Privacy Policy

Effective Date: February 1, 2024

PRIVACY POLICY FOR RELIANT LIFE SHARES, LLC RECEIVERSHIP

This Privacy Policy (the “Policy”) explains how the Court-Appointed Receiver for Reliant Life Shares, LLC (the “Receivership” or the “Receivership Team”) handles personal information that is collected through the Receivership website located at www.reliantreceivership.com (the “Website”) and any services offered via the Website (the “Services”).

Please review this Policy carefully. By using the Receivership Website or any Services offered through the Website, you agree to the personal information practices explained below, which may be updated or modified from time to time without prior notice.   You can determine when this Policy was last revised by referring to the date it was “Last Updated” above.  Amendments to this Policy are effective immediately when posted on this Website.  If you do not agree with these practices, please do not use the Website or Services or otherwise provide the Receivership Team with your personal information.  Your continued use of the Website after posting of amendments will be deemed your acceptance of the changes to this Policy.  If you have a disability, you may access this Privacy Policy in an alternative format by contacting receiver@reliantilfeshares.com.

Information Collected by the Receivership Team

The Receivership Team collects certain personal information when you register or create an account through the Website or when you use Services.   The Receivership Team will only use personal information as directed by the courts or to accomplish the purposes for which such information was provided to them. The Receivership Team may also use personal information to investigate or prevent illegal activities such as suspected fraud, and to comply with applicable laws, regulations, and court orders.

Information you provide to us directly:  The Receivership Team collects information you voluntarily provide to us. For example, we collect personal identifiers such as your name and email address from you when you register at the Website or when you create an account, so that you can log in to access your account. We may collect your phone number, email address, billing address, home/physical address, age, date of birth and credit card information (we retain only the last 4 digits, as your full credit card information is processed by a third party), so that we can manage and administer the Reliant Receivership and comply with various court orders and directives.  The Receivership Team may also collect information you provide for technical or customer service requests including via email, text and phone. If you participate in user testing, we collect recordings of your user testing session.

Information About Other People:  The Receivership Team may collect and store information about other people that you provide to us when you use the Website or Services, including without limitation email and mailing addresses of your attorney, sales agent, or IRA provider.  Any such information you store is personal information. We rely on you to obtain the permission of other people to allow us to collect their personal information. Please be mindful of your own privacy needs and those of others as you choose what to share and what to make public. We cannot control the privacy or security of personal information you choose to make public. We do not, however, “sell” or “share” this information for advertising purposes within the meaning of the CCPA and CPRA (see “California Privacy Rights”).

Use of Personal Information Collected by the Receivership Team

The Receivership Team retains personal information only so long as is necessary to accomplish the purposes for which it was provided subject to, as applicable, orders of the court, document retention requirements, and contractual requirements.  All personal information is disposed of or destroyed in a manner that prevents loss, theft, misuse, reconstitution, or unauthorized access to the information.

Disclosure of Personal Information by the Receivership Team

The Receivership Team may disclose personal information to certain trusted service providers who provide support services to the Receivership Team in connection with the administration of the Receivership. These service providers are restricted from using the personal information provided to them for any purpose not related to their engagement or as directed by the courts, and they are required to ensure the confidentiality of the personal information provided to them.

When required to do so, the Receivership Team may disclose personal information to regulatory or taxing authorities in connection with applicable income reporting requirements. Additionally, the Receivership Team may be required, in accordance with court orders or applicable law, to provide personal information to state or federal authorities, to the court in which a matter is pending, to the litigants in a proceeding, or to their counsel when it is necessary to complete the claims process.

The Receivership Team may also disclose personal information to consumers and their retained professionals, counsel, auditors, or other third parties to the extent it is required by a court or if the Receivership Team deems such disclosure reasonably necessary to accomplish the purposes of the Receivership or for which the Receivership Team acquired the personal information.

The Receivership Team reserves the right to disclose personal information it has acquired if it believes, in good faith, that such disclosure is required by law, regulation or legal process, or that such disclosure may be necessary to establish or protect the Receivership Team’s legal rights, property or safety, or the rights, property or safety of others.

Information Automatically Collected by the Receivership Team

The information described below includes the following categories of data within the meaning of the CCPA and CPRA (described under “California Privacy Rights”) that may be collected by the Receivership Team or the Website:   Identifiers; Other individual records; Demographics; Commercial information; Internet activity; Sensory visual data; Geolocation data; and Inferences.

