- Information We Collect
- Use of Personal Information
- Sharing Personal Information
- Your Rights and Choices
- Contact Information
Effective Date: June 2, 2021
Last Updated on: June 2, 2021
This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we collect the following categories of personal information from consumers within the last twelve (12) months:
|Category||Personal Information Collected|
|Identifiers.||name, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address.|
|Personal information categories listed in the California Customer Records.||address, telephone number; medical health information; type of life insurance policy, insurance payout amount, and term policy convertible.|
|Protected classification characteristics under California or federal law.||age, medical condition, physical health, and gender.|
|Internet or other similar network activity.||browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from policy holders. For example, we collect personal information such as your age, gender and insurance policy.
- Directly from users. For example, we collect information from the forms you complete.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
- To sell your personal information to a settlement provider.
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.
- To provide, support, personalize, and develop our Website, products, and services.
- To process your requests.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and deliver content that may be relevant to your interests through our Website, third-party sites, and via email (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may share your personal information by disclosing it to a third party for a business purpose “Business Purpose”. We only make these Business Purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a Business Purpose to the categories of third parties indicated in the chart below.
California law also requires us to be transparent about personal information we “sell” to partners in exchange for valuable consideration. In other words, we share and sell your personal information to third parties; however, you have a right to opt-out of those sales.
Our personal information sales do not include information about individuals we know are under age 18.
In the preceding twelve (12) months, Company has sold the categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures*||Sales*|
|Identifiers.||To third party marketers and service providers. These third parties provide services on our behalf (such as hosting services, marketing or advertising services).||To third parties who are interested in buying your personal information. Such third parties may be settlement providers who are interested in buying your insurance policy.|
|California Customer Records personal information categories.||To third party marketers and service providers. These third parties provide services our behalf (such as hosting services, marketing or advertising services).||To third parties who are interested in buying your personal information. Such third parties may be settlement providers who are interested in buying your insurance policy.|
|Protected classification characteristics under California or federal law.||To third party marketers and service providers. These third parties provide services on our behalf. For example, such third parties provide services that we need to secure your personal information.||To third parties who are interested in selling their life settlement products and services.|
|Internet or other similar network activity.||To third party marketers and service providers. These third parties provide services on our behalf (i.e., cookies) to improve our Website as well see the content and articles that benefit our users.||None.|
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with a legal obligation.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either: calling us at (415) 696-9222 or emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. For example, you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Personal Information Sales Opt-Out and Opt-In Rights
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://dawnlifesettlements.com/do-not-sell.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.
45 Lansing St, Suite 2812
San Francisco, CA 94105
If you need to access this Policy in an alternative format due to having a disability, please contact firstname.lastname@example.org and (415) 696-9222.