Privacy Policy

PRIVACY POLICY

Version Date: August 12, 2015

THIS PRIVACY POLICY (“Policy”) of FIRST SEQUOIA CAPITAL, LLC, a Maryland limited liability company (such entity, along with its corporate parents, subsidiaries and legal affiliates, hereinafter called “We,” “Us” or “Our,” as applicable) applies to: (a) any application by You (“You” or “Your,” as applicable) for the Services (as defined below); (b) the Services; and (c) Our website, www.FirstSequoia.com (“Site”).

  1. Collection of Information. The Site enables You to complete an application (“Application”), if You are a qualified applicant as stated in Our Notice, for Us to evaluate whether and on what terms and conditions We will provide You an offer (“Offer”) to purchase certain rights You have to receive payments relating to lottery winnings (“Lottery Payments”). Due to the nature of the Site and the Services, we will collect Information from You when You submit an Application through the Site. As used herein, “Services” means the services provided by us, Our agents and/or marketing partners in accordance with the terms and conditions of the Site. As used herein, the term “Information” means non-public personally identifiable information. The Service is only available to United States residents in jurisdictions where Our Services are not prohibited by law.
  2. Types of Information Collected. If You complete an Application, You will be submitting to Us Information including, but not limited to, the following: Your name, street address, telephone number, email address, phone number, information about Your Lottery Payments, and Your current living expenses.
  3. Reasons for Collecting Information. We collect the Information for the following five (5) reasons: (i) to make an Offer to You or to evaluate or consummate the proposed terms of any Offer; (ii) to enforce, exercise or defend Our legal rights; (iii) in connection with a proposed or actual assignment, sale, merger, transfer, exchange or consolidation of Our company or any portion of Our business interests, rights or assets; (iv) to secure services from Our professional advisors; or (v) to permit Our marketing affiliates to contact You about other products and services offered by Us. The Information will not be used for any other purpose without Your prior consent. We will communicate with You in response to Your inquiries, to provide the services You request, and to manage Your account. We will communicate with You by email and/or telephone.

For testimonials, we will obtain Your consent prior to posting Your name along with Your testimonial. We are not responsible for the personally identifiable information You choose to submit through testimonials. Information You provide will be safeguarded according to industry standards for security and confidentiality. We recognize and appreciate the importance of responsible use of the Information You choose to provide. We take steps to require that Our vendors, consultants, suppliers, and contractors follow this Policy with respect to security and the collection, use, and exchange of Information. They are expected to abide by this Policy when conducting work for us and are prohibited from using Your Information for any other purpose.

  1. Limitations on Disclosure to Third Parties. We will not disclose, sell or provide Your Information to a third party, except as stated in this Policy, without Your consent. We will only disclose the Information if required to do so by law or in the good-faith belief that such action is necessary to: (i) conform to applicable law or comply with legal process served on us, (ii) protect and defend our rights or property, the Site or Our consumers, or (iii) under emergency circumstances, to protect the personal safety of Our affiliates, agents, consumers, or the public. We may disclose Your Information to non-affiliated third parties, agents and marketing partners, but solely for the reasons set forth in Section 3 above.
  2. Marketing Partners. If one of Our marketing partners sold You the Services for which You have subscribed, such marketing partner’s privacy policy will apply to the Information that You have given them, once we receive Your Information from the marketing partner, Our treatment of such information shall be governed by this Policy.
  3. Accuracy of Information. We do not vouch for, and bear no responsibility for, incomplete, inaccurate or out-of-date data about You (including, without limitation, any part of the Information) that may be supplied to us by You or any third-party source, including, without limitation, Our agents (including, without further limitation, third party service providers) or marketing partners.
  4. Data Security. We are committed to protecting Your personal information. Security measures are in place on the Site to protect against the loss, misuse, and alteration of the Information under Our control. We offer industry-standard security measures available through Your Web browser. When You are on this Web site, the sensitive information You provide such as any credit card data and/or other financial information is encrypted with secure socket layer (SSL) technology. E-mail, which is different from the encrypted sessions above, is not secure. Therefore, do not send sensitive information such as credit card, social security numbers or account numbers to us via an unsecured e-mail message.
  5. Automatic Collection of Data. When You visit the Site, the web server for the Site automatically recognizes Your domain name and IP address. An electronic record of the pages You access on the Site and the amount of time You spend on each page is captured in statistical form. We use these statistics for internal informative purposes only.
  6. Our Commitment to the Gramm-Leach-Bliley Act and other US and state privacy laws. We maintain policies and procedures to help ensure that Your Information is used appropriately and within the scope of applicable laws. Information is made available to others for fraud prevention and detection purposes and for authorized criminal or government investigations. This Information is made available to protect consumers and financial services companies; such disclosures are permitted by law.
  7. Third Party Offers. While You are visiting or using the Site, You may be presented with an opportunity to subscribe or be required to subscribe or purchase third-party services. If You click on one of the presented offers, You will be redirected to the web site of the third party, and any Information You provide in response to the offer will be collected and used by the third party. Such Information You provide to the third party and any dealings You have with the third party will be governed by the privacy and other policies of that third party.
  8. Children Visiting Our Site. The Site is directed at adults. We do not knowingly collect or use information from children. If You are under 18, You may use the Site only with the involvement and permission of a parent or guardian. We are committed to protecting the privacy and rights of children online. We believe children should be able to use the Internet in a safe, productive, and efficient manner and should be afforded the highest protection available with respect to their personal information. As such, We have made it policy to not collect any individually identifiable information from users whom We know to be under the age of 18.
  9. Other Web Sites. We are not responsible for the content or information practices employed by other web sites that are linked to or from the Site. In most cases, links to unrelated web sites are provided solely as pointers to information on topics that may be useful to the users of the Site. This Policy applies only to information collected on the Site.
  10. Opt Out; Other Notices: You can ask to view the Information about You held by Us and request corrections to such Information. Please note that under certain circumstances We may be prohibited by law from disclosing certain Information to You. At any time, You may withdraw Your consent to further collection, use or disclosure of Information by giving Us reasonable notice. Your withdrawal of consent will affect Our ability to provide You with the Services. We are committed to ensuring that the information We obtain and use about Our customers is accurate. You can help Us maintain accurate records by contacting Us as follows: U.S. Annuity Services, LLC, 5340 Spectrum Drive Suite K, Frederick, MD 21703 Phone: 888-720-1225, E-mail: info@firstsequoia.com.
  11. Miscellaneous. We reserve the right to amend this Policy from time to time by posting a revised version of this Policy on the Site, so please review it frequently. This Policy is effective as of the date set forth above and shall remain in effect until We amend, restate, supplement, modify or replace this Policy.

 

 

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