Privacy Policy

Last Updated: December 30, 2019

Introduction

FamilyAssets Group LLC, (the “Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the type of information we may collect from you or that you may provide when you visit the website www.familyassets.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information we collect:

  • on our Website;
  • directly from you through your use of our Website, the Company Services or the Planner Services (as defined in the Terms of Use);
  • in email, text, mail, or other electronic messages between you and our Website or through your direct communication with our employees;
  • on behalf of or from the Planner for use in or monitoring of the Engagement (as defined in the Terms of Use);

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our Website or on or through any of its features, register on our Website, use any of the interactive or public comment features of our Website or provide any information about yourself to the Company, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at advisors@familyassets.com.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Website and Clients (as defined in the Terms of Use), including information:

  • by which you may be personally identified, such as name, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline (“Personal Information”);
  • that is about you but individually does not identify you such as bank account information, benefits you receive, income, assets, information about your home; or
  • about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through our Website (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies);
  • from third parties, for example, the Planner.

Information You Provide to Us

The information we collect on our through our Website may include:

  • information that you provide: by filling in forms on our Website, at the time of registering to use our Website, to the Company or the Planner for the purpose of receiving services, while posting material, by uploading documents, or while requesting further services;
  • records and copies of your correspondence (including email addresses and phone numbers);
  • details of transactions you carry out through our Website including payment information; or
  • your search queries on our Website.

You also may provide information to be published or displayed on public areas of our Website, or transmitted to other users of our Website or third parties (collectively, "User Content"). User Content is posted on and transmitted to others at your own risk. Please be aware that we cannot control the actions of other users of our Website with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
  • information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact us at advisors@familyassets.com if you would like to opt out of behavioral tracking on this website and learn how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize our Website according to your individual interests;
  • speed up your searches;
  • recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • to present our Website and its contents to you;
  • to provide you with information, products, or services that you request from us;
  • to fulfill any other purpose for which you provide it;
  • to provide you with notices about your account;
  • to carry out our obligations and enforce our rights arising from the Terms of Use, including for billing and collection;
  • to notify you about changes to our Website or any services we offer or provide though it;
  • to allow you to participate in interactive features on our Website;
  • in any other way we may describe when you provide the information; or
  • for any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • to any of our subsidiaries and affiliates;
  • to employees, contractors, service providers, and other third parties including a Planner, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred;
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; or
  • with your consent.

We may also disclose your personal information:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms of Use and any other agreements, including for billing and collection purposes;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at advisors@familyassets.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from our Website, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on our Website, including User Content, is governed by our Terms of Use.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to advisors@familyassets.com.



Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The Company safeguards the security of the information you provide to us with physical, electronic, and managerial procedures. In certain areas of our Website, we use industry-standard SSL-encryption to enhance the security of data transmissions. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal information when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Special Notification for California Residents — Your California Privacy Rights

Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around Familyassets Group LLC’s collection, use, and sharing of their personal information.

Familyassets Group LLC collects various categories of personal information when you use our Website, including identifiers, commercial information, internet or other electronic network or device activity information, and geolocation data. A more detailed description of the information Familyassets Group LLC collects and how we use it is provided above in Information We Collect and Receive About You and How We Use Information. Furthermore, the section How We Disclose Information describes the categories of third parties with whom we may share personal information, and what information may be shared under different circumstances.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow Familyassets Group LLC to retain and use certain personal information notwithstanding your deletion request. You may send your request for access to that information or request deletion by email to advisors@familyassets.com. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes.

Such requests must be submitted to us at advisors@familyassets.com or in writing at:

Familyassets Group LLC

ATTN: Legal Department

353 Third Ave #382

New York, NY 10010

California privacy rights requests must include the reference “Request for California Privacy Information” on the subject line and in the body of the message and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified above.

Information We Collect and Receive About You

We might receive or collect several types of information about you, such as the information described below.

