Law Enforcement Guidelines

The Canada Life Insurance Company, 100 Canada Life Way, Lansing, MI 48906, United States.These guidelines are for law enforcement officials and governmental entities seeking information or records from Canada Life ("we," "us," or "our"). They do not create any obligation or enforceable right against Canada Life, nor do they constitute legal advice or a waiver of any objection we may have in any particular case. We reserve the right to modify these guidelines at any time. All references to legal process and production of data are to be understood in the context of applicable U.S. federal and state law.

Stored User Information

We store and maintain user information as described in our Privacy Policy. We do not track a device's location when the user is not actively using our services. We cannot guarantee that the information described in our Privacy Policy will be available for any given user or time period. The information we may produce in response to legal process may depend on the type of process and the applicable legal basis (including, where relevant, the Stored Communications Act, the Electronic Communications Privacy Act, or other U.S. federal or state legislation).

Any data we produce will typically be in raw form (e.g. activity logs, exported data) and may require specific software or expertise to interpret. We do not provide depictions, interpretations, or opinions regarding the data. We recommend considering engagement of a professional who can help interpret raw data if needed for your situation.

User Consent

Law enforcement or other entities seeking Canada Life data from individuals who consent to sharing their data should seek that data directly from those individuals. Users can download their own information where we provide such tools. We do not produce user data solely on the basis of user consent provided to the requesting agency; valid legal process is required for us to produce records.

Preservation Requests

We may attempt to preserve user data upon receipt of a formal preservation request from law enforcement in connection with an official criminal investigation, pending receipt of a court order or other legal process requiring production. Preservation requests should be sent on official law enforcement letterhead and signed by a law enforcement official. We do not produce any data upon receiving a preservation request; a valid court order or other approved legal process is required for user data to be produced.

Requirements to Produce User Information

For U.S. Law Enforcement

We respond only to valid legal process properly served on us in the United States in accordance with applicable federal and state law. Requests should identify the legal basis (e.g. subpoena, court order, search warrant, or other lawful authority) and be sent to our designated contact (see Contact below). We will respond in accordance with our obligations under applicable U.S. law.

For Non-U.S. Law Enforcement

Law enforcement agencies outside the United States seeking information from Canada Life should submit requests through the appropriate international channel. This typically involves working with U.S. authorities (e.g. via a mutual legal assistance treaty (MLAT), letter rogatory, or other formal mechanism recognized under U.S. law) so that valid U.S. legal process can be obtained. We do not respond to direct requests that do not comply with U.S. law or that have not been properly channelled where required.

How to Submit a Request

Legal process must be served or submitted in accordance with applicable U.S. law. Please send requests to our designated contact for law enforcement (see Contact below). Acceptance of legal process does not waive any objections we may have, including lack of jurisdiction or improper service.

Information Required

We are unable to process overly broad or vague requests (e.g. all users in a particular area and time). We do not participate in bulk collection of user data at the government's request. All requests must identify the user account and requested records with sufficient specificity. To avoid delay or denial, we ask that you provide as much of the following as possible:

• The user's legal name and/or account name
• The user's date of birth (if known)
• The user's location of residence (e.g. city, state, country)
• The email address or unique account identifier linked to the user's Canada Life account
• Date of the reported incident or a limited date range of relevant activity
• Location of the reported incident or relevant activity (e.g. geolocation or address)

User Notification

Our policy is to notify users when we receive requests for their data, including by providing them a copy of the request where permitted by law, before producing their information. We may make exceptions where: (1) we are legally prohibited from providing notice (e.g. by court order or under applicable U.S. legislation); (2) we have reason to believe that providing notice would result in imminent harm or serious bodily injury; or (3) we have reason to believe notice would not reach the actual account holder (e.g. invalid email or compromised account).

Emergency Requests

If you are aware of a situation involving imminent serious bodily injury, please contact your local law enforcement authority immediately. If local law enforcement requires our assistance to avoid imminent serious bodily injury (e.g. locating a missing person who may have used our service), the entity may submit an emergency request for user information. We only respond to emergency requests from law enforcement. We will review and respond to emergency requests on a case-by-case basis in accordance with applicable law.

Testimony Requests

Upon request, we may provide a business record certification with our productions where appropriate, which may reduce the need for live testimony to authenticate records. We do not provide in-person or expert witness testimony.

Cost Reimbursement

We reserve the right to seek reasonable reimbursement for costs incurred in preserving or producing information. If we decide to seek reimbursement, we will provide a good-faith estimate before processing the request or producing data. Costs are based on the amount of data, time, and resources required to query, access, export, and/or produce the requested information.

Contact

Canada Life is a U.S.-based company. Law enforcement and governmental requests should be sent to customersupport@canadalife.com(subject line: "Law Enforcement Request") or to the U.S. address we publish for legal process. Please include your agency name, contact information, and reference to the legal process or request type. Requests are handled in accordance with applicable U.S. law.