Disclosure Information

1. How we collect personal information through our online services

We may collect Personal Information through Our Online Services when:

1. You or your authorized agent enter, send, or submit information to us through activities such completing forms, questionnaires, or surveys, sending emails, texts, or other electronic messages, creating an account, or submitting applications, servicing requests, or claims information relating to Our products and services.
2. We or Our Service Providers may automatically collect information when you interact with Our Online Services. Please read below for more detailed information about Our use of Tracking Technologies.

It is Our practice to protect your information by, among other things, requiring our Service Providers to agree they will keep Personal Information they collect on Our behalf confidential and only use it ways that are related to performing services for us. We do not allow them to use Personal Information they collect through Our Online Services to market their own or others' products or services.

When you ask us to provide certain advice or services, we will gather information from your accounts at other financial institutions, with your authorization or consent if required. This may include details like current balances, transaction histories, and holdings from your brokerage, investment, bank, and credit card accounts. By giving us the name of the financial institution, your login details, and other information, you allow the Northwestern Mutual Family of Companies and its Service Providers to access and securely transfer your personal and financial information from these institutions on your behalf.

2. Categories of personal information we may collect through our online services

The Personal Information we or Our Service Providers collect from you through Our Online Services will vary according to your activities using the Services as well as the preferences you have selected. The information collected will also depend upon whether you have created an account and the products or services you are interested in or have purchased.

The categories of Personal Information we may collect include:

Categories of personal information we collect

Category of Personal Information	Examples
Identifiers	Name, alias, date of birth, home address, driver's license number or state identification card, passport number, Social Security Number, email address, contact information, physical or electronic signature
Demographics	Age, gender identity, sex/gender sexual orientation, personal pronouns, disability status, birth country, citizenship, marital status, family member information, military/veteran status
Professional or Employment Information	Employment contract, Salary, employment history, professional designations, veteran or military status, disciplinary action, employment reviews, performance reviews, and other information collected from job applications or resumes professional designations
Education Information	School(s) attended, dates attended, degree(s) earned, academic achievements, transcripts and other information collected from job applications or resumes
Financial Information	Bank accounts, investment or brokerage accounts, information regarding estate or tax planning (including tax return or tax-document information), debts, income, or trusts, credit or debit card number(s)
Medical and Health Information	Medical history, medical questionnaires, information regarding physical, mental, and behavioral health, genetic, neural, or disability information within medical records, physical characteristics or description, medical condition, information regarding payment for health care services
Biometric Information	Information derived from biometric identifiers, such as fingerprints or voice recognition, and other physiological, biological, or behavioral characteristics when used for purposes of identifying an individual
Internet or Other Electronic Network Activity Information	Browser or device information, browsing history, search history, information, IP address, online identifiers, cookies, web beacons, pixel tags, and clickstream or other traffic data interaction with our websites, mobile app, and advertisements
Geolocation Data	Information derived from geolocation data such as zip code
Profile Information	Profiles reflecting a person's preferences, such as interests, hobbies, characteristic tendencies, behaviors, attitude or aptitude, goals and inferences drawn from any Personal Information, including browsing information and clickstream or other website traffic data
Commercial Information	Policy / account number, policy / account values, beneficiary, ownership arrangements, transaction history, claims, records of personal property, products or services purchased, obtained, or considered.
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information	On-site security cameras, pictures, video, and audio recordings
Sensitive Personal Information	A subset of the Personal Information described above that includes social security number, driver's license number, state identification card number, or passport number, account login or account number in combination with information allowing access to an account, genetic data, neural data, biometric information derived from biometric identifiers, health information, sex life or sexual orientation

3. Categories of service providers and third-parties to whom we may disclose personal information collected through the online services

Depending on your activities using the services, the preferences you have selected, the authorization or consent you have provided, and the products or services you are interested in or have purchased, we may disclose information about you to the following categories of recipients:

