At List Funding Inc. together with each of its subsidiaries and affiliates (collectively, “List” or the “Company”) we take our ethical responsibilities and your privacy seriously by recognizing that your privacy is important. We have a strong commitment to providing excellent service to all our customers and visitors of the www.listfunding.com website (the “Site”), including respecting your concerns about privacy.  This Privacy Policy discloses how we collect personal information, the types of personal information we receive and collect, our use of current and former consumer information, as well as the steps that we take to safeguard your information.  If you visit (and use) the Site, you explicitly agree to the terms and conditions of this Privacy Policy, as in effect at the time of your visit (and use). We hope that this statement will help increase your confidence in our Site. Therefore, in compliance with industry standards and regulations enforced typically by the Federal and State Governments, we adhere to the following policy. 

 

General

The Company is committed to adhering to its obligations under this Privacy Policy to maintain the confidentiality of all personal, financial, health and medical information received from or pertaining to visitors and users of our Site, including without limitation investors seeking to invest in such policies (the “Investors”) via the Company’s services.

 

Browsing Our Website

The Company does not collect Personal Information (as defined below) from your computer when you browse the Site and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with Personal Information, we will not know your name, your email address, or any other Personal Information.  The Company’s servers automatically record non-Personal Information when you visit our Site or use some of our basic features which do not require any form of registration.  When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the date and time of the request, the URL of your request, the language used, the browser type and any other information that is provided in the HTTP header.  We collect the HTTP request header information to make our website function correctly and provide you the functionality that you see on the Site.  We also use this information to better understand how visitors use our Site and how we can better tune it, its contents and functionality to meet your needs.

Information Collected

While you take advantage of the Company’s offerings, we may need to collect certain information from you, such as:

 

• Personal Information: Your name, address, email address, social security number, driver’s license number and information pertaining to prospective Investors (collectively, “Personal Information”).  We address protected health information below.

 

When we need to collect Personal Information from you and/or others to execute certain requested investment transactions or provide you with a particular service, we may ask you to voluntarily supply us with the information we need.  If you should refuse to do so, we may not be able to provision the service.

 

In addition, when you provide contact details in connection with prospective investment transactions, we will use the contact information to keep you updated about future offers or promotions unless you opt-out online or otherwise notify us. This information may be collected from, but not limited to, the following sources:

• Our communications with you, including information obtained when you register for a Company service or otherwise volunteer information;
• Your investment transactions with us, our affiliates, or others;
• Outside companies, such as consumer reporting agencies, to evaluate your creditworthiness and credit history; and
• Public sources, such as bankruptcy records and real estate records.

 

Aside from the purposes mentioned above, we sometimes use your Personal Information in other ways.

 

How Company Uses Personal Information

We may disclose a person’s Personal Information to effect or carry out any transaction that you have requested of us or as necessary to complete our contractual obligations with you. The personal information collected on this Site and by third parties will be used to operate the Site and to provide the services or products or carry out the transactions you have requested or authorized.

Except as provided hereunder to the contrary, we prohibit the sale or transfer of personal information to non-affiliated entities for their use without giving you the opportunity to opt-out. We may share your Personal Information with affiliated companies that are directly or indirectly controlled by, or under common control of the Company.

We may also use your Personal Information for auditing, research and analysis to operate and improve the Company’s technologies and services.  

We may also share Aggregated Information that does not identify you with third parties.  “Aggregated Information” refers to information the Company gathers by aggregating non-Personal Information to provide summaries of use of the Site. The aggregated information is used to show usage patterns and to do such things as negotiate with vendors of internet services. Such information shall not be linked to a user’s Personal Information.

Your Choices/Opt-out

We offer you choices when we ask for Personal Information, whenever reasonably possible.  We provide you the opportunity to ‘opt-out’ of having your Personal Information used for certain purposes, when we ask for this information. For example, if you register with us but do not wish to receive any marketing material from us, you can indicate your preference on your registration form and/or by sending an opt-out email to the Company at the address set forth below.

You may decline to provide Personal Information to us and/or refuse cookies in your browser, although some of our features or services may not function properly as a result.

By providing Personal Information to the Company you are consenting to the collection, use and disclosure of such Personal Information in the manner described in this Privacy Policy, unless you affirmatively opt-out from doing so.  We provide you the opportunity to withdraw your consent when such information is collected or at any later time by sending an email to [email protected].

