My Principal Lifestyle Privacy Policy

Effective Date: May 1, 2018

OVERVIEW

This Privacy Policy describes the privacy practices for the My Principal Lifestyle Application (the "App"). You will learn about the information we collect, how we use it, who we share it with, the controls we give you over your information, and the measures we take to keep it safe.

Please review this Privacy Policy carefully. When you submit information to or through the App, you consent to the collection and processing of your information as described in this Privacy Policy. If you have not done so already, please also review the App's Terms and Conditions and the App's End User License Agreement. This Privacy Policy is incorporated into and made a part of the App's Terms and Conditions.

If you do not agree with any part of this Privacy Policy, the App's Terms and Conditions, or the App's End User License Agreement, then please do not download or use the App.

If you have other products or services within the Principal Financial Group (“Principal”), you are subject to the terms and conditions, privacy notices, and other policies for those products and services. Additional detail about Principal's other privacy policies and notices is available at www.principal.com/privacy-policies

INFORMATION WE COLLECT

When you use our App, we collect the following types of information.

INFORMATION YOU PROVIDE US

ACCOUNT INFORMATION

Some information is required to create an account on our App, such as your name, email address, password, date of birth, state of residence, and your mobile telephone number. You may also choose to provide other types of information, such as a profile photo, community username, food log, and messages on discussion boards or to your friends on the App.

ADDITIONAL INFORMATION, INCLUDING SOCIAL MEDIA AND EXERCISE/ACTIVITY INFORMATION

To help improve your experience or enable certain features of the App, you may choose to provide us with additional information. For example:

If you contact us or participate in a survey, quiz, poll, contest, promotion, or other similar activity we collect the information you submit such as your name, contact information, response, and message.

If you choose to share your personal story with us, and explicitly agree that it can be shared, we may share your story consistent with the consent you provide.

If you choose to connect your account on our App to your account on another service, we may receive information from the other service. For example, if you connect to social media sites through our App such as Facebook, Twitter, and LinkedIn, we may receive information like your name, profile picture, age range, language, email address, posts, pictures, information about your contacts, and other personal information you have separately provided to the social media sites. Your social media site may allow you to control what information you choose to share with the App. In addition, you can stop sharing with us the information from social media sites by removing our access to those sites.

You may also choose to grant us access to your exercise or activity data from another service or device. For example, you may choose to connect your wearable fitness device to the App, which will allow us to receive information from that fitness device. You can stop sharing with us the information from the services and devices by removing our access to those services or disconnecting the device.

You may choose to manually enter certain exercise or activity data. For example, you may choose to enter that you lifted weights for 45 minutes, or that you burned 200 calories playing basketball.

If you choose to connect to your medical portal through the App, we will be able to receive personal medical history from your medical providers.

INFORMATION WE RECEIVE FROM YOUR USE OF OUR APP

INFORMATION FROM CONNECTED DEVICES

If you have connected a device (e.g., wearable fitness device, scale) to the App, we will receive the information collected by that device that you have chosen to share with us. For example, your device may collect data like the number of steps you take, your distance traveled, calories burned, weight, heart rate, sleep stages, active minutes, and location. The data we receive varies depending on which device you use and what you choose to share with us through the App. When your device syncs with our App, data recorded on your device is transferred from your device to our App.

LOCATION INFORMATION

The App includes features that use precise location data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can always remove our access using your mobile device settings. We may also derive your approximate location from your IP address. If you choose to permit the App to access location information from your device, this information allows us to know your precise location and calculate motion (e.g., how fast you are driving) and time (e.g., when you are at a specific location).

HOW YOU INTERACT WITH THE APP

When you access or use our App, we receive certain data that shows how you are interacting within the App. This includes information about when you view or search content in the App, create or log into your account, pair your device to your account, or open or interact with an application such as a social media account via the App on your device. This information is used for a variety of reasons, as explained further in the How We Use Information section. For example, if your interactions within the App indicate that you have viewed several articles about a certain financial product, this information may be shared with your advisor. Additional detail about how your information is shared is available in the How Information Is Shared And Disclosed section

USAGE INFORMATION

We also collect data about the devices and computers you use to access the App, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

INFORMATION COLLECTED BY USE OF COOKIES AND SPOTLIGHT TAGS

We allow third-party companies, including Google Analytics and others, to use cookies and spotlight tags to collect certain information when you visit the App website at www.myprincipallifestyle.com ("Usage Information"). Usage Information helps us measure the performance of our online advertising campaigns, analyze visitor activity on our websites, and for other business purpose. Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features on the website.

