United States Employee/Contractor Privacy Policy

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UNITED STATES EMPLOYEE/CONTRACTOR PRIVACY POLICY

Pacific Life and our subsidiaries (collectively, “Pacific Life,” “we” or “us”) value the trust of our employees and contractors and endeavor to protect the privacy of their personal information. The purpose of this United States Employee/Contractor Privacy Policy (the “Policy”) is to notify U.S. residents (“you”) of the processing of information that can reasonably be linked with you and that we collect, use, retain, and disclose in the context of your current or former role as our employees or contractors (“Personal Information”).

If you are an employee, the Policy also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Policy and ensure that you have the right to provide their Personal Information to us.

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we may collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date this Policy was last updated.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, alias, postal address, unique personal identifiers, IP address, email address, account name, online identifiers, photo badges, beneficiary designations and government-issued identifiers (e.g., Social Security number, driver’s license number, passport number)	Our subsidiaries; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Personal information as defined in the California customer records law, such as name, contact information, signature, Social Security number, passport number; medical, insurance, financial, education and employment information, physical characteristics or description	Our subsidiaries; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, gender, race, disability, medical conditions, citizenship, gender identity and expression, primary language, immigration status, marital status, and requests for leave	Our subsidiaries; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Commercial Information, such as transaction information and purchase history, including travel expenses and information about corporate credit card purchases	Our subsidiaries; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Internet or network activity information, such as access and usage information regarding websites, applications and systems, information about online communications, including browsing and search history, timestamp information, and access and activity logs	Our subsidiaries; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Biometric Information, such as fingerprints and faceprints, collected and used for security purposes	Our subsidiaries; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Geolocation Data, such as device location and approximate location derived from IP address	Our subsidiaries; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Audio/Video Data. Audio, electronic, visual and similar information, such as call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage, and photos on websites or in personnel directories	Our subsidiaries; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Education Information subject to the federal Family Educational Rights and Privacy Act such as student transcripts, grades, academic standing and disciplinary records, confirmation of graduation	Our subsidiaries; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions	Our subsidiaries; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Sensitive Personal Information. Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; Account log-in in combination with any required security or access code, password, or credentials allowing access to an account; Racial or ethnic origin, citizenship, immigration status, or union membership; Personal Information collected and analyzed concerning an individual’s health; Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation.	Our subsidiaries; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Purposes for the Collection, Use, and Disclosure of Personal Information

We collect, use, and disclose Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:

Plan and manage workforce activities and personnel generally, including for recruitment, onboarding, appropriate staffing, performance management, training and career development, payments and benefit administration, training, leaves and promotions;
Conduct workforce assessments, including determining physical or mental fitness for work and evaluating work performance;
Process payroll, manage wages and other awards such as bonuses, reimburse expenses and provide healthcare, pensions, savings plans and other benefits;
Operate, maintain, monitor and secure our facilities, equipment, systems, networks, applications and infrastructure;
Manage attendance, time keeping, leaves of absence and vacation;
Facilitate communication and workforce travel;
Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;
Conduct research, analytics, and data analysis, such as to assist in succession planning and to ensure business continuity, as well as to design retention programs and diversity initiatives;
Perform identity verification, accounting, budgeting, audit, and other internal functions, such as internal investigations, disciplinary matters and handling grievances and terminations;
Operate and manage IT and communications systems and facilities, allocate company assets and human resources, and undertake strategic planning and project management; and
Comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements such as income tax deductions, record-keeping, work permit and immigration regulations and reporting obligations, and the exercise or defense of legal claims.

Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information

We collect, use, and disclose Sensitive Personal Information for purposes of: performing services on behalf of our business; ensuring the quality or safety of services we control or improving those services; ensuring the security and integrity of our infrastructure and the individuals we interact with; establishing and maintaining your employment relationship with us; managing payroll and corporate credit card use; administering and providing benefits; short-term transient use; securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure; preventing, detecting, and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use or disclose Sensitive Personal Information for additional purposes.

Retention Period

We retain each category of Personal Information including Sensitive Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The duration of your employment or your contract with us;
The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your records for a certain period of time); and
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Sources of Personal Information

We collect this Personal Information from you and from third-party sources such as our subsidiaries, your colleagues, and managers, references you provide, prior employers or schools, credit reporting agencies, background check providers, providers of benefits, and publicly available databases.

Pacific Life, as referred, means Pacific Life Insurance Company and its US subsidiaries, including, but not limited to, Pacific Life & Annuity Company, and Pacific Select Distributors, LLC.

Changes to this Policy

We may change or update this Policy from time to time. When we do, we will communicate changes and updates to this Policy by posting the updated Policy on this page with a new “Last Updated” date.

Contact Us

Please contact Enterprise Compliance at PrivacyMatters@pacificlife.com if you have any questions regarding this Policy.

Additional Information for California Residents Only

Rights Requests

If you are a California resident, you may make the following requests:

You may request that we disclose to you the following information:
- a. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- b. The business or commercial purpose for collecting Personal Information about you; and
- c. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable)
You may request to correct inaccuracies in your Personal Information.
You may request to have your Personal Information deleted.
You may request to receive the specific pieces of your Personal Information, including a copy of the Personal Information you provided to us in a portable format.

To exercise the above rights employees should contact human resources.

We will not unlawfully retaliate against you for making a request. To make a request, please contact us via AskHR@pacificlife.com, toll-free at 1-800-800-7646, or by mail to:

Pacific Life Insurance Company
Human Resources Department
700 Newport Center Drive
Newport Beach, CA 92660

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your name, email address, and employee number, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Rights Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Rights Requests” or confirm that you provided the agent permission to submit the request.

We do not “sell” or “share” your Personal Information, including your Sensitive Personal Information, as defined under the California Consumer Privacy Act. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.

LAST UPDATED: 03/29/2024