Privacy Notice for California Residents

Abacus Life, Inc. and its subsidiaries Abacus Settlements, LLC, Longevity Market Assets, LLC and ABL Technologies, LLC (“Abacus,” “our,” “us” or “we”) works with consumers, investment advisors, insurance companies, pension plans,  financial institutions, government entities, benefit plan sponsors, and other clients to help locate people who may be eligible for benefits. We also help with our clients’ other legitimate business purposes, such as preventing fraud or avoiding overpayment of benefits to deceased individuals.

Where personal information is provided to Abacus by those organizations and ABACUS is a service provider or contractor to such organizations. As the business and controller of personal information related to you, your pension plan, insurance company, or other business is the proper entity to address any questions or requests related to your personal information.

1. About This Privacy Notice

This Privacy Notice for California Residents (the “Privacy Notice”) supplements the information contained in ABACUS’s [] and applies solely to personal information for individuals who reside in the State of California (“consumers” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 et seq.), as amended (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

This Privacy Notice does not apply to workforce-related personal information collected from ABACUS’s California-based employees, job applicants, contractors, or similar individuals.

2. Collection of Personal Information

ABACUS collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). In particular, in the last twelve (12) months, ABACUS has collected or processed for ABACUS’s business clients the categories of personal information from consumers indicated in the third column:

Category	Examples	Collected
A. Identifiers.	A 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.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A 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. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information regarding a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
I. Professional or employment-related information.	Current or past job history, performance evaluations, human resources file, union membership, or employer/affiliated company name.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	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.	No
K. Inferences drawn from other personal information.	Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Personal information does not include:

• Lawfully obtained, truthful information that is a matter of public concern.
• Publicly available information, which is lawfully made available from federal, state and local government records; that a business has reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”), clinical trial data, or other qualifying research data; or
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

ABACUS obtains the categories of personal information listed above from the following categories of sources:

• From third parties pursuant to a servicing, licensing or vendor contract.
• From government sources, such as state, local and federal government entities.
• From published obituaries and death notices.
• Directly from you, including phone, mail or internet forms, or in-person contact.
• Indirectly from your use of ABACUS’s websites or applications or your attendance at marketing-related events, such as conferences.
• From purchasing marketing lists from third parties.

3. Use of Personal Information

ABACUS may use or disclose the personal information we collect for one or more of the following business purposes (including on behalf of ABACUS’s business clients):

• To perform services pursuant to servicing contracts, including but not limited to determining life expectancies, transacting in life insurance policies, matching to death records, identifying maturities, facilitating payments that may be due to you, and confirming address and contact information for clients.
• To fulfill or meet the reason you or a third party provided the information.
• To offer customized content and individualized personalization of ABACUS’s services and websites to make them more relevant to your or a third party’s interests and needs.
• To notify you or a third party about changes or updates to ABACUS’s services and products.
• To provide you or a third party with information about ABACUS’s services as well as products, events and services of ours or our affiliates.
• To invite you or a third party to participate in surveys.
• To respond to your or a third party’s requests, inquiries, comments and concerns.
• To provide, evaluate and improve ABACUS’s services, websites, and applications and to develop new products, services and benefits.
• To identify usage trends and for data analysis, including for purposes of research, audit, reporting and license fees to third-party providers, such as data providers, or in other ways to which you or a third party acting on your behalf have expressly agreed in an agreement.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• To debug products to identify and repair errors that impair existing intended functionality.
• Short-term transient use, provided your personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual customer’s experience outside the current interaction, including, but not limited to, the contextual characterization of ads shown as part of the same interaction.
• To conduct internal research for technological development and demonstration.
• To perform activities to verify or maintain the quality or safety of a service or device that is owned or controlled by ABACUS, and to improve, upgrade, or enhance the service or device that is owned, or controlled by ABACUS.
• To provide technical, product and other support and to help keep ABACUS’s services, websites, and applications working, safe and secure.
• To perform services on behalf of ABACUS or our service providers, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of ABACUS or our service providers.
• To comply with our legal obligations, resolve disputes, and enforce our agreements.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about consumers is among the assets transferred.