About cookies and how we use cookies

Cookies are used to store information on your computer and are a way to have your web browser "remember" specific bits of information about your previous visits to our site. They allow you to access secured information, conduct secured transactions, and take advantage of promotional opportunities. They are designed to help you have a better user experience within our website, and we use the information to improve our site content and site functionality.

Different websites store the information in cookies differently. Cookies allow us to identify your device, which in combination with other information we are collecting, may allow us to identify you personally. Any such information is stored in our protected systems and not in the cookie or on the Internet.

Cookies save you time as they help us to remember who you are and they help us to be more efficient. We can learn about what content is important to you and what is not. We can revise or remove web pages that are not of interest and focus our energies on content you want.

Type of cookies we use

There are different types of cookies. We use what are referred to as session cookies. These are temporary and expire when you leave our website or are inactive for a specified length of time. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently.

About spotlight tags

Spotlight tags analyze behavior of users who have previously clicked or viewed one of our online advertisements. Spotlight tags only collect anonymous, non-personally identifiable information, and at no time do spotlight tags record user name, password, email, IP home addresses, etc. Spotlight activities are reported only if they are created by a user who meets the following three criteria:

Clicks one of our ads and is redirected to our website, or views one of our ads and accesses our website later;

Performs an activity on a page containing a spotlight tag; and

Performs this activity within 30 days of clicking and/or viewing one of our ads.

How you can control what data is collected through cookies

The information we collect may depend on your browser settings. Most web browsers automatically accept cookies, but you can usually alter the setting of your browser to prevent that; however, doing so may limit your access to certain sections of our website, including account information found behind the log in.

If you do not wish to receive cookies, please refer to the help section of your Internet browser (Chrome, Safari, Firefox, Internet Explorer, etc.) to learn how to either block all cookies or receive a warning before a cookie is stored on your computer. In addition to altering the cookie settings on your browser, you can also install the Google Analytics Opt-out Add-on, which prevents Google Analytics from collecting information about your website visits.

Internet applications

During some visits to our website we may collect session information, including page response times, download errors, what time you visited our website, how long you were on our website, if you've been to the website before, what web pages you visited, page interaction such as scrolling, clicks, and mouse overs, what type of browser you used to access our website and methods to browse away from the page. This information helps us identify ways to modify and improve our websites. Examples of information we collect and analyze include the Internet protocol (IP) address or other unique identifier for the device you use to access the Internet, login email address, computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions and operating systems.

Principal considers the information collected through our Website Digital Technologies valuable. At this time, Principal does not respond to do-not-track signals or similar technologies sent by a browser setting. However, visitors will continue to have the ability to control cookie settings for Principal’s websites. The information we receive from your web browser and device may or may not be personally identifiable and we may combine it with other information in an attempt to identify you.

HOW WE USE INFORMATION

We may use the information we collect for any of the following purposes:

to provide your Principal advisor with information that can facilitate conversations you have with your advisor and to help your advisor identify products or services that might be of interest to you; for example:

If your interactions within the App (e.g., clicking on educational or informative content) indicate you might be interested in, or have a need for, a certain financial product or service, this information may be provided to your Principal advisor to facilitate future conversations.

If the information we receive from your social media sites (those sites that you have connected the App to) indicates that you have had a life event (e.g., a marriage, new job, or new child), this information may be provided to your Principal advisor to facilitate future conversations.

If your location data or other information collected through the App indicates that you have had a life event (e.g., a marriage, new job, or new child) or have an interest in a specific product or service, this information may be provided to your Principal advisor to facilitate future conversations.

If you indicate in the App that you want to contact your advisor, that request will be provided to a Principal advisor.

If you have a Principal advisor, the request will be sent to that individual.

If you do not have a Principal advisor, you will be contacted by an advisor within the Principal advisor network.

to develop, provide, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;

For example, we use the information to provide you with the services you request; understand how you and other users interact with the services; track exercise, activity, and other trends; provide customer support; troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.

We may also use your information to help you find and connect with other users and to allow other users to find and connect with you on the App. For example, your account contact information allows other users to add you as a friend. When another user has your email or mobile phone number in their contact list or in their friend network on a connected service, we show that user that you are a user of the App.

When you allow us to collect precise location information, we use that information to provide and improve features of the App such as showing you certain insights about your day-to-day activities.

for customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the App;

We use the information we collect to promote the safety and security of the App, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

to communicate with users either via email, telephone, text (SMS) messages, mail, or as otherwise authorized by you;

We use your information to send you Service notifications and inform you of new features or products we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the 'Unsubscribe' link in an email. We also use your information to respond to you when you contact us.

to better understand how users access and use the App, for the purposes of trying to improve the App and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users’ usage of the App;

We use the information we collect to personalize the App, make inferences, and show you more relevant content. Here are some examples:

Information like your height, weight, gender, and age allows us to personalize your daily exercise and activity statistics like the number of calories you burned and the distance you traveled.