• Among Our Northwestern Mutual Family of Companies, including our sales force.
• To Service Providers who help us advertise and market Our products and services.
• To Service Providers who provide supplemental staffing services or perform certain printing, mailing, or emailing services.
• To reinsurers, attorneys, accountants, and outside auditors who perform business functions for our Northwestern Mutual Family of Companies.
• To regulators and others with legal authority, such as law enforcement agencies, government authorities, parties with a valid subpoena, or others as permitted or required by law.
• To Service Providers and Third Parties for data security and anti-fraud purposes.
• To Service Providers who provide technologies, software, platforms, or tools that are used to support the business functions of our Northwestern Mutual Family of Companies.
• To consultants or contractors who provide supplemental staffing, underwriting or claims evaluation, business-related studies, analysis, and analytics, and other services to support the business functions of our Northwestern Mutual Family of Companies.
• To Third-Parties at your direction or with your authorization, such as other insurance companies if you were not eligible for coverage under a Northwestern Mutual product and other Non-affiliated third parties whose services you choose to use.
• To your authorized representative.
• To nonaffiliated third parties at your request or with your authorization. These third parties may include companies that provide products and services related to your finances such as banks, tax preparation, credit unions, lending institutions, and payment processors.

When we disclose Personal Information to Our Service Providers, consultants, or contractors, we contractually obligate them to keep the information we share confidential and limit its use for purposes of performing services under the contract.

We do not sell Personal Information for money. We do, though, disclose Personal Information in connection with our online advertising in ways that may be considered a "sale" or "share", as defined by the California Consumer Privacy Act. You have the right to opt out of this type of sharing by clicking on this "Do Not Sell or Share My Personal Information" link or by clicking "Opt Out" on the banner on our website and deselecting "Marketing Cookies," or by using an industry-accepted opt-out preference signal. We do not knowingly sell or share Personal Information of minors.

4. How we use tracking technologies

We, along with Our Service Providers, may use tracking technologies in the Online Services Tracking technologies refer to tools and methods used by websites and applications to collect and analyze data about user interactions and behaviors. Common examples include cookies, web beacons, pixels, software development kits (SDKs), (collectively "Tracking Technologies"). Tracking Technologies can track your use of Our Online Services by collecting information such as the IP address of the computer that uses Our Online Services, the pages visited, when and for how long a page is visited, clickstream data (such as mouse clicks, mouse movements, scrolling activity and the like), the type of browser used, and a randomly generated identification number associated with the computer previously placed by the Online Services.

We use the information collected through Tracking Technologies for Our business purposes, including enhanced user experience, responding to your requests or questions, research and development, data security, authentication, anti-fraud, analytics, capturing your activity (including where you click and pages you view), Our marketing or advertising, underwriting, auditing or debugging.

For example, we may use Tracking Technologies to help us recognize your browser or device, maintain your preferences, provide certain online features, analyze your behavior in the Online Services, or collect information about your interactions with the Online Services, its content, and Our communications. When corresponding with you via email, Tracking Technologies may let us know whether you received and opened Our email, clicked on a link, or otherwise interacted with Our content. This information may be associated with information previously collected about you. We also gather statistical information about the usage of the Online Services to continually improve their design and functionality, understand how the Online Services are used, and to assist us with resolving questions regarding the Online Services.

We partner with other third-parties, including third-party media companies, advertising networks, and social media platforms, to manage Our advertising on other websites. Our third-party partners may use Tracking Technologies to collect or receive information about an IP address, device type, date and time of visit, browser type, and your activities on Our Services, other websites, or elsewhere on the Internet. This information may be used to provide measurement services and targeted advertising for us.

5. Your choices about tracking technologies

You have the right to opt-out of Our interest-based advertising (also known as Targeted Advertising or Cross-Contextual Behavioral Advertising). Your choices will be shown when you click on the opt-out button located on the banner or by clicking on the Do Not Sell or Share My Personal Information link within the footer on the Sites and within the settings on the Mobile Apps.

You can also opt out of collection of your Personal Information via Tracking Technologies for Targeted Advertising purposes on websites, including the Sites, by enabling a Global Privacy Control ("GPC") signal. The GPC can be accessed by installing a supported web browser or browser extension. Please refer to the help section of your browser or visit the official Global Privacy Control website for more information.

