Last Updated: January 6, 2014
Eagil.com, an Internet property of Eagil Financial Group LLC (“Eagil,” “us” or “we”), has created this privacy policy (the “Privacy Policy”) in order to disclose our information gathering and dissemination practices. We understand the importance that Internet users place on privacy and have designed our website with this in mind. Eagil is fully committed to 100% permission-based marketing. You agree to this Privacy Policy, in its entirety, when you: (1) access or use our website located at www.eagil.com (the “Website”); (2) agree to receive e-mail from us; (3) obtain, or attempt to obtain, a quote regarding the sale of your life insurance policy to Eagil; and/or (4) obtain, or attempt to obtain, life settlement associated information and/or services from Eagil at this Website or at a website belonging to an affiliate of Eagil or (items (3) and (4) shall be referred to collectively as, the “Service”).
EAGIL IS NOT A COVERED ENTITY FOR PURPOSES OF THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (“HIPAA”), NOR IS THE INFORMATION PROVIDED BY YOU TO EAGIL CONSIDERED PROTECTED HEALTH INFORMATION UNDER HIPAA. AS SUCH, THE ADDITIONAL PRIVACY AND SECURITY PROTECTIONS AFFORDED TO CONSUMERS/PATIENTS UNDER HIPAA ARE NOT CONTEMPLATED BY, NOR CONTAINED WITHIN, THIS PRIVACY POLICY.
For purposes of compliance with the Gramm-Leach-Bliley Act, 15 U.S.C. 6802 (the “GLB Act”), the California Financial Privacy Act (“CFPA”) and the Vermont Fair Credit Reporting Act, 8 V.S.A. 10202 (“VFCRA”), this Privacy Policy shall serve as both your initial customer relationship and annual "Privacy Notice" as defined under the GLB Act, CFPA and VFCRA, respectively. If you would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please Click Here.
Information Collected
Online Registration/Application We provide an online application and/or information request forms to process your request for Service. Understand that the information that you submit is voluntary, but required if you request Service, whether or not you enter into a formal application with Eagil. The information submitted in connection with your registration/application, the information regarding your transactions with Eagil and any and all other information that Eagil collects, confirms or gathers in connection with your registration/application, or otherwise, both online and offline, is referred to, collectively, herein as "Personal Information." Upon registration, you may be required to provide all or some of the following Personal Information: (1) name; (2) gender; (3) e-mail address; (4) mailing address; (5) daytime telephone number, nighttime telephone number and/or cellular telephone number; (6) birth date; (7) information regarding your health and any existing medical conditions; (8) information regarding your bank account; (9) Social Security Number; and (10) answers to various eligibility questions, including providing information (or authorizing us to locate information) concerning your existing life insurance policy(ies). For purposes of this Privacy Policy, items (7) through (10) in the preceding sentence shall be referred to, collectively, as “Sensitive Information.”
Eagil reserves the right to transfer and/or sell aggregate or group data about Eagil users for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of Eagil users as a group without disclosing personally identifiable information. Subject to applicable state and federal law, by submitting your Personal Information to, and/or using, the Website, you agree to allow Eagil to transfer and/or sell such aggregate data to third-parties.
IP Addresses
We use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is used to gather broad and specific demographic information as well as for validation purposes.
Cookies
We use cookies to deliver content specific to your interests, to save your password so that you do not have to re-enter it each time that you visit our Website (if you choose), and for other purposes.
Web Site Tracking Software
Web servers, or those of third-party vendors, utilize certain tracking software to capture your domain name address (the address of your Internet Service Provider) for purposes of tracking Website statistics. Note that we only collect information about you when you voluntarily provide that information through an application or registration, by visiting the Website request form, or some other Website activity that we may provide from time to time. The capture of your domain name is a common practice among websites for measuring the number of hits, pages visited, and length of user session. We use this information to measure the effectiveness of the Website offerings in order to service you better.
