CCPA Policy

Effective January 1, 2020, this notice applies to you and supplements our Privacy Policy if you are a resident of the State of California.  It is intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended.

MAGNA LIFE SETTLEMENTS MAY SELL SOME OF YOUR PERSONAL INFORMATION AS DEFINED IN THE CCPA.

This notice applies to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers (“Personal Information”).

Personal Information does not include publicly available information we obtain from government records or de-identified or aggregated consumer information.

IMPORTANT NOTE:  Under the CCPA, we may collect process, retain, and disclose Personal Information in order to:

Comply with federal, state and local laws, including state insurance and life settlement laws;
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
Cooperate with law enforcement agencies concerning investigations;
Exercise or defend legal claims; and
Use, sell, or disclose consumer information that is de-identified or aggregates consumer information.

Additionally, the CCPA exempts Personal Information about our clients, customers, participants, and consumers from most of the CCPA requirements if such information is regulated under one or more the following federal or state laws:

Gramm-Leach-Bliley Act and its implementing Regulations (GLBA);
California Financial Information Privacy Act;
Fair Credit Reporting Act;
Health Insurance Portability and Accountability Act (HIPAA);
California Confidentiality of Medical Information Act; and
Driver’s Privacy Protection Act of 1994.

INFORMATION WE COLLECT

The following describes the categories of Personal Information that we have collected from consumers within the last twelve (12) months, the categories of sources of such collection, the business purpose for which such Personal Information has been collected, and the categories of third parties to whom such information may have been disclosed:

Categories of Personal Information Collected Categories of Sources of Collection Business/Commercial Purpose for Collection Categories of Third Parties Receiving Personal Information
A) Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers You,
Third Party Source(s),
Our Website(s),
Publicly Available Information
Provide services to you;
Respond to questions;
Provide you with information about our services;
Enhance customer experience;
Detect security incidents and protect against fraud or illegal activity;
Conduct hiring and/or other human resources activities;
For research, analysis, and product development;
To evaluate or process a commercial transaction; andAs required by applicable law or government regulation
Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
B) Personal information categories listed in Cal. Civ. Code § 1798.80 such as  name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note, some personal information included in this category may overlap with other categories You,
Third Party Source(s),
Our Websites(s),
Publicly Available Information
Provide services to you;
Respond to questions;
Provide you with information about our services;
Enhance customer experience;
Detect security incidents and protect against fraud or illegal activity;
Conduct hiring and/or other human resources activities;
For research, analysis, and product development;
To evaluate or process a commercial transaction;As required by applicable law or government regulation.
Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
C) Protected classification characteristics under California or federal law such as age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, sex, gender identity, sexual orientation, medical conditions (including pregnancy or childbirth, physical or mental disability or related medical conditions), parental status, veteran or military status, genetic information (including familial genetic information) You,
Third Party Source(s),
Publicly Available Information
Provide services to you;
Enhance customer experience;
Conduct hiring and/or other human resources activities;
For research, analysis, and product development;
To evaluate or process a commercial transaction;As required by applicable law or government regulation
Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
D) Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies You,
Third Party Source(s)
Provide services to you;
Enhance customer experience;
Detect security incidents and protect against fraud or illegal activity;
For research, analysis, and product development;
To evaluate or process a commercial transaction;As required by applicable law or government regulation
Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
E) Biometric information We do not collect N/A N/A
F) Internet or other similar network activity such as browsing history, search history, information on interactions with an internet website, application, or advertisement You,
Third Party Source(s),
Our Website(s)
Provide services to you;
Enhance customer experience;Detect security incidents and protect against fraud or illegal activity
Our affiliates;
Service providers;Business partners to further a commercial or business transaction;
G) Geolocation data such as physical location or movements We do not collect N/A N/A
H) Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information You Provide services to you;

To evaluate or process a commercial transaction

Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
I) Professional or employment-related information such as current and prior employment, performance evaluations, and results of background checks You,
Third Party Source(s),
Publicly Available Information
Provide services to you;
Enhance customer experience;
Conduct hiring and/or other human resources activities;
For research, analysis, and product development;
To evaluate or process a commercial transaction;As required by applicable law or government
Our affiliates;
Service providers;
Business partners to further a commercial or business transaction
J) Non-public education information defined in 20 U.S.C. Section 1232g, 34 C.F.R. Part 99 such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records You Conduct hiring and/or other human resources activities Our affiliates
K) Inferences drawn from other personal information such as Information reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitude, intelligence, ability, aptitude, and any other inferences drawn from your personal information You,
Third Party Source(s)
Provide services to you;
Enhance customer experience;
Conduct hiring and/or other human resources activities;
For research, analysis, and product development
Our affiliates;
Service providers

Business Purposes for Collecting Personal Information Generally

Collecting and using Personal Information is necessary to our business as a life settlement provider in order to develop, enhance, and administer our products and services, transact business with you, respond to your requests, inquiries and concerns, inform and educate you about our company, and for advertising and marketing purposes. It also helps us to confirm your identity for certain transactions you request or that are initiated on your behalf, improve our website and, authenticate users, prevent and detect fraud and potential security issues, and fulfill our legal and regulatory obligations.

