Privacy statement

By accessing the Site or using the Site, you agree to be bound by this Privacy Statement. We may make changes to this Privacy Statement from time to time. We will post any changes to https://www.guardian-well.com/privacy-policy and update the “Last Updated” date at the bottom of this policy, so be sure to check back periodically. Such changes will become effective when they are posted. Your continued use of the Site following the posting of any changes will mean you accept those changes.

B. Information We Collect From or About You

Below we describe the different types of information we may collect from you, including from the devices you use, when you interact with the Site and/or take advantage of our Site.

Information You Provide to Us: We collect and maintain personal information about you from many sources to understand and meet your needs, provide our Site, manage our business, and for other purposes disclosed to you. We collect and store any information you provide to us directly or indirectly, including via our service providers, including when you enter information on the Site, provide it to us in written form, or communicate with us verbally. This information may include:

• Personal identifiers such as your name, address, email address, etc.;

• Commercial and financial information such as records of offerings ordered or considered and other purchasing or consuming histories

• Audio, electronic, visual, or similar information

This information may also include information you provide through surveys or questionnaires.

Information We Collect Automatically: When you interact with the Site, we may collect certain information from you or your device automatically. This information may include device and connection information, such as statistics on your page views, traffic to and from the Site, referral URL, advertising data, your IP address, browser type, and device identifiers. This information also may include, if applicable, your transaction history on our websites and third-party partner websites, and your web log information, how you search for or navigate the Site, key strokes made on certain forms on the Site, the websites you click on from the Site or emails, whether and when you open our emails, and your browsing activities across other websites including our third-party partner websites. Information we collect automatically may include tracking data and information collected via cookies and other tracking technologies. Please see “Cookies and Other Tracking Technologies” below for more information.

Location Information: When you interact with the Site, we may collect information about your location and your device. Some of this information may be general, such as the state or city associated with your zip code, while some of this information may be more precise, such as information associated with your mobile device or desktop computer. Location information may allow us to provide location-based Site content to you. Most mobile devices allow you to control or disable the use of precise location services globally or per application in the device’s settings menu.

Information from Social Media and Third Party Services: When you connect to, authenticate through, or interact with us or the Site using a social media platform (such as by clicking on a social media icon linked from the Site) or third party service (such as a Google account), we will collect information, including personal information, available through the service or the service’s application programming interfaces (APIs). This information may include your name, account ID or username, contact details, email address(es), information related to your contacts, calendars, location information, profile picture, the contents of your posts or other communications, and other information the platform or third-party service makes available. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party service. You should check your privacy settings on these platforms and third-party site(s) to understand what information is made available to us, and you may be able to change the settings for these platforms or services to prevent, limit or otherwise control the information made available to us.

C. Cookies, Other Tracking Technologies and Targeted Advertising

We and third party partners we engage make use of cookies, pixels and other online tracking technologies, including software development kits (“SDKs”) in an effort to provide the Site and for other purposes, including to understand visitor activity on the Site, to remember certain information about your preferences, to better understand and help improve your experience while using the Site, and to engage in analytics and targeted advertising.

A cookie is a text file sent by a web server and placed on your computer or device by your web browser. We may also use other tracking technologies such as pixels or web beacons. Some cookies and tracking technologies are placed for the length of a session and others are persistent. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Site. Cookies and other tracking technologies may collect information automatically, as set forth above in “Information We Collect Automatically.”

Cookies and other tracking technologies we use may fall into a variety of categories, and may be used for a number of purposes. For example, we, our service providers and other third party partners we engage may use cookies and other tracking technologies:

• For functional purposes, such as to provide the Site and its content to you.

• For analytics purposes, such as to provide us with information about which portions of our Site are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page.

To personalize your experience on our Site (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, or to tailor content, or product and service offerings to you). For advertising purposes, such as to provide advertisements to you on our Site or other Sites, which may include sharing your information across the ad-tech ecosystem.

Your Choices

You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set, however, certain parts of the Site may function differently and not as well, and you may not be able to use some portions of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, the Site will issue cookies when you logon to the Sites. For more information about how to manage your cookies preferences, you should use the “help” menu of your web browser or explore the customer support sections of your web browser. Please note that you may need to configure each browser on each device that you use if you wish to opt-out or block some or all cookies. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here. Your browser or device may include “Do Not Track” functionality. As noted in our cookies section, at this time, GuardianWell does not respond to browser “Do Not Track” signals.

Global Privacy Control (GPC) Signals

We honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of your personal information:

• When we detect a GPC signal from your browser or device, we will process it as an opt-out request for that browser or device and any identifiable associated consumer profile.

• You do not need to provide additional information for us to honor the GPC signal.