Sharing of Information
In order for us to service your requests, process your applications and conduct business from day-to-day, we must occasionally share your Personal Information with other companies. These companies may include, but are not limited to, underwriters and lenders who are involved in the processing, funding and closing of a life settlement purchase, as well as third-party credit report providers and medical underwriters. We reserve the right to share this Personal Information in accordance with the terms of HIPAA, the GLB Act, for California State residents only, the CFPA and, for Vermont State residents only, the VFCRA. For purposes of compliance with the GLB Act, CFPA and VFCRA, Eagil will not share “non-public personal information” with its affiliates or non-affiliates without providing customers with an annual “Privacy Notice” explaining that Eagil will be sharing this non-public personal information with affiliates or non-affiliates of Eagil and, for purposes of the GLB Act, providing customers with the opportunity to opt-out from such disclosures. Notwithstanding the foregoing, the non-public personal information of California State residents shall not be shared by Eagil with third-parties unless: (1) Eagil has obtained a fully executed consent acknowledgement from the applicable California resident; or (2) the California resident already has a relationship with a non-affiliated financial institution pursuant to, and as defined under, the CFPA. To fully execute a CFPA consent acknowledgement, please email Eagil. For purposes of compliance with the VFCRA, Eagil will not share “non-public personal financial information” (as defined in the VFCRA) with third-parties without providing Vermont State residents with an annual notice explaining that Eagil will be sharing this non-public personal information with non-affiliated third-parties. Notwithstanding the foregoing, the non-public personal financial information of Vermont State residents shall not be shared by Eagil with non-affiliated third-parties unless: (a) Eagil has obtained authorization from the applicable Vermont resident; provided, however, that such authorization must be in written form, or where the applicable Vermont resident agrees, electronic form; (b) the disclosure is made to third-parties for the sole purpose of processing transactions or other related processes on behalf of Eagil; and/or (c) the disclosure is made to third-parties that market Eagil’s own products and services to its customers. To fully execute a VFCRA authorization, please email Eagil
We use the Personal Information that you supply to personalize your experience with the Website, to evaluate whether you are qualified for the Service and for verification purposes. The Personal Information that you submit to Eagil remains your property, but by submitting that Personal Information to Eagil, you grant Eagil the right, subject to applicable state and federal law, to use that Personal Information for marketing purposes. By agreeing to this Privacy Policy, you authorize Eagil to use your Personal Information to obtain other information about you from third-parties where such information was either not requested on the applicable registration form, or where such registration form was incompletely or improperly filled out. Such third-parties include, but are not limited to, consumer reporting agencies, consumer credit bureaus, medical underwriters and other outside parties as permitted or required by applicable laws. Any and all Sensitive Information that we collect as part of your Service application, and from third-parties, will be used to determine your eligibility for the Service only and will not be shared with third-parties other than underwriters and lenders who are involved in the processing, funding and closing of a life settlement purchase, medical underwriters, consumer reporting agencies and consumer credit bureaus, as applicable, for purposes of evaluating your qualifications for life insurance settlement and provision of the Service should you qualify. If you choose to provide information such as your Social Security Number, or authorize us to obtain your Social Security Number on your behalf, we may use that information to determine the status of your life insurance policy(ies) in connection with settlement thereof, by utilizing consumer reporting agencies, consumer credit bureaus, medical underwriters or for any other lawful purposes. If you do not provide such information, we may also use other information that you provided for the purpose of verifying your eligibility for life insurance settlement or for any other programs, offers or services applied for by and through the Website.
Subject to restrictions contained in applicable state and federal law, we may sell Personal Information (other than: (i) Sensitive Information; (ii) where you have opted-out from the use of such information; (iii) where we have not received your authorization or met the requirements of an exception under the VFCRA, if you are a Vermont State resident; and (iv) where we have not received your acknowledgement and consent or met the requirements of an exception under the CFPA, if you are a California State resident;) and/or join together with other businesses to bring selected opportunities to our customers. Eagil is able to offer its Service to you, in part, based on your willingness to be reached by our third-party advertisers. This information may also be shared with advertisers on an aggregate basis. We also use contact information from your registration data to send you information about Eagil and to keep you informed of our other products and services that may be of interest to you. Please keep in mind, though, that Eagil does not control, and is not responsible for, the practices of our third-party advertisers. Your contact information is also used to reach you, when necessary, regarding issues concerning your use of the Website. If you wish to stop receiving future communications from us and/or third-party advertisers, or if you wish to prevent the transfer and/or sale of your Personal Information to third-parties (subject to restrictions contained in applicable state and federal law), please see the Opt-Out/Unsubscribe section below.
By submitting your e-mail address at the Website and/or submitting an application for the Service, you agree to receive life insurance settlement applications and information from Eagil and/or its corporate affiliates. You also agree that by submitting your e-mail address at the Website, you may receive e-mail marketing from Eagil (including other Eagil properties) and our third-party advertisers.
