Privacy & Confidentiality Notice
We at Welcome Life Securities LLC (below as "WLS" and "we") thank you again for taking the time to evaluate the sale of your existing variable life insurance policy. WLS's Management Team recognizes the tremendous importance of protecting your privacy and will do so in accordance with Regulation S-P of FINRA. Therefore, we have implemented policies to maintain the complete confidentiality and security of all personal information throughout the entire process. Please find our policy below which will help you understand what information we collect and how we use such information to service your account, to evaluate your circumstances and to facilitate your transaction.
Confidentiality and Security
We only allow access to nonpublic, personal information about you to those employees and agents who need to know such information to provide the necessary products or services to you. We maintain physical, electronic, and procedural safeguards to protect your nonpublic, personal information. Confidential files are only accessible by authorized firm personnel. All desktop computers are password protected. Firm mail will only be handled by persons registered by WLS. There are no deposits of customer funds or withdrawals made by WLS.
Information that WLS Discloses and to Whom
We do not disclose any nonpublic, personal information about you or former customers to anyone, except as permitted by law and unless required to effectuate the applicable life settlement transaction. WLS adheres to strict criteria in order to protect the identity of the insured from the investors who purchase and/or attempt to purchase your policy. WLS works exclusively with providers &/or institutional investors that hold the same standards as WLS. Prior to the formation of a business relationship with WLS, clients, providers, institutional investors and advisors are required to provide formal consent to protect the identity of the insured and to adhere to the Health Insurance Portability and Accountability Act (HIPAA) which sets National Standards to protect the privacy of personal health information. Upon completion of the required privacy consents, WLS may share nonpublic, personal information with affiliated companies, including providers and agents in which the individual has authorized pursuant to a signed consent, for purposes of underwriting, solicitation &/or negotiation of offers in order to complete the applicable transaction.
We collect nonpublic, personal information about you from the following sources:
- Evaluation requests or other forms;
- Your transactions with us, our affiliates or others;
- Consumer-reporting agencies; and
- As a result of the Signed Authorizations contained herein, including but not limited to medical records/reports from your physicians.
Secure Removal of Trash
WLS will discard all sensitive materials into secured trash recepticles to be shredded, unless required by law to store, where full confidentiality shall be maintained (see "Disposal of Consumer Report Information and Medical Information" below). WLS will utilize a "confetti" shredder to destroy all proprietary and confidential documents. Such documents will include:
- All client information (including potential clients).
- Consumer marketing research and information, non-public business results and financial information and trade secrets.
- Work of authorship including but not limited to, agreements, engagements and memorandums.
- Third party information supplied to WLS for certain specifics, confidential information and trade secrets.
Once the information has been shredded in accordance with firm policy, it will be discarded.
Sharing of Information for Marketing Purposes
WLS does not share information obtained in the course of its securities business for the purposes of marketing and does not participate in any private label credit card programs.
Disposal of Consumer Report Information and Medical Information
WLS does not utilize information obtained from Consumer Reporting Agencies. Following the close of all life settlements, or if the life settlement process is cancelled, WLS will transfer all confidential information, including medical files of clients, to a secured location where they will be archived for a specified period, as required by state insurance regulations. The Designated Principal (DP) shall be responsible for maintaining an indexed list of archived files and reconciling this list against the state requirements specific to each individual client.
Customer Information Safeguard for New Technologies
All desktop computers are equipped with virus protection software. No orders or client information shall be transmitted remotely for the purposes of conducting WLS's security business. Should a registered person of WLS choose to access the servers remotely, doing so will require the user to go through a layer of password protected firewalls. Due to the nature of WLS's operations, customers will not use the website for the purposes of transacting business.
If you prefer that we not disclose nonpublic, personal information about you to your referring representative/advisor, if any, you may opt out of such disclosure - that is, you may direct us to not disclose such information (other than those permitted by law). If you wish to opt out of disclosures to your referring personal representative/advisor, if any, then you must provide written notice to WLS to 6001 Broken Sound Parkway - Suite 320, Boca Raton, FL 33487 or by sending an email to: privacy@WelcomeLifeSecurities.com. Your written request should include your name, address, telephone number to which the opt-out applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party. Please note that by electing to opt out, WLS may not be able to open an account or maintain a relationship with you.