My Special Aflac Duck® Privacy Policy

SCOPE

This Privacy Policy ("Policy") describes how the American Family Life Assurance Company of Columbus ("Aflac") treats the information we collect through our My Special Aflac Duck mobile application ("Application"). This Policy does not apply to information we might collect from you offline or through other services offered by Aflac Incorporated and the Aflac group of insurance companies, including Aflac, its wholly owned subsidiary American Family Life Assurance Company of New York, Aflac Life Insurance Japan Ltd. and Continental American Insurance Company ("Aflac Group"). This policy describes the types of information that we may collect, or that you may provide when you download, access, or use the Application; and our practices for collecting, using, maintaining, protecting, and disclosing that information.

CHILDREN UNDER 13

We do not knowingly collect personal information (as defined under the Children's Online Privacy Protection Act or "COPPA") through the Application from persons under the age of 13. Where COPPA is applicable, we  comply with the provisions of COPPA. Children under the age of 13 may only use the Application with the involvement of a parent or legal guardian. By approving the download of the Application through an Apple App Store, Google Play, or Amazon Appstore account, parents or legal guardians provide the necessary consent for their child’s use. We do not require additional parental verification because the Application does not collect names, contact details, or any other information that directly identifies a child.   If you are a parent, legal guardian,  or any other statutory agent  and think your child under 13 has provided us with personal information, please contact us at contactus@AflacChildhoodCancer.org. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request." Parents, you can learn more about how to protect children's privacy from the Federal Trade Commission on-line here.

ACKNOWLEDGEMENTS

By using the Apps in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. If you are using the Apps on behalf of another party, you represent and warrant that: (i) you have all rights, consents, and permissions to do so; and (ii) that you have obtained such party’s express consent and agreement to the terms of this policy. If you do not agree with our policies and practices, do not download, register with, or use the Apps.

This policy may change from time to time. Your continued use of the Apps after we revise this policy means you accept those changes, so please check the policy periodically for updates.

TYPES OF INFORMATION WE COLLECT

When you download, access, and interact with this Application, we may use technology to automatically collect information on how you are using and accessing the Application. When you first download the Application, we will generate an anonymous code to collect your usage data. This anonymous code cannot be used to identify you because we do not collect any personally identifiable information that may be used to link this to you. We may look at what country our Application was downloaded in and how often it is used. We may also collect information about how you or your child interacts with the Application. We may also collect this information over an unlimited period of time. We may also collect information about the mobile network used to access the Application or information about the Bluetooth functionality in the device you or your child uses to access the Application. The information that we may collect is done with the intention to improve My Special Aflac Duck and the Application over time to provide the best experience for you and your child. The Application does not collect and does not allow you to submit any images, recordings, or information that could be used to identify you.

HOW WE COLLECT YOUR INFORMATION

We passively collect information when you or your child visit and navigate our Application. Our third party service providers may also collect information this way on our Application.

HOW WE USE YOUR INFORMATION

We may use the information that we collect through our Application to:

• Provide and improve the Application. We may also use the information for security purposes, as otherwise permitted by law or as we may notify you.
• Carry out our obligations and enforce our rights arising from any contracts entered into between any third party service providers.
• Understand how you interact with the Application, identify which features are least and most utilized, identify problem areas within the Application, and inform design development for future updates.
• Operate and improve the Application.
• Carry out any other purpose conveyed to you at the time that the information was collected.

HOW WE SHARE YOUR INFORMATION

We may share the information we collect or that you provide through the Application internally within Aflac or externally with our service providers. For example, this may include Empath Labs Inc., the company that helps us run our Application, and Google LLC, the company that provides our analytics services. We may also share the information with successors to all or part of our business or one of our brands, or to comply with the law or protect ourselves. We may also share information for other reasons we may describe to you when we collect the information. In addition, we may disclose information if we are required to do so by law or legal process, such as to comply with a court order.

U.S. STATE PRIVACY RIGHTS

Certain U.S. states, including California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, provide residents of the state with additional privacy rights, including rights to (i) access the personal information we have collected about you; (ii) correct inaccuracies in your personal information; (iii) receive personal information we have about you in a readily usable format; (iv) request deletion of your personal information; and (v) to opt-out of processing your personal information for targeted advertising or sales of personal information. The exact scope of these rights may vary by state and may be subject to exceptions.

To exercise your privacy rights, please email us at privacyoffice@aflac.com. Only you, or an agent legally authorized to act on your behalf, may make a request related to your personal information. We will make every effort to respond to your request within 45 days from when you contact us. After submitting a request, we may ask you to provide information that will enable us to verify your identify in order to comply with your request. Please note that we may deny an opt-out request if we have a good faith, reasonable belief that the request is fraudulent. Further, in most instances, we do not collect types of personal information that enable us to identify you. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. To appeal our decision regarding a request related to your privacy rights, you may email us at privacyoffice@aflac.com.

INTERNATIONAL PRIVACY RIGHTS

You may have additional rights under the laws of your country. We will respond to requests to exercise such rights in accordance with applicable law.

CROSS BORDER TRANSFERS

We process and store data in the United States. If you are located outside of the United States, your data may be transferred internationally. We take steps consistent with applicable law to ensure that such transfers provide adequate safeguards for your information.

LEGAL BASIS FOR PROCESSING

We process limited technical and usage information (as described in Section III) only: (i) where it is necessary to provide and operate the Apps; or (ii) where we have a legitimate interest in keeping the Apps secure, reliable, and supported, provided it is not overridden by your data protection rights.

In some regions, such as the United Kingdom (“UK”), local laws require us to explain these legal bases. The same bases apply to our processing globally.

DATA RETENTION

We retain the anonymous code and usage data for as long as reasonably necessary for the purposes outlined in this policy, including without limitation, to comply with our legal obligations and enforce our rights. Since the data we retain cannot be linked to individual users, there is no personal data retention period. We store and process the information we collect in the United States.

YOUR CHOICES AND HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or if you would like us to delete the information we maintain about you or your child, please email us at contactus@AflacChildhoodCancer.org. You may also write to us at the following address:

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Application. Please check our Application periodically for updates.

© American Family Life Assurance Company of Columbus.

Aflac herein means American Family Life Assurance Company of Columbus and American Family Life Assurance of New York. WWHQ | 1932 Wynnton Road | Columbus, GA 31999.