At the time we collect personal information, Highcrest Insurance may provide additional or supplemental privacy policies to individuals for specific products or services that we offer. For example, if you sign up for, apply for, or previously had one of our Insurance Products (as defined below), the Highcrest Insurance Consumer Privacy Notice applies to you. For individuals in this context, the Highcrest Insurance Consumer Privacy Notice provides more information about how we collect, use, and share your personal information and outlines certain choices you may have. If there were a conflict between this Online Privacy Policy and any privacy notice, disclosure, policy, or terms relating to any Insurance Product, the privacy notice, disclosure, policies, or terms relating to the Insurance Product govern. As another example in which an additional or supplemental privacy policy may apply to you, if you are a life insurance agent who wants to partner with Highcrest Insurance, our Agent Privacy Notice applies to the information that we collect about you.

Glossary

We want you to understand the following defined terms that we use throughout this Online Privacy Policy. When we use the term:

"Estate Planning Document" or "Estate Planning Documents," we mean an estate planning document offered through Tomorrow Ideas, Inc. (an Highcrest Insurance affiliate). "Including" or "includes," we mean "including but not limited to" or "includes but is not limited to." "Insurance Product" or "Insurance Products," we mean the life insurance policy(ies) offered through Highcrest Insurance, including any policyholder account, as well as financial educational information and materials. For clarity, the Insurance Products do not include any Estate Planning Documents. Personal information: How we collect and generate it, and why

Depending on the applicable Insurance Product, Estate Planning Document, and the relationship we have with you, we may collect or generate personal information about you or a third party acting for you. For example:

Before you begin an application, sign up for an account, obtain a policy, or otherwise obtain an Insurance Product and/or Estate Planning Document, we may collect data from affiliates, as well as third parties such as data analytics providers, consumer reporting agencies, Highcrest Insurance customers, service providers (including insurance agents), and others. While applying, signing up for an account, or obtaining a policy through the Service or otherwise obtaining an Insurance Product and/or Estate Planning Document, and over the course of your relationship with us, we collect information about you from the following sources: You

Affiliates Third parties, such as private sources (insurance agents, consumer reporting agencies, healthcare providers, health information exchanges, and other data providers), semi-private sources such as social media platforms, and public sources (like government agencies) Service providers (such as identity verification and fraud prevention vendors) Independent business partners (such as insurance agents, brokerages, carriers, and/or marketing firms) Through the tools described in the “Cookies and Other Tracking Technologies” section below Internally (as we may generate new information about you.)

When you communicate and otherwise interact with us through the Service and/or over the phone, social media, and/or other platforms, we, Highcrest Insurance, may monitor and record the communications' content and collect information about your use and interactions with the Service (such as through the mechanisms or similar mechanisms described in the “Cookies and Other Tracking Technologies” section below). By communicating or otherwise interacting with us, you acknowledge that your communication(s) or interaction(s) may be monitored and/or recorded without further notice or warning by us or third parties.

When you interact with the Service and in connection with our marketing and other communications, we, Highcrest Insurance, may collect personal information using cookies, web beacons, page tags, pixels, and/or other similar tools (for more information see the “Cookies and Other Tracking Technologies” section below) that we and our service providers and other third parties have set.

When you interact with the Service via a social media platform, we, Highcrest Insurance, may collect a copy of the posts and other information, such as account identification information or username.

Below, we provide examples of the types of personal information we, Highcrest Insurance, and others may collect:

