Privacy policies and practices

Constellation Insurance and its affiliated companies thank you for your trust and confidence. Constellation is committed to providing you, our customer, with competitive insurance and annuity products and services to help you meet your changing needs.

We are equally committed to protecting the private and personal information we collect and maintain about you. Federal law requires us to tell you how we collect and protect this information. Please read this notice carefully to understand what we do. Our privacy policies and practices are posted online at constellationinsurance.com. If you wish to continue to receive a hard copy on an annual basis, you may do so by contacting us at 513.794.6100. Unless substantive changes are made or otherwise requested, the privacy policy will no longer be mailed to your home.

Collection of information

We gather private and nonpublic personal information about you in order to provide you with our insurance products and services. The information we collect starts with the information you provide on applications and other forms, when you request services, and when you file a claim. Although you provide most of the information yourself, we may also ask others about you, including, (1) health care providers, (2) consumer reporting agencies in compliance with the federal Fair Credit Reporting Act, (3) your employer, business associates or advisers, (4) interviews with persons who have knowledge of your circumstances and (5) public records, including motor vehicle reports.

We only seek to collect and use personal information that is necessary and appropriate for the needs of our business. We may collect, use and share information that relates to your insurance or investment needs and objectives. Such information may include income, finances, Social Security number, credit history, credit scores, employment, health, habits, and other factors that relate to the insurance products or services we are providing. Federal law gives you, the customer, the right to limit only (1) sharing information regarding your creditworthiness for affiliates’ everyday business purposes, (2) affiliates from using your information to market to you and (3) sharing for non-affiliates to market to you.

Maintaining complete and accurate information on our customers’ records is important. You have the right to see and, if necessary, request a correction on your record. If you would like a copy of your record or if you believe that your record is incorrect or incomplete, please write or call us at Constellation Insurance, Attention: Underwriting Division, P.O. Box 237, Cincinnati, OH 45201-0237, telephone 800.366.6654.

Disclosure of information

Federal law gives consumers the right to limit some but not all sharing of personal information. However, Constellation does not disclose private or nonpublic personal information about our customers or former customers to anyone, except as described in this notice. We do not sell customer lists or any information about our customers. In order to service your policy or contract, we may disclose information about you to our affiliated companies, your insurance agent and, where applicable, your broker/dealer. We may disclose your information for our everyday business purposes to affiliates and non-affiliates that perform services (including administrative and claims services) on our behalf. Before disclosing information to non-affiliated service providers, we require them to agree to keep the information confidential and use it only for the purposes we have authorized. We may also disclose information to affiliates and non-affiliates as required or otherwise permitted by law. This includes a routine filing, such as a Form 1099, to the Internal Revenue Service. Additionally, we may disclose information to protect against suspected fraud or in response to a valid subpoena or other legal process. If you have any questions about the disclosure of your personal information, please call us at 800.366.6654 or visit constellationinsurance.com.

Protecting confidentiality of customer records

Your files or records are made available only to our personnel or representatives who need access to the information in order to perform their assigned duties. We do not disclose information about your health, except when authorized by you or as explained to you in our “Notice of Information Practices” delivered at the time you applied for your policy or contract. To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. In order to protect the security, confidentiality and integrity of nonpublic personal information we have gathered and maintain about you, we maintain and monitor a comprehensive information security program that contains administrative, technical and physical safeguards. Additionally, we routinely review our policies and procedures, monitor our computer networks and test the strength of our security.

Affiliates

If you applied with us for a variable life insurance policy or variable annuity contract, this notice covers the following affiliates in addition to those named above: AuguStar Distributors, Inc. (a wholesale broker/dealer), The O.N. Equity Sales Company (ONESCO, a retail broker/dealer) and its subsidiaries, including O.N. Investment Management Company and AuguStar Insurance Agency, Inc.

Persons with disabilities

We strive to ensure that every person has access to information related to our products and services, including this privacy policy. Please contact us if you would like this privacy policy provided in an alternative format and we will seek to meet your needs.

Do you need to do anything?

You do not need to take any action in response to this notice of our Privacy Policies and Practices. Because we do not share your private or nonpublic personal information other than as described above, you do not need to “opt-out.” If, however, you want more information concerning our privacy practices, please contact us at Constellation Insurance, Attn: Legal, One Financial Way, Cincinnati, OH 45242, telephone 513.794.6100, constellationinsurance.com.

Privacy Notice for California Residents Only

Submit a Verifiable Consumer Request

This Privacy Notice supplements our “Privacy Policies and Practices” and applies only to California residents (“consumers” or “you”).

