Privacy Policy

This Policy describes how Life & Wealth Network LLC (the “Company”, “we” or “us”) collect, use, transfer, and disclose your information.

This Policy covers information the Company collects in connection with your access as an end-user to our software-as-a-service offerings (collectively, the “Services”) consisting of an online database of life and wealth professionals and related content available at members.lifeandwealthnetwork.com (the “Site”) and related services (including technical support services and/or other professional services). Alternatively, if you are financial advisor who accesses the Services to provide access to portions of the Services to your clients, this Policy covers information the Company collects in connection with such access and use of the Services and Site.

This Policy also covers information collected through:

• the Site,
• the software applications we make available for use and access on or through computers or mobile devices (the “Apps”),
• our social media pages and applications to which the Site links (collectively, our “Social Media Pages”), and
• HTML-formatted email messages we send to you that link to this Policy (collectively, including the Site, Apps, and Social Media Pages, the “Online Systems”).

This Policy also covers other means by which we collect information. For example, it also covers how we collect information from in-person discussions, telephone conversations, and through non-electronic communications (i.e., collection through other means than our Online Systems).

YOU AGREE TO THE TERMS AND CONDITIONS OF THIS POLICY AND ANY UPDATES WE MAKE BY YOUR USE OF OUR ONLINE SYSTEMS OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION. THIS IS OUR COMPLETE POLICY, AND SUPERSEDES ALL EARLIER VERSIONS.

WHO WE ARE

We offer the Services to assist and guide individuals in quantifying not just financial investment gains, but gains in other parts of a person’s life—relationships, family, security, leisure, career, health, home and education, among other aspects.

We may also conduct assessments and other life, wellness and benefit analyses (where permitted by law) in order to provide individuals with access to certain products and services.

PERSONAL INFORMATION WE COLLECT

We collect information that identifies you as an individual or relates to an identifiable individual (“Personal Information”) to provide you with access to and use of the Services, and if applicable, for the provision of the Services to your clients, and to operate our business. The type of Personal Information we collect depends on the situation at hand.

• We may collect your name, address, telephone number, email address and other contact details provided by you, as well as preferred means of communication. We may also collect your responses and feedback to assessments.
• When you are utilizing our Online Systems, we may collect login user credentials like user names, passwords, security questions and answers, and password hints.

Please do not provide us with any Personal Information if you do not agree with this Policy.

HOW WE COLLECT PERSONAL INFORMATION

As you interact with the Company, you provide some Personal Information directly.

• We may collect Personal Information when you register to use or provide access to our Online Systems, submit information, complete assessments or surveys, provide Personal Information about yourself or contact us via email, electronic forms, telephone or postal mail.
• If you submit any Personal Information about other people (including, if applicable, your clients) to us, you represent that you have the authority to do so and to permit us to use such information in accordance with this Policy.

Personal Information about you may also come from other third parties who may have access to the Services (including, if applicable, your financial advisor).

We may from time to time make available through the Services certain products, websites, materials, documentation, information, stories, articles, text, images, multimedia data, pictures, graphics, video, audio, trademarks, services logos, marks, symbols, artistic content, webinars, presentations and other content (collectively, “Content”) provided by or on behalf of third parties or jointly developed by a Provider (as defined below) with such third parties or otherwise about or in reference to third parties (collectively, the “Third Party Content”), including but not limited to service providers and other professionals in various disciplines collectively, the “Providers”). Certain Third Party Content may be subject to additional terms, conditions and policies, and you should not (or, if applicable, permit or direct your clients to) install, access or otherwise use such Third Party Content if you and, if applicable, your applicable client(s) do not agree to abide by the applicable terms and conditions therefor.

If you wish to access or use Third Party Content, you (or, if applicable, your clients) may be directed to a webpage that is hosted by a third party and not by the Company. Any Personal Information that you or, if applicable, your clients provide through those pages to third parties will be subject to the third party’s privacy policy, rather than this Policy. We do not control, and are not responsible for, a third party’s use of information collected through those pages. Please note that this Policy does not address the collection and use of information through the third party’s page or the privacy or information practices of the third party.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We use the Personal Information it collects in several ways. The summary below provides additional details about the ways we use the Personal Information we collect.

