Last updated: January 1, 2020



Our Privacy Commitment

This notice describes what we do with your Personally Identifiable Information (“PII”) and the choices you have about how it is used and shared. Our privacy practices apply to our prospective, current and former customers.

PII is information that clearly identifies you. Your name, address, policy number, birth date, Social Security number, health and financial information, and other nonpublic personal information is PII.

We will not ask for your PII unless it is reasonably necessary to issue or service your insurance with us.

This notice explains the privacy practices of insurers owned by Oxford Life Insurance Company. (“Affiliates”). This notice covers health insurance, life insurance and annuities issued by Affiliates, as well as third-party insurance products that are administered by Oxford Life Insurance Company. The privacy practices of Oxford Life Insurance Company are explained in a notice provided to its insurance and annuity customers.

The Oxford Life® Family of Companies includes: Oxford Life Insurance Company®; North American Insurance Company®; Christian Fidelity Life Insurance Company®; and Oxford Life Insurance Company® in its capacity as third party administrator for certain Medicare supplement insurance policies issued by Celtic Insurance Company and USAble.

We may change our privacy practices at any time. We will post a copy of our current notice on our website(s), and a paper copy of our most current notice is available to you at any time upon request. Our Life, Annuity and Medicare Supplement plans comply with federal health privacy laws as a single entity.

Protecting Your Information

Your trust is important to us. We take your privacy seriously. We limit access to our buildings and our information systems to authorized persons. We have policies, procedures, and training designed to keep PII safe and secure. We use privacy and security safeguards that obey state and federal regulations. If the laws differ, then we will follow the stricter law.

Types of PII We Collect and Why We Collect It

Mostly, we collect your PII directly from you. You provide PII when you apply for insurance, make a claim or ask us to perform a policy transaction. We ask for your name, contact information, birth date, and may need your Social Security number. Depending on the coverage you apply for, we may ask about your past or present health status, financial assets or other identifying information.

We collect PII from third parties if it is required to determine your eligibility for coverage or to process a claim. We may get reports from MIB, Inc., a nonprofit insurance support organization that exchanges information with its members. We must obtain your permission before we obtain from or provide information about you to MIB. We ask your permission to obtain this information, unless the law allows otherwise. We are not permitted to use genetic health information to make underwriting decisions.

Mostly, we use your PII to issue and service your coverage with us, such as to pay claims or to conduct quality assessments and customer service improvement activities, or in connection with risk management and business planning functions. If permitted by law, we may also use your PII to offer you other insurance-related products and services. If you have health coverage, we will not use PII associated with your health plan for marketing purposes unless the law allows it, such as when you discuss your insurance needs directly with your insurance agent.

Sharing PII Fairly and Legally

We may disclose your PII to nonaffiliated companies that perform services for us to administer your policy, or with whom we have joint marketing agreements. We have written agreements with these companies requiring them to maintain strict privacy and security standards. You cannot opt out of this type of sharing. We may disclose your PII to Affiliates, and other entities with which we are under common control or nonaffiliated companies as allowed by law, to protect the security of our records and information systems, to meet legal or regulatory requests, or to follow state, federal or local laws (such as for public health purposes, to report abuse or neglect, or to comply with a court order). You cannot opt out of this type of sharing.

In addition, we may make limited disclosures of your PII to individuals involved in your care if you are incapacitated, or in an emergency situation if we believe the disclosure would be in your best interest.

Your Opt-Out Rights

If the law allows us to share your PII for marketing purposes, you have the right to opt out by calling the toll-free number listed below. You can restrict sharing of your PII with Oxford Life, nonaffiliated companies or both. If you opt out of Affiliate sharing, this choice is effective for five (5) years. If you opt out of nonaffiliated company sharing, this choice is effective until you revoke it. We will not unfairly discriminate against you because of your opt out choice.

California, Montana, New Mexico and North Dakota

We will not share your PII with nonaffiliated companies for marketing purposes. You do not need to take any action to opt out of this kind of sharing. However, we still may share your PII with nonaffiliated companies for purposes that are allowed by law.

To Opt Out – Call us at (866) 641-9999

Please have your policy number ready and our automated opt out line will lead you through your choices.

Or Write to us at 2721 N. Central Avenue, Phoenix, AZ 85004. We need your full name, mailing address, and policy number(s).

You Can Access Your PII

You may ask to see or receive a copy of the PII we maintain about you. Please ask us in writing. We will need your full name, mailing address, and policy number(s). We will respond within the time frame required by law, generally about 30 days after receipt. Your request should be signed by you or your legal representative. We may charge a reasonable, cost-based fee.

You Can Correct Your PII

You may ask us to correct, amend or delete the PII we maintain about you. Please ask us in writing. We will need your full name, mailing address, and policy number(s). Even if we have contradictory information, we will keep your request with your file for as long as you are our customer. If we agree to your request, we will make reasonable efforts to communicate the correction, amendment or fact of deletion to other parties who may need this information. We do not have to agree to your request if we did not create the PII, if we do not store the information, or if your PII is already accurate and complete. Your request should be signed by you or your legal representative. If we deny your request, we will explain why in writing and let you know how to submit a complaint to us or regulatory agencies.

You Can Request a List of Disclosures of Your PII

You may ask us for a list of disclosures of your PII made within the last six years for health plans and two years for other types of insurance. Please ask us in writing. We will need your full name, mailing address, policy number(s), and the time period of your request. We do not have to include disclosures that were requested by you (or your legal representative), or disclosures we made about payment or health care operations. Your request should be signed by you or your legal representative. We will provide this information free of charge once a year; otherwise, we may charge a reasonable, cost-based fee.

