California Consumer Workforce – Financial Professionals Privacy Disclosure

Last Updated on: October 4th, 2024

This Privacy Disclosure ("Disclosure") explains how we handle Personal Information of California Consumers who are RWM Representatives, such as agents and brokers (including prospective agents and brokers) who sell our policies or perform similar roles. It does not cover Personal Information gathered about other individuals or in different contexts. For instance, if you engage with our commercial websites or job application platforms, the CCPA Consumer Disclosure or the privacy notice provided on that site will apply instead of this Disclosure.

Updates: We may revise this Disclosure periodically. Any updates will take effect when posted. Please review this Disclosure regularly for changes. If required by law, we will notify you directly with an updated version.

  • We collect your Personal Information from the following sources:

    A. Directly from you: This includes Personal Information you provide when you contact us, interact with us at events like tradeshows, sign up for newsletters or offers, communicate with us, place or customize orders, or apply/register to become an agent or broker.

    B. Automatically through tracking technologies: We may gather information automatically through cookies and other tracking tools. This may include data on how you use and interact with our websites or services, including information about devices used to access them.

    C. From third parties: We may obtain Personal Information from independent third parties, such as data brokers and social media platforms.

    D. From service providers: These are third parties that collect information on our behalf.

    E. Affiliated companies and subsidiaries: We may collect information from our related entities.

    F. Your employer (if applicable): If relevant, we may receive your Personal Information from your employer.

    G. Publicly available sources: We may gather Personal Information from public sources, such as government records and public profiles.

    We may combine the information gathered from these sources, including third-party data, and use or disclose it for the purposes outlined below.

  • The type of Personal Information we collect depends on how you interact with us. We may collect the following categories of Personal Information:

    A. Identifiers: This includes your name, email address, physical address, phone number, business contact details, account number, and device identifiers.

    B. Records: Such as signatures, financial details (including bank account information), and background check data (where legally permitted or required).

    C. Protected class and demographic information: This may include your age (including birthdate) and gender.

    D. Commercial information: This covers policies you sell, transaction-related details, and information tied to compliance and book of business reviews.

    E. Internet or other electronic network activity information: We may collect details about your device and how you interact with us online, including browsing history, search history, preferences (including marketing preferences), account settings, operating system, browser type, and online interactions (e.g., pages viewed or email communications).

    F. Non-precise geolocation data: Your location information, such as that derived from your IP address.

    G. Audio, electronic, visual, or other sensory data: Examples include security camera footage from our premises, and audio/video recordings (such as those from calls or training sessions).

    H. Professional or employment-related information: This includes job titles, organization, professional licenses, credentials, affiliations, experience, references, performance evaluations, compliance data, resumes, interview notes, and other professional information.

    I. Educational information: Data related to your educational background.

    J. Inferences: We may derive inferences about your preferences and behavior based on the information we collect.

    K. Sensitive Personal Information: This includes your Social Security number, driver’s license or passport number, account login details, racial or ethnic background (if provided voluntarily), and content from communications (mail, email, text messages) sent via our systems or company-provided devices where we are not the intended recipient. We may monitor the contents of such communications for legal and compliance purposes.

  • We may use your Personal Information for the following purposes:

    A. To provide products and services: This includes communicating with you or your company/employer, delivering information you request, assisting with marketing and selling our policies, processing transactions, verifying eligibility for programs or benefits, responding to inquiries or complaints, and supporting your overall relationship with us.

    B. For internal business purposes: We may use Personal Information to maintain or service accounts, operate our business (including online services), manage internal records, enforce policies, manage assets and workforce, conduct audits, keep track of business activities (e.g., accounting, procurement, and document management), provide trainings, manage budgets, administer IT systems, and ensure IT security.

    C. For internal research and improvement: We may use the information to enhance our business operations, develop new products and services, and assess the effectiveness of our marketing and advertising efforts.

    D. For legal, safety, or security reasons: This includes compliance with legal and reporting obligations, investigating claims, establishing or defending legal claims, protecting the safety and property of the Company, its employees, customers, and others, detecting and preventing security incidents, and safeguarding against fraudulent or illegal activities.

    E. In connection with corporate transactions: If the Company or its assets are acquired by another entity, including in the event of bankruptcy or other corporate changes, your information may be transferred in the process.

    F. For marketing purposes: We may use your information to promote our business or that of our affiliates and business partners. This could include sending newsletters, surveys, promotions, or event information, displaying personalized ads, analyzing email interactions, identifying target audiences, or publicly disclosing names and contact information of Financial Professionals attending events, via social media, public relations, branding efforts, and direct communications.

    We may also use anonymized, de-identified, or aggregated information for any lawful purpose.

4. How We Disclose Personal Information

We may share Personal Information with third parties, including the categories of recipients listed below. While we do not “sell” Personal Information in exchange for money, we engage in practices involving third parties that may be considered a "sale" (i.e., disclosing Personal Information to a third party for valuable consideration) or “sharing” (i.e., disclosing Personal Information for targeted advertising), as defined by the California Consumer Privacy Act (CCPA). We do not knowingly sell or share Personal Information of minors.

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose


    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure
    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure


    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared



The categories of recipients in the chart above refer to:

G. Affiliates and subsidiaries: This includes parent companies, corporate affiliates, subsidiaries, business units, and other entities under common ownership.

