Effective Date: April 2023
To help inform you, we provide this policy explaining our information practices and the choices you can make about the collection and use of information you submit; or we collect online through 1) our website , our mobile websites, and other applications (the “Site”), and 2) our offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (“Offline Services”). The Site and Offline Services are collectively referred to in this policy as the “Services.” The Services are owned and operated by Trans-Oceanic Life Insurance Company (TOLIC) and Trans-Oceanic Life Insurance Company of America (TOLICA).
You can browse the Site without telling us who you are or revealing any personal information about yourself (e.g., name, username, password, PIN, email address, physical address, social security number, policy number, financial information, telephone number, mobile telephone number, text messages or email, health and medical information, audio, family and children’s information, date of birth, and photos). If you register for an account with us, or enroll online or through a call center, you choose to give us your personal information and are not anonymous to us. When you register an account, enroll online or through a call center, create a profile, purchase Services, download a mobile application or otherwise apply for, request or engage with our Services on our Site or through another enrollment system, you may provide personal information. Personal information is only associated with your account/profile on the Site when you sign in as a registered user. Personal information is also collected via Offline Services when you provide it to us, such as applications submitted by you or on your behalf, information about your other transactions with us, and medical exams and tests you take in connection with your application or policy.
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, internet protocol (IP) address, computer type, operating system name and version, device manufacturer and model, language, internet browser type and version, and browser click-through and usage data. We may use this information for purposes such as analyzing the use of and interaction with our Site and Services, detecting fraud and diagnosing server problems.
Our Careers section of the Site gives you the opportunity to create an “Application Account” to search and apply for jobs. TOLIC and TOLICA is an equal opportunity employer. In addition, when you apply for a job or authorize us to obtain reports about you (e.g., background check), we will collect personal and non-personal information (e.g., name, address, telephone number, resume, employment history, reference information, compensation, compensation history, education, social security number, and so on).
You may give us your personal information when you submit a claim, or when you make changes to, check on, or update your claim.
You may give us your personal information so we can respond to your requests for information, review or process your application, and send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section Notices of Information We Share Pursuant to State and Federal Laws.
We may offer sign-in services that allow you to use third-party login credentials to access the Site. We also may offer Services that allow you to share information with third-party social media websites such as Facebook, Google, Twitter, and others.
You agree that we may collect and share your video viewing with, or obtain information about your video viewing from, analytics service providers, advertising partners and third-party social media sites for two years or until you withdraw consent.
You agree that we may collect and share your demographic information (including city, state, and date of birth), claim number, policyholder information, contact information, and other information you may provide to conduct policyholder surveys.
Employers, benefit brokers and authorized representatives, and their designees may choose to submit applications for other people, either on the Site or through an affiliate or vendor of ours. The applications for our products and services may contain the applicants’ personal information. By submitting information on behalf of someone else to us, you represent and confirm that you have obtained consent from them to do so.
The information about you that we collect may be combined with information we receive from other sources and from outside records that we have acquired in accordance with the law (e.g., demographic information, navigation information, and/or additional contact information). If you are a policyholder, personal information that you provide at Sites may be combined with certain other information we have collected about you through our policy application/administration procedures. In reviewing applications, policies, claims or performing our Services, we may collect additional information from you or others, such as from other insurance companies, consumer reporting agencies and credit bureaus, as permitted by the Fair Credit Reporting Act, public records, public databases, government agencies, information clearinghouses and other third parties. In addition, you will have received a Privacy Notice from us explaining how we protect the privacy and security of information you provide and that is collected by Us (please see ).
We may collect additional information from you if you access our Site through a mobile device (e.g., your unique device identifier, location or GPS/geo-location).
When you visit our Site, we collect usage information, sent to us by your computer, mobile, or other access device, that tells us how you are using the Site. We use tracking technologies including , , , , and E-Tags to collect usage information.
We may also collect password information from you when you log in to our Services, as well as computer and/or connection information. During some visits, we may use software tools to measure and collect session information, pages viewed, including page response times, files downloaded, download errors, time spent on certain pages, page interaction information, applications used, browser type, the user’s internet service provider (ISP), and the user’s computer operating system.
Our goal is to collect and use only the information that we think is required for our legitimate business purposes, in order to better understand your interests and improve the Services. To learn more about how we use tracking technologies and cookies, seeand/or our .
When you contact our Call Center, we may collect your name, account ID and other information you provide so that we may assist you.