Based on your sleep data, we may make inferences about your sleeping patterns and provide you with customized insights to help you improve your sleep.

We may personalize exercise and activity goals for you based on the goals you previously set and your historical exercise or activity data.

to help us develop new products and services and improve our existing products and services;

to provide users with educational or informative content that may be relevant to you;

to provide users with advertising and direct marketing that is more relevant to you;

to take the information we collect from your use of the App and combine it with information we receive from other sources, such as your interactions with www.principal.com, your interactions with your advisor, or information you provided as part of other products and services you have with us;

to enforce our Terms and Conditions of the App or other applicable policies; and

to assess the effectiveness of and improve advertising and other marketing and promotional activities.

Please note that information collected through the App may be used in an aggregated or individualized manner.

HOW INFORMATION IS SHARED AND DISCLOSED

We do not share your personal information except in the circumstances described below.

WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct us to disclose your information to others, such as when you use our community features like the forums and other social tools. For certain information, we provide you with privacy preferences in account settings and other tools to control how your information may be accessed by other users on the App. Just remember that if you choose to participate in a challenge, information like your profile photo, points earned, total steps in the challenge, personal statistics, and achievements, is not governed by your privacy preferences and will be visible to all other challenge participants.

You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings.

FOR PROCESSING WITHIN PRINCIPAL

We may share information we collect about you with other member companies within Principal for a variety of purposes. For example, we share information to assist us in providing service and account maintenance of the App and other products and services you may have with Principal, to help us design and improve products, to offer products and services that may be of interest to you, and to provide educational or informative content that may be relevant to you.

FOR PROCESSING EXTERNALLY BY OUR THIRD-PARTY SERVICE PROVIDERS

We may share information we collect from you with external third-party service providers, and other partners who process information for us, based on our instructions, and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. These partners provide us with a variety of services, including customer support, information technology, data analysis, research, and surveys.

For example, we may share your information with third-parties, such as reinsurers who provide us with data analysis and research, and with third-party developers who assist us in operating and improving the App.

FOR USE BY YOUR PRINCIPAL ADVISOR

We may share information we collect from you with your Principal advisor. This information is provided to your advisor to facilitate conversations you have with your advisor and to help your advisor identify products or services that might be of interest to you.

For example, we may provide information to your advisor if:

your interactions within the App (e.g., clicking on educational or informative content) indicate you might be interested in, or have a need for, a certain financial product or service;

the information we receive from your social media sites (those sites that you have connected the App to) indicates that you have had a life event (e.g., a marriage, new job, or new child); or

the location data or other information we collect through the App indicates that you have had a life event (e.g., a marriage, new job, or new child) or have an interest in a specific product or service.

In addition, if you indicate in the App that you want to contact your advisor, that request will be provided to a Principal advisor. If you have a Principal advisor, the request will be sent to that individual. If you do not have a Principal advisor, you will be contacted by an advisor within the Principal advisor network.

FOR LEGAL REASONS OR TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the App or the physical safety of any person.

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.

HOW TO ACCESS OR DELETE YOUR PERSONAL INFORMATION

We provide you with account settings and tools to access and manage the personal information associated with your account. We store information associated with your account until your account is deleted. You can delete your account at any time by contacting Customer Support. Please note that it may take up to thirty (30) days to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the How Information Is Shared And Disclosed section.

You can also manage certain information about your principal.com account by accessing "My Profile" at www.principal.com.

OUR POLICIES FOR CHILDREN

The App is not directed toward or intended for use by children. Users under the age of 18, or the equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts and use the App. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at myprincipallifestyle@principal.com.

INFORMATION SECURITY

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. We have comprehensive security practices and procedures in place to protect data entrusted to us. Additional detail about how Principal protects your data is available online at https://www.principal.com/privacy-policies under "Important Information". No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact our Privacy Officer at P.O. Box 14582, Des Moines, IA 50306-3582 or at CorpPrivacy@exchange.principal.com.

EFFECTIVE DATE AND CHANGES TO THIS POLICY

The Effective Date of this Privacy Policy is set forth at the top of this page. Whenever possible, we will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the App. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the App after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. Archived versions of this Privacy Policy are available online.

HOW TO CONTACT US

If you have questions about this policy, or about our use of your information, please contact us at CorpPrivacy@exchange.principal.com or at:

Privacy Officer
P.O. Box 14582
Des Moines, IA 50306-3582