The Receivership Team may collect information through automatic means when individuals access the Website or Services. Such information may include an individual’s device type, browser type, operating system, and Internet Protocol (IP) address. Additionally, the Receivership Team may collect information regarding website activity such as the pages an individual visits on a website, how long an individual remains on a page, whether an individual is a return visitor, and referring website details. The Receivership Team uses the information obtained to improve its website, to describe the use of the websites to appropriate stakeholders, and to prevent fraudulent claims or misuse of the website.

In order to collect such information, the Website may use browser cookies, which are small text files that a website transfers to an individual’s browser for record-keeping purposes. Without identifying individual visitors to the Website, the cookies enable the Receivership Team to analyze how its Website is used and to monitor its performance. You may block or disable cookies on your device at any time by indicating this in the preferences or options menus in your browser. You may also delete the cookies that are stored on your device. Please note, however, that blocking, disabling or deleting cookies may affect the availability and functionality of the Website or Services.

The Receivership Team may use third-party software to automatically collect the types of information discussed above. This software collects this information through the use of cookies and similar tracking technologies to measure and report on user interactions with the Receivership Team’s website. The Receivership Team utilizes the information provided by this software solely to analyze the traffic and usage of the Website.

Links to Other Websites

The Receivership Website may contain links to other websites that are beyond the Receivership Team’s control. This Privacy Policy does not apply to the security and privacy practices of other websites. The Receivership Team is not responsible for the privacy practices of those other websites and cannot guarantee the security of any personal information that may be collected from those websites.

Sale of Personal Information Collected by the Receivership Team

The Receivership Team has not, does not, and will not sell any of the personal information it collects from the Website or that is obtained in connection with any Services.

Children’s Privacy

The Receivership Team understands the importance of protecting children’s online privacy. The Receivership Team’s services are not directed to children under the age of 18 and, therefore, the Receivership Team does not knowingly collect personal information from children under the age of 18. If you are a parent or guardian of a child under 18 and believe we may have collected personal information about your child, please contact us as at receiver@reliantlifeshares.com.

Security

Protecting the security of personal information submitted through the Website or Services is very important.   The Receivership Team employs reasonable administrative, technical, and physical safeguards to protect all personal information we collect and to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. Nevertheless, data transmission over the internet is never 100% secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, the Receivership Team cannot warrant or guarantee the security of any personal information transmitted to us online.

Do Not Track Technology

Some web browsers have a “Do Not Track” preference that transmits a “Do Not Track” message to the websites you visit with information indicating that you do not want your online activity to be tracked.  At this time, the Receivership Team does not respond to browser “Do Not Track” signals.

Changes to Privacy Notice

The Receivership Team reserves the right to change this Privacy Policy at any time. When we make material changes to the Privacy Policy, the “Last Modified” date located on the top of the page will be updated. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access the Website. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

Your Choices

You may choose not to submit personal information to the Receivership Team or opt out of the Receivership Team’s use or disclosure of personal information in connection with our administration of the Receivership Estate and the handling of Reliant Receivership matters. Please be advised, however, that if you choose not to submit personal information or to opt out  of the Receivership Team’s use or disclosure of your personal information, you may not receive important communications about the Reliant Receivership, and you may be prohibited from participating in the administration of the Reliant Receivership Estate, as a result, be barred from receiving a maturity payment or other settlement benefit.

You may request modifications to your personal information by contacting us at receiver@reliantlifeshares.com. If you do not wish to receive e-mails from the Receivership Team in connection with the Receivership, you may unsubscribe by contacting the Receivership Team at receiver@reliantlifeshares.com.  Please provide your full name and contact information when you make your request to unsubscribe.

Disclaimer

Information contained herein and on the Website does not constitute legal advice, tax advice, or financial advice. The Receivership Team makes no representations about the privacy practices of any other parties.

Contact Us

If you have questions about this Privacy Policy, please email us at receiver@reliantlifeshares.com.

You may also write to us at:

Attention:  Christopher Conway

Receiver, Reliant Life Shares, LLC

2472 Jett Ferry Road, Suite 400-191

Atlanta, GA  30338

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide California residents with additional rights as described below. 