Frictionless Processing

Guardian processes GPC signals in a frictionless manner, meaning:

• No pop-ups, interstitials, or changes to your experience.

• No fees or consideration required.

• Your opt-out request is honored automatically.

Because we process GPC signals in a frictionless manner, we are not required to display the “Do Not Sell or Share My Personal Information” link on our website. Nonetheless, we still provide the “Do Not Sell or Share My Personal Information” link on our website as another option to opt-out.

How to Enable GPC

GPC is available in certain browsers and extensions (e.g., Brave, DuckDuckGo, Firefox). For instructions, visit https://globalprivacycontrol.org.

D. How We Use Information We Collect From or About You

We may use information you give us or information we collect about you to:

• Communicate with you, including to respond to your inquiries and fulfill your requests;

• Respond to your comments and queries for our internal business purposes;

• Provide, maintain, personalize, optimize, secure and improve the Site, including research and analytics regarding use of the Site, social media platforms and third party services, physical locations, facilities and infrastructure and to remember you when you leave and return to the Site;

• Provide and improve the Site, to process any transactions you request, or to authenticate your identity;

• Engage in as well as deliver advertising, including interest-based advertising on the Site, other websites and applications and other media, or email, for purposes including marketing;

• For our own, or our affiliates, analytic or marketing purposes.

• To engage in advertising, including to deliver advertising on the Site or via email, and for marketing purposes;

• In connection with the establishment and defense of legal interests;

• Comply with our obligations, including legal, regulatory, operational or fiscal obligations, including to report adverse events to regulators;

• Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal; and

For all other purposes to which you have agreed or as may otherwise be permitted or required by law.

We may combine information that you provide to us or information that we collect automatically through the Site with other information we obtain from our business records, including your use of GuardianWell and its affiliates and third-party partner’s products, websites and applications and, where applicable, your preferences and other personal characteristics. We also may use or combine information that we collect with information we obtain from third parties, including demographic information and other attributes, such as census data, purchasing data, demonstrated interests (for example, an interest in travel), loyalty programs, organizational affiliations and customer lists. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

We may use information we collect from or about you to create aggregated or de-identified data that does not identify you. Once the data is aggregated or de-identified, we may use it for any purpose permitted by law and we may share it with third parties for their own uses.

E. How We Share Information About You

We may share your information:

• With companies who work on our behalf to help us provide and support the Site.

• With GuardianWell agents or third-party partners that sell and manage GuardianWell products so that they may communicate with you about our products and Site, as well as to deliver marketing communications, including emails, newsletters, offers tailored to you, and other materials that they believe may be of interest to you.

• With third parties, including for purposes of targeted advertising.

• With our affiliates in a deidentified and aggregated manner, or with respect to certain GuardianWell member offerings in a limited identifiable manner, for their independent marketing purposes subject to your right to opt out of sharing identifiable information.

• With our affiliates to market products and services to you or evaluate benefits under an insurance offering with your authorization.

• Where disclosure is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, recruiting and talent management, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences, and trends and dispute resolution.

We may change our ownership or corporate organization. We may transfer to another entity or its affiliates or service providers some or all of the information we hold about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.

We also may disclose information pursuant to a request from law enforcement or pursuant to other legal or regulatory process, or as otherwise required by law, or, in our sole discretion, to protect our rights, property or interests, including to enforce this Privacy Statement or our Terms and Conditions of Use.

We may use or disclose information about you if required to do so by law or on the good-faith believe that such sharing is necessary to (a) conform to applicable law or comply with legal process served on us or our Sites; (b) protect and defend our rights or property, our Sites, or our users; or (c) act to protect the personal safety of our employees and agents, other users of our Sites, or members of the public.

F. Rights You May Have Regarding Our Data Handling Practices

Rights You May Have Related to your Personal Information

Depending on your state of residence, and subject to certain exceptions, you may have certain rights with respect to personal information collected, used, transferred, disclosed, sold, or processed by GuardianWell. Rights may vary state to state. For California customers please see our separate notice applicable to California.

You can, subject to proper validation:

• Request confirmation as to whether GuardianWell has Personal Information relating to you;

• Request to know the Personal Information, including the categories of personal information, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting, selling or sharing personal information, the categories of third parties in a form permissible under applicable laws and regulations;

• Request a list of third party entities to which we have disclosed personal information;

• Request access or a copy of the personal information we have collected;

• Request deletion of your personal information, subject to certain exceptions;

• Request correction of inaccurate personal information, taking into account the nature of personal data and purposes of processing such information;

• Request to opt out of the sale or sharing of your personal information;

• Request to opt out of targeted advertising; and

• Request to opt out of certain kinds of profiling or automated decision making.

