Empower®

"Certain personal information may be shared among our affiliates as permitted by law to provide our services to you, to make it easier to do business with us, and for their everyday business purposes. We do not share your personal information with affiliates for their marketing purposes. From time to time, we may make you aware of products and services that are available from our affiliates."

Empower shares data across a large family of over 20 affiliated companies for 'everyday business purposes,' and also shares with service providers, plan sponsors, identity verification providers, fraud analysis providers, banking providers, and custodial brokerage providers.

"We use session replay technology to help us understand how you interact with our website and to improve your experience. This technology captures your interactions—such as clicks, scrolling, and typing behavior—so we can identify usability issues and optimize our content. Sensitive information is automatically masked, and we do not use Session Replay to collect or store passwords, credit card numbers, or other sensitive data."

Empower uses session replay technology to capture detailed user interactions including clicks, scrolling, and typing behavior, combined with cookies, web beacons, and advertising identifiers to track users across their websites and mobile applications.

"We collect your IP address from you when you visit our websites. This applies to visitors, users, retirement plan participants, retail customers, insurance customers, and advisory clients. We retain this information until all applicable legal and business obligations are fulfilled."

Empower collects geolocation data via IP addresses from all website visitors and app users, with no defined retention limit beyond vague 'legal and business obligations.'

"We retain this information until all applicable legal and business obligations are fulfilled. After your relationship with us ends, the terms of this policy shall continue to be applicable to your data for as long as we retain your data."

Every category of personal information is retained until 'all applicable legal and business obligations are fulfilled' — an open-ended standard with no specific timeframes, and data is explicitly retained even after the customer relationship ends.

"We collect government-issued ID images (front/back), selfie images/video, facial templates or embeddings (biometric identifiers), and voice recordings/voiceprints for identity verification and fraud prevention. This applies to participants, retail customers, insurance customers, and advisory clients."

Empower collects sensitive biometric data including facial templates, selfie videos, and voiceprints, which goes beyond typical financial service data collection, though it is used for identity verification purposes.

"We may modify or amend this privacy policy from time to time as the need arises. We advise you to visit our website regularly to check for any amendments. Any material changes will be communicated to you in accordance with applicable law through an appropriate channel, depending on how we normally communicate with you."

Empower reserves the right to change the privacy policy at any time, placing the burden on users to regularly check for amendments, with only vaguely defined communication of 'material changes.'