, and email address);
• demographic information (such as your gender);
• bank account and credit/debit card numbers, and transaction information; and
• beneficiary information, recent correspondence and statements, and other account information; and
• other information specific to you.

Usage Information: The types of usage information that Penn Mutual collects may contain generic information about you when you visit the Web Properties, which may include, among other things, the following categories of information (collectively, “Usage Information”):

• your Internet Protocol (or IP) address, protocol, and sequence information;
• your browser language and type;
• domain name system requests;
• your operating system and platform, device type, and device identifiers;
• your browsing history (including time spent at a domain, time and date of your visit) and number of clicks;
• any hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data;
• your MAC address, device ID/UDID, or similar device-specific code; and
• aggregated information.

We may collect Personal Information and Usage Information about you from the following sources:

• information about your transactions with us, as well as information we receive from you as a result of your use of our services or purchase of our products;
• information we receive from you, or on your behalf, through applications or other forms that you complete, or if you contact us, for example to ask a question or to sign up for our email list;
• information we receive from you through the Web Properties, such as when you create a user account for use in connection with the Penn Mutual Online Account Access (your “User Account”);
• information we receive from your computer or mobile device;
• information we receive from our partners or service providers; and
• information we receive from other sources such as insurance-support organizations, as permitted by applicable laws, rules and regulations.

In addition to the situations above where we may request and use your email address, we offer an email subscription program. Our email subscription program allows you to opt out of emails we may send from time-to-time. You may choose to opt-in to emails based on specific areas of interest. You may unsubscribe or change your preferences at any time on our Web Properties.

The Web Properties may permit you to submit content, including such things as statements, reviews, ratings, opinions, photos, video, text, graphics, music, sounds, questions, suggestions, messages, comments, feedback, ideas, notes, drawings, articles, stories about you, or any other content of any kind whatsoever. We may now or in the future allow you to create a User Account and electronically submit content through the Web Properties.

We may collect Usage Information from you in the following ways:

Cookies: From time to time, we may use “cookies” to keep track of your visit and your use of the Web Properties. A cookie is a small piece of data that your browser stores on your computer’s or device’s hard drive and is used to collect information, such as identifying those areas of the Web Properties that you have visited in the past in order to enhance your next visit to the Web Properties. You can choose whether to accept cookies by changing the settings of your browser, but some functionality of the Web Properties may be impaired or not function as intended if you choose not to accept cookies. Each browser is a little different, so look at your Help menu to learn the correct way to modify your cookies.

Statistics and Log Files: We collect aggregate information about our visitors, including the IP address, type of information used and browser software. In addition, we track what portion of our Web properties are visited, the number of visitors, and time spent on our Web Properties. We keep this information for our internal use for statistical purposes, to analyze trends, and to improve our Web Properties. None of the information is linked back to you as an individual user.

iBeacons and Geolocation: While using certain features of the Web Properties, we may track the physical location of your mobile device or web browser. WiFi and IP addresses received from your device or browser may be used to determine your approximate location. You will always have control over whether to transmit your physical location, and you can prevent such disclosure by disabling Bluetooth and Wi-Fi, declining the request to share your physical location, or adjusting your privacy settings.

Information collected by Penn Mutual may be used for the following primary purposes:

1. To enable the features of the Web Properties, including, but not limited to, setting up and managing your online account, processing your requests for information or to contribute content;, and/or providing support, products, features, or services to you.
2. To improve the Web Properties by determining which of our products, features, and services are most popular. We may analyze your information to enable us to provide effective services to you, for our internal business purposes, and to develop new features, functionality, and services.
3. To personalize your experience on the Web Properties.
4. To inform you about our products and services. We may send you and keep you updated with information about existing and new services, products, features, and special offers by email, telephone, mail, or by means of any other contact details that you provide to us or to our third party service providers.

We may allow you to create a User Account to access the Penn Mutual Online Account Access and other features of the Web Properties. For certain features available through the Web Properties, including use of your User Account, we may require the use of encryption technologies provided for your protection. We use reasonable precautions to protect the privacy of your username, password, and User Account information and to ensure that information collected through the Web Properties is not lost, misused, or altered inappropriately by administering security measures. Sensitive information, such as contract/policy numbers, is encrypted and is protected with the most widely accepted software in the industry. While on a secure page, the lock icon on your web browser becomes locked, as opposed to being unlocked when you are just surfing the Web Properties.