Contact data. This includes first and last name; alias; salutation; previous name; email address; billing address; mailing address; account username; social media profile; and phone number. Device and online identifiers and related data. This includes your device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), internet protocol (“IP”) address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), email interaction information (whether you open and/or forward our emails); and general location such as city, state or geographic area. Background data. This includes familial (including household) information; place of birth; information about your personal and professional associations, criminal history, and motor vehicle records. Health data. This includes your general health status; medical history; familial medical history; diagnosis, treatment, prescription, and other medical information; information regarding mental illness, alcohol use, drug use and/or nicotine use; height; weight; health insurance information; and other health data. Financial data. This includes credit report information (also known as consumer report or background check data); credit-based insurance scores; bank account routing number; bank account number; transaction information (including any accounts that you link to an Insurance Product and/or Estate Planning Document); financial account information (including statements and checks); payment card numbers; account information about externally linked accounts; account login credentials you use to access our Insurance Products and/or Estate Planning Documents; household income data; tax documents; insurance policy number(s); existing or past life insurance coverage; your authority over financial accounts (including trusted contact(s)/beneficial interest in and other information about entities with whom you are associated); public company affiliations; source of wealth information; net worth; and other financial information. Profile data. This includes the username and password that you may set to establish an online account on the Highcrest Insurance Service; redemption code(s); biographical details (such as date of birth); photograph or picture; interests; preferences; information about your participation in our contests, promotions, and/or surveys; and any other information that you add to your account profile. Government-issued identification data. This includes Social Security number; tax-identification number; passport number; state or local identification number (for example, driver’s license or state identification number); alien registration number; and copies (including images) of relevant government-issued identifications. Protected classification characteristics data. This includes age; national origin; citizenship; nationality; marital status; sex; and veteran or military status. Communications data. This includes information based on our exchanges with you, including when you contact Highcrest Insurance through the Service, social media, or otherwise. Transactional data. This includes information relating to or needed to complete your orders/purchases on or through the Highcrest Insurance Service, including policy numbers and transaction history. Marketing data. This includes your preferences for receiving Highcrest Insurance's marketing communications and details about your engagement with them. Relationship data. This includes information regarding beneficiaries, familial (including household) and other relationships to third parties whose personal information you may provide to Highcrest Insurance. Promotion data. This includes information you share when you enter a competition, promotion, or complete a survey. Please note that if you participate in a sweepstakes, contest, or giveaway through the Highcrest Insurance Service, we may ask you for your contact data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter. Internet, application, and network activity data. This includes data related to your activity (e.g., when and how you use the Highcrest Insurance Service and interact with our communications including emails) such as email history, browsing history (including pages or screens you viewed, how long you spent on a page or screen), search history (including the website you visited before browsing to the Highcrest Insurance Service) and clickstream history, online website tracking information, email access information, other data related to online activity, and URL referral header information. We may collect this type of information automatically via cookies, browser web storage, web beacons, and similar technologies (see our Cookies and Other Tracking Technologies Notice for more information). Location data. This includes your zip code and other information about your location and your mobile device including a unique identifier for your device; in addition, in some instances, location information can be estimated from your IP address or through your wireless signal. Sensory data. This includes audio and visual data such as a recording of your voice when you communicate on the phone or video with Highcrest Insurance. Professional or employment-related data. This includes occupation; title; employer; employment history; income; and industry affiliations. Education data. This includes your degrees and level of education. Inferential data. This includes a profile reflecting your preferences; characteristics; predispositions; behavior; attitudes; creditworthiness; and insurability profile. User-generated content data. This includes photos; images; comments; questions; messages, works of authorship; and other content or information that you generate, transmit, or otherwise make available on the Highcrest Insurance Service, as well as associated metadata.

Metadata includes information on how, when, where, and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that individuals can add or have added to their content, such as keywords, geographical or location information, and other similar data.

Other data not specifically listed here, which Highcrest Insurance will use as described in this Online Privacy Policy or as otherwise disclosed at the time of collection.

While you do not have to supply any of the personal information that Highcrest Insurance may request, if you do not provide such information, Highcrest Insurance may not be able to provide the Insurance Products and/or Estate Planning Documents to you, or you may not be able to engage with their Service. Highcrest Insurance may offer features that help individuals invite their family, friends, or other contacts to use the Service, and they may collect contact details about these invitees to deliver their invitations. Please do not refer someone to Highcrest Insurance or share their contact details unless you have their permission to do so.

Cookies and Other Tracking Technologies

Some of Highcrest Insurance's data collection is facilitated by cookies and other tracking technologies. For more information, see Highcrest Insurance's Cookies and Other Tracking Technologies Notice, which is incorporated into this Online Privacy Policy. In connection with the Service, Highcrest Insurance may make a record of your preferences for each browser on each device regarding the use of these technologies.

How Highcrest Insurance Uses Your Personal Information

Highcrest Insurance uses your personal information for administering, operating, and managing your relationship with them, the Insurance Products, and/or Estate Planning Documents. They use your personal information for operating, evaluating, and improving their business, the Service, their Insurance Products and/or Estate Planning Documents (including assessing and managing risk, fulfilling legal requirements, developing new products and services, improving and personalizing existing Insurance Products and/or Estate Planning Documents and services, and performing accounting, auditing, and other internal functions). Without limitation to how Highcrest Insurance may use your personal information as otherwise described in this Online Privacy Notice or at the time of collection, for illustrative purposes only, they outline below how they may use your personal information.

