Privacy Policy

1. Introduction and Scope

Crossfield Strategic Partners (‘Company,’ ‘we,’ ‘us,’ or ‘our’) is committed to protecting the privacy and security of your personal and financial information. This Privacy Policy describes how we collect, use, disclose, and safeguard information obtained through our website at crossfield.partners (‘Site’) and through related business communications.

This Privacy Policy applies to all visitors and users of our Site, including prospective clients, existing clients, and other individuals who interact with us online or through our licensed producers. By using the Site, you consent to the practices described in this Privacy Policy.

As a licensed insurance marketing organization providing life insurance and financial strategies, Crossfield Strategic Partners is subject to federal and state privacy laws governing the collection and use of Non-Public Personal Information (‘NPI’), including the Gramm-Leach-Bliley Act and applicable state insurance privacy regulations.

2. Gramm-Leach-Bliley Act (GLB) — Financial Privacy Notice

Under the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) and applicable implementing regulations, Crossfield Strategic Partners is required to provide you with notice of our privacy practices with respect to your Non-Public Personal Information.

What Is Non-Public Personal Information (NPI)?

NPI is personally identifiable financial information provided by you or collected in connection with a financial product or service, including:

• Name, address, date of birth, and Social Security Number
• Income, assets, net worth, and financial account information
• Health and medical information provided in connection with life insurance applications
• Insurance policy information and premium payment history
• Information derived from applications, forms, and transactions with us

Categories of NPI We Collect

• Information you provide directly — through contact forms, inquiry submissions, or conversations with our licensed producers
• Information from third parties — including insurance carriers, lenders in connection with premium finance arrangements, and other service providers
• Transaction information — related to insurance applications, policy issuance, and premium payments
• Information from public sources — as permitted by applicable law

How We Use Your NPI

• Evaluate your eligibility for life insurance and related financial products
• Process insurance applications and facilitate policy issuance with licensed carriers
• Communicate with you about your coverage, policy status, and related matters
• Comply with legal and regulatory obligations, including state insurance department requirements
• Administer our business operations and improve our services

Sharing of NPI

We do not sell your NPI to unaffiliated third parties for their own marketing purposes. We may share your NPI with:

• Insurance carriers and underwriters — for the purpose of evaluating and issuing life insurance policies
• Premium finance lenders — in connection with premium finance strategies, as applicable and with your consent
• Service providers and vendors — who perform services on our behalf (technology, data processing, compliance), subject to appropriate confidentiality obligations
• Regulatory authorities — as required by applicable law, including state insurance departments
• Professional advisors — including attorneys, accountants, and compliance consultants, under appropriate confidentiality protections

To the extent permitted by law, you may opt out of certain information sharing practices by contacting us as described in Section 9.

3. State Insurance Privacy Regulations

In addition to federal GLB requirements, Crossfield Strategic Partners complies with state-specific insurance privacy regulations, including those based on the National Association of Insurance Commissioners (NAIC) Insurance Information and Privacy Protection Model Act, as adopted by applicable state insurance departments.

Residents of states where Crossfield Strategic Partners holds active producer licenses may have rights under their respective state insurance privacy laws, including rights to access, correct, or limit the use and disclosure of their NPI collected in connection with insurance transactions. To exercise these rights, please contact us at the address provided in Section 9.

California Residents — CCPA / CPRA Notice

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may grant you additional rights regarding your personal information. Please note that certain personal information collected in connection with insurance products and services may be exempt from CCPA requirements under the California Insurance Code and applicable exemptions. To the extent CCPA applies to your information, you may have the following rights:

• The right to know what personal information we collect, use, disclose, and sell
• The right to request deletion of your personal information, subject to applicable legal exceptions
• The right to opt out of the sale or sharing of your personal information — we do not sell personal information
• The right to correct inaccurate personal information
• The right to non-discrimination for exercising your privacy rights

To exercise your California privacy rights, contact us at the information provided in Section 9. We will respond to verifiable requests within 45 days, subject to permitted extensions.

