Questions or requests? To submit privacy-related questions or requests, please call our toll-free number at 855-756-4738 or send us an email at Participant_services@empower-retirement.com. Please do not put any confidential or personal account information in an email request.

December 8, 2019

PRIVACY POLICY

In this privacy policy, we will cover:

Welcome to the Empower Retirement website.

Empower Retirement takes data privacy very seriously and is committed to protecting and respecting the privacy, security and integrity of your personal information. This policy sets out key information regarding Empower Retirement and how your personal data will be collected, used and protected. Please note that certain portions of this policy may, or may not, be applicable to you based on the services and products in which you are enrolled and applicable laws. This policy is supplemented by specific notices, set out in links within this policy, that provide additional information pertaining to your relationship with Empower or addressing the requirements of the jurisdiction in which you live. In this policy, the terms “Empower,” “Empower Retirement,” “we” and “our” refer to each and all of the Empower family of companies listed at the end of this notice.

How we collect data

Empower collects personal information only as required or permitted by law. Based on the services or products you receive from us, or other transactions initiated by you, your personal data may be collected from the following sources:

  • From you when you communicate with us by email, by web (including online chat) or electronic communication on our websites, by correspondence, or by phone
  • From you, or your representative, when you complete applications and forms for various products or services.
  • From your plan sponsor (your employer or former employer) for a retirement plan in which you are enrolled and for which Empower provides services (your data may be provided by your plan sponsor or its service providers, such as payroll providers, third-party administrators or advisors).
  • From activity in your account (for example, data from the administration of your investments, balances, trades and elections).
  • From you when you browse our website (see website, cookies and web beacons sections below) and from tracking technologies in emails that we or third parties send to you.
  • From Empower’s suppliers, consumer and insurance reporting companies, data providers and other third parties as permitted by law.
  • From other sources to complete transactions initiated by you or your representative (for example, to transfer balances from another retirement account into a new retirement account).

How we use data

Empower uses your personal data to respond to your requests and inquiries and to provide you with services and products you receive from us. In the event you are enrolled in a retirement plan that is administered by Empower pursuant to a services agreement with the plan sponsor (your employer or former employer) of your retirement plan, Empower will process your data to perform its services to the plan sponsor. If you contract directly with Empower or its affiliates for other services offered by Empower to individual customers, such as advisory services, financial products or financial wellness services, Empower will use your data to process transactions and perform its obligations in connection with such services. Empower will also use your data as permitted by law to make you aware of other financial products or services that may be of interest to you, including products and services that we offer directly or in conjunction with third party companies specializing in such products or services.

Empower will use your data for other purposes as permitted by law, including to protect your interests and ours in the detection, prevention and mitigation of fraud, to meet the requirements of applicable laws and regulations, to comply with requests of regulators with jurisdiction over our services, and for product development and delivery.

How we share data

We limit the information we share and the parties we share it with. We do not sell your personal data. What we share depends on the types of products or services you have procured and applicable law. As we are permitted to share your information pursuant to applicable laws and as described in this notice, the Empower does not respond to “do not track” signals or similar digital privacy mechanisms. We do not share your personal data in any way that requires that we offer you an “opt-out” of such sharing.

Personal data may be shared as necessary to effect, administer, or enforce a transaction you request or authorize, or with your consent, or at your direction, or as allowed by applicable law. For example:

  • Retirement plans – If you are enrolled in a retirement plan sponsored by a plan sponsor (your employer or former employer), personal data may be shared with the plan sponsor and with that plan sponsor’s third-party administrators, advisors, and service providers as authorized or directed by the plan sponsor.
  • Affiliate sharing – Certain personal data may be shared among our affiliates as permitted by law for their everyday business purposes, to make it easier to do business with us, and for such affiliates to market to you. Our affiliates are listed below in this policy and include, but are not limited to, our broker-dealer, our advisory service provider and our trust company.
  • Nonaffiliated third parties – Your personal information may be shared with nonaffiliated third parties to provide services on our behalf, including marketing our products or services. These third parties agree to maintain the confidentiality of the personal data and use it solely to provide their services to us.
  • Joint Marketing – Your information may be shared with financial institutions that have joint marketing or service agreements with us and who agree not to use the information other than as specified in such agreements or as permitted by law.
  • Health Information – Your health information will not be shared except as permitted or required by law.

Other disclosures of your data that may be made, subject to applicable law, include disclosures:

  • To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.
  • For institutional risk control, or for resolving customer disputes or inquiries.
  • To persons acting in a fiduciary or representative capacity on your behalf.
  • To provide information to persons assessing our compliance with industry standards, and our attorneys, accountants and auditors.
  • To protect the confidentiality or security of our records pertaining to you, the service or product, or the transaction therein.
  • To comply with federal, state, or local laws, rules, and other applicable legal requirements.
  • To comply with a properly authorized civil, criminal or regulatory investigation or subpoena or summons by federal, state or local authorities, or to respond to judicial process or government regulatory authorities having jurisdiction over the financial institution for examination, compliance or other purposes as authorized by law.
  • To a group policyholder to report claims experience or for an audit.
  • In connection with a proposed or actual sale, merger, transfer or exchange of all or part of our business.
  • To a government agency to determine your eligibility for benefits they may have to pay for.
  • To a certificate holder or policyholder to provide information about the status of a transaction.
  • To consumer and insurance reporting organizations (such as your credit, financial or health history; please note, these organizations may retain information provided by us and disclose it to others).
  • For purposes otherwise permitted or required by law.

