PRIVACY POLICY

1INTRODUCTION

EternaTrust Insurance Group LLC (“EternaTrust,” “we,” “our,” “us”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us when individuals (“you,” “users,” “customers,” “applicants”) visit our website, request a quote, submit an application, or otherwise interact with our services.

This Privacy Policy explains:

• What information we collect
• How we use it
• How we protect it
• Your rights and choices
• State-specific notices, including California and New York
• How to contact us regarding privacy

By using this website, you agree to the practices described in this Privacy Policy.

2WHO WE ARE

This Privacy Policy applies to:

EternaTrust Insurance Group LLC

and our state-specific operating entities:

• New York: ETI Services LLC
• California: EternaSure Insurance Services (CA License #6017223)

This includes all affiliated brands, platforms, and service tools used for marketing, quoting, underwriting, or policy issuance, including EternaSync.

3INFORMATION WE COLLECT

We may collect the following categories of personal information:

A. Personal Identifiers

• Full name
• Address
• Phone numbers
• Email address
• Date of birth
• Driver’s license or state ID (where required)

B. Financial Information (GLBA Protected)

• Income
• Banking information (for premium payments)
• Credit history indicators (non-score)
• Payment authorization details

C. Health & Medical Information (HIPAA-Aligned)

We collect limited medical data needed to provide life insurance quotes, underwriting, or product recommendations, including:

• Medical conditions
• Prescription history
• Height/weight
• Tobacco use
• Family history
• Physician information
• MIB (Medical Information Bureau) data (via carriers)

Note: EternaTrust is not a HIPAA-covered entity, but we voluntarily follow HIPAA privacy & safeguard standards.

D. Application Data

• Beneficiary information
• Policy preferences
• Coverage amounts
• Underwriting questionnaire responses

E. Website & Technical Data

• IP address
• Browser/device type
• Pages visited
• Cookies & tracking data
• Geolocation (approximate)
• Session recordings (if enabled)

F. Communications Data

• Call recordings
• Chat transcripts
• SMS opt-in data
• Email correspondence

4HOW WE USE YOUR INFORMATION

We use information to:

• Provide insurance quotes
• Submit applications to TruStage Insurance Company
• Determine eligibility
• Facilitate underwriting
• Verify identity
• Detect and prevent fraud
• Provide customer support
• Communicate via phone, text, email (with consent)
• Improve website functionality
• Comply with legal obligations

We do not use or sell personal information for unrelated marketing purposes.

5HOW WE SHARE INFORMATION

• ✔ Insurance carriers

Primarily with Insurance Carriers for underwriting and policy issuance.

• ✔ Service providers

• Identity verification partners
• Data processors
• Call center or retention services
• Cloud hosting providers
• Email & SMS delivery systems

All third parties are required to:

• Protect your information
• Use it only for authorized purposes
• Maintain confidentiality

• ✔ Legal, Regulatory, or Compliance Authorities

We may share information when required by:

• State Departments of Insurance
• NY DFS
• California DOI
• Law enforcement
• Court orders

• ✔ Your Agent or Downline/Upline (as applicable)

To facilitate servicing and policy management.

• ❌ We do NOT sell personal information.

Required by CCPA/CPRA: We also do not “share” personal info for cross-context advertising.

6HOW WE PROTECT YOUR DATA (Security Practices)

We follow:

• GLBA Safeguards Rule
• NY SHIELD Act requirements
• HIPAA-style administrative, physical, and technical protections

Security measures include, but are not limited to:

• Encrypted data transmission (SSL/TLS)
• Firewall and DDoS protection
• User authentication controls
• Limited employee access
• Encrypted databases
• Secure backup protocols
• Regular security audits
• Vendor security assessments

No system is completely foolproof, but we take reasonable measures to ensure confidentiality, integrity, and security.

7YOUR PRIVACY RIGHTS

Depending on your state, you may have rights including:

• ✔ Access your information
• ✔ Correct inaccurate data
• ✔ Request deletion (with exceptions)
• ✔ Opt out of certain disclosures
• ✔ Limit use of sensitive information (California)
• ✔ Request a copy of data collected
• ✔ File a complaint with your state regulator

California (CCPA/CPRA) Rights

• A list of personal data collected
• Deletion of personal information
• Opt-out of sale (we do not sell)
• Correction of inaccurate data

New York (SHIELD Act) Rights

• Explanation of data safeguards
• Breach notifications
• Access to stored personal information

8DATA RETENTION

We retain personal information only as long as necessary to:

• Complete underwriting
• Maintain active policies
• Comply with state and federal regulations
• Resolve disputes
• Prevent fraud

Insurance laws often require retention of applications for 7+ years.

9COOKIES & TRACKING TECHNOLOGIES

We use:

• Essential website cookies
• Analytics (Google Analytics, if enabled)
• Session tools
• Advertising pixels (Meta, Google, etc., if used)

Users can manage cookie preferences through browser settings.

10CHILDREN’S PRIVACY

We do not knowingly collect information from children under 13.

A parent may request deletion if data was collected unintentionally.

11COMMUNICATION CONSENT (TCPA)

By submitting your information:

• You consent to receive calls, emails, and text messages
• Communications may be autodialed
• You may opt out anytime by replying STOP
• Consent is not a condition of purchase

A full TCPA disclosure is provided separately.

12STATE-SPECIFIC DISCLOSURES

California

Operations under: EternaSure Insurance Services (CA License #6017223)

California residents may exercise privacy rights via:

• Email: click here

New York

Operations under: ETI Services LLC

NY SHIELD Act requires us to maintain:

• Administrative safeguards
• Technical safeguards
• Physical safeguards

13CHANGES TO THIS POLICY

We may update this Privacy Policy occasionally.

Updates will be posted with a revised effective date.

14CONTACT US

For privacy concerns, requests, or questions, contact:

EternaTrust Insurance Group LLC

Compliance Department: click here