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UNUM GROUP BEHAVIORAL HEALTH PRIVACY POLICY

Unum Group (“Unum”,” “we,” “our” or “us”), understands that privacy is important to our users. This Privacy Policy explains how we collect, use, share and protect your personal information that we collect through the Unum Behavioral Health solution (the “Service”). By using our Service, you agree to the terms of this Privacy Policy.

WHAT INFORMATION DO WE COLLECT

The categories of information we collect can include:

• Information you provide to us directly: “Personal information” means individually identifiable information collected online about an individual that can be used to locate or to contact that individual directly. It is data that is unique to an individual, such as a name, physical address, Social Security number, e-mail address, telephone number, or any other identifier that permits the physical or online contacting of a specific individual. We may collect Personal Information such as a username and password, first and last name, Social Security number, e-mail address, phone number, work location, and employer when you register for a Unum account, use our Service, or if you correspond with us. We may also collect additional information you provide to us about your company or employer, as well as details about your health, such as your responses to health questionnaires, which we will consider to be Personal Information if it is linked to your identifying information. We may combine this information with data we collect from you through other methods, such as electronic document exchange services.

• Information we collect from third parties: We may obtain Information about you from third parties, such as your employer and any third-party partners you elect to interact with from within the Service.

• Information we collect from your Service usage: We and our third parties may automatically collect certain types of usage data when you visit our website or use our Service. This may include sending one or more cookies to your computer that uniquely identifies your browser and conveys information to us about how you use the Service (e.g., pages viewed, how frequently you use the Service). We may also log information such as the Internet Protocol (“IP”) address, browser type, mobile device type, links clicked, and pages viewed. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service.

We use this information to operate, maintain, and provide to you the features of the Service. We may also use this information to send you Service-related emails or messages (e.g., account verification, event reminders, change or updates to features of the Service) or to follow up with you about our Service and your account.

PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL DATA

We collect and process your Personal Information for the following purposes:

Providing our Unum Service: We will process your Personal Information to the extent this is necessary for the performance of our contract with you for the use of our online services and to fulfill our obligations under the applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our services and to provide you with the content you access and request.

Promoting security of our Service: We will process your Personal Information by tracking use of our online services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies, to the extent this is necessary for the purpose of our legitimate interests in promoting the safety and security of the systems and application used for our services, and protecting our rights and the rights of others;

Managing user registrations: We will process your Personal Information by managing your user account for the purpose of performing services for you according to any applicable terms of service;

Handling contact and user support requests: If you request user support, or if you contact us by other means, we will process your Personal Data for the performance of our services with you and to the extent it is necessary for the purpose of our legitimate interests to fulfill your request and communicate with you;

Developing and improving our websites: We will process aggregated, de-identified data about your use of the Service to analyze trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites and to provide our users with more relevant and interesting content;

Displaying personalized content and recommendations: We will process your Personal Information to provide personalized information and other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interests or, where necessary, to the extent you have provided your prior separate consent;

Complying with legal obligations: We will process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court orders or legal process, and/or to respond to lawful requests.

Where we need to collect and process Personal Data by law, or under a contract we have entered into with you and you fail to provide that required Personal Data when requested, we may not be able to perform all Unum services to you.

SHARING OF YOUR INFORMATION

We may share your personal information collected to provide this Service with:

• Other parties you authorize us to share data with through our Service. This may include your employer, your benefits providers, our insurance subsidiaries, and any other company or individual you engage with through our Services;

• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include web hosting, or providing analytic services;

• Our business partners who offer a service to you jointly with us, or who partner with us to provide our Services to you; and

• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Unum, our Users, or others.

• We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

FOR CALIFORNIA RESIDENTS: If you would like to exercise one of the rights granted to you under the California Consumer Privacy Act, such as the right to know what personal information Unum collected, sold or disclosed about you, the right to request a copy of the personal information collected about you (portability), or to request that Unum delete your personal information, download the California Privacy Notice.

MANAGING YOUR INFORMATION

Controlling your communications preferences: If we send promotional email communications, you can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Modifying or deleting your information: We will retain your information for as long as your account is active, as needed to provide you Services, or as needed to comply with our legal obligations or to enforce our agreements. You may view and modify your personal information through your user and account settings. We may not be able to modify or delete your information in all circumstances, as federal and state law may require that we maintain certain types of information for a set period of time. You may not be able to delete or modify certain information that we maintain.

HOW WE PROTECT YOUR INFORMATION

Storage and Processing: Your information collected through the Service may be stored and processed in the United States or any other country in which Unum or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Unum or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe: Unum cares about the security of your information, and uses robust and state-of-the-art physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is perfectly secure and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Unum will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

CHILDREN’S PRIVACY

Unum does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13.

LINKS TO OTHER WEB SITES AND SERVICES

Our Service may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third party websites or services embedded in, linked to, linked from, or connected with the Service and your interactions with any third-party website or service are subject to that third party’s own rules and policies. We encourage you to read the privacy statements of these third party sites and services, as their privacy practices may differ from ours.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please contact us at privacy@unum.com

CHANGES TO OUR PRIVACY POLICY

Unum may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last modified’ date at the bottom of this page.

This privacy policy was last modified in 2023.