 

Disclosure of Personal Information Generally

Your Personal Information may have been disclosed to:
You, your authorized representatives, legal agents, and other persons acting on your behalf or to whom you ask, instruct, or authorize us to disclose your Personal Information;
Our contracted service providers who provide a service to or on behalf of Magna, including analytics service providers, account servicers, payment processors, and intermediaries;
Our auditors, consultants, accountants, attorneys and others providing professional advice to Magna and our affiliates;
Other financial institutions, insurers and reinsurers;
Financial intermediaries (your advisors, broker, or brokerage firm), aggregators, clearinghouses, clearing or settlement systems;
Group policy plan sponsors and their third-party administrators;
External custodians and business partners of Magna;
Applicable governmental, regulatory, supervisory, law enforcement, tax or similar authorities or industry bodies;
Any other person or entity Magna reasonably thinks customary, necessary or advisable for the business purposes disclosed in our Privacy Policy or to whom Magna is obliged by applicable law or regulation to make the disclosure;
Any other party required for Magna to process a transaction that you have requested, consented to, or acknowledged; and
Any other party where Magna has obtained your consent or authorization.

Business Purposes for Disclosure of Personal Information Generally

Your Personal Information may have been disclosed for the follow business purposes:
To advertise and market to you, and to consumers who are similar to you;
To perform services on our behalf, including providing customer service, processing or fulfilling orders, account maintenance, distributions, and transactions, processing payments, financing, and quality control;
For risk management purposes, identity verification, information security, fraud detection and prevention;
To prevent money laundering, terrorist financing, bribery, and corruption;
Undertaking internal research, operational efficiencies and improvements, product enhancements, and business development purposes;
In connection with legal proceedings, such as responding to a subpoena or court order;
To demonstrate compliance with our regulatory obligations, including insurance and life settlement laws;
For reinsurance or other insurance purposes;
To report tax information to relevant tax authorities;
In the event of any planned or actual company reorganization, merger, sale, or transfer, of our business; and
In the event of any planned or actual transaction involving the sale, assignment, or transfer of a life insurance policy related to you.

YOUR CCPA RIGHTS

Right to Opt Out

California residents have the right to opt out of the sale of their Personal Information. Magna may sell your personal contact information to another life settlement provider.

Right to Know

California residents have the right to request that we disclose certain information to them about our collection of their Personal Information.  Such information shall cover the 12-month period preceding our receipt of such request. Upon our receipt of your verified request, we will provide you with the following:

The categories of Personal Information we have collected about you;
The categories of sources from which we have collected your Personal Information;
Our business or commercial purpose(s) for collecting or sharing your Personal Information;
The categories of third parties with whom we have shared your Personal Information; and
The specific pieces of Personal Information we have collected about you.

Please note that even if your request is validated, we will not at any time disclose sensitive information such as a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, account password, or answers to security questions.

You have the right to request that we disclose certain information to you about our disclosures of your Personal Information to third parties. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

The categories of Personal Information we have collected from you; and
The categories of Personal Information that we disclosed about you for a business purpose.

Right to Delete

California residents have the right to request that we delete certain Personal Information we have collected from them.  We will use commercially reasonable efforts to honor verified requests in compliance with the CCPA.  However, in many cases, we cannot delete some or all of your Personal Information due to our regulatory obligations to retain certain information or when retention is required or permitted by other applicable laws, such as to comply with or complete transactions pursuant to insurance or life settlement laws and for fraud prevention and similar purposes. We will respond so that you understand what we will delete and what we cannot and the reason for any such retention.

How to Exercise Your CCPA Rights

We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you.

To submit a request to exercise any of your rights provided in this notice, please use our online form or submit your request by phone by calling us at 866-996-2475.

Please note that before we take action on your requests, we must be able to verify your identity and relationship to Magna.  Please provide sufficient information to assist us, including a transaction date, account or policy number, and state of residence.  Let us know if there is anything specific that you are requesting.

You may designate an authorized individual to make a request on your behalf. To do so, you must provide a valid Power of Attorney and a valid copy of the authorized individual’s government-issued identification.