• We use your Personal Information to provide and make available the Services to you and, if applicable, your clients. We do this to fulfill our contractual relationships with you and where we have a legitimate, beneficial interest in using Personal Information to conduct our business.

In the course of our Services, we may use Personal Information that we have collected to create a profile about you. This profile may be used to identify other aspects of our Services (or other services or products) that we think may be of interest to you or, if applicable, your clients. We may contact you from time to time regarding such services or products.

You can always object to our creating a profile about you; see the “Choices and Access” section below on how you can object. If you object, we will remove your profile from our systems pursuant to the terms of this Policy.

We use your Personal Information to respond to your inquiries, to verify your information, to share information with you and fulfill your requests. If you contact us, we may keep a record of your contact information and correspondence, and use information you provide in your message to respond to your inquiry. We do so to manage our contractual relationship with you.

From time to time we use your Personal Information to send you important information regarding the Services and the Online Systems, changes to our terms, conditions, policies, and other administrative information. We may also contact you to verify that the Personal Information we collected about you is accurate and current. We use the Personal Information to manage our contractual relationship with you or to comply with a legal obligation.

We use your Personal Information to operate our business.

We use your Personal Information for business purposes, such as audits, internal communications, determining the effectiveness of our promotional activities, administering our Services, maintaining and securing our infrastructure.

We may use Personal Information to conduct analytics and thought leadership materials. Any published product will refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you (unless otherwise consented to by you). We may perform analytics because we have a legitimate beneficial business interest in doing so.

We may retain and use Personal Information about you for research, publication, development, benchmarking and norms, validation, longitudinal studies, trend analysis, to improve and enhance our Services or to develop and market new Services. We may use Personal Information about you to ensure that our Services conform with legal requirements.

We may also anonymize, aggregate or de-identify Personal Information so the end-product does not identify you or any other individual. Such aggregated, anonymized or de-identified information is not considered Personal Information for purposes of this Policy and we may use it for any purpose, where permitted by applicable law.

We may use your Personal Information to send you information or marketing materials.

We may send informational emails, articles and other information regarding our Services. We also use your Personal Information to conduct assessments and trainings. We do so either with your consent or because we have a legitimate beneficial business interest. Occasionally, we may desire to use your Personal Information in press releases and direct marketing materials. Before we use your Personal Information in that way, we will obtain consent from you.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

How your Personal Information is disclosed will depend upon the situation.

To the extent permitted by law, we may share Personal Information with our affiliates to provide seamless Services for you. We are responsible for managing jointly-used Personal Information.

From time to time, we also disclose Personal Information to our strategic alliance partners.

We may disclose Personal Information to third parties who provide Third Party Content or otherwise provide support for our Services or business operation. We work with third parties who provide services that may include, but are not limited to, assessment services, website hosting and information technology consulting services, data analysis, marketing services, attorneys, accountants, and other administrative and back-up and security services. As part of providing these services, these third parties may be provided with access to Personal Information. In addition, our software development partners may use Personal Information to modify, improve, refine, and validate their technology, research and development.

When we share your Personal Information with such third parties, we require the security and confidentiality of your and, if applicable, your client’s Personal Information, as well as limit their use of the information as reasonable and necessary to carry out their work with us and comply with applicable laws, rules and regulations.

We may disclose or transfer all or part of your and, if applicable, your clients’ Personal Information in the event of a sale of our company, equity or business or one or more of our affiliates. We may also disclose or transfer all or part of your and, if applicable, your clients’ Personal Information in the event of a merger or consolidation involving our company or one or more of our affiliates. This may also occur if there is a sale or transfer of assets of any portion of our business or the business of one or more of our affiliates.

There may be other times that we disclose your and, if applicable, your clients’ Personal Information. We may also use or disclose Personal Information (to comply with legal, governmental or regulatory obligations or because we have legitimate interest to do so) in order to: (i) comply with applicable laws, rules or regulations, (ii) respond to inquiries, requests or orders from public, government or regulatory authorities, or (iii) protect the rights, privacy, safety or property, of the Company and our affiliates, you or others.

We cannot and do not assume any responsibility for the actions or omissions of third parties, including Providers, including the way they use or access Personal Information received either from the Company or from other independent sources.