While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception, or error. You are ultimately responsible for protecting your username, password, and User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies.

For individuals interested in job opportunities with us, the Web Properties allow prospective employees to request additional job opportunity information and apply for a job online. The Web Properties may be used to collect Personal Information from prospective employees for human resources recruitment purposes. By submitting any of the foregoing information, you consent to its dissemination to, and use by, us. The foregoing also applies to job application inquiries and submissions that you may transmit to us other than through the Web Properties.

The Web Properties are not intended or designed to attract children under the age of thirteen (13). You will need to affirm that you are more than eighteen (18) years of age, you are an emancipated minor, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Notice, and to abide by and comply with this Privacy Notice. In any case, by using the Web Properties, you affirm that you are over the age of thirteen (13), as THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER THIRTEEN (13) WHO ARE UNACCOMPANIED BY THEIR PARENT(S) OR LEGAL GUARDIAN(S).

Parents and legal guardians should be aware that this Privacy Notice will govern our use of Personal Information, but also that information that is voluntarily given by children -- or others -- in email exchanges, bulletin boards, or the like, may be used by other parties to generate unsolicited communications. We encourage all parents and legal guardians to instruct their children in the safe and responsible use of their Personal Information while using the Internet.

The Web Properties may contain various links to other websites, including, but not limited to, Facebook, Twitter, LinkedIn and YouTube, among others. We are not and cannot be responsible for the privacy practices or the content of any of those websites. Other than under agreements with certain reputable organizations and companies, and except for third party service providers (as described in this Privacy Notice), we do not share any of the Personal Information that you provide to us with any of the websites to which the Web Properties link. Please check with those websites in order to determine their privacy policies and your rights under them.

We may use the services of third party service providers, for example to process payments and other transactions. By using our Web Properties, you grant us all necessary rights and consents under applicable laws to disclose to our third party service providers -- or allow those third party service providers to collect, use, retain, and disclose -- any Personal Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

The Web Properties and our products and services are hosted in the United States and are governed by United States law. If you are using the Web Properties or our products or services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Web Properties or our products and services, you consent to your Personal Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide any Personal Information to us. However, this information is essential for the provision and quality of some of the services that we offer to you, so we cannot provide you with certain services or provide you with access to certain features if you choose to withhold requested information. For example, “Contact Us” and “Client Services” requests may require you to provide information, such as your email and home address, telephone number, and contract/policy numbers, which allows us to identify you as the requester of the service.

You may choose to prevent us from disclosing or using your Personal Information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Notice, including by using our toll free telephone number, (215)-956-8000, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your Personal Information is to be disclosed and used in accordance with the stated purposes in this Privacy Notice, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent. There are some uses from which you cannot opt out, such as to provide products, features, or services that you have requested from us.

Please note that opting out of the disclosure and use of your Personal Information as a prospective employee may prevent you from being hired as an employee to the extent you are using the Web Properties to apply for an open position.

For California Residents: Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us (once per calendar year) information about the customer information that we shared (if any) with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. As set forth in this Privacy Notice, we do not sure your Personal Information with any third party for that third party’s marketing purposes.

Under California Civil Code Section 1789.3, California residents who use the Web Properties are entitled to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through the Web Properties, please send an email to privacy@pennmutual.com. You may also contact us by writing to 600 Dresher Rd, Horsham, PA 19044, or by calling us at (215)-956-8000. Currently there is no charge to use the Web Properties, other than any services or products that you may purchase through the Web Properties, and any applicable taxes, shipping fees, and other charges associated with those purchases. Unless otherwise stated, these charges appear for each purchase on the order confirmation pages relating to each purchase. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

Please contact us in the manner specified at the end of this Privacy Notice to access your Personal Information in our possession and correct inaccuracies of that information in our records. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances, as permitted by applicable laws, rules, and regulations.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, Penn Mutual currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

By using the Web Properties, you consent to the collection and use of your information (including Personal Information) by us as specified above or as we otherwise see fit, in compliance with this Privacy Notice, unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Notice or some part of it, we will make an effort to post those changes on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Web Properties following our publication of any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

If you have additional questions or comments or would like to access your recorded Personal Information or opt out of certain sharing, please let us know by sending your comments or requests to:

This California Privacy Policy describes The Penn Mutual Life Insurance Company's (“Penn Mutual,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of California residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”), and explains how Consumers may contact Penn Mutual to exercise those rights. This policy only applies to the personal information of Consumers (i.e., California residents).