We use the information collected to 1) respond to your requests; 2) allow you to manage your policies and claims; 3) allow us to service your policies and manage your claims; 4) give you information about your account; (5) provide customer service (e.g., to resolve disputes, problems with your account/profile or the Services); 6) personalize your experience by providing information and content about our products and services to you that we believe may be of interest to you; 7) operate our promotions; 8) manage, administer and improve our operations and Services, including Services via employers, brokers, agents, and enrollment systems; 9) conduct surveys; 10) allow you to use our online technologies; and 11), provide you with a safe, efficient, and customized experience.
We use aggregate information about our users and non-personal information to administer, analyze and improve the Services and to analyze user behavior and prepare aggregated reports.
We use information we collect to prevent, detect, mitigate, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our .
We use your information to contact you by U.S. mail, telephone, email, text message and other means to maintain the Services and your account, to comply with your stated communication preferences, to provide other services requested by you (as described at the time when we collect the information from you), to send you marketing communications, to respond to requests related to recruiting brokers, agents and clients, or contact you for other purposes authorized by law.
We retain information as long as it is necessary and relevant for our operations, including servicing your account. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.
Information collected through the Services may be shared with:
We may disclose your information to service providers under contract who help with our business operations and Services (such as, but not limited to, call centers, application and benefit enrollment services, policyholder claims, processors and adjustors, survey providers, fraud investigations, advertising, computer software and hardware, ). We require these third parties not to further disclose your personal information to any other third party or use it for any other purpose.
Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). You may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request.
Law enforcement, governmental agencies, or authorized third parties include but not limited to inspections, reviews, and those in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability. In this regard, we may share your information with third parties in response to a subpoena, court order, search warrant, other legal process and/or to others as required or permitted by law. In such events, we may disclose information relevant and necessary to the inspection, investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation. As appropriate, we also may disclose information to persons identified in our records who have a legal or legitimate interest in your policy, such as mortgagees, lessors or lienholders.
If you access the Services through a mobile device, we may also share your information with carriers, operating systems and platforms.
Under various state laws and the Gramm-Leach-Bliley Act, insurers and authorized representatives must describe their information practices in addition to providing a HIPAA Notice of Privacy Practices.
Select your appropriate notice or form below:
Florida and Puerto Rico – |
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule provides individuals with the right to receive a notice that describes 1) how their individual health information, personal information and other protected health information (PHI) may be used and/or disclosed; (2) their privacy rights with respect to their PHI (including their right to access their PHI and other rights); and (3) our obligations with respect to that information. TOLIC/TOLICA is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule, in safeguarding PHI.
For our HIPAA-covered insurance policies, TOLIC/TOLICA is federally mandated to send a notice (Notice of Privacy Practices) to its insureds and to post the notice on its website. You should be aware that your state law may provide additional access and amendment rights to you, which differ from those granted by HIPAA. If you would like additional information concerning the collection and disclosure of PHI and your rights under state law to access and amend such information, it will be furnished upon request. Please e-mail your request to
A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
We offer certain features that are available only through the use of tracking technologies.
We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).
You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
We use tracking technologies with your prior consent, as obtained through your use of this Site.
We encode and protect the tracking technologies that we set, so that only we can interpret the information stored in them.
You may encounter tracking technologies and/or cookies from our third-party service providers that we have allowed on our Site that assist us with various aspects of our , such as Google Analytics.
You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another service user, there may be a cookie placed by that web page.)
We may target and track the videos you view on the Site. You consent to our tracking of your video viewing through the Site or third-party social media for up to two years, or as permitted by applicable law, or until consent is withdrawn.
Our Site may contain links to other third-party websites, or they may provide services on our Sites. We are not responsible for the privacy practices or the content of these third parties. Please refer to the privacy policies of these third-party sites to learn how they collect and use your information.
We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures designed to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third parties. Also, as a reminder, the internet and email generally are not always secure, and they should not be used for sending sensitive personal information, such as your SSN, birthdate or financial information. Emails also can be intercepted and/or read by unintended recipients. If you choose to communicate with us by email, then in order to contact us in a more secure manner, and if applicable, you should log into your TOLIC/TOLICA account on the Site, which has additional safeguards in place.
The Site is a general audience site, and it is not directed to minors under the age of 18. We do not knowingly collect personal information via our Services from users in this age group.
121 O’Neill St.
San Juan, Puerto Rico 00918
P.O. Box 363467
San Juan, PR 00936-3467
8240 Exchange Drive
Suites Cloud 1
Orlando, FL 32809
P.O. Box 691628
Orlando, FL 32809
We know that not all accidents are the same.
That’s why we offer you a variety of policies that you can customize to suit your needs by combining them with the various optional coverages available.