The Industrial Alliance Group-U.S. Operations is composed of Industrial Alliance Insurance and Financial Services Inc.’s U.S. Branch and Industrial Alliance Insurance and Financial Services Inc.’s U.S. subsidiaries, including but not limited to IA American Life Insurance Company, American-Amicable Life Insurance Company of Texas, Occidental Life Insurance Company of North Carolina, Pioneer American Insurance Company, Pioneer Security Life Insurance Company and Industrial Alliance Portfolio Management (U.S.) LLC (the “Company”). The Company is committed to protecting the Company’s clients’, employees’ and representatives’ (the “Individual/s”) privacy, and to ensuring the confidentiality of the personal information provided to it in the course of the Company’s business.

The Company’s Privacy Policy sets out the Company’s standards for collecting, using, disclosing and storing the Individual’s personal information. The Company’s Privacy Policy also explains how the Company safeguards the Individual’s personal information and the Individual’s right to access that information.

Personal Information is any information about an individual that identifies him or her, such as financial, lifestyle or health information, but not their name, title or business address, telephone or email.

Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.

Collecting information about the Individual is necessary in order for the Company to provide the Individual with high quality services. The nature and sensitivity of the information the Company collects about the Individual varies according to the services the Company provides the Individual, and to legal requirements imposed on it (such as the Individual’s social security number, where investment income is generated by a chosen product).

The purposes for which the Company collects personal information about the Individual are identified at or before the time of collection. For example, information may be collected while submitting an application or a claim.

Purposes for collecting information generally include providing products or services requested, confirming the Individual’s identity, protecting against fraud, or dealing with matters concerning the relationship between the Company and the Individual. Any questions and concerns the Individual may have regarding the purposes for collecting information may be directed to us at either of the addresses provided below.

The Company limits the collection of the Individual’s personal information to what the Company needs in relation to the purposes identified to the Individual.

The Company collects the information directly from the Individual unless the Individual allows the Company to collect information from a third party or in accordance with the law.

The Company limits the use of the Individual’s personal information to the purposes the Company has identified to the Individual. This means that the Company cannot use the Individual’s personal information for other purposes without the Individual’s consent, except as permitted or required by law.

The Company cannot disclose the Individual’s personal information to anyone except with the Individual’s consent or as permitted or required by law.

The Individual’s personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties.

The Individual has the right to know, on request to whom the information was disclosed. Only in rare instances is the Company prevented by law from honoring such a request. The Company maintains accurate records, recording to whom it discloses personal information and in what circumstances the information was disclosed.

The Company will occasionally share the Individual’s personal information with service providers or agents to ensure the proper administration of products or to provide an Individual with the services the Individual requires. These service providers or agents must agree to comply with privacy legislation before receiving any personal information.

Any questions concerning the collection, transfer or use of personal information can be forwarded to the Privacy Officer at either of the addresses provided below.

The Company only retains the Individual’s personal information for as long as needed for the purpose it was collected. The Company must destroy this information in accordance with the law and the Company’s record retention guidelines. When the Company destroys the Individual’s personal information, the Company makes sure that confidentiality is secured and that no unauthorized person can access the information during the destruction process.

The Company does not disclose an individual’s personal information to any non-affiliated third party except as authorized by that individual. We may disclose personal information to one of our affiliated companies within the Industrial Alliance Group with the individual’s written permission, or to process a transaction, such as a claim, or otherwise as permitted by law. The Company does not sell client lists to third parties.

The Company makes every possible effort to ensure that the Individual’s personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.

The Company is responsible for the Individual’s personal information in the Company’s possession or control, including information that may be transferred by the Company to third parties for processing. The Company requires such third parties to keep personal information under strict standards of privacy and protection.

The Company adheres to legislated and self-imposed rules, aimed to safeguard the Individual’s privacy. The rules are established by this Privacy Policy, the Company’s privacy compliance program, the Code of Business Conduct (applicable to directors, officers and employees), and the Compliance Guidelines for Our Producers in Today’s Market Place (applicable to agents and brokers), as well as insurance industry guidelines and applicable law. The Company’s staff is trained on these processes and procedures and is provided with information about privacy laws.

The Company has implemented and continues to implement rigorous safeguards so that the Individual’s personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Protection methods include organizational measures such as requiring security clearances and limiting access to a “need-to-know'' basis, physical measures (e.g. building access cards for employees, visitor registration and identification cards, off-site backups and archiving), and technological measures such as the use of password and encryption (e.g. the use of routinely changing passwords, firewalls and segmented operator access).

The Individual has the right to be informed whether the Company holds personal information about the Individual and to see that information. The Individual also has the right to inquire as to how the Company collected the Individual’s information, how the Company used it and to whom it may have been disclosed.

This information will be provided to the Individual within a reasonable time from the date the Company receives the Individual’s written request. The Company may charge a reasonable fee for processing the Individual’s request.

In certain limited and specific circumstances, the Company may refuse to provide to the Individual the requested information. Exceptions to the Individual’s access right can include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential money laundering or fraud, and information that is subject to attorney-client or litigation privilege.

In cases where the Company holds medical information about the Individual, the Company may refuse to provide the Individual with direct access to this information and may instead request that a health care professional be designated to provide the information to the Individual.

The Individual may challenge the accuracy and completeness of the Individual’s personal information. The Company will respond to an amendment request within a reasonable time.

Any request for access to information or request for amendment must be sent to either of the following address:

Privacy Officer IA American Life Insurance Company
17550 N. Perimeter Drive, Suite 210
Scottsdale, Arizona 85255
American-Amicable Life Insurance Company of Texas
425 Austin Avenue
Waco, Texas 76701

The Company’s employees and representatives are trained to respond to the Individual’s questions or concerns about personal information. Should the Individual be unsatisfied with the Company’s employee's’ or representative’s response, the Individual may contact the Privacy Officer at the addresses mentioned above.

A complaint concerning the protection of personal information should be addressed to the Privacy Officer at the addresses provided below.