Purpose

Highcrest Insurance uses your personal information for the following purposes related to the Service, Insurance Products, and Estate Planning Documents:

1. Provide and operate the Service, Insurance Products, and Estate Planning Documents, as well as operate our business.
2. Establish and maintain your user profile on the Service and/or in relation to the Insurance Products and/or Estate Planning Documents.
3. Assist in the underwriting of your life insurance application, including eligibility determinations, risk ratings, policy issuance, and post-issuance services.
4. Administer claims and coverage.
5. Authenticate your identity, such as sending security codes via email, text, and/or SMS.
6. Mitigate fraud and enhance the security of the Service, our Insurance Products, and/or Estate Planning Documents, as well as our services.
7. Remember your devices and preferences.
8. Understand your needs and interests in relation to the Service, Insurance Products, and/or Estate Planning Documents, and our business.
9. Personalize your experience with the Service, Insurance Products, and/or Estate Planning Documents, and our communications.
10. Provide support for the Service and respond to your requests, questions, and feedback.
11. Communicate with you about the Service, including sending Service-related announcements, updates, security alerts, and support and administrative messages.
12. Present your profile and post your user-generated content (except for messages) in line with your configuration of relevant settings on the Service.
13. Administer events, promotions, and contests.
14. Facilitate your invitations to family, friends, and other contacts whom you want to invite to join the Service.

Categories of personal information we may use:

1. Contact data
2. Device and online identifiers and related data
3. Background data
4. Health data
5. Financial data
6. Profile data
7. Government-issued identification data
8. Protected classification characteristics data
9. Communications data
10. Transactional data
11. Biometric data
12. Marketing data
13. Relationship data
14. Promotion data
15. Internet, application, and network activity data
16. Location data
17. Sensory data
18. Professional or employment-related data
19. Education data
20. Inferential data
21. User-generated content data
22. Other data

For purposes of this Online Privacy Policy, we refer to the above categories as "Any and all data types relevant in the circumstances."

Purpose

Highcrest Insurance may use your personal information for the following purposes related to Marketing:

1. Send you direct marketing communications (you may opt-out of our marketing communications as described in the Opt-out of Marketing section below).
2. Personalize our marketing communications according to your needs and interests.
3. Develop and implement marketing and acquisition models.
4. Identify marketing recipients.
5. Monitor your interaction with our communications, including whether you opened them, to measure the success of our communication campaigns and your engagement with those communications. This helps us manage our content more effectively and make it more relevant to you.
6. Facilitate your invitations to family, friends, and other contacts whom you want to invite to join the Service.
7. Disclose to third parties for their purposes of offering Highcrest Insurance and/or non-Highcrest Insurance products and services.
8. Present third-party products and services we think may be of interest.

Categories of personal information we may use:

1. Contact data
2. Device and online identifiers and related data
3. Background data
4. Financial data
5. Communications data
6. Transactional data
7. Marketing data
8. Promotion data
9. Internet, application, and network activity data
10. Location data
11. Inferential data

Purpose

Interest-based advertising, which may include using your personal information to:

1. Share aggregated, de-identified, or otherwise anonymized data with third parties, including to promote our business through interest-based advertising on third-party channels.
2. Share information about our users with our third-party advertising partners to facilitate interest-based advertising to those or similar users on other online platforms.
3. Allow our third-party advertising partners to collect information about your interaction with the Service, our communications, and other online services over time and use that information to serve online ads that they think will interest you.

Categories of personal information we may use:

1. Device and online identifiers and related data
2. Internet, application, and network activity data
3. Location data
4. Inferential data

Purpose

Research and development, which may include using your personal information to:

1. Improve the Service, Insurance Products, and/or Estate Planning Documents.
2. Improve our business.

Categories of personal information we may use:

Any and all data types relevant in the circumstances.

Purpose

Analytics, which may include using your personal information to:

1. Analyze your use of the Service, Insurance Products, and/or Estate Planning Documents.
2. Analyze your responses to our communications.
3. Improve the Service, Insurance Products, and/or Estate Planning Documents.
4. Improve the rest of our business.
5. Help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Compliance with legal obligations and cooperation with others, which may include using your personal information to:

1. Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
2. Comply with contractual obligations, industry standards, and our policies.
3. Audit our internal processes for compliance with legal and contractual requirements or our internal policies.
4. Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
5. Cooperate with law enforcement authorities in investigating and prosecuting users who violate any terms and conditions governing the use of the Service or engage in behavior that is illegal or harmful to other users, including suspected fraud or situations involving potential threats to the physical safety of any person.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Protection and enforcement of rights, which may include using your personal information to:

1. Protect our, your, or others' rights, privacy, safety, or property, including making and defending legal claims.
2. Enforce the terms and conditions that govern the Service.
3. Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Data sharing in the context of corporate events, Highcrest Insurance may share certain personal information in the context of actual or prospective corporate events.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Data aggregation, de-identification, and/or anonymization: Highcrest Insurance may create aggregated, de-identified, and/or anonymized data from your personal information and the personal information of other individuals we collect. This is achieved by removing information that identifies you specifically.