This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact Penn Mutual to exercise these rights, please see the section below entitled, “How to Submit a Request.”

A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:

1. The categories of personal information it has collected about that Consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of third parties with whom the business shares personal information.
5. The specific pieces of personal information it has collected about that Consumer.

A Consumer may request that a business that sells the Consumer's personal information, or that discloses it for a business purpose, disclose to that Consumer:

1. The categories of personal information that the business collected about the Consumer.
2. The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
3. The Penn Mutual California Privacy Policy describes how and for what purposes Penn Mutual collects, processes and uses the Personal Information of Penn Mutual California clients.

This California Privacy Policy describes The Penn Mutual Life Insurance Company's (“Penn Mutual,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of California residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”), and explains how Consumers may contact Penn Mutual to exercise those rights. This policy only applies to the personal information of Consumers (i.e., California residents).

A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for Penn Mutual to maintain the personal information for certain purposes, Penn Mutual is not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer's rights under the CCPA. Penn Mutual may charge a Consumer a different price or rate, or provide a different level or quality of goods or services to the Consumer, if that difference is reasonably related to the value provided to the Consumer by the Consumer's data.

To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting Penn Mutual through one of the following methods:

• Calling 1-800-523-0650 or
• Filling out the following online form: www.pennmutual.com/ccpa-request-form

You may submit a request twice in any 12-month period.

To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. In certain circumstances, we may also require you to provide a written declaration that you are who you say you are.

You may make a verifiable Consumer request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf. Upon request, your authorized agent must provide proof of identity and authority to speak on your behalf.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor's identity or authority to make the request.

Penn Mutual has collected the following categories of Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy:

• Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
• Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Biometric information.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer's interaction with an Internet Web site, application, or advertisement.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Education information.
• Inferences drawn from any personal information to create a profile about a Consumer reflecting the
• Consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Penn Mutual collects the personal information described above from the following categories of sources:

• From you directly, when you provide us with information over our websites or in person, in applications or questionnaire responses you submit in connection with one of our products or services, when you provide information about yourself to one of our Financial Professionals.
• From others on your behalf, such as when you are named as a beneficiary or emergency contact of one of our employees or associated with a policy held by one of our clients.
• From data aggregators who provide us with information about individuals in order for us to understand who may be interested in our products or services.
• From public records or published databases.

Penn Mutual collects the personal information described above for a variety of business purposes. Penn Mutual uses the personal information to:

• Provide our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services;
• Improve, upgrade, or enhance our products and services;
• Provide you with information about products and services that we and other businesses may provide that we think may be of interest to you;
• Detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debug to identify and repair errors that impair existing functionality;
• For research and analysis purposes.

Penn Mutual may share the personal information described above with the following categories of third parties:

We share your personal information with our service providers to assist us in providing our products and services to you, including service providers that:

• host our databases, infrastructure and websites;
• provide analytics services to help us understand the activity on our website;
• assist us with marketing and communications with our clients or potential clients;
• assist us to analyze and understand the financial status and needs of our client base;
• assist us with the financial, regulatory and legal aspects of our business,
• assist us with quote and estimates specific to particular individuals interested in our products or services;
• assist us with event planning; and
• assist us with data security and privacy.
• With courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.

Penn Mutual has not sold Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy.

Penn Mutual has disclosed Personal Information about Consumers for a business purpose in the twelve (12) months prior to the Effective Date of this Policy.

Penn Mutual has disclosed the following categories of Personal Information about Consumers for a business purpose in the twelve (12) months prior to the Effective Date of this Policy:

• Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
• Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classifications under California or federal law (race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Biometric information.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer's interaction with an Internet Web site, application, or advertisement.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Education information.
• Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

If you have any questions or concerns about Penn Mutual's privacy policy and practices, please contact:

The Penn Mutual Life Insurance Company
600 Dresher Road
Horsham, PA 19044
Phone: (215)-956-8000
privacy@pennmutual.com

Effective Date: January 1, 2020