Information You Provide

The following are situations in which you may provide Your Information to us:

  • When you fill out forms or fields through our Website;
  • When you sign up for any newsletters or other materials, or other products and services through our Website;
  • When you provide information to us through a third-party application, service or website;
  • When you communicate with us or request information about us or our Website, whether via email or other means;
  • When you participate in online surveys;
  • When you participate in forums or provide user generated content or submissions.

Information Third Parties Provide - We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), other users and our business partners.

General Use and Preference Information - We may collect, receive and store information regarding your general use of our Website (such as details of how and when you used our Website, interactions with our Website, log in information, resources that you access, your Internet protocol address, your browser type, and your device type), as well as your preferences.

Device Information - When you use our Website through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Website, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

Location Information - If you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device’s GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers), or obtain your location information from third parties.

Phone Numbers - We may collect your phone number in several ways. For example, we may collect your phone number: (i) if you submit your phone number to us through our Website; (ii) by capturing your phone number if you call us; or (iii) if a third party provides your phone number to us.

Non-Personally Identifiable Information - We may collect demographic information about you such as gender, zip code, and birth date, and information regarding your preferences and usage. This type of information is not, by itself, personally identifiable information. However, if we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as personally identifiable information for purposes of this Privacy Policy.

Log Files, Cookies and Anonymous Identifiers As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality, and to document your consent to receiving products, services or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as personally identifiable information for purposes of this Privacy Policy.

Technologies such as cookies, beacons, tags and scripts are used by us and our partners, affiliates, advertisers, analytics teams, or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Website, and compile other information regarding use of our Website. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use cookies to collect and store information. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We use Local Storage Objects (LSOs) such as HTML5 Storage to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML5 Storage to collect and store information.

Network Advertising From time to time, we may participate in, partner with, or use advertising networks, such as third-party advertising servers, advertising agencies, technology vendors and research firms. For example, we use Google AdSense to publish ads on our Website. When you view or click on an ad, a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. In addition, we may use third-party advertising networks to serve advertisements to you on our Web site, or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. This practice is often referred to as “online behavioral advertising.” Please see the “Online Behavioral Advertising” subsection of Choices About How We Use and Collect Your Information below to read about how you can prevent certain third-party advertising networks from collecting information about you.

How We Use Information

We may make Use of Your Information for various lawful business purposes. Among others, these purposes may include using Your Information to:

Engage in customer support. For example, we might confirm and complete transactions requested by you, verify information you provide to us and provide you with administrative notices.

Contact you and provide you with information. For example, we or our partners might provide or contact you through telephone, email, postal or other communications with Website updates, promotional materials, surveys, offers, quotes, personalized information and other information from us or our business partners.

Analyze, improve and manage our Website and operations. For example, we might obtain feedback regarding our WEbsite, understand and anticipate your needs and preferences, better understand your use of our Website, customize and tailor Website content and advertising, improve our marketing and promotional efforts, engage in statistical analysis and provide feedback to our vendors, advert

Resolve problems and disputes, and engage in other legal and security matters. For example, we may use Your Information to comply with, monitor compliance with and enforce this Privacy Policy, our Terms of Use and any other applicable agreements and policies, meet other legal and regulatory requirements, and to protect the security and integrity of our Website and your information.

How We Disclose Information

General Disclosure of Your Information We will share your personally identifiable information with third parties only in the ways that are described in this privacy policy.

We may disclose Your Information:

  • To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
  • To our third-party vendors so that they may provide support for our internal and business operations, including for the handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Website's maintenance and security. These companies are authorized to Use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;
  • To third parties when you use our Website to obtain a quote, services, or information from one or more of those third parties (e.g. a senior living community in connection with your completion of an information request form, or a third party senior living referral service.) (“Service Providers”), such as by clicking “Find Cost Information” or other similar buttons at the end of a form, and we may be compensated in connection with such disclosure;
  • To third parties when you engage in certain activities through our Website that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party. When we disclose Your Information to these third parties, we may be compensated, and Your Information will become subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of Your Information;
  • To third parties that are interested in contacting you or providing offers to you that may be related to our Website or about products or services you may find of interest, and we may be compensated for such disclosure;
  • As required by law or ordered by a court, regulatory, or administrative agency;
  • As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
  • If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
  • To enforce our Terms of Use, this Privacy Policy, and any other applicable agreements and policies;
  • To enforce or protect our rights;
  • In connection with a Business Transfer, as defined below (see Business Transfers below); and

If you do not want Your Information shared as described above, then you should not provide us with Your Information.

