This privacy notice informs you how we collect, share and protect personally identifiable information (“personal information”) which you give us or we obtain in connection with providing our financial products and services. It presents the privacy practices of Global Atlantic Financial Group Limited and its subsidiaries, including Accordia Life and Annuity Company, Commonwealth Annuity and Life Insurance Company, First Allmerica Financial Life Insurance Company, Forethought Life Insurance Company, Forethought National Life Insurance Company and Global Atlantic Re Limited (the “Global Atlantic Companies”). Please read this notice carefully to understand what we do to ensure the privacy and security of your personal information.

Information Collection

We collect personal information in order to provide you with our products and services. The types of personal information we collect and share depend upon the products and services you have with us or you request. These can include:

Using and Sharing Your Information

We may use and share your personal information for our everyday business purposes to offer and deliver responsive information and solutions to you in connection with retirement, life and preneed products and services.

We may share your personal information with our affiliated companies and employees who need that information to provide you our products and services. We do not, however, share your personal information with affiliated companies for purposes of marketing their products and services. We also may share your personal information with select third parties located in the United States or in another country in certain circumstances. For example, we may share your personal information with third parties:

We do not, however, sell or rent your personal information to anyone.

Third parties with which we may share your personal information include, among others, independent contractors, insurance support organizations, insurance agents and brokers, health information management providers, third party administrators, reinsurance providers, credit reporting agencies, financial institutions for joint marketing purposes, courts and government agencies. These third parties may retain your information and provide such information to other parties as permitted by law.

You cannot limit this sharing. However, we do not share your personal health information with anyone without your authorization or unless permitted by law.

We may continue to share your personal information as described in this notice when you no longer are our customer.

Access to Your Personal Information

You may review and obtain a copy of certain personal information we have about you by writing to us at 20 Guest Street, Brighton, MA 02135. Please provide your name, address, contract number and the specific information you are requesting. You can ask us to update or change personal information you believe is in error. If we agree, we will change it. However, if we do not agree, we will notify you and permit you to file a written statement which we will include when we disclose your personal information to a third party.

If required by the law of the state in which you reside, upon your written request we will tell you the types of parties to whom we have disclosed your personal information within the past two years or those to whom we usually disclose such information. These parties may include the entities specified above in the section titled Using and Sharing Your Information.

Security

To protect your personal information from unauthorized access and use, we have adopted and maintain physical, electronic and procedural safeguards that comply with applicable law and which are reasonably designed to protect the availability, confidentiality and integrity of the personal information of our customers. These security measures include computer safeguards and secured files and buildings.

Effective Date

This notice is effective as of June 14, 2016.