You Can Request Information on Adverse Underwriting Decisions

If you apply for individually underwritten insurance and your application is: declined; offered at higher than standard rates; if your agent did not apply for the coverage you requested, or if we take a permitted action to terminate your coverage (other than for nonpayment), we will communicate with you. We will either provide you with a written explanation of the specific reason(s) for our decision, or let you know that you may receive this information by writing to us at the address listed at the bottom of this notice. If you write to us within 90 business days of the underwriting decision, we will respond within 21 business days. We will also provide you with a summary of your rights to request access, correction, amendment or deletion of your recorded PII.

Your Right to File a Complaint

If you have a privacy related complaint, please let us know in writing so we can address your concern. Write to us at 2721 N. Central Avenue, Phoenix, AZ 85004. You may also file a complaint with 1) your state department of insurance or 2) the Secretary of the U.S. Department of Health and Human Services in Washington, D.C. within 180 days of the conduct. We will not retaliate against you for filing a complaint.

You Can Request Alternative Communications

You may ask us to communicate with you in a different way, such as directing your mail to a post office box. Please ask us in writing. We will consider all reasonable requests, but must say “yes” if you tell us that disclosure of all or part of your PII could place you in danger. Your request for highly confidential handling should be signed by you or your legal representative.

Your Right to Request a Restriction on Communications

You may ask that we not share your PII (including health information) regarding payment or for our business operations with certain persons. Please ask us in writing. We will consider your request, but are not required to agree if we believe it would affect your medical care or performance of our business operations. If we deny a new or ongoing request, we will explain why to you in writing. Your request should be signed by you or your legal representative. You can revoke your request at any time by phone or in writing.

Additional Rights for New Mexico Residents

In the course of collecting PII from sources other than you, we may receive information about acts of domestic abuse or domestic abuse status. Under New Mexico law, victims of domestic abuse may notify us to be designated as a “protected person.” A “protected person” is someone who has notified us that he or she is or has been a victim of domestic abuse and who is either a present or proposed principal insured or policy owner, an insurance applicant, or a claimant for benefits under an insurance policy. If you want to know more about our confidential abuse information practices or wish to be designated a “protected person,” please ask us in writing. Write to us at 2721 N. Central Avenue, Phoenix, AZ 85004.

Additional Privacy Standards For Health Insurance Plans

If you have health insurance coverage, there are some additional privacy standards that apply to you. Remember, PII includes specific health and financial information, as well as personal identifiers and demographic information about you.

  • You have the right to be notified following a breach of your unsecured PII.
  • Except in limited circumstances, we are required to obtain your permission to use or disclose PII for marketing purposes.
  • We will not disclose psychotherapy notes, or sell or use PII for fundraising purposes without obtaining prior written permission.
  • Except for the disclosures of PII made at your request, or for payment activities or health care operations, we will obtain your permission before using or disclosing your PII.

Information Practices for Determining Eligibility for Insurance

Fair Credit Reporting Act Notice

As part of our life insurance underwriting procedures, we may get an investigative consumer report. The report will contain information about your character, general reputation, personal characteristics and mode of living. The information is obtained through interviews with your friends, neighbors and associates. You have a right to ask for details on the nature and scope of this report. You have a right to make a written request to be personally interviewed in connection with the preparation of this report. You have the right to contact the consumer reporting agency to review a copy of the report. If you write to us we will let you know if we have in fact obtained a report; and, if so, the name and the address of the agency making the report.

Privacy Policy- California Residents Only

The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. Personally Identifiable Information ("personal information") is defined for purposes of this section of the Policy as information that identifies, relates, describes, references, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, you as an individual. Personal information includes information collected directly from you if you choose to purchase products, use certain services available on our sites, or personal information that you voluntarily provide.

Sharing Personal Information

We may disclose your personal information to our affiliates and service providers, so we can provide you information about our products and services, as well as perform various business functions. We do not authorize our service providers to use or disclose the information except as necessary to perform services or functions on our behalf, or to comply with legal requirements.

We do not sell your personal information.

Rights Under the CCPA and How to Exercise Them

If you are a California resident whose personal information is covered by the CCPA, you may have certain rights under the CCPA as listed below. We will comply with your request in accordance with, and to the extent permissible under applicable law.

Right to Know

You have the right to request that Oxford Life Insurance Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, a separate document containing the identification of the personal information categories that each recipient purchased, and the identification of the personal information categories that each recipient obtained, will be included.

Should you choose to exercise this right, the above information will be supplied to you, at no extra cost.

Right to Delete

You also have the right to request the deletion the personal information we have collected from you (and direct our service providers to do the same). However, there are a number of exceptions that include, but are not limited to, when the information is necessary for us to do any of the following:

  • Provide goods or services to you;
  • Complete your transaction or request;
  • Perform a contract between us and you;
  • Detect or resolve issues related to security or functionality;
  • Comply with the law;
  • Conduct research in the public interest;
  • Make internal or lawful uses of the information that are compatible with the context in which you provided it;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.);
  • Safeguard the right to free speech; or
  • Carry out any actions for internal purposes that the consumer might reasonably expect.

Should you request deletion of your personal information and any of the above exceptions apply, you will be notified in writing that your request has been denied, including an explanation of the applicable exception(s).

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for good or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
How to Exercise Your Rights

To exercise any of your rights under the CCPA, please submit a verifiable request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request twice in a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.