Privacy Policy

Last updated

Wrightwood Advisory (“Wrightwood,” “we,” “us,” or “our”) provides ICOLI.com as a resource for insurance companies and their advisors evaluating insurance company owned life insurance. This Privacy Policy explains what information this website collects, why we collect it, who we share it with, and the choices you have.

This policy covers ICOLI.com and the modeling tools hosted on it. It does not cover any separate service you reach by following a link from this site, and it does not cover the advisory relationship itself — if you become a client, the privacy notice you receive in connection with that relationship governs the information we collect as your advisor.

The Short Version

  • We do not use advertising trackers, analytics pixels, or third-party marketing tags on this site.
  • We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
  • You can read every public page of this site without giving us any personal information and without us setting a cookie.
  • Census data you put into the illustration tool is parsed in your browser. It is only transmitted to us if you are signed in and choose to save a scenario — and then only in a reduced form, described below.
  • Accounts are passwordless. We never ask for, receive, or store a password for this site.

Information You Give Us

Contact Form

When you send a message through our contact form, we collect your name, your email address, the content of your message, and, where the form includes them, your company and the subject of your inquiry. The submission is delivered to our advisory inbox by email so that we can respond. We keep this correspondence as a business record.

Account Registration and Sign-In

The modeling tools are available to registered users. When you request access, we collect your name and email address. When you sign in, we collect your email address.

Sign-in is passwordless: we email you a single-use link rather than asking you to create a password. We do not collect, receive, or store a password for this site.

We maintain an account record containing your name, email address, the date your account was created, whether your account is pending, active, or disabled, and whether it carries administrative privileges. Our administrators can see this account record in order to approve access requests and manage accounts.

Information You Enter Into the Modeling Tools

The illustration and tax-impact tools accept assumptions such as total premium, net admitted assets, allocation percentage, projection horizon, and either a summary description of a group of insured lives (number of lives, average age, percentage male) or a detailed employee census.

Assumptions entered in summary mode are not personal information — they describe a group, not an identifiable person.

How Census Data Is Handled

This section describes the most sensitive information the site can receive, so we want to be precise about it.

The illustration tool lets you upload or paste an employee census file containing, for each life, gender, date of birth, date of hire, and total compensation.

When you run an illustration. The census file is read and parsed entirely within your browser. The file itself is never uploaded to us or to anyone else. The parsed values are held in your browser’s session storage so that the results page can use them, and that storage is cleared when you close the browser tab.

When you save a scenario. If you are signed in and choose to save a scenario, a reduced version of the census is transmitted to and stored in our database so the scenario can be reloaded later. What is stored for each life is: age at the time of the calculation, gender, allocated premium, compensation, and hire date. Names, dates of birth, and any other column present in your file are not stored. The saved scenario also includes the name you give it and, if you enter one, a client label.

Saved scenarios are visible to you as the account that saved them, and to our administrators. Access is enforced at the database level, not only in the interface.

Your responsibility for census data. A census describes other people — typically your employees. By uploading, pasting, or saving one, you represent that you are authorized to provide that information to us for the purpose of modeling, and that doing so is consistent with your own privacy obligations and any notice or consent your employees are owed. If you would rather not transmit individual-level data at all, use summary mode, or run the illustration without saving the scenario.

Information Collected Automatically

Our web host records standard server logs when your browser requests a page: IP address, browser type and version, the page requested, the referring page, and the date and time. These logs are used to operate the site, diagnose errors, and protect against abuse.

We do not run analytics software, advertising tags, tracking pixels, session-recording tools, or third-party marketing scripts on this site. If that changes, we will update this policy before deploying them.

Cookies and Local Storage

Browsing the public pages of this site does not set any cookie.

The site uses your browser’s own storage in two limited ways:

  • Session storage holds the assumptions you have entered into a modeling tool so they carry from the input page to the results page. It is cleared when you close the tab.
  • Local storage holds your sign-in token after you use an emailed sign-in link, so that you stay signed in between pages. Signing out removes it.

Neither is used for advertising, profiling, or tracking you across other websites. WordPress, the software this site runs on, also sets cookies for users who sign in to its administrative area; that applies to our staff, not to site visitors.

Service Providers

We use a small number of providers to operate this site. They receive only what they need to perform their function, and they are not permitted to use it for their own purposes.

  • Our web hosting provider serves the site and maintains the server logs described above.
  • Supabase provides the authentication service and the database that store account records and saved scenarios, and sends the sign-in emails.
  • Our email delivery provider transmits contact-form submissions and notification messages to our inbox.
  • Google Fonts and Adobe Fonts serve the typefaces used on this site. Because your browser requests these files directly, Google and Adobe receive your IP address and basic request information. They do not receive anything you enter on this site.