New Jersey Residents

New Jersey residents may have additional rights under the New Jersey Insurance Information and Privacy Protection Act (N.J.S.A. 17:23A-1 et seq.), including the right to access and correct NPI collected in connection with insurance transactions, and the right to know how such information is used and disclosed. To exercise these rights, contact us at the information provided in Section 9.

4. Website Information Collection — Cookies and Tracking Technologies

Information Collected Automatically

When you visit our Site, we and our service providers may automatically collect technical information including IP address, browser type and version, operating system, pages viewed, navigation path, referring URLs, and date and time of visit. This information is used to maintain and improve the Site and is not used to identify individual visitors except as described in this Privacy Policy.

Cookies and Similar Technologies

Our Site uses cookies and similar tracking technologies. Please refer to our Cookie Policy for a complete description of the cookies we use, their purpose, and how to manage your preferences.

5. How We Use Collected Information

• Respond to inquiries and provide information about our life insurance and financial strategies
• Connect prospective clients with licensed producers for needs analysis and consultations
• Process insurance applications submitted through or in connection with our Site
• Send communications about our services, regulatory updates, or educational content where you have consented or where permitted by law
• Comply with legal, regulatory, and compliance obligations
• Improve our Site, marketing, and service delivery
• Detect and prevent fraud, security incidents, and violations of our Terms of Service

6. Data Sharing with Carriers, Lenders, and Third Parties

Insurance Carriers

We share relevant personal and health information with insurance carriers for the purpose of underwriting and issuing life insurance policies. Carriers receiving your information are subject to their own privacy policies and applicable insurance privacy regulations.

Premium Finance Lenders

Where you pursue a premium finance strategy, we share relevant financial and policy information with licensed premium finance lenders. Your consent is obtained before sharing with lenders where required by applicable law.

Marketing and Technology Service Providers

We use third-party vendors to support our website, CRM, email communications, and marketing operations, including GoHighLevel (CRM and marketing automation) and Google (analytics and advertising). These vendors are contractually required to use your information only as directed by us and to maintain appropriate security and confidentiality standards consistent with applicable law.

Legal and Regulatory Requirements

We may disclose your information when required by law, regulation, court order, or lawful government request, including requirements of state insurance departments.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. As a licensed insurance organization, we maintain records in accordance with applicable state insurance record retention requirements, generally a minimum of seven (7) years from the date of the insurance transaction, unless a longer period is required by applicable law. Records are securely destroyed at the end of their applicable retention period.

8. Information Security

Crossfield Strategic Partners implements reasonable administrative, technical, and physical safeguards to protect your NPI and other personal information from unauthorized access, disclosure, alteration, or destruction, including:

• Encryption of sensitive data in transit using industry-standard TLS protocols
• Access controls limiting employee and vendor access to personal information on a need-to-know basis
• Regular review of our information security practices and vendor security standards
• Data processing agreements with third-party service providers

No electronic transmission or storage method is 100% secure. In the event of a data breach affecting your NPI, we will notify you as required by applicable state breach notification laws.

9. Your Rights and How to Contact Us

Depending on your state of residence and applicable law, you may have rights to access, correct, delete, or limit the use of your personal information. To exercise any applicable rights, or with questions about this Privacy Policy, please contact:

Crossfield Strategic Partners — Privacy Compliance
401 Hackensack Ave Suite 804
Hackensack, NJ 07601
Email: tomer@crossfield.partners
Phone: (877) 502-7677

10. Children’s Privacy

Our website is not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately at the address in Section 9 and we will promptly delete such information.

11. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, applicable law, or regulatory requirements. When we make material changes, we will update the ‘Last Updated’ date and provide additional notice where required by law. Your continued use of our Site following any changes constitutes acceptance of the updated Privacy Policy.

12. Governing Law

This Privacy Policy is governed by the laws of the State of New Jersey and applicable federal law, including the Gramm-Leach-Bliley Act and applicable NAIC model regulations adopted by state insurance departments.