You can make such a request by submitting a request via the Consumer Privacy Rights Request Intake Form on our website or by emailing us at privacy_office@guardianwell.com. If required by law, we will disclose and deliver the required information to you free of charge by mail or in a portable and readily usable electronic format within 45 days of receiving a verifiable request (with an additional extension of 45 days if reasonably necessary). You may request this information free of charge up to two (2) times in a 12-month period.

We will verify your request by measures that include reviewing the information that we require in our Consumer Privacy Rights Request Intake Form to authenticate your identity. In certain states, you may also designate an authorized agent to make a request on your behalf through the above methods. If you submit a request through an authorized agent, we may request that such authorized agent provide information sufficient to verify your request and authenticate your identity and that your agent is in fact authorized to act on your behalf. You may also make a request for household information; however, household requests will only be processed upon the verified request of each member of the household.

To verify your request, we may ask for information including your full legal name, residential address, email, phone, date of birth and last four digits of your social security number, as well information we may have on file about you (such as your policy number or a date of hire). The information we require may vary depending on your relationship to us. If you are requesting on behalf of another consumer, we may request additional information from you and/or the consumer to verify their identity. If you have not previously purchased a product or service from us or been employed by us we may require you to take additional steps to verify your identity. If we are unable to verify your identity using this process, we will provide you with a response explaining so and what additional action you may take to ensure we can successfully verify your request.

If you request your information to be deleted by us, we will verify the request and provide you with an explanation if we need to retain information about you such as document retention schedules as well as applicable law. Prior to deleting your information, we may ask that you reconfirm that you would like us to do so.

Some of the information that we collect may not be reasonably associated with you directly. In such instances that information will not be addressed as part of your request. You can learn about aggregate information throughout this Statement.

You can learn additional information about the categories of personal information we collect, the sources of collection for each category of personal information, the purpose of collection and use for each category of personal information, and the types of third parties with which we share each category of personal information.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney.

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at same method used to submit requests within 30 days after your receipt of our decision.

California Privacy Practices

Please find information for California consumers below:

Privacy Notice for California Residents

Texas Privacy Practices

Please find information for Texas consumers below:

Privacy Note for Texas for Residents

G. Additional Opt-out

We may share Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement with third party advertising and analytics providers for certain targeted advertising or analytics purposes, and you have the right to opt out of such sales or sharing.

H. How We Secure the Information We Collect From or About You

We use a combination of commercially reasonable physical, technical, and administrative safeguards in an effort to protect the information we collect on the Site and offline.

While we use these precautions to safeguard your personal information, please be aware that no security measures are perfect or impenetrable. We cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf or guarantee that the information you provide to us will not be disclosed or used in a manner that is inconsistent with the statements set forth in this Privacy Statement. Please use caution when submitting any personal or other sensitive information to us.

I. Other Important Information

Updating Your Information

You may have the opportunity to update or correct your personal information, such as your contact information. In such cases, we may rely on you to keep personal information accurate and up to date, which may be done through our self-service websites or by emailing us at hello@guardian-well.com.

Retaining Your Information

In general, we do not keep Personal Information longer than we believe is reasonably necessary for the purpose or purposes for which the Information was originally collected and processed and subject to our retention policies, schedules and for the purposes of satisfying any legal, regulatory, accounting or reporting requirements to which we believe we are subject.

Information related to Minors: GuardianWell does not knowingly collect information directly from minors—persons under the age of 13, or another age of a minor as defined by law—via our Sites or offline, other than when required to comply with applicable law including public agency directives.

If you are a parent or guardian of a minor who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by emailing us at privacy_office@guardianwell.com.

Users Outside of the United States: We are based in the United States and the Site is directed to residents of the United States. The information you submit to us and that we collect as a result of using our Site may be transferred to the United States or to another jurisdiction in which our service providers operate. By using our Site, you consent to the collection, international transfer, storage, and processing of your information by us and our service providers. If you use the Site outside of the United States, you understand and consent to the transfer of information about you, and the collection, processing, and storage of information about you, in the United States and elsewhere. The laws in the U.S. and these countries regarding personal information may be different than the laws of your state or country. If it is illegal to access our Sites or transfer your data to the United States, please do not use our Site.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please visit our Accessibility page for additional information.

For Questions, or to Report a Problem

If you have other questions, comments or concerns about our privacy practices, or if you wish to issue a request to exercise your rights where applicable by law, please email our Privacy Office at privacy_office@guardianwell.com. Please provide your name and contact information along with the request.

Alternatively, inquiries may be mailed to the following address:

Mailing address:

GuardianWell c/o Privacy Office 10 Hudson Yards New York, NY 10001 USA

Last Updated: December 1, 2025