Privacy Policy

Last updated: April 24, 2025

Introduction

This Privacy Policy is effective as of March 10, 2025, and represents the Privacy Policy of The BYOB Innovations LLC ("BYOB Innovations", " BYOB Vault", "we", "our", or "us").

This Privacy Policy addresses the privacy rights of individuals who:

  • visit our Website or use our Services;
  • interact with us on behalf of a Customer in connection with the provision of our Services;
  • interact with us on behalf of an Independent Insurance Agent marketing our Services;
  • interact with us on behalf of a Service Provider in connection with the products and services our Service Provider provides to us;
  • interact with us on behalf of a business partner in connection with our relationship with the business partner;
  • apply to work with us;
  • receive marketing communications from us; and/or
  • interact with us by registering for, attending and/or otherwise taking part in our trade events, webinars, or conferences or who communicate with us via email, phone, or in-person.

This Privacy Policy, which includes and incorporates our GDPR Privacy Policy, is designed to assist individuals and businesses that interact with us to understand the types of Personal Data we collect, how that Personal Data is Processed, and the practices we have adopted to protect Personal Data.

Definitions

"Controller" means a person or organization that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

"Customer" means a business or individual that has, formerly had, or is contemplating purchasing or using our Services, or any party that is employed by such business and accesses Services pursuant to such business purchasing or using our Services.

"GDPR" means the EU General Data Protection Regulation 2016/679.

"Independent Insurance Agent(s)" A licensed insurance professional who is not an employee of BYOB Innovations LLC but works independently to market and facilitate the Infinite Banking Concept and related financial services to consumers.

"NYDFS" means New York State Department of Financial Services.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Privacy Policy" means this Privacy Policy.

"Process" and "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

"Processor" means a person or organization that engages in Processing.

"Representative" means an individual who (i) acts on behalf of, or is employed by, a Customer, including, a Customer's employees, agents, and representatives, (ii) acts on behalf of a Service Provider, including, a Service Provider's employees, agents, and representatives, (iii) acts on behalf of a business partner, including a business partner's employees, agents, and representatives or (iv) otherwise interacts with us in any manner, for example through our Website or uses our Services, in any manner whatsoever.

"Service Provider" means a supplier, subcontractor, vendor, or other third party who provides services to us, including but not limited to the sell and commercialization of our Services to Customers.

"Services" means the products and services provided by us, including, but not limited to, financial education and coaching, insurance advisory services, marketing of the "Infinite Banking Concept", online and in person courses, webinars, and any other educational or consulting services we may make available from time to time.

"Website" means all of the websites and applications maintained by us that display a link to the Privacy Policy.

"Website Visitor" means an individual who visits the Website.

Personal Data Collected

For our Customers, we may collect the Personal Data of you or your Representatives (e.g., name, job title, business contact details, final information, and any other necessary information for policy applications) when you or your Representatives inquire about, negotiate, purchase, or use any of our Services.

For our Service Providers, we may collect the Personal Data of your Representatives when we inquire about or purchase services from you to support our business operations.

For our business partners, we may collect the Personal Data of your Representatives in connection with our interactions with you.

For prospective employees, we may collect your Personal Data when you visit, browse, or register on our Websites, when you submit an application for employment, when you provide additional Personal Data during the application and interview process, when you speak to our employees during your interview process, and when you otherwise provide or authorize us to collect your Personal Data during the application and interview process.

For our Independent Insurance Agents, we collect information from agents to monitor their use of our platforms, marketing practices, and compliance with regulations.

For our Website Visitors, we may collect certain Personal Data from you when you visit, browse, register on our Websites, complete a form on our Websites, or engage in online support received through our Websites. We may also collect certain information about your session when you visit our Websites, including internet protocol (IP) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data, as further outlined below.

We may also collect the Personal Data of Representatives if they (i) register for a trade event, webinar, or conference hosted by us, (ii) download or request content and information regarding our Services, (iii) complete a survey or form, (iv) request online support through our Websites, or (v) receive marketing communications from us.

Purpose of Personal Data Collection and Processing

We collect and Process Personal Data for the following purposes:

  • To provide, assess, and improve our customer support and customer service;
  • To personalize your experience using our Services or Websites;