Invescor, Ltd. - Privacy Policy

INVESCOR, LTD. PRIVACY POLICY
PROTECTING PRIVACY AND SECURITY STATEMENT OF POLICY It is the policy of Invescor, Ltd. ("the company") to safeguard both personal health information (PHI) and personal financial information (PFI) obtained as part of our business, in connection with life settlements.1 Although Invescor, Ltd. is not a covered entity for purposes of the Health Insurance Portability and Accountability Act of 1996 and the promulgated privacy regulations ("HIPAA"), the company does obtain, use, and disclose protected PHI in order to conduct business and thus has implemented this privacy policy to safeguard PHI and PFI with regard to life settlements. INVESCOR, LTD. VALUES PRIVACY The collection and use of PHI and PFI is fundamental to our ability to service our life insurance agents, life settlement agent/brokers and their clients. We collect and use PHI and PFI for such purposes as assisting with an underwriting request for life settlements. Additionally, PHI and PFI are needed for the administering of our services. Our relationship with our life settlement agents/brokers and their clients is our most important asset. We understand that you and your clients have entrusted us with your PHI and PFI and we are doing everything we can to maintain that trust. PROCEDURES - GENERAL BUSINESS PRACTICES 1. We do not sell personal information to anyone. 2. We do not disclose personal information to third parties, unless one of the following limited exceptions applies: We may disclose personal information such as account and transaction data to companies, including financial institutions, that contract with Invescor, Ltd. or its life settlement agents/brokers to transact life settlements or otherwise act in a custodial capacity. We have contracts with these companies that obligate them to use your personal information only for the purpose of executing the specific services we have requested. We may disclose nonpublic information about policy owners or insureds to the following types of third parties: Financial service providers, such as life settlements providers, financing entities, life insurers, securities broker-dealers, and their life insurance agents, life settlement agent/brokers, and registered representatives. We may disclose personal information to companies that help us process or service transactions (i.e. order medical records) or account(s). We have contracts with these companies that obligate them to use personal information only for the purpose of executing the specific services we have requested. We may disclose the following nonpublic personal information about policy owners or insureds: Information we receive on applications or other forms, such as name, address, social security number, assets, income, and beneficiaries Information about transactions with us, our affiliates or others, such as policy coverage, premiums, and payment history We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required by law or legal process, for example, to cooperate with regulators, court orders, or law enforcement authorities to resolve consumer disputes, and to perform credit/authentication checks. Outside of these exceptions, we will not share personal information with third parties unless specifically asked to do so. We may also disclose nonpublic personal information to nonaffiliated third parties as permitted by law. We do not disclose any nonpublic personal information about your customers to anyone, except as permitted by law. 3. We do collect personal information in the normal course of business in order to administer policies and/or accounts and to serve you better. Most of the information we collect is obtained directly from the agent/broker, doctors, medical facilities, or representatives for the processing of a life settlement. For all life settlements, we may collect information pertaining to an insured's health or other personal characteristics. The information we collect may include name, address, phone number, business address, business phone number, email address, Social Security number, date of birth, marital status, and financial information. If we need to verify information or need additional information, we may obtain information from third parties (e.g. consumer reporting agencies, employers, plan sponsors, third party administrators, and insurance companies). Personal information collected may vary depending upon the type of policy or service. We typically only collect medical information in connection with underwriting life settlements. 4. We protect the confidentiality and security of personal information. Companies we hire to provide support services are not allowed to use personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of personal information to the performance of the specific service we have requested. We restrict access to personal information to select employees and agents/brokers who have a need for such information for business purposes only. All such employees are trained and required to safeguard such information. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard nonpublic personal information. Safeguards It is the policy of the company that employees are required to use due care to safeguard PHI and PFI in conducting their employment responsibilities. This includes, but is not limited to taking precautions with hardcopy and electronic PHI and PFI. Employees are also required to use precaution when transmitting PHI and PFI. For example, faxes must be sent with a cover sheet containing the company's confidentiality statement. Documents containing PHI and PFI shall be properly disposed of when the documents no longer need to be retained pursuant to applicable federal and state laws. For example, paper documents containing PHI and PFI shall be shredded upon disposal or otherwise disposed of in a secure and confidential manner. All disks, tapes, CDs and other media that may contain electronic PHI and PFI shall be erased prior to reuse and destroyed or erased prior to disposal. 5. We continue to evaluate our efforts to protect personal information and make every effort to keep personal information accurate and up to date. If any inaccuracy in personal information is discovered, or needs to be changed, please contact us so that we may promptly update our records. 6. We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any personal information in a way that is inconsistent with this policy, we will give advance ¹Many states use the term "viatical settlements" and define it to include all settlements without regard to the individual's health. Invescor only brokers life settlements where the insured person does not have a terminal illness or chronic condition, and refers to these settlements as "life settlements". This Privacy Policy applies to all cases reviewed by Invescor.
Copyright 2006-2009 Invescor, Ltd.