In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR §310 et seq. (the “ATSR”). With respect to the ATSR, and notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, Eagil retains the right to contact you via telemarketing in accordance with the terms of the ATSR. Moreover, by registering with, or requesting information from, a third-party advertiser at or through the Website, such action shall constitute a purchase, an inquiry and/or an application with the respective third-party advertiser for purposes of their compliance with the ATSR and you may be contacted via e-mail, direct mail and/or telemarketing by such third-party advertiser in accordance with the terms of the ATSR.
Eagil reserves the right to release current or past user information and Personal Information: (A) in the event that we believe that the Website and/or the Service is being or has been used in violation of the Website Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed; or (C) if Eagil is sold or acquired. Moreover, you hereby consent to disclosure of any record or communication to any third-party when Eagil, in its sole discretion, determines the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time.
Other Websites
This Website may contain links to other third-party owned and/or operated websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Eagil has no responsibility or liability relating to them. Additionally, some third party underwriters and lenders that are involved in the processing, funding and closing of a life settlement purchase, as well as medical underwriters, consumer reporting agencies, consumer credit bureaus and marketing partners may require the transfer of some or all of the Personal Information that you supplied to Eagil. When necessary, Eagil provides this information to those third party underwriters and lenders that are involved in the processing, funding and closing of a life settlement purchase, as well as medical underwriters, consumer reporting agencies, consumer credit bureaus and our marketing partners (subject to restrictions contained in applicable state and federal law). Eagil is not responsible for the privacy practices of these third party underwriters and lenders.
Third-Party Offers
Eagil provides you with the opportunity to receive special offers, products and/or services from other third-party companies. To receive such offers, products and/or services, certain of your Personal Information (other than the Sensitive Information) will be shared with such third-party companies (subject to restrictions contained in applicable state and federal law), so that they may provide their offer, product or service to you without requiring that you first complete another registration form.
Security
All collected information is stored in a technically and physically secure environment. When our registration/application process asks users to enter Sensitive Information (such as medical records, bank account information, Social Security Number, etc), and when we store and transmit such sensitive information, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we also do everything in our power to protect user Personal Information (including Sensitive Information) off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information (including Sensitive Information), we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure its security on our systems. Access to this information is strictly limited, and not accessible to the public. All of our users’ Personal Information, not just the Sensitive Information, is restricted in our offices. Only employees who need the information to perform a specific job (for example a customer service representative) are granted access to Personal Information. Our employees are dedicated to ensuring the security and privacy of all Eagil user information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state law, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Minors
Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at our Website. Eagil does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Eagil encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
Opt-Out/Unsubscribe
To stop receiving future communications from Eagil, please Click Here. To opt-out of having your information shared with third-parties, please Click Here. Eagil uses Personal Information to provide promotional offers by e-mail to individuals. Eagil may maintain separate e-mail lists for different purposes. If e-mail recipients wish to end their e-mail subscription to a particular list, they need to follow the instructions at the end of each e-mail message to unsubscribe from the particular list. To unsubscribe from all Eagil e-mail lists, please Click Here
Changes in Privacy Policy
Eagil reserves the right to change or update this Privacy Policy at any time by posting a notice at the Website explaining that we are changing our Privacy Policy. If the manner in which we use Personal Information changes, Eagil will notify its users by posting the changes on the Website, sending out an e-mail notification to its customers notifying them of the changes and providing them with the opportunity to opt-out of the provisions relating to the transfer of their Personal Information. Other than where the user opts-out, and other than where affirmative consent is required for California residents and Vermont residents, the user's continued use of the Service and/or continued receipt of Eagil e-mails constitutes an affirmative acknowledgement and acceptance by the user of the modified Privacy Policy.
Correct/Update Personal Information supplied to Eagil during registration can be modified by: (1) logging in to your Eagil account; (2) clicking on User Settings; or (3) modifying any of the desired fields.
Contacting the Website
Our "About Us" page contains information that allows you to contact us directly with any questions or comments that you may have. We listen to or read, as applicable, every message that we receive and endeavor to reply promptly to each one. This information is used to respond directly to your questions or comments. If you have any questions about this Privacy Policy or the practices of Eagil, please feel free to contact us at 1-888-693-2445 or at info@eagil.com