Service Providers

We require the use of outside third-party companies to provide certain offerings including clerical, underwriting and information processing services.   When you sign up for our offerings, we will share only as much information as is necessary for the provision of those offerings.  We require that all third parties engaged by Company comply with our Privacy Policy in order to keep your information safe and secure. These third parties are prohibited from using or sharing your Personal Information for any purpose other than the job they are engaged to carry out. The various categories of non-affiliated third-party service providers with which we may share Personal Information include (without limitation):

• Attorneys and financial advisors representing Investors directly in connection with any investment transactions;
• Service providers, consultants and funding entities who work with the Company directly in connection with evaluating, processing and closing investment transactions. These include the Company’s funding entities and their advisors, trustees and independent escrow agents. Such parties are required to sign written agreements obligating them to preserve confidentiality and privacy of nonpublic personal information;
• Consultants and service providers who work under contract to the Company for policy/transaction administration and tracking, each of which agrees in writing to preserve the confidentiality and privacy of nonpublic personal information;
• Consultants and service providers who work for the Company to assist with design and maintenance of computer systems and other general business support, each of which agrees in writing to preserve confidentiality and privacy of nonpublic personal information; and
• Regulators and legal authorities that the Company must report to as a matter of law.

 

Securing the Transmission and Storage of Information

The security of your Personal Information is extremely important to us.  We employ generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it.  We process Personal Information on servers in the United States and in other countries.  Access to information about you is restricted to authorized employees and contractors obtaining the information for business purposes. If you have any questions about the security on our Website, please feel free to e-mail us.

HIPAA/PHI of Insureds

 

From time to time, the Company may receive PHI (as defined below) from individuals (i.e., insureds).  As a result, the Company takes the confidentiality of an insured’s health information very seriously, and we’ve chosen to adopt the strict rules of the Health Insurance Portability and Accountability Act, aka “HIPAA”, in maintaining the privacy of each insured’s protected health information, as such term is defined under HIPAA (“PHI”) and to provide such insured, at his/her request, with notice of our assumed duties and privacy practices with respect to PHI. PHI is information that may identify an individual and that relates to such individual’s past, present or future physical or mental health or condition, the provision of health care products and services to such individual or payment for such services. Whenever possible, we will use an insured’s PHI to create de-identified data, which is stripped of any identifiable data and no longer identifies such insured.  This Notice describes how we may use and disclose PHI about our insureds, as well as how our insureds can obtain access to such PHI. This Notice also describes our insureds’ rights with respect to their PHI. 

 

We will use our insureds’ PHI for the following limited purposes:

• Treatment. We may use an insured’s PHI to analyze potential investment opportunities associated with such party’s life insurance policy(s).
• Technology / Operations. We may use PHI to improve our systems, technologies and analytic tools, for our customer service activities, quality improvement, performance evaluation, and other internal business management purposes. 

• Business Associate Subcontractors. We may contract with third parties to perform certain services for us, such as billing services, copy services or consulting services. These Third Party Service Providers, referred to as Business Associate Subcontractors, may need to access to such PHI to perform services for us and in such case we will use our best efforts to ensure they are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us. 
• To Communicate with individuals involved in their care. We may disclose to a family member, other relative, close personal friend, or any other person identified by an insured, PHI directly relevant to that person’s involvement in the insured’s care. If a person has the authority by law to make health care decisions for an insured, we will generally regard that person as the insured’s “personal representative” and treat him or her the same way we would treat the insured with respect to the insured’s PHI. 
• Law Enforcement. We may disclose an insured’s PHI for law enforcement purposes as required or permitted by law for example, in response to a subpoena or court order, in response to a request from law enforcement, and to report limited information in certain circumstances. 
• As Required by Law. We will disclose an insured’s PHI when required to do so by federal, state or local law. 
• Health Oversight Activities. We may disclose an insured’s PHI to an oversight agency for activities authorized by law. These oversight activities include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs and compliance with civil rights laws. 
• Judicial and Administrative Proceedings. If an insured is involved in a lawsuit or a dispute, we may disclose his/her PHI in response to a court or administrative order. We may also disclose the insured’s PHI in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to first tell the insured about the request or to obtain an order protecting the information requested. 