H. Benefits service providers: Companies that offer health, insurance, and other employee benefits.

I. Professional consultants: These include accountants, lawyers, financial advisors, and audit firms.

J. Vendors necessary for transactions: Entities like shipping companies that are needed to complete transactions you request.

K. Law enforcement, government agencies, and others for legal, security, or safety purposes: We may share information to comply with legal obligations, enforce our Terms of Use or Service, or protect the safety, property, or rights of the Company, our customers, or third parties.

L. Other entities in corporate transactions: If we or our assets are acquired by another entity, including through bankruptcy or other corporate changes, your information may be transferred as part of the transaction.

M. Entities you have consented to disclose information to: We share your information with parties you have authorized.

  • Our platforms, along with authorized third parties, use cookies and other tracking technologies to gather information about you, your device, and your interactions with our platforms. This section provides further details on the following:

    - The types of tracking technologies we use and their intended purposes

    - The types of information collected through these technologies

    - How we share or disclose the information collected

    - The choices available to you regarding the use of these technologies

    A. Types of cookies and tracking technologies we use

    Our Platforms and the third parties that we authorize may use the following tracking technologies:

    • Cookies, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.

    • Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described in Section 5.B below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.

    • Session replay tools, which record your interactions with our Platforms, such as how you move throughout our Platforms and engage with our webforms. In addition to the uses described in Section 5.B below, this information helps us improve our Platforms and identify and fix technical issues visitors may be having with our Platforms.

    • Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences, some of which may be developed by a third party.

    B. Purposes for Using These Technologies

    We and authorized third parties use these technologies for purposes including:

    • Personalization, such as remembering user preferences, login details and browsing behavior; tracking your activity across online properties and platforms over time to better understand your preferences and interests; and personalizing your online content;

    • Improving performance, such as maintaining and improving the performance of our Platforms;

    • Analytics, such as analyzing how our Platforms are used. For example, we use Google Analytics to help us improve our Platforms, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners; and

    • Advertising, such as providing you with offers that may be of interest to you; conducting targeted advertising to you on our Platforms and those of third parties; and measuring the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with our communications.

    C. Personal Information Collected

    These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Platforms (such as pages on our Platforms that you have viewed).

    D. Disclosures of Personal Information

    We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Platforms, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platforms.

    E. Your Choices

    Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

    You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Platforms’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

    Some browsers have incorporated Do Not Track (“DNT”) preferences. We do not currently honor such signals.

  • Our Information Governance and Records Management Program establishes and enforces company policies and procedures for the creation, retention, storage, and disposal of corporate records and information. Records are deleted or destroyed unless they are subject to regulatory retention requirements or legal holds. We retain corporate records for the minimum duration required by law or regulation, and may retain them longer if needed for business purposes. Retention periods are determined based on legal and regulatory requirements as well as business needs. These periods are regularly reviewed and updated by outside counsel. Records related to CCPA rights requests are retained for two years, as mandated by California law.

  • California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

    • Right to Know. You may request information about the categories of Personal Information we have collected about you; the categories of sources from which we collected the Personal Information; the purposes for collecting, selling, or sharing the Personal Information; and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you

    • Right to Delete. You may request that we delete Personal Information that we have collected from you.

    • Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.

    • Right to Limit Sensitive Personal Information Processing. We generally only use Sensitive Personal Information that is subject to the CCPA for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you. In limited circumstances, you may have the right to request that we limit our processing of your Sensitive Personal Information.

    • Right to Opt Out of Sale/Sharing. You may request to opt out from the sale or sharing of your Personal Information. We do not knowingly sell or share any Personal Information of minors under the age of 16.

    You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing via our webform.

    You may exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing by visiting our Preference Hub. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

    Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.

    Verification: In order to process requests, we may need to obtain information locate you in our records or verify your identity using reasonable methods. For Right to Know, Right to Delete, Right to Correct, and Right to Limit Processing of Sensitive Personal Information, we will collect some or all of the following data elements: Name, Date of Birth, Email, Phone Number, and Address. We use a third party identity verification and fraud prevention service to verify the information you provide on your rights request form and which may present you with additional knowledge-based questions. When it comes to identity verification, our third party only tells us whether your identity passes verification and we do not use this information for any other purpose. In some cases, we may ask for more or different information if needed to otherwise support you request such as in cases of authorized agents. To exercise the Right to Opt Out of Sale/Sharing, you may be asked to provide and verify your email address.

    Authorized Agents: Authorized agents may exercise rights on behalf of workforce members who are Financial Professionals by submitting a request via our online webform and indicating that they are submitting the request as an agent. Agents should provide their own information to verify the agent’s identity, after which we will contact the agent with additional instructions to complete the consumer right submission process. We may require agents to demonstrate authority to act on behalf of a consumer by providing signed permission and may require consumers to directly verify their identity with us using the methods described above.

    Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request. We will respond to Right to Limit Sensitive Personal Information Processing and Opt Out of Sale/Sharing requests within 15 days.

  • If you need assistance submitting a request or have questions regarding this Disclosure or how the Company uses your Personal Information, please contact us at 360-258-0555 or email us at andrew@rwamashongyewealthmanagement.com