Two further services are reached only if you choose to click through to them, and this policy does not govern them:

  • Calendly hosts the scheduling page behind our “Book a Consultation” links. Nothing is sent to Calendly unless you follow one of those links, and any information you enter on that page is handled under Calendly’s privacy policy and ours as the recipient of the booking.
  • LinkedIn hosts our company page, which we link to from the footer.

How We Use Information

We use the information described above to:

  • Respond to your inquiry and provide the information or consultation you asked for;
  • Create and administer your account, and verify who is signing in;
  • Run the modeling tools and save and reload the scenarios you ask us to save;
  • Operate, secure, maintain, and improve the site;
  • Communicate with you about your account or a scenario you have saved; and
  • Meet our legal, regulatory, and recordkeeping obligations.

We do not use the information you provide through this site to build advertising profiles, and we do not use census data for any purpose other than producing the modeling output you requested.

When We Disclose Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose information only:

  • To the service providers listed above, for the functions described;
  • To carriers or other parties, at your direction, when you ask us to obtain a formal illustration or quote on your behalf;
  • To our professional advisors, auditors, and regulators where required in connection with our business;
  • Where required by law, subpoena, or other legal process, or to protect the rights, safety, or property of Wrightwood Advisory, our clients, or others; and
  • In connection with a merger, acquisition, or sale of assets, under terms that continue to protect the information.

Data Retention

We keep contact-form correspondence and account records for as long as the relationship is active and thereafter for as long as our regulatory recordkeeping obligations require.

Saved scenarios, including the reduced census stored with them, are kept until you delete them or ask us to close your account. You can delete any saved scenario yourself from the saved-scenarios panel in the illustration tool.

Assumptions held in your browser’s session storage are not retained by us at all; they disappear when you close the tab.

Security

The site is served over HTTPS. Accounts are passwordless, which removes the risk of a stolen or reused password for this site. Access to account records and saved scenarios is restricted at the database level to the account that owns them and to our administrators. Access to our systems is limited to personnel who need it.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive personal information — Social Security numbers, account numbers, or medical information — through the contact form or by unencrypted email.

Your Choices and Rights

You can:

  • Use the public pages of this site without providing any personal information;
  • Use summary mode instead of uploading a census, or run an illustration without saving it;
  • Delete any saved scenario from within the tool;
  • Ask us to access, correct, or delete the personal information we hold about you, or to close your account; and
  • Set your browser to block or clear local and session storage, though the modeling tools and sign-in will not function without them.

Depending on where you live, you may have additional rights under state privacy law — including the right to confirm whether we process your personal information, to obtain a copy of it, to correct or delete it, and not to be discriminated against for exercising those rights. Because we do not sell personal information or share it for cross-context behavioral advertising, and because we do not use it for profiling that produces legal or similarly significant effects, there is nothing for you to opt out of in those categories. Some information we hold is subject to financial-privacy law and is handled under the notice described below rather than under state privacy law.

To exercise any of these rights, contact us using the details at the end of this policy. We will verify your request against the information we already hold before acting on it, and we will respond within the time the applicable law allows. You may use an authorized agent where state law permits.

Financial Privacy Notice

Wrightwood Advisory is a financial services firm. Information collected in connection with an advisory or brokerage relationship is governed by our financial privacy notice, which is provided separately at the outset of that relationship and annually thereafter as required. This Privacy Policy governs the website; where the two overlap, the financial privacy notice controls for information collected as part of a client relationship.

Children

This site is intended for insurance company professionals and their advisors. It is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a child has provided us information, contact us and we will delete it.

Jurisdiction

This site is published for residents of the United States only, and our systems are operated in the United States. If you access the site from outside the United States, understand that your information will be processed in the United States under United States law.

Links to Other Sites

This site links to third-party resources, including regulatory and industry sources, our scheduling page, and documents published by unaffiliated firms. We are not responsible for the content or privacy practices of those sites. Review their policies before providing information to them.

Changes to This Policy

We may update this Privacy Policy as the site changes. The revision date shown at the top of this page reflects the most recent change. If we make a material change — including adding any analytics or advertising technology — we will say so here before or when the change takes effect.

Contact Us

Questions about this policy, or requests regarding your personal information:

Wrightwood Advisory
9185 Research Blvd.
Austin, TX 78758
info@wrightwoodadvisory.com
512.332.9443