This Privacy Policy covers the following product offerings’ websites from Axonic Insurance Services:

• VantagePoint MYGA

• VistaPoint MYGA

• ViewPoint MYGA

Last Updated: February 3, 2025

This Privacy Policy describes how Axonic Insurance Services LLC (“we”, “us,” “our”) collects, uses and discloses information about individuals who use our website (www.axonicinsuranceservices.com), applications, services, tools and features (including Waypoint MYGA, Incline MYGA, Skyline MYGA, Trailhead FIA, VantagePoint MYGA, VistaPoint MYGA and ViewPoint MYGA), or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Policy. However, this Policy does not apply to information collected about agents through the Agent Portal, and we recommend that agents review the privacy policy available through the Portal. Please note that the Services are designed for users in the United States only and are not intended for users located outside the United States.

Please read this Privacy Policy carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Policy. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF YOUR INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, address, phone number, and email. We use this information to provide the Services, and to communicate with you (including to tell you about products or services that may be of interest to you).

• Any other information you choose to include in communications with us, for example, when sending a message via email.

Information We Collect Automatically

 We and third parties also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels or other tracking technologies (“Tracking Technologies”) to automatically collect certain information about your interactions with the Services. Usage Data includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.

• Location information, such as approximate location.

• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, interactions with marketing emails, and ad impressions.

We use Usage Data to tailor features and content to you, market to you, run analytics and better understand user interaction with the Services. For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, communicating with you, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Like many websites, our website is not designed to respond to such signals, and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference signals.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information to third parties for legitimate purposes subject to this Privacy Policy, including to:

• Our affiliates or others within our corporate group.

• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.

• Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

5. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

6. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Policy. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

7. PRIVACY RIGHTS

Depending on where you live and applicable law, you may have certain rights in relation to your personal information. Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law.

• Access: You may have the right to request access to the personal information we hold about you, and to obtain information about how we use it, and with whom we share or have shared it in the past.

• Deletion / Erasure: You may have the right to request that we delete personal information we hold about you.

• Correction: You may have the right to correct inaccurate personal information we hold about you.

Opt-Out of Marketing: You may opt out of marketing at any time by using the opt-out function displayed in our communications to you. Please note that if you opt out, we may still send you transactional or administrative messages, such as emails about your account.

To make a request, please contact us via email at privacy@axonicinsurance.com. We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your name, address, relationship with us, date of birth or government issued ID. To verify your identity, we will compare the information provided to the information we have on file. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. You do not need to create an account to exercise a right outlined in this section.

8. CALIFORNIA RESIDENTS

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).

In the preceding 12 months, we collected and (where indicated below) disclosed the following categories of personal information: