Last Updated and Effective Date: March 15, 2023

This Privacy Policy describes how Nippon Life Global Investors Americas, Inc. (“NLGIA,” “we,” or “us”) collects, uses, and discloses personal information about you. Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. This Privacy Policy applies to personal information we collect when you communicate with us through the contact methods on our website.

We may provide different or additional notices of our privacy practices with respect to other personal information collection practices not within the scope of this Privacy Policy, in which case this Privacy Policy will not apply.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with an additional notice in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Contents

Source and Type of Personal Information We Collect

A. Personal Information You Provide to Us
B. Personal Information We Collect Automatically
C. Personal Information We Collect from Other Sources
D. Personal Information We Derive

Purpose and Use of Personal Information
Disclosure of Personal Information
Retention of Personal Information
Analytics
Communication Preferences
Children
Your California Privacy Rights
Contact Us

 

Source and Type of Personal Information We Collect

A. Personal Information You Provide to Us

We collect personal information you provide directly to us. For example, we collect information directly from you when you communicate with us through the contact methods on our website. The types of personal information that we may collect directly from you include certain identifiers and contact information, such as name, phone number, business name, email address, geolocation/postal address, and other similar identifiers.

B. Personal Information We Collect Automatically

We automatically collect certain personal information about your interactions with us or our website, including:

  • Activity Information: We may collect information about your activity on our website, such as session statistics, approximate geolocation and browser/device information.
  • Device and Usage Information: We may collect information about how you access our website, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We may also collect information about your activity on our website, such as access times, pages viewed, links clicked, and the page you visited before navigating to our website.
  • Information Collected by Cookies and Similar Tracking Technologies: We and others that control collection of personal information use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our website and your experience, see which areas and features of our website are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our website to help deliver cookies, count visits, and understand usage.

C. Personal Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect information from data analytics providers, operating systems and platforms, mailing list providers, and social networks. This information includes your contact information and usage data collected through cookies and other trackers described in the Analytics section below.

D. Personal Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer about your preferences based on your browsing behavior.

Purpose and Use of Personal Information

We may use your personal information for the following purposes:

  • Provide, maintain, and improve our products and services;
  • Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
  • Personalize and improve your experience on our website;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by NLGIA and others and provide news and information that we think will interest you;
  • Monitor and analyze trends, usage, and activities in connection with our website;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of NLGIA and others;
  • Debug to identify and repair errors in our website;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.

Disclosure of Personal Information

We disclose personal information in the following circumstances or as otherwise described in this policy:

  • Our Service Providers and Contractors: We may disclose or make available your personal information to our service providers and contractors who provide our business certain services, such as lawyers, accountants and IT service providers;
  • Sale of Personal Information to Third Parties: We do not sell your personal information to third parties.
  • Sharing of Personal Information for Cross-Context Behavioral Advertising: We do not share your personal information with third parties for cross-context behavioral advertising.
  • Legal Disclosures: We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of NLGIA, our users, the public, or others.
  • Advisors and Lawyers: We disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • Disclosure of Personal Information During Change of Ownership: We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Among Our Family of Companies: Personal information is disclosed between and among NLGIA and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
  • With Your Consent: We disclose personal information with your consent or at your direction.
  • Disclosure of Non-Personal Information: We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

 

Retention of Personal Information

We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Analytics

We may allow others to provide analytics services to us on this website. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our website, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, and links clicked. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Communication Preferences

You may opt out of receiving promotional emails from NLGIA by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such about our ongoing business relations.

Children

This website is not intended for or directed at children under the age of 18. In addition, we do not knowingly collect personal information from children under the age of 18. We also do not knowingly sell, share, use for targeted advertising or disclose the personal information of children under the age of 18.

Your California Privacy Rights

The California Privacy Rights Act (“CPRA”) and other laws in California afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

Summary of Prior 12-Month Personal Information Handling Practices

We have not collected personal information through the contact methods on our website in the 12 months prior to the Last Updated and Effective date listed above, which is also when our website went live.

Selling or Sharing of Personal Information

We do not sell or share your personal information with third parties. We also do not knowingly sell, share, use for cross-context behavioral advertising or disclose the personal information of children under the age of 16.

Your Rights

The CPRA affords consumers residing in California the following rights with respect to their personal information, subject to certain exceptions:

  • (1) Right to Delete. You have the right to request us to delete the personal information we have collected about you.
  • (2) Right to Correct. You have the right to request us to correct inaccurate personal information we maintain about you.
  • (3) Right to Know and Access. You have the right to know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
  • (4) Right to Data Portability. You have the right to receive the information under right (3) in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment.
  • (5) Right to Opt-Out of Profiling. You have the right to opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
  • (6) Rights Related to Sharing for Cross-Context Behavioral Advertising or Sale. We do not share your personal information for cross-context behavioral advertising or sell your personal information. Please Contact Us below if you have any questions.
  • (7) Rights Related to Sensitive Personal Information or Data. The CPRA provides additional protection for sensitive personal information. However, because we do not collect sensitive personal information, we do not offer a Limit Use and Disclosure of Sensitive Personal Information right.
  • (8) Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

Instructions on How to Exercise Your Privacy Rights

You may exercise your privacy rights by emailing us at info@nipponlifeglobal.com.  In some instances, we will need to verify your identity before honoring your privacy right request. We will verify your identity by asking you to provide personal information related to your recent interactions with us. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension under the CPRA.

Authorized Agents

You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.   If you are an authorized agent seeking to make a request, please Contact Us.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@nipponlifeglobal.com.