 

If you’re an insured and you’ve provided us with your PHI, then your Health Information Rights consist of:

• Obtain a paper copy of the Notice upon request. You may request a copy of our current Notice at any time. Even if you have agreed to receive the Notice electronically, you are still entitled to a paper copy. You may obtain a paper copy at the site where you obtain health care services from us or by contacting [email protected]. 
• Inspect and obtain a copy of PHI. With a few exceptions, you have the right to access and obtain a copy of the PHI that we maintain about you. If we maintain an electronic health record containing your PHI, you have the right to request to obtain the PHI in an electronic format. To inspect or obtain a copy of your PHI, you must send a written request to [email protected]. You may ask us to send a copy of your PHI to other individuals or entities that you designate. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to your PHI, you may request that the denial be reviewed. 
• Request an amendment of PHI. If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to [email protected]. You must include a reason that supports your request. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it. 
• Receive an accounting of disclosures of PHI. With the exception of certain disclosures, you have a right to receive a list of the disclosures we have made of your PHI. To request an accounting, you must submit a request in writing to [email protected]. Your request must specify a time period. 
• Notification of a Breach. You have a right to be notified following a breach of your unsecured PHI, and we will notify you in accordance with applicable law. 

 

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to Personal Information.

Links to Other Sites

Our Site may contain links to other sites such as our affiliates as well as third parties which are not owned or controlled by us. Please be aware that this Privacy Policy only addresses our Company’s use and disclosure of your information collected on this Site.  While we try to link only to sites that share our standards and respect for privacy, we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the applicable privacy policies and terms of conditions of each and every website that collects Personal Information.

Co-branded Sites

We may be co-branded with “partners and affiliates” or part of a corporate group.  We may share information about customers and former customers with these co-branded / corporate group companies.  These business to business relationships are helpful to us and to you as they afford all concerned with greater product and service opportunities. We always provide opt-out opportunities regarding the sharing of your information with such partners and affiliates. Please note the sites linked to our Site are governed by their own privacy policies which may or may not reach the standards set by our company.

Minors

To use the Site, you must be over the age of sixteen (16). Therefore, we do not knowingly collect Personal Information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site. If we learn that we have collected personal information from a child under sixteen (16) years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at [email protected].

Access to Personal Information

We will make good faith efforts to provide you access to your Personal Information upon request.  If your Personal Information changes, or if you no longer desire our offerings, you may correct, update, delete or deactivate same by sending an email to the email address set forth in this Privacy Policy.

Legal Disclaimer

We reserve the right to disclose your Personal Information, as required, to comply with the law, applicable regulations, governmental and quasi-governmental requests, judicial proceedings, court orders or subpoenas, to enforce our Legal Notices or other agreements, or to protect our rights, property or safety or the rights, or to protect the property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.), and to ensure the security of our network and services.

Enhancement of Information

We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our database of individual customers, we tie this information to the Personal Information users have provided to us.

Business Transitions

In the event the Company goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You will be notified via e-mail and/or a prominent notice on our Site for 30 days of any such change in ownership or control of your Personal Information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We will not jeopardize your privacy. The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices with respect to the Site. We encourage you to check our Site frequently to see the current Privacy Policy to be informed of how we are committed to protecting your information and providing you with improved content on our website in order to enhance your online experience.  Upon any material changes to the Privacy Policy, we will post those changes to this Privacy Policy, to the homepage and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Disputes

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of New Jersey. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court situated in the State of New Jersey.  

Have any Questions?

 

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [email protected] and we will undertake to reply within a reasonable timeframe.  By contacting us, and accessing the Site, you warrant and agree that you are free to do so, and that you are not providing us with information which violates any third party intellectual or privacy rights.

COOKIE POLICY

We use certain monitoring and tracking technologies, including ones offered by third party service providers to collect and process the personal information we specified above. These technologies are used in order to maintain, provide and improve our Site on an ongoing basis, in order to provide a better experience to our users. For example, these technologies enable us to: (i) keep track of and apply our user’s preferences and authenticated sessions, (ii) better secure our offerings by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our offerings, and (iv) create and monitor analytics relating to our offerings.  Based on the foregoing, we’ve adopted this policy (“Cookie Policy“) to explain how we use cookies and your related choices and options. In this policy we use the term “cookies” to refer to any applicable tracking technologies described herein. 

1. WHAT ARE COOKIES 
   • Cookies are a small text file that is stored on your device to help websites and mobile apps remember things about you. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. To learn more about cookies, visit http://www.allaboutcookies.org/.

 

• Pixel Tags (also known as web beacons or clear GIFs) are transparent images, iFrames, or JavaScript placed on a website or in marketing emails that are used to understand how you interact with such websites or emails.

 

• Social Media Features, such as the Facebook “like” button, may collect your IP address and which page you are visiting on a website, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

  

• Single Sign-on allows you to log in to certain websites or mobile applications using sign-in services provided by third parties, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. 