OTHER INFORMATION WE COLLECT

Please contact support@lifeandwealthnetwork.com for information on how to access your data.

We collect or track other information that does not reveal specific identity (“Other Information”), such as: (i) information collected through cookies, pixel tags, and other technologies, App and Site usage data, (ii) browser type, operating system, accessing, loading or exiting of web pages, and the Internet Protocol (IP) address of your computer or device, (iii) demographic information and other information provided by you, and (iv) aggregated information.

Because Other Information does not reveal your specific identity, we may use it for any purpose. If we combine Other Information with Personal Information that identifies you directly (like combining your name with your location), we will treat the combined information as Personal Information for as long as it is combined.

If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose your Personal Information as detailed in this Policy.

We and our third party service providers may collect Other Information in a variety of ways.

We may contract with third parties to place advertisements for our Services on websites that are not our own. We may place these advertisements where we think they are likely to be most relevant. These advertisements on third party websites allow us to track responses to our advertisements. We may use this information to track the performance of our advertising and marketing campaigns by using tools like cookies, web beacons and similar technologies. We may use these tools to collect and store information about your visits, page visits and duration, and the specific advertisement or link that the user clicked on to visit the site.

We may use “cookies” (small text files placed on a visitor’s computer hard drive) and other similar technologies to help us determine information like the type of content a visitor to the Site consumes, and the length of time each visitor spends at any area of the Site. Cookies and similar technologies enhance your experience on the Site. You can configure your browser settings to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie(s) from a particular site. Please refer to http://www.allaboutcookies.org/manage-cookies for information on how to manage cookies stored on your computer. If you disable cookies and similar technologies, your experience on the Site may be diminished and some features may not work as intended.

A web beacon embeds a small transparent .gif image in a web page or email used to track when the page or email has been viewed. A similar device may be used where a product, service or functionality sends data to a server when a set of user-initiated events occur such as clicking a button on the website or in an email. This is similar to a cookie—it tracks Site visits and the data is only read by the server that receives the data. However, it differs because it is not browser-based, may not function as an identification card and does not store any data on your computer.

ADDITIONAL GUIDELINES

We may from time to time sponsor special features, events (live or virtual), webinars, or promotions on the Online Systems and additional privacy information may be posted. Depending on the nature of the Service being utilized or accessed, you may be asked to consent to the collection, use, transfer, and disclosure of Personal Information. You may also be shown a privacy notice before participating in a Service. That privacy notice, to the extent it conflicts with this Policy, will govern that particular Service, feature, or promotion.

CHOICE AND ACCESS

Your provision of Personal Information to us is voluntary, although if you do not provide certain Personal Information you may not be able to participate in or access our Services. Contact us support@lifeandwealthnetwork.com if you would like to:

• ask questions about how we handle Personal Information,
• withdraw your consent to our use of your Personal Information,
• object to our use of your Personal Information for our legitimate business interests, or
• request an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law),
• request to review, correct, update, suppress or restrict the use of your Personal Information,
• request that your Personal Information be removed from our systems,
  • We will make reasonable attempts to delete Personal Information upon your request.
  • Please note that to maintain consistency in our Services and operations, we retain backup systems. When you ask that your information be removed from our systems, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this Policy.

If you would like to opt-out of receiving marketing communications from us (to the extent you may receive them), please select “unsubscribe” in the applicable email communication or contact us at support@lifeandwealthnetwork.com to have your contact information removed from our systems.

• If you request to have your information removed from our systems through an email request, please include “Remove User” in the subject line of the email, and include your full name, login ID, and telephone number in the body of the email message.
• You can also forward a copy of the email or communications from which you want to opt-out.
• We will respond to your request consistent with applicable law. We may decline to process requests that in our reasonable opinion may jeopardize the privacy of others or put our intellectual property at risk.
• For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practical and may need to contact you to be sure that we understand your request.
• We also may need to retain certain Personal Information about you such as your email address to honor opt-out or similar requests. Please keep in mind that this residual Personal Information will remain within our systems and records, which may or may not contain identifiable Personal Information. The residual Personal Information will not be used for commercial purposes. However, we reserve the right, from time to time, to recontact former users of the Services as appropriate.