After your relationship with us ends, the terms of this policy shall continue to be applicable to your data as long as we retain your data, consistent with applicable law.

Children

Empower Retirement will not knowingly collect personal data from children under the age of 16 without seeking prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definitions of "child" or "children" may be slightly different as set forth in various applicable laws.

Security

We use physical, administrative and technical safeguards designed to protect the confidentiality, integrity and availability of your data. In addition, Empower Retirement provides a security guarantee to its customers and participants as described here.

Website use

When you access our websites or mobile applications, we or our third party suppliers use a variety of technologies, such as cookies and web beacons, that automatically collect data (such as: without limitation, your device type, browser type, internet protocol address, operating system used, number of visits, average time spent on the site and pages viewed). This data is used to operate the websites more efficiently, maintain the security of your online session, improve our websites’ design, perform online advertising, and improve website navigation. If you have created an account with us, we may combine the data collected through the tracking systems described herein with other information we know about you. We use this information internally to provide you with a better user experience and to offer you products and services that may be of interest to you.

Some of our websites include links or navigation to third-party sites. These third-party sites may include informational sites, sites providing financial wellness tools and services, or services offered to you solely by a third party, as further described in the disclosures provided on such sites.

Cookies and web beacons

A cookie is a piece of information that is stored on your computer, tablet, phone or other device by your web browser. Web beacons (also known as clear gifs, web bugs or pixels) are small graphics with a unique identifier and are embedded invisibly on web pages. Empower and third party service providers we hire may use such cookies and web beacons to track the online movements of users of our websites and mobile applications, and to collect other data such as IP address, type of device used, and browser information. Empower and its third party service providers use such data to customize your experience on our website, personalize our communications with you, and to send you information about our products and services. With respect to e-mails that are sent to you, we or our service providers also use cookies and web beacons to determine when you receive and open our emails, whether you click any links in the email, and other information about the device from which you access the email, as permitted by law.

If you do not want to have cookies on your computer or device, you can use the settings or tools offered on your browser to refuse or deny cookies, or to delete cookies that have already been stored. If you refuse or delete cookies, you may notice an impact on your use of Empower’s (and its affiliates’) websites; for example, you may not be able to sign in and access your account without additional authentication, or we may not be able to recognize you, your device or your online preferences.

Analytics

We engage third-party suppliers to collect, research and report on the information described above. These third parties use cookies or web beacons to collect information about your activity on our website, mobile application or regarding your receipt and access to information in emails that we send to you. Specifically, we use a tool called “Google Analytics” to collect such information. Google Analytics collects information such as how often users visit our websites, what pages they visit when they do so, and what other sites they used prior to coming to this site. For more information about how Google uses data, see the site “How Google uses information from sites or apps that use our services,” here. You can prevent Google Analytics from recognizing you on return visits to our webpages by using your browser settings to disable cookies.

Interest-based advertising and communications

Empower advertises its products and services on its websites and mobile applications and on websites not affiliated with Empower, and we contract with third party advertisers to place those advertisements. Empower and its suppliers may also send you advertising and communications that are tailored to you or that provide you with products or services that may be of interest to you, based on information that we or that such third-party service providers have collected about you (“interest-based advertising”). Such advertising may include advertising on websites not affiliated with Empower, such as social networks. Our third-party advertising providers might use information collected from cookies or beacons about your use of our websites to provide Empower or non-Empower interest-based advertisements based on your online activity as permitted by law. We do not provide any information that identifies you to these service providers. If you would like to opt-out of such interest-based advertising, you may find more information through the Network Advertising Initiative here.

Requests, questions or complaints

You may send us requests, questions or complaints as described at the top of this privacy policy. In addition, you may contact us by mail to the address below:

Empower Retirement
Attn: Privacy Officer
8525 E Orchard Rd, 2T3
Greenwood Village, CO 80111

Changes to this policy

This policy shall be reviewed annually and updated to reflect any changes, if applicable.

About us

The policy is applicable to the following family of companies and brands:

  • Empower Retirement, LLC
  • Great-West Life & Annuity Insurance Company
  • The Great-West Life Assurance Company (US operations)
  • Great-West Life & Annuity Insurance Company of New York
  • Great-West Financial Retirement Plan Services, LLC
  • Advised Assets Group, LLC
  • GWFS Equities, Inc.
  • The Canada Life Assurance Company (US operations)
  • Emjay Corporation
  • Empower Retirement*
  • FASCore, LLC
  • Great-West Life & Annuity Insurance Company of South Carolina
  • Great-West Capital Management, LLC
  • Great-West Funds, Inc.
  • Great-West Trust Company, LLC.

GWFS Equities, Inc. is a Member of the Securities Investor Protection Corporation ("SIPC"). You may obtain information about SIPC, including the SIPC brochure, by contacting SIPC:
Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215
Email: asksipc@sipc.org
Tel: (202)-371-8300
Information about SIPC is also available at www.sipc.org.

*Empower Retirement is a brand name for retirement services provided by certain of the companies set forth above.