Disclosures of Your Personal Information

Notice of Collection:  The Receivership Team may collect the categories of personal information from or about consumers as described under “Personal Information Collected By Receivership Team” and “Information Automatically Collected By Receivership Team” and may disclose this information for a business or legal purpose. To learn more about the business or legal purposes for collecting this information, see “Use of Information Collected by Receivership Team” and “Disclosure of Information by Receivership Team.” 

YOUR RIGHTS UNDER THE CCPA AND CPRA

Access: You have the right to request certain information about our collection and use of your personal information over the past 12 months. In response, we will provide you with the following information, as requested by you:

  • The categories of personal information that we have collected about you;
  • The categories of sources from which that personal information was collected;
  • The business or commercial purpose for collecting or sharing your personal information;
  • The categories of third parties with whom we have shared your personal information;
  • The specific pieces of personal information that we have collected about you; and
  • If we have shared your personal information to any third parties for a business purpose over the past 12 months, the categories of personal information shared with each category of third party recipient.

Deletion: You have the right to request that we delete the personal information that we have collected about you. Under the CCPA and CPRA, this right is subject to certain exceptions: for example, we may need to retain your personal information as required by law or we may need to retain your data to provide you with Services or complete a transaction related to the Receivership or as directed by court order or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request. If we are not able to comply with your request for data deletion, we will let you know we are unable to comply and the reason why.

Correction: You have the right to request that we correct inaccurate personal information that we maintain about you. We will take into account the nature of the personal information and the purposes for which we process it. We may require documentation from you in order to process your request, including your name, email address, phone number, and request details.

Exercising Your Rights: To exercise the rights described above, you must send the Receivership Team a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not be able to honor requests that do not meet these criteria or if a court order prohibits us from doing so. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt, though this time period may be extended under the CCPA and CPRA if we need more time to complete your request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request using the following methods:

Attention:  Christopher Conway

Receiver, Reliant Life Shares, LLC

2472 Jett Ferry Road, Suite 400-191

Atlanta, GA  30338

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and you must provide The Receivership Team with a copy of this written permission from your Authorized Agent when they make a request on your behalf.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA and CPRA: We will not discriminate against you for exercising your rights under the CCPA and CPRA.  

Retention of Personal Information

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, for one year after your account becomes inactive, as needed to provide you Services you have requested, or to comply with applicable legal, tax or accounting requirements). This may also include situations where litigation is pending or ongoing and such information is subject to a legal hold.

When we have no further ongoing legitimate legal or business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Where we rely on your consent, you have the right to withdraw it at any time in the manner indicated when you consent. After you have requested that your account be closed, we will retain the personal information for one year upon which it will be deleted, unless required otherwise by legal process or regulatory authority. If you have questions about or need further information concerning the retention of your personal information, please email us at reliant@reliantlifeshares.com.

DEADLINE TO REMIT PAYMENT FOR ALL PAST DUE INVOICES

On March 8, 2024, the Receiver began issuing invoices for amounts due in arrears to all fractional interest position holders (a.k.a., investors) on a per policy (as in per series trust) basis. All invoices for all series trusts in which one or more fractional interest position holders had an amount due in arrears, including administrative fees, were issued on or before May 14, 2024.

As expressly stated on the invoices, payments were due not later than 30 days from the issue date of the invoice. As of July 4, 2024, those investors who have not yet paid their invoices for amounts due in arrears are at least a month past due.

All investors are hereby notified that all outstanding invoices must be paid in full by no later than 5:00 PM Pacific Daylight Time on July 31st, 2024. NO EXTENSIONS OR EXCEPTIONS WILL BE GRANTED.

Once this deadline passes, all outstanding and unpaid invoices will be canceled by the Receiver, and the benefit amounts associated with each such invoice will be permanently forfeited.

Those investors who wish to preserve their investments and any benefit amount associated with any fractional position for which they have an outstanding invoice MUST remit payment in full for such invoice no later than July 31, 2024 at 5:00 PM Pacific Time. NO ADDITIONAL WARNINGS OR TIME WILL BE GRANTED. IF YOU DO NOT PAY YOUR OUTSTANDING INVOICES, YOUR FRACTIONAL INTEREST POSITIONS AND ALL MONIES PREVIOUSLY TENDERED IN RELATION TO THEM WILL BE PERMANENTLY FORFEITED.

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