We may match or combine personal information with information that we obtain from other sources or that is already in our records, whether collected online or offline, by predecessors or another company in our family of companies, for the purposes described above.

ABACUS will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice or updating this Privacy Notice.

4. Disclosing Personal Information

ABACUS may disclose your personal information to a third party for a business purpose. When ABACUS makes business purpose disclosures, we enter a written contract that describes the purpose and requires the recipient to both keep personal information confidential and not to use it for any purpose except as set forth in the contract. Per our contracts, we do not allow any personal information disclosures to be resold or shared.

We disclose your personal information with the following categories of third parties:

• Another company in our family of companies.
• Our service providers, suppliers, contractors, agents and representatives.
• Our clients pursuant to servicing or licensing agreements.
• An individual’s business entity sponsor, if the individual accesses ABACUS’s services, websites or applications under an entity’s agreement (for example, a company, corporation, nonprofit, partnership, bank or other business entity).

1. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, ABACUS has disclosed the following categories (which may include the sensitive information categories described above in Section 2) of personal information for a business purpose:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category C: Protected classification characteristics under California or federal law
• Category F: Internet or other similar network activity
• Category H: Sensory data
• Category I: Professional or employment-related information

We disclose your personal information for a business purpose to the following categories of third parties:

• Our corporate affiliates on a need to know basis and subject to an intercompany agreement.
• Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, and customer support, and to process the information for us based on our instructions and in compliance with this Privacy Notice and any other appropriate confidentiality and security measures.
• Our clients pursuant to servicing or licensing agreements.

5. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

1. Right to Know and Data Portability Rights

You have the right to request that ABACUS disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and verify your identity (see Section 5.C. Exercising Right to Know, Data Portability, and Right to Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list describing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

1. Right to Delete

You have the right to request that ABACUS delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and verify your identity (see Section 5.C. Exercising Right to Know, Data Portability, and Right to Delete), we will review your request to see if an exception allowing us to retain the information applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9. Right to Modify

Consumers may have the right to request correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.

1. Right to Limit

Consumers may have the right to request to limit our use of sensitive personal information unless our use of sensitive personal information falls into one of the limited business purposes. We do not generally collect or process sensitive personal information for the purpose of inferring characteristics about a consumer.

1. Exercising Your Privacy Rights

To exercise the right to know or delete described above, please submit a request to us by either:

• Calling us at 800-561-4148
• Visiting https://abacuslifesettlements.com/contact-us/

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request on behalf of your minor child.

You may only make a request to know twice within a twelve (12) month period. The request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

1. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please call 800-561-4148.  We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6. Non-Discrimination
   We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Changes to this Privacy Notice
   ABACUS reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on ABACUS’s website and will update the Privacy Notice’s effective date. Your continued use of ABACUS’s websites, applications, and services following the posting of changes constitutes your acceptance of such changes.
8. Data Retention
   Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means. We specify the retention periods for your personal information in our document retention policy.
9. Contact Information
   If you have any questions, comments or requests about this Privacy Notice, the ways in which ABACUS collects and uses your information described in this Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us at:

Phone: 800-561-4148

Website: https://abacuslifesettlements.com/contact-us/

Postal Address:
ABACUS LIFE, INC.
Attn: Chief Information Security Officer]
2101 Park Center Drive

Orlando, FL 32835

 

If you use assistive technology (such as a Braille reader, a screen reader, TTY, etc.) and the format of this Privacy Notice interferes with your ability to access this Privacy Notice, please contact ABACUS for assistance. Please indicate the nature of your accessibility problem, the preferred format you would like to receive this Privacy Notice, and your contact information so that we may respond in a manner most helpful to you.

Effective Date: 1/1/2024

Last Revision: 1/1/2024