1. Who We Are
This privacy policy explains how Citizens Life Group ("Citizens Life Group," "CLG," "we," "us," or "our") handles personal information collected through https://www.citizenslifegroup.com (the "Site") and through the related forms, calls, emails, and text messages we use to deliver the services described on the Site (together, the "Services").
Citizens Life Group is based in Orlando, Florida. We help seniors understand the value of their existing life insurance policies on the secondary market and connect qualified policyholders with state-licensed brokerages that handle the actual life settlement transaction. We are not a life settlement provider, we do not buy policies, and we do not act as a fiduciary for the seller. Transactions are handled by licensed brokerages under each state's Viatical or Life Settlement Act.
Our Founding Principal, Jeff Hallman, is also Co-Founder and Managing Partner of Asset Life Settlements, a Florida-licensed viatical settlement brokerage. Citizens Life Group and Asset Life Settlements are affiliated, and the affiliation creates a financial interest in transactions that originate through this Site. We disclose this relationship throughout the Site, in this policy, and in writing before any transaction closes.
2. Information We Collect
2.1 Information you give us directly
When you fill out the free-estimate form, the contact form, or another tool on the Site, or when you call, email, or text us, we collect the information you choose to share. This typically includes:
- Identifiers: first and last name, postal address (if you provide one), email address, and phone number.
- Policy information: general policy type (whole life, universal life, term, or "not sure"), the death benefit (face value) range, and similar non-detailed facts about a life insurance policy you own.
- Information about the insured person: general age range and a general health rating (excellent, good, fair, or poor) that you self-attest. We do not collect detailed medical records, diagnoses, or treatment information through the Site.
- Free-text information: anything you type into a "How can we help?" message, an email, or a text.
- Call recordings and notes, where applicable: if you call us, we may record the call for quality and training, and we keep notes of our conversation. We will tell you at the start of any recorded call.
2.2 A note about health-related information
Citizens Life Group is not a HIPAA-covered entity, and the general health rating we collect on the Site is self-attested rather than drawn from a medical record. State life settlement laws nevertheless treat any health information collected in connection with a possible life settlement as confidential, and we handle it that way. If a transaction proceeds, the licensed brokerage handling the sale will collect more detailed medical information directly from you under separate written authorizations and HIPAA releases. Those documents are governed by the brokerage's own privacy notice and the applicable state life settlement statute.
2.3 Partial form submissions
To make sure we can follow up if you accidentally close your browser, the estimate form is designed to capture the information you have entered even if you do not finish. If you fill out part of the form and then leave the page, the partial information you entered, including any contact details, is sent to us so a member of our team can reach out. If you would prefer that we not retain or follow up on partial submissions, contact us using the information at the end of this policy and we will delete the record.
2.4 Information collected automatically when you visit the Site
When you visit the Site, the following information is collected automatically through cookies, pixels, server logs, and similar technologies:
- Device and connection data: IP address, approximate location derived from your IP, device type, operating system, browser type and version, screen size, and language settings.
- Usage data: pages viewed, links clicked, the page that referred you to ours, time spent, and similar interaction events.
- Marketing-attribution identifiers: click identifiers and campaign tags from advertising platforms (for example, Google Ads click IDs and Meta browser/click identifiers) that let us measure which ads led to a visit.
2.5 Information from third parties
We may receive information about you from advertising platforms (Google, Meta), analytics providers, and consumer-data providers we use to verify a phone number or to determine whether to advance a lead to one of our broker partners. We may also receive information from referral partners, professional advisors, or family members who are helping you with a possible life settlement. We treat this information under this policy.
3. How We Use Your Information
We use the information described above for these purposes:
- Providing the Services. Reviewing your form, estimating whether your policy is likely to qualify, contacting you to discuss next steps, and connecting you with a licensed brokerage if you choose to move forward.
- Customer service and follow-up. Responding to questions, returning calls, sending email or text replies, and continuing a conversation you started.
- Site operations. Hosting, security, fraud prevention, debugging, and improving the Site.