A copy of our Privacy Policies and Practices can be found at constellationinsurance.com. This Notice is being provided to you to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and to inform you of your rights and how to exercise those rights under the CCPA.

Your rights under CCPA

The CCPA provides California residents with specific rights regarding their personal information, including the: (1) Right to Know and Access Your Personal Information — You have the right to request that we disclose certain information to you about our collection, disclosure, use and sale of your personal information, including the right to request the specific pieces of personal information collected about you; (2) Right to Correct Your Personal Information – You have the right to request that we correct any inaccurate personal information we maintain about you; (3) Right to Delete Your Personal Information — You have the right to request that we delete the personal information that we have collected and retained about you; (4) Right to Limit Use and Disclosure of Sensitive Personal Information – You have the right to request that we limit our use and disclosure of your sensitive personal information to that which is necessary to provide goods or services to you; and (5) Right to Opt-Out of the Sale or Sharing of Your Personal Information — You have the right to opt-out of the selling or sharing of your personal information to third parties in exchange for valuable consideration.

Please note, that our use and disclosure of your sensitive personal information is already limited to that which is necessary to provide goods and services to you. Additionally, we do not sell or share the personal information of our consumers to third parties in exchange for money or other valuable consideration. Accordingly, you do not need to opt-out of the sale or sharing of your personal information.

Personal information we collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or a member of your household.

We may have collected the following categories of personal information directly from you or about you in the last twelve (12) months. We do not necessarily collect all examples of personal information listed in a particular category, nor do we collect all categories of personal information for all consumers.

Category	Examples
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	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
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric information	Fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Geolocation data	Physical location or movements
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information	Current or past job history
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sensitive personal information	Social security, driver’s license, state identification card, or passport number; geolocation data; racial or ethnic origin, religious or philosophical beliefs, or union membership; genetic data; neural data; health data; sexual orientation

Categories of sources of personal information

For each category of personal information described above, we collect that information from the following categories of sources: (1) directly from consumers or their agents (for example, from documents consumers submit to us in order for us to provide them with products and services); (2) indirectly from consumers or their agents (for example, through information we collect about consumers from consumer reporting agencies, health care providers, government entities, etc. in the course of providing services to them); and (3) directly and indirectly from activity on our website (constellationinsurance.com) (for example, from website usage details collected automatically).

Use and disclosure of personal information

We disclose your personal information for business purposes to the following categories of third parties: (1) our affiliated companies; (2) service providers; (3) your agent; and (4) if applicable, your broker/ dealer.

For each category of personal information described above, we may use or disclose that information for the following business purposes:

To provide you with products or to administer your policy or contract.
To communicate with you as part of our business.
For third parties to perform services on your policy or contract.
For business research and analysis.
As required or otherwise permitted by law.
To respond to and resolve complaints.
To protect against suspected fraud.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes as described herein without providing you notice.

We generally retain our records that contain personal information in accordance with our records retention schedule and as needed to provide you services. We also retain your personal information as required or permitted by law, to comply with our legal obligations, resolve disputes, and enforce our agreements.

How to exercise your rights

You (on behalf of yourself or your minor child), or a person registered with the Secretary of State and authorized by you to act on your behalf, may exercise your CCPA rights described above by submitting a Verifiable Consumer Request to us by calling 800.366.6654, visiting constellationinsurance.com or writing to us at Constellation Insurance, Attn: Legal, One Financial Way, Cincinnati, OH 45242.

The request must provide sufficient personal information about you (for example, your date of birth, address, last four digits of your Social Security number, etc.) to allow us to match that information with the personal information we have already collected and retained about you, in order to verify your identity.

We cannot respond to your request if we cannot verify your identity or authority to make the request, or if we cannot confirm that you are the consumer whose personal information we have collected and retained. Making a request does not require you to create an account with us. We will only use the personal information provided in a request to verify your identity or authority to make the request.

Response time

When possible, we will respond within 45 days of our receipt of your request. If we are unable to meet this deadline we will notify you that we need more time (up to 90 days). We may deny your request if an exemption or exception under the CCPA applies.

Non-discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. We will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services; (3) provide you with a different level or quality of goods or services; or (4) suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Questions/additional information

For questions or additional information on the CCPA, our Privacy Policies and Practices or this supplement thereto, you may contact us by calling 800.366.6654, visiting constellationinsurance.com or writing to us at Constellation Insurance, Attn: Legal, One Financial Way, Cincinnati, OH 45242.