LOCATION OF PERSONAL INFORMATION COLLECTED AND MAINTAINED

Your Personal Information will only be collected, used, processed, disclosed, and transferred within the United States.

SECURITY

We have reasonable organizational, technical, physical, and administrative measures in place designed to protect (i) your and, if applicable, your clients’ Personal Information’s security, confidentiality and integrity, and (ii) against the loss, misuse, and alteration of Personal Information about users of the Online Systems which is under our control.

Unfortunately, however, no security system, or system of transmitting information over the Internet can be guaranteed to be 100% secure. If you have reason to believe that your Personal Information or your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised or your user credentials are no longer secure), please immediately notify us of the problem by contacting us as described in the “Questions” section below.

RETENTION PERIOD

We retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and, if applicable, your clients (e.g., for as long as you, or, if applicable, your clients have an account with us or keep using the Services),
• A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain such information for analysis, record-keeping and compliance with data retention schedules,
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them), or
• Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation or regulatory investigations).

LINKS TO OTHER WEBSITES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any other third parties (including, without limitation, our providers of Third Party Content). On the Online Systems, you may have the opportunity to follow a link from or to other websites maintained by third parties. The inclusion of a link on our Online Systems does not imply our endorsement of the linked site or the provider of such Third Party Content. Because these other websites may not be hosted or controlled by us, this Policy does not address the privacy practices of those websites. We encourage you to review the privacy policies of each of those websites.

Please note that we are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

UPDATES TO THIS POLICY

We review our privacy practices regularly, and those practices are subject to change. You can determine when this Policy was last revised by checking the “Last Updated” legend at the bottom of the Policy. Any changes to the Policy will become effective upon posting of the revised Policy on the Internet, accessible through the Site.

USE OF ONLINE SYSTEMS BY CHILDREN

We never intend to collect personal information from children under 16 years of age. If we learn or are notified that we have collected this information from a child under the age of 16, we will promptly remove the data from our system.

The Online Systems are not directed to individuals under the age of 16, and we request that these individuals do not provide their personal information through the Online Systems.

SUMMARIES OF POLICY

Except as otherwise agreed to in writing between you and us, this Policy is the sole authorized statement of our practices with respect to the online collection of Personal Information through the Online Systems and the usage of Personal Information. Any summaries of this Policy generated by third party software or otherwise have no legal effect, are in no way binding upon the Company, cannot be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.

QUESTIONS

We are responsible for collection, use, and disclosure of your Personal Information under this Policy.

Questions regarding this Policy should be directed to the Company at support@lifeandwealthnetwork.com or, if by postal mail, at 4 Campus Drive, Parsippany, NJ 07054, Attn: Privacy Office.

FOR CALIFORNIA RESIDENTS ONLY

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of Personal Information that we collect, use and disclose about California residents and California residents’ rights.

We collect, and have collected within the preceding 12 months, the following categories of Personal Information, as listed in the CCPA. This list also shows the categories of information we have sold in the previous 12 months and the categories of information we have disclosed for a business purpose in the previous 12 months.

For information on the sources of the above categories of Personal Information, please refer to the “How we Collect Personal Information” section in this Policy.

For information on our purpose for collecting and, if applicable, selling the above categories of Personal Information, please refer to the “How We Use the Personal Information We Collect” section of this Policy.

For information on the third parties to whom the above categories of Personal Information are shared, please refer to the “Who Has Access to Your Personal Information” section of this Policy.

If you are a California resident, you may request that we:

• Disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
• Delete Personal Information we collected from you.
• Stop the sale of your Personal Information (if applicable).

To make a request for the disclosures, deletion, or opt-out of sale (if applicable) described above, please contact us at support@lifeandwealthnetwork.com or call us at our number at 646-328-7506.

In most cases, we will verify your request by: (1) confirming that you control the email address associated with your Personal Information; and (2) confirming that your description of your interactions with us matches our records. If necessary, we may require additional information to verify your request. If you are making a request on someone else’s behalf, you must also submit signed proof of authorization and, if necessary, we may ask for additional information. We will respond to your request consistent with applicable law.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Last Updated: February 16, 2021.

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