Requests for Quotes, Information and Services from Service Providers.

As noted above, we may share Your Information with Service Providers when you use our Website to obtain or request a quote, services or information from one or more third parties (an “Inquiry”). The Service Providers we may share Your Information with may be determined subsequent to your Inquiry (e.g. after you talk to a family advisor or by an automated matching algorithm). IF YOU SUBMIT AN INQUIRY, SERVICE PROVIDERS MAY CONTACT YOU DIRECTLY VIA MAIL, TELEPHONE, TEXT MESSAGE, FAX, EMAIL AND OTHER MEANS OF COMMUNICATION. IN ORDER TO ASSIST YOU IN FINDING SENIOR CARE, YOU MAY RECEIVE CALLS FROM OUR LEAD PARTNERS OR SERVICE PROVIDERS AS A CONSEQUENCE OF SUBMITTING AN INQUIRY THROUGH OUR SERVICES, EVEN IF YOU ARE ON THE NATIONAL DO NOT CALL REGISTRY OR ANY OTHER DO NOT CALL REGISTRY. THE FCC MAY VIEW THESE CALLS AS TELEMARKETING CALLS.

If you are matched with Service Providers, you expressly consent to the Service Providers conducting any research necessary to provide you with information related to your Inquiry. Service Providers may need to share Your Information to conduct such research. If you do not want Service Providers to conduct necessary research to provide you with information for your Inquiry, then you should not submit an Inquiry.

Please note that if you submit an Inquiry through our Website and we share Your Information as described above in connection with your Inquiry, you will not have the opportunity to opt out of the disclosure of Your Information in connection with that Request.

Aggregation and De-Personalization - We may take Your Information and de-identify it either by combining it with information about other individuals (aggregating Your Information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-identifying Your Information). We reserve the right to share, loan, rent, sell, or otherwise disclose such information to third parties at any time, for any lawful purpose, without notice or compensation to you.

Circumvention of Security Measures - No method of transmission or method of electronic storage, is 100% secure, and we cannot guarantee absolute security. Additionally, by way of example (without limiting the foregoing), we may be forced to disclose Your Information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. Therefore, notwithstanding anything to the contrary within this Privacy Policy, our Terms of Use or any other applicable agreement or policy, you use our Website at your own risk and we do not promise or guarantee, and you should not expect, that Your Information will always remain private. In the event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate Your information.

Business Transfers - We specifically and expressly reserve the right to disclose, lease, sell, assign or transfer Your Information collected through our Website, and any of our databases, together with any personally identifiable information contained in such databases, to third parties in connection with a Business Transfer. A “Business Transfer” means a share or asset sale, acquisition, merger, consolidation, reorganization, spin-off, bankruptcy or other corporate change involving us and/or our affiliates, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part or a whole of our business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, and/or assets (including our Website) to an affiliate or independent third party at any time, for any lawful purpose, without compensation to you.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personally identifiable information you provide to us. Below are some mechanisms that provide you with control over certain information:

Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Website may then be inaccessible or may not function properly.

Email Offers from Us. If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (other than emails related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions through our Website) by using the unsubscribe process at the bottom of the email.

Log Files. Various browsers may offer their own management tools for removing HTML5 Storage LSOs.

Online Behavioral Advertising. If you wish to not have third party advertisers collect your information for the purpose of serving you interest-based ads, you may opt-out by clicking here. In addition, certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by clicking here and following the NAI’s directions. You may also opt-out of Google Adsense’s use of its cookie by visiting Google’s Advertising and Privacy page. Please note that these opt-outs do not opt you out of being served ads. You will continue to receive generic ads.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on our Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: advisors@familyassets.com.