 

1. HOW WE USE COOKIES

The cookies we may use can be classified in one of the following categories:

Strictly Necessary cookies	We may use these cookies to enable you to use our Site’s features, such as enabling movement between pages and remembering information you enter on forms.  Without these necessary cookies, services and functions on our Website will not be possible and our Website will not perform as it should.
Security cookies	We may use these cookies to help identity and prevent security risks.
Authentication cookies	We may use these cookies to help us show you the right information and settings when you are logged-in to our website.
Performance and Analytics cookies	We may use these cookies to collect information about Users’ use of our Site to help improve the way the Site works. An example is counting the number of different people coming to our website or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited the website once each week for three weeks we would count you as three separate users. We would find it difficult to analyze how well our website was performing and improve it without these cookies.
Functionality and Preference cookies	We may use these cookies to remember the choices you make such as which language you prefer and to provide you with personalized features.
Targeting and Advertising cookies	We may use these cookies to deliver you with ads when you browse the web that are more relevant to you and your interests, by remembering information such as what you looked at on our Site and to track the performance of these ads.
Social Sharing cookies	We may use these cookies to allow you to share content directly on the social network/sharing sites, like Facebook, Twitter or Google+ on which you have a user account. Examples would be if you wanted to “like” or “tweet” about a service or product advertised on our website

 

1. YOUR CHOICES
   • Strictly Necessary Cookies: Because these cookies are essential to operate our Site, there is no option to opt out of these cookies.  
   • Targeting and Advertising Cookies: 
   • You can opt out of interest-based targeting provided by participating ad servers through the Network Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at www.aboutads.info/

 

• You may be able to change your device settings (on your iPhone, iPad or Android) to control whether you see online interest-based ads 
• You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the applicable third-party service providers listed in the table below in their privacy policy.
• You can learn more about your options by visiting www.youradchoices.com or www.youradchoices.eu.
• Other Cookies:  
• You can follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools” or “Edit” facility) to modify your cookie settings.  
• You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the relevant third-party service providers listed in the table below, in its privacy policy:

Third party & Type of cookies	Service provided
Google Optimize – Analytics	This cookie allows us to test and evaluate the best ways to present our website to our users. https://policies.google.com/technologies/cookies
Google – Analytics	Google provides anonymized data about the visits made to our Site. https://policies.google.com/privacy?hl=en&gl=uk
Google – Social Sharing	Google store cookies which allow the “Google +”social sharing” functionality. https://policies.google.com/privacy?hl=en&gl=uk
Facebook – Social Sharing	Facebook store cookies which allow the Facebook “Like” social sharing functionality but only if you click on the Facebook “Like” button on our Site or log in using your Facebook account. https://www.facebook.com/about/privacy/
CRITEO – Targeting and Advertising cookies	These cookies collect data for the purpose of interest-based advertising. https://policies.google.com/privacy?hl=en&gl=uk” https://policies.google.com/privacy?hl=en&gl=uk
Impact – Analytics	Impact provides anonymized data about the visits made to our Site. https://impact.com/privacy-policy/
Google Adwords – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://policies.google.com/privacy?hl=en&gl=uk” https://policies.google.com/privacy?hl=en&gl=uk
Google Double Click – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://policies.google.com/privacy?hl=en&gl=uk
Facebook – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://www.facebook.com/about/privacy/
OATH – Yahoo – Gemini – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://gemini.com/privacy-policy/
Microsoft – Bing – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://advertise.bingads.microsoft.com/en-us/resources/policies/microsoft-bing-ads-privacy-policy
TCA – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
TV Squared – Analytics	This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive. https://tvsquared.com/privacy-policy/

 

 

• DELETING ALL WEB BROWSER COOKIES

 

All of the Web browser cookies we use are stored on users’ browser local memory. Therefore, by deleting such cookies from your local memory, we will not be able to associate any information we have about you, unless you login to our Site as a registered user.

1. DO NOT TRACK

We do not currently commit to responding to your browsers’ ‘Do Not Track’ signals with respect to our Site, in part, because no common industry standard for ‘Do Not Track’ has been adopted by regulators, including no consistent standard of interpreting a user’s intent. We are committed to monitoring the developments around ‘Do Not Track’ and the implementation of a standard.

1. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto. If we make any changes to this Cookie Policy that significantly impact the way we use cookies, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website. Your continued use of our Site constitutes your agreement to this Cookie Policy and any updates.

1. CONTACT US

If you have any questions about our use of cookies, please contact us at [email protected].