INVESCOR, LTD. PRIVACY POLICY

PROTECTING PRIVACY AND SECURITY

STATEMENT OF POLICY

It is the policy of Invescor, Ltd. ("the company") to safeguard both personal health information (PHI) and personal financial information (PFI) obtained as part of our business, in connection with life settlements.1 Although Invescor, Ltd. is not a covered entity for purposes of the Health Insurance Portability and Accountability Act of 1996 and the promulgated privacy regulations ("HIPAA"), the company does obtain, use, and disclose protected PHI in order to conduct business and thus has implemented this privacy policy to safeguard PHI and PFI with regard to life settlements.

INVESCOR, LTD. VALUES PRIVACY

The collection and use of PHI and PFI is fundamental to our ability to service our life insurance agents, life settlement agent/brokers and their clients. We collect and use PHI and PFI for such purposes as assisting with an underwriting request for life settlements. Additionally, PHI and PFI are needed for the administering of our services.

Our relationship with our life settlement agents/brokers and their clients is our most important asset. We understand that you and your clients have entrusted us with your PHI and PFI and we are doing everything we can to maintain that trust.

PROCEDURES - GENERAL BUSINESS PRACTICES

1. We do not sell personal information to anyone.

2. We do not disclose personal information to third parties, unless one of the following limited exceptions applies:

We may disclose personal information such as account and transaction data to companies, including financial institutions, that contract with Invescor, Ltd. or its life settlement agents/brokers to transact life settlements or otherwise act in a custodial capacity. We have contracts with these companies that obligate them to use your personal information only for the purpose of executing the specific services we have requested.

We may disclose nonpublic information about policy owners or insureds to the following types of third parties:

Financial service providers, such as life settlements providers, financing entities, life insurers, securities broker-dealers, and their life insurance agents, life settlement agent/brokers, and registered representatives.

We may disclose personal information to companies that help us process or service transactions (i.e. order medical records) or account(s). We have contracts with these companies that obligate them to use personal information only for the purpose of executing the specific services we have requested.

We may disclose the following nonpublic personal information about policy owners or insureds:

Information we receive on applications or other forms, such as name, address, social security number, assets, income, and beneficiaries
Information about transactions with us, our affiliates or others, such as policy coverage, premiums, and payment history

We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required by law or legal process, for example, to cooperate with regulators, court orders, or law enforcement authorities to resolve consumer disputes, and to perform credit/authentication checks.

Outside of these exceptions, we will not share personal information with third parties unless specifically asked to do so.

We may also disclose nonpublic personal information to nonaffiliated third parties as permitted by law.

We do not disclose any nonpublic personal information about your customers to anyone, except as permitted by law.

3. We do collect personal information in the normal course of business in order to administer policies and/or accounts and to serve you better.

Most of the information we collect is obtained directly from the agent/broker, doctors, medical facilities, or representatives for the processing of a life settlement. For all life settlements, we may collect information pertaining to an insured's health or other personal characteristics.

The information we collect may include name, address, phone number, business address, business phone number, email address, Social Security number, date of birth, marital status, and financial information.

If we need to verify information or need additional information, we may obtain information from third parties (e.g. consumer reporting agencies, employers, plan sponsors, third party administrators, and insurance companies).

Personal information collected may vary depending upon the type of policy or service. We typically only collect medical information in connection with underwriting life settlements.

4. We protect the confidentiality and security of personal information.

Companies we hire to provide support services are not allowed to use personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of personal information to the performance of the specific service we have requested.

We restrict access to personal information to select employees and agents/brokers who have a need for such information for business purposes only. All such employees are trained and required to safeguard such information.

We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard nonpublic personal information.

Safeguards

It is the policy of the company that employees are required to use due care to safeguard PHI and PFI in conducting their employment responsibilities. This includes, but is not limited to taking precautions with hardcopy and electronic PHI and PFI.

Employees are also required to use precaution when transmitting PHI and PFI. For example, faxes must be sent with a cover sheet containing the company's confidentiality statement.

Documents containing PHI and PFI shall be properly disposed of when the documents no longer need to be retained pursuant to applicable federal and state laws. For example, paper documents containing PHI and PFI shall be shredded upon disposal or otherwise disposed of in a secure and confidential manner. All disks, tapes, CDs and other media that may contain electronic PHI and PFI shall be erased prior to reuse and destroyed or erased prior to disposal.

5. We continue to evaluate our efforts to protect personal information and make every effort to keep personal information accurate and up to date.

If any inaccuracy in personal information is discovered, or needs to be changed, please contact us so that we may promptly update our records.

6. We will provide notice of changes in our information sharing practices.

If, at any time in the future, it is necessary to disclose any personal information in a way that is inconsistent with this policy, we will give advance

¹Many states use the term "viatical settlements" and define it to include all settlements without regard to the individual's health. Invescor only brokers life settlements where the insured person does not have a terminal illness or chronic condition, and refers to these settlements as "life settlements". This Privacy Policy applies to all cases reviewed by Invescor.