Privacy

December 10, 2024

Introduction

This privacy notice describes how Athene Annuity Re Ltd. and all its affiliates and subsidiaries (“Athene Bermuda”, “we”, “our” or “us”) that fall within scope of the Personal Information Protection Act 2016 (as amended) (“PIPA”) may collect, hold, use and disclose personal information in connection with the services that we provide (the “Services”). This privacy notice applies to all of the Services offered by Athene Bermuda.

Athene Bermuda is responsible for any personal information that is collected, held, used or disclosed in relation to the Services.

This privacy notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to personal information and is intended to comply with the requirements of PIPA.

The following key definitions are critical to the understanding of this privacy notice.

• Personal Information – Any information about an identified or identifiable natural person.
• Sensitive Personal Information – Any Personal Information relating to a natural person’s place of origin, race, color, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genic information.
• Use or using – In relation to Personal Information, means carrying out any operation on Personal Information, including collecting, obtaining, recording, holding, storing, organizing, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it.

It is not Athene Bermuda’s general practice to obtain or receive Personal Information. However, in limited cases, Athene Bermuda may collect and use your Personal Information in order for us to provide you with the Services. Athene Bermuda may directly and indirectly collect and use Personal Information (including Sensitive Personal Information) obtained from you or your intermediaries through the following non-exhaustive list of sources:

• Provided by you by completing applications, policies and other forms (which may include: your name, address, email, passport, government identification number, age, gender, marital status, number of dependents, health history, employment history, income and personal financial information)
• Third parties including credit reference agencies and criminal background checks

We will take reasonable steps and adopt appropriate safeguards against risk (including physical and IT based security measures and controls) proportional to the potential harm, sensitivity and context of the Personal Information which comply with applicable laws to protect your Personal Information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse. Access to your Personal Information is also restricted to authorized employees and agents of Athene Bermuda who require access for a permitted purpose to perform their employment functions, and whom have been advised as to its proper handling.

We do not knowingly collect and retain Personal Information from children under the age of 14 without consent from a parent or guardian of such child. If you believe that your child has provided their Personal Information to Athene Bermuda without your consent, please contact us so that we can identify and delete such information.

We may use your Personal Information for the following purposes or as otherwise described at the time of collection:

• to administer, maintain, manage and operate our Services;
• to process, assess and determine any applications, requests or questions made by you in connection with our Services;
• to communicate with you about our Services;
• to facilitate our recruitment activities;
• to process employment applications;
• to monitor recruitment statistics;
• to comply with applicable laws and regulations, lawful requests, court orders and legal process;
• to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• to audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• to enforce the terms and conditions that govern the Services;
• to prevent, identify, monitor, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity;
• to send marketing communications related to our Services or other marketing communications as permitted by law (you may opt-out of our marketing communications by contacting us); and
• for research and development purposes, including to analyze and improve the Service and our business.

We may share your Personal Information with: (i) our subsidiaries and affiliates; (ii) contractors, service providers, analytics providers and other third parties we use to support our business; and (iii) to any potential buyer or other successor in the event of a merger, amalgamation, divestiture, restructuring, reorganization, dissolution, or other business combination to effect the sale or transfer of some or all of Athene Bermuda’s assets.

We may also disclose Personal Information about you to third parties where we have a legitimate purpose for doing so, including: (i) if we are required to do so by any rule or law or by the order of any court, (ii) in response to a request from law enforcement authorities or other government or regulatory officials, or (iii) when we believe disclosure is necessary or appropriate to enforce our rights or agreements, prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.

Our business operates internationally and as such your Personal Information may be transferred to and used by parties located in other jurisdictions (including the United States of America, Canada and the United Kingdom and other jurisdictions with privacy and data protection regimes that differ from Bermuda). Where your Personal Information is transferred to a third party located outside of Bermuda, we will take steps to ensure that your Personal Information is adequately protected and transferred in accordance with any applicable data transfer requirements, and that the third party recipients of such information are obligated to provide a comparable level of protection to that provided by Athene Bermuda.

You have certain rights with respect to your Personal Information, and you may submit to us reasonable written requests to:

• Access, examine or receive a copy of your Personal Information that is in our custody or control
• Correct an error or omission in any of your Personal Information which is under our control
• Cease, or not to begin, using your Personal Information (i) for the purposes of advertising, marketing or public relations or (ii) where the use is causing or likely to cause substantial damage or substantial distress to yourself or another
• Erase or destroy your Personal Information where it is no longer relevant for the purposes of its use

In certain circumstances, we may not be obligated to comply with your request and you can request a review by the Bermuda Privacy Commissioner of our decision, action or failure to act, and you may initiate a complaint against us with the Bermuda Privacy Commissioner.

For general inquiries about Athene Bermuda or any of our Services, more information can be found at our website, https://www.athene.com/bermuda. Our offices are located at Second Floor, Washington House, 16 Church Street, Hamilton, HM 11, Bermuda, and we can also be reached at +1 441 279 8400

If you have any questions about this privacy notice or to request more details about your rights and how we collect, use and disclose your Personal Information, please contact our Privacy Officer, Ashanti Caesar, ashanti.caesar@athene.bm. Any request must be in writing and provide sufficient detail to enable us to identify the Personal Information to which the request relates.

This privacy notice is subject to change in accordance with changes to applicable laws or our internal policies and procedures. The date above indicates when this privacy notice was last revised.

Any changes to this privacy notice will be effective upon publication of the revised privacy notice, and continued use of our Services following such changes indicates your acceptance of the revised privacy notice.