We may utilize this aggregated, de-identified, and/or anonymized data for lawful business purposes, including analyzing and improving the Service and promoting our business. We may also share this data with third parties.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Further uses: If we intend to use your personal information for purposes beyond the initial reason it was collected, we will seek your consent before doing so. This applies when the additional purposes are not compatible with the original purpose.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Consent-based uses: With your consent, we may collect and/or share your personal information.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

Purpose

Retention: In general, we retain personal information to fulfill the purposes for which it was collected. This includes meeting legal, accounting, or reporting requirements, establishing or defending legal claims, or preventing fraud. The retention period for personal information is determined based on factors such as the amount, nature, and sensitivity of the information, the potential risk of unauthorized use or disclosure, the purposes of processing the information, alternative means to achieve those purposes, and applicable legal requirements.

When we no longer need the personal information we have collected, we may delete it, anonymize it, or isolate it from further processing.

Categories of personal information Highcrest Insurance may use:

Any and all data types relevant in the circumstances.

How Highcrest Insurance Shares Your Personal Information

Highcrest Insurance may share your personal information with the following parties, as well as in other instances described in this Online Privacy Policy or during the collection process:

1. Ethos affiliates: We may share personal information with companies within the Ethos family, including our corporate parent, subsidiaries, and affiliates.
2. Service providers: Personal information may be shared with non-affiliated entities or individuals who provide services on our behalf. These services may include data collection, data analytics, identity verification, risk management, security, advertising, marketing, communications, data hosting, information technology, customer support, and consumer research.
3. Payment processors: When making a purchase on the Service, your payment card information is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data according to its own privacy policy. You may also choose to be billed by your mobile communications provider, who will handle your payment data in accordance with their privacy policies.
4. Insurance producers or referral partners: Personal information may be shared with entities or individuals who assist in your purchase of our Insurance Products or direct you to our Service. We may not have control over how these insurance producers (including insurance agents) or referral partners use your personal information.
5. Insurance carriers: Personal information may be shared with insurance carriers and reinsurers. We do not control how these insurance carriers (including reinsurers) use your personal information.
6. Consumer reporting agencies: Personal information may be shared with consumer reporting agencies, such as credit reporting agencies, MIB Group, Inc., and similar entities. Information obtained from these agencies may be retained and disclosed to other parties. We do not control how consumer reporting agencies use your personal information.
7. Advertising partners: Personal information may be shared with third-party advertising companies for interest-based advertising purposes, as described above. We may not have control over how advertising partners use your personal information.
8. Third parties designated by you: Personal information may be shared with third parties when you have provided consent or instructed us to do so. For example, your authorized representatives, agents, and beneficiaries may receive your personal information. We do not control how these third parties use your personal information.
9. Business and marketing partners: Certain personal information may be shared with third parties with whom we co-sponsor events or promotions, jointly offer products or services, or whose products or services may interest you. We may not have control over how these business and marketing partners use your personal information.
10. Professional advisors: Personal information may be shared with professional advisors such as lawyers, auditors, bankers, and insurers when necessary for the professional services they provide to us.
11. Authorities and others: Personal information may be shared with law enforcement, government authorities (including insurance regulators), and private parties in good faith when necessary for compliance with legal obligations, cooperation with others, or protection and enforcement of rights.
12. Business transferees: Personal information may be shared in the context of actual or prospective business transactions, such as investments, financings, sale, transfer, or merger of all or part of our business, assets, or shares. This includes sharing information with prospective counterparties, advisers, and, in the event of a merger or acquisition, an acquirer, successor, or assignee of Highcrest Insurance.
13. Medical institutions (including medical providers): Personal information may be shared with medical institutions or providers as needed to analyze and verify insurance coverage or benefits, inform you of medical issues, or conduct operations or service audits related to your treatment.
14. Other users and the public: Certain personal information, such as feedback regarding our products and services, may be shared with other users of the Service and the public. Please note that this information can be seen, collected, and used by others