In addition, most browsers allow you to block, manage, delete, or receive notification of Tracking Technologies through their privacy settings. For additional information, refer to the help section of your browser or mobile device. Through this functionality, you can opt-out of Ours and others' interest-based advertising and analytics activities that use Tracking Technologies by setting browser notifications and blocking Tracking Technologies as you choose. Please note that if you block Our functional or strictly necessary Tracking Technologies, you may not be able to use the full functionality of the Online Services. For example, you may not be able to maintain your session, which could require you to log in repeatedly.

For mobile devices, you can opt out of all online interest-based advertising, including Ours, by turning off personal ads on iOS devices or opting out of ads personalization on Android devices.

6. How we respond to do not track signals

Your browser or device may include "Do Not Track" functionality. How browsers communicate the Do Not Track signal is not uniform and a standard technological response has not yet been developed. Therefore, the Online Services may not recognize automated browser signals regarding Do Not Track signals or instructions, unless you use a GPC signal as described above.

7. Other choices we honor—opt-out of affiliate sharing for marketing purposes

Northwestern Mutual may disclose Personal Information among our Family of Companies for business purposes, including marketing purposes, and NLTC may disclose Personal Information to Northwestern Mutual for NLTC business purposes other than marketing, without obtaining your prior consent or authorization when allowed by law, and the law does not allow you to restrict these types of disclosures. We will not disclose Personal Information among our Family of Companies without your prior consent or authorization when your consent or authorization is required by law and neither Northwestern Mutual nor NLTC share medical information with Northwestern Mutual Investment Services, LLC, or the Northwestern Mutual Wealth Management Company.

You may restrict sharing of Personal Information among the Northwestern Mutual Family of Companies for marketing purposes by exercising your right to opt-out. To exercise this right, call (866) 950-4644 and when prompted say, "limit sharing."

8. Third party websites

Our Services may contain links to third party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices of those websites or services. These links do not imply an affiliation between Northwestern Mutual and the website owner, or any endorsement, approval, or verification of any content contained on other websites.

We encourage you to be aware when you leave Our site to read the privacy policies or statements of every website you visit, as those privacy policies or statements may differ from Ours.

Our Services may also contain links to the Northwestern Mutual pages of several third-party social media websites and additional links to third-party websites that may appear as a "like" or "share" button. When you click on these links, the third-party website may use Tracking Technologies or similar technologies to enable the feature to function properly. Additionally, these links may collect which page you are visiting on Our website.

9. Request to access, correct, or delete your personal information

We voluntarily, and as required by law, respond to verifiable requests for access, correction, or deletion of Personal Information. If you or your authorized representative would like to make a request, you may do so here: https://ConsumerRightsRequest.nm.com/

10. Protecting information about you

Protecting Personal Information is important to you and to us at Northwestern Mutual. We take Our responsibility to protect Personal Information seriously and we use reasonable technical, administrative, and physical controls to safeguard it. Additionally, Personal Information may only be accessed by and disclosed to Our employees and others with a legitimate business "need to know" in accordance with applicable laws and regulations. Unfortunately, no website, mobile application, database, or system can be guaranteed to be completely secure. If you have reason to believe that your online account has been compromised, please contact us immediately.

Read about information protection and to learn more about what you can do to help protect what is most valuable to you.

11. Use by minors prohibited

Our Services are not intended for use by minors. We do not knowingly collect information through the Services from individuals who are less than 18 years old. By using the Services, you represent that you are 18 years of age or older.

12. Use outside of the u.s. and by non-u.s. residents prohibited

The Services are intended for use solely by U.S. Residents within the United States. Use by non-U.S. residents and use outside of the U.S. is prohibited.

13. Updates to our online privacy policy

We may update this Policy periodically. Changes become effective when we post the revised Policy on the Services. We will let you know when we update the Policy by changing the "Last Updated" date at the top of this notice. Your continued use of the Services following these changes means that you accept and agree to the changes. Please visit Our Services periodically to review the Policy for any changes.

14. Accessibility

We are committed to providing all consumers with the same level of access to this Policy. We strive to ensure that this Policy is compatible with standard screen readers. If you need further assistance accessing this Policy or Our Services, please contact us at +1-800-950-4644.

15. You can contact us

To submit privacy-related requests or inquiries, write to:

Privacy OfficeThe Northwestern Mutual Life Insurance Company720 East Wisconsin AvenueMilwaukee, Wisconsin 53202