Mutual of Omaha Insurance Company and its applicable subsidiaries and affiliates ("the Company," "we," "us," or "our") are committed to protecting the privacy and security of personal information of its employees. The California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively “CPRA”) provide employees residing in California ("California Employees", "you", or "your") with specific rights regarding their personal information. This Notice supplements the Mutual of Omaha Online Privacy Policy and applies solely to California Employees. This Notice describes our practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information we will collect from you and have collected from California Employees in the past 12 months.

Personal Information is defined for purposes of this Notice and the CPRA as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you as an individual or your household.

Under the CPRA, personal information does not include:

• Publicly available information, such as information from government records, information we reasonably believe you made available to the general public, or unrestricted information you have disclosed or made available;
• De-identified or aggregated consumer information we maintain in deidentified form and do not attempt to reidentify except as required or permitted by law;
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); and
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA") or California Financial Information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act of 1994 ("DPPA").

We separately provide notices required under other state and federal laws, such as GLBA and HIPAA in connection with products and services subject to those laws. Those notices can be found by clicking here.

We may collect employee personal information from a variety of sources, such as from you; employees, managers, supervisors, or other representatives; healthcare providers; and background check companies. We may collect, use, and/or disclose to third parties, and in the past 12 months have collected, used, and/or disclosed to third parties, personal information for the business purposes described below.

Identifying information - such as your legal name, SSN, driver’s license, telephone numbers, email addresses, physical and mailing addresses, emergency contact information, state ID card, passport, visa, date of birth, signatures, and vehicle information. The Company may collect and/or use this information for various business purposes, such as to onboard new employees; to conduct background checks; to conduct facility management; for safety and security programs; to facilitate travel arrangements; to assess employee satisfaction; for communication; for deliveries/shipments; and for identification purposes; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Characteristics of protected classes - such as race, ethnic origin, gender, disability, military, sexual orientation, or veteran status. The Company may collect and/or use this information for various business purposes, such as to support diversity, equity, and inclusion initiatives; monitor recruiting efforts; to administer health, wellness and Workers’ Compensation programs; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Audio, electronic, and visual information - such as audio or video clips and quotes, professional photos, and photos for identification badges and system profiles. The Company may collect and/or use this information for various business purposes, such as for identification; to onboard new employees; to conduct facility management; for safety and security programs; for public communications; to represent the Company for business purposes; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Education and professional information - such as educational records, licenses and certifications, work history, performance review and evaluation information, training and development information, and disciplinary information. The Company may collect and/or use this information for various business purposes, such as for hiring decisions; to conduct background checks; to represent the Company for business purposes; to manage employee and monitor employee performance; for training and development; to conduct internal audits and workplace investigations; to enforce Company policies and procedures; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Benefit enrollment and administration information - such as 401k, retirement, pension, and other benefit elections; marital status; medical records; charitable donation amount; and dependent/beneficiary information. The Company may collect and/or use this information for various business purposes, such as to manage employee benefits enrollment and administration; to review claims; for absence management; for the matching gift program; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Payroll information - such as compensation data, bank account information, payroll deductions, and tax withholding information. The Company may collect and/or use this information for various business purposes, such as for timekeeping; payroll; the Employee Financial Assistance program; expense administration; litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Health information - such as health history and conditions, job restrictions, drug testing information, workplace accident and illness information, and health insurance information. The Company may collect and/or use this information for various business purposes, such as to administer health, wellness and Workers’ Compensation programs; for litigation; and to comply with applicable laws, regulations, contractual requirements, and legal obligations.

Internet or other similar network activity information - such as your search and browsing history, login information, and IP addresses on the Company's information systems and networks. The Company may collect and/or use this information for various business purposes, such as for data privacy; for physical and network security; to conduct internal audits and workplace investigations; for litigation; to enforce Company policies and procedures; and to comply with applicable laws, regulations, contractual requirements, legal obligations.

The Company does not sell or share, and in the past 12 months has not sold or shared, employee personal information.

You should provide this Notice and the information contained within it to your emergency contacts, dependent/beneficiaries, and others prior to disclosing their personal information.

We will retain your personal information that we collect and maintain subject to this Notice as long as is reasonably necessary to fulfill the purposes for which it was collected. Generally, personal information is retained for the duration of the employment relationship with you, plus any legally required record or data retention period. We will also retain your information, including after your relationship with us ends, as long as necessary to enforce or comply with our legal or contractual rights and obligations, to resolve disputes and defend claims, and to reserve our legal rights.

The Company’s Privacy Policy is located at https://www.mutualofomaha.com/legal-services

For more information about your rights regarding your personal information under the CPRA, please visit https://www.mutualofomaha.com/legal-services/california-residents-only

If you have any questions about this Notice, you may contact us by:

• Sending an e-mail to privacy.office@mutualofomaha.com
• Sending a letter via US Mail to:

If you need to access this Notice in an alternative format due to a disability, please contact Mutual of Omaha Health Services Department at 1-800-780-0304.

Last Updated: December 31, 2022