- Marketing and analytics. Measuring the performance of our content and advertising, understanding which articles or pages help seniors most, and tailoring relevant ads on platforms like Google and Meta. You can control most of this with the tools described in Sections 7 and 8.
- Compliance and legal obligations. Complying with applicable laws, including life settlement regulations, the Gramm-Leach-Bliley Act, telemarketing and texting rules, recordkeeping rules, and responding to valid legal process.
- Protecting our rights. Detecting, preventing, and responding to suspected fraud, abuse of the Site, threats to our team, or violations of our Terms of Use.
We do not use the information you submit to make decisions about you that have legal or similarly significant effects without meaningful human review. Our affiliated and partner brokers make qualification and offer decisions, and a real person reviews each lead.
4. Who We Share Information With
4.1 Our affiliated brokerage
Qualified leads are typically referred to Asset Life Settlements, a Florida-licensed viatical settlement brokerage co-founded by our Founding Principal, Jeff Hallman. Asset Life Settlements receives the information you submitted along with our notes, and a licensed broker from that firm may contact you to discuss the transaction. The brokerage owes a fiduciary duty to you as the seller and is regulated by state insurance departments. The affiliation gives Citizens Life Group a financial interest in transactions that close through Asset Life Settlements, which is disclosed to you in writing before you sign anything.
4.2 Other licensed broker partners
In some cases, your information may instead be shared with a different state-licensed life settlement brokerage in our broker network, particularly if your policy is in a state where Asset Life Settlements is not licensed, or if a different brokerage is better suited for your specific policy. Each brokerage we work with is licensed under the applicable state life settlement statute and is contractually required to protect your information consistent with the Gramm-Leach-Bliley Act and applicable state law.
4.3 Service providers
We use the following service providers to operate the Site and the Services. Each one only processes information on our behalf and is contractually required to keep it confidential and use it only for the purposes we authorize:
- Hosting and content-delivery provider: serving the website, delivering pages quickly, and protecting against denial-of-service and other attacks.
- Transactional email provider: delivering lead notifications to our team and follow-up emails to you.
- Lead and customer-records platform: storing leads, notes, and basic customer-relationship data so we can follow up and keep our records straight.
- Analytics and advertising platforms: measuring website performance and the effectiveness of our advertising. We currently use Google Analytics, Google Ads conversion tracking, and the Meta (Facebook) Pixel for these purposes.
This list reflects the categories of processors we use as of the "Last Updated" date above. We may add or replace providers as we improve the Site, and we will update this section when there are material changes. You can request the specific names of our current providers by contacting us using Section 16.
4.4 Professional advisors and government bodies
We may share information with our attorneys, auditors, insurers, and similar professional advisors, and with regulators or law enforcement when we are legally required to do so or to protect ourselves, our team, our clients, or the public.
4.5 Business changes
If Citizens Life Group is involved in a merger, acquisition, financing, sale of assets, or similar transaction, your information may be transferred to the relevant party, subject to commitments at least as protective as this policy.
4.6 We do not sell your personal information
Citizens Life Group does not sell your personal information for money. We do not share your information with unrelated third parties for their independent marketing. Some of the analytics and advertising activities described in Section 7 may qualify as "sharing" or "sale" under broader definitions in California and a handful of other state privacy laws because they involve the use of cookies and similar identifiers by ad platforms. You can opt out of those activities using the controls in Sections 7 and 8.
5. Financial Privacy Notice (Gramm-Leach-Bliley Act)
Life settlement brokers and providers are treated as financial institutions for purposes of the federal Gramm-Leach-Bliley Act (GLBA) and the privacy provisions of state life settlement statutes (for example, Florida's Viatical Settlement Act, the New York Insurance Law, and the National Association of Insurance Commissioners model regulation that most states have adopted). Although Citizens Life Group is not itself a licensed broker or provider, we voluntarily adhere to the same standards for information handled in connection with a possible life settlement. This Section 5 serves as your privacy notice for that purpose.
5.1 Categories of nonpublic personal information we collect
- Information you provide on the Site or in calls and emails (Section 2.1).
- Information about your transactions with us, our affiliates, and the brokerages we work with.
- Information from consumer reporting agencies or other third parties used to verify identity or evaluate a policy.
5.2 Categories of parties with whom we may share that information
- Our affiliated brokerage (Asset Life Settlements).
- Other licensed life settlement brokers and providers with whom you authorize us to share information in order to obtain offers on your policy.
- Service providers and professional advisors as described in Section 4.
- Government bodies and persons authorized by law to receive the information.
5.3 Your right to opt out of certain sharing
You may instruct us not to share your nonpublic personal information with nonaffiliated third parties for their own purposes (other than the limited categories permitted by GLBA, such as service providers acting on our behalf and disclosures required by law). To opt out, contact us using Section 16. Opting out will not prevent the sharing necessary to evaluate your policy and obtain offers from licensed brokers, which is the core service you have requested.
5.4 How we protect this information
We maintain administrative, technical, and physical safeguards designed to protect nonpublic personal information from unauthorized access, use, or disclosure. See Section 10 for more detail.
6. Your Privacy Rights
Depending on where you live, you have the privacy rights described below. We honor these rights for residents of any U.S. state whose law grants similar rights, even if our business does not technically meet that state's applicability thresholds.
6.1 California residents (CCPA / CPRA)
If you are a California resident, you have the right to:
- Know what personal information we have collected about you, the categories of sources, the purposes of collection, and the categories of recipients.
- Access a copy of the specific pieces of personal information we have collected about you in the past 12 months.
- Correct inaccurate personal information we maintain about you.
- Delete personal information we have collected about you, subject to legal exceptions (for example, recordkeeping required for completed transactions).
- Limit the use of sensitive personal information. The only sensitive category we collect is the self-attested general health rating, and we already use it only for the purposes described in Section 3.
- Opt out of "sale" or "sharing" of personal information for cross-context behavioral advertising. We do not sell information for money, but our use of cookies and similar identifiers with Google and Meta as described in Section 7 may qualify as "sharing" under California law. You can opt out by enabling Global Privacy Control in your browser (see Section 8) or by contacting us.
- Non-discrimination. You will not be charged a different price or given a different level of service for exercising any of these rights.
- Authorized agent. You may use an authorized agent to make a request on your behalf, with proof of authorization.
6.2 Residents of other states
Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have varying rights to access, correct, delete, port, and opt out of certain processing of their personal information under their respective state laws. Citizens Life Group honors these rights to the extent they apply to information we hold about you.
6.3 How to exercise your rights
Send a request by email to contact@citizenslifegroup.com or by phone to (321) 270-0279. Please include enough information for us to verify your identity (typically the name, email, and phone number you used with us) and a clear description of what you are asking us to do. We will respond within the time required by your state's law (in most cases, 45 days), and we may extend that period once if reasonably necessary, with written notice to you. If we cannot honor a request, we will tell you why. You may appeal a denial by replying to our response.
6.4 Florida residents
The Florida Digital Bill of Rights (Fla. Stat. §§ 501.701 et seq.) currently applies only to large technology companies that meet specific revenue and processing thresholds, which Citizens Life Group does not meet. We nonetheless extend the access, correction, and deletion rights described in Section 6.1 to Florida residents on request.
7. Cookies and Tracking Technologies
Cookies are small data files that a website places on your device. We and our service providers use cookies, pixels, and similar technologies for the following purposes:
- Strictly necessary: running the Site, remembering form progress, basic security.
- Analytics: understanding which pages are useful, which paths lead to a completed estimate, and how to improve the Site (currently Google Analytics 4).
- Advertising: measuring the performance of our ads on Google and Meta, building broad audiences (for example, "people interested in life settlements"), and not showing the same ad to the same person too many times. We use the Google Ads conversion tag and the Meta Pixel for this purpose.
You can control cookies in several ways:
Blocking some cookies may cause parts of the Site to work less well. Strictly necessary cookies cannot be turned off without breaking core features.
8. Do Not Track and Global Privacy Control
Some browsers offer a "Do Not Track" (DNT) signal. Because there is no industry standard for how a website should respond to DNT, the Site does not currently respond to DNT signals.
The Site does honor the Global Privacy Control (GPC) signal as an opt-out of "sale" and "sharing" of personal information for cross-context behavioral advertising in U.S. states whose laws recognize GPC (currently California, Colorado, and Connecticut, and others as their attorneys general adopt the standard). If your browser sends a GPC signal, we treat it as an opt-out from the advertising-related sharing described in Section 7 for that browser.
9. Communications, Calls, and Texts
When you submit the estimate form or otherwise give us your phone number or email address, you consent to be contacted at the number and email you provide so we can deliver the Services you requested. Initial outreach is handled by a real person at Citizens Life Group, not an automated dialer.
We may use email, text message (SMS), or phone calls to follow up on your inquiry, deliver your estimate, schedule a call, or share information you have asked for. Standard message and data rates may apply for SMS. You can opt out at any time:
- Email: click "unsubscribe" in any of our emails, or reply asking us to stop emailing you.
- Text: reply STOP to opt out of further text messages, or HELP for help. We will honor a STOP within the time required by applicable law (15 days under Florida's Telephone Solicitation Act and immediately wherever practicable).
- Phone: tell us on the call or send us a written request that we not call again.
Opting out of marketing communications will not stop transactional or compliance communications related to a transaction in progress, or communications you specifically request.
More detailed terms governing our communications appear in our Terms of Use and in any consent language presented at the point of submission.
10. How We Protect Your Information
We maintain administrative, technical, and physical safeguards designed to protect the personal information we hold from unauthorized access, use, alteration, or destruction. These include encrypted transport (HTTPS) on all Site pages, encrypted storage at our service providers, access controls that limit who on our team and at our brokerage can view your information, and contractual confidentiality obligations on every service provider we use.
No system can be guaranteed 100% secure. If we ever experience a security incident affecting your personal information, we will notify you in the manner and within the time required by Florida law (the Florida Information Protection Act) and any other state law that applies to you.
11. How Long We Keep Your Information
We keep personal information only as long as we need it for the purposes described in this policy:
- Lead and contact records: typically up to 3 years after our last contact with you, unless you ask us to delete sooner.
- Records related to a closed transaction: for the recordkeeping period required by the applicable state life settlement statute (commonly 5 to 7 years), and as needed for tax, audit, and legal purposes.
- Website analytics data: retained at the default period set by Google Analytics (currently 14 months), unless we shorten that period.
- Backups and security logs: retained for limited periods consistent with industry practice.
You can ask us to delete personal information sooner using the rights in Section 6. Some information must be retained for legal reasons even after a deletion request, and we will tell you when that applies.
12. Children Under 18
The Site and the Services are designed for adults, and they are most directly relevant to seniors and their adult family members and caregivers. We do not knowingly collect personal information from anyone under 18. If you believe a minor has submitted information to us, contact us using Section 16 and we will delete it.
13. Third-Party Websites
The Site links to other websites we think are useful (state insurance departments, regulatory bodies, the Florida DFS Licensee Search, professional associations, and similar resources). Those websites are operated by their own organizations and are governed by their own privacy policies. We are not responsible for their content or their information practices.
14. Visitors Outside the United States
The Services are intended for residents of the United States. Life settlements are a U.S. regulated transaction and we do not currently work with policies issued outside the U.S. or with non-U.S. residents. If you visit the Site from another country, the information we collect is processed in the United States, and you should not submit personal information through the Site unless you are comfortable with that.
15. Changes to This Policy
We may update this policy from time to time to reflect changes in our practices or in the law. The "Last Updated" date at the top of this page tells you when the policy last changed. If we make material changes, we will provide more prominent notice (for example, a banner on the Site or an email if you are an active client) before the changes take effect.
16. How to Contact Us
For any privacy question, request, or concern, contact us in any of these ways:
You may also reach state regulators directly. In Florida, that is the Florida Department of Financial Services. The state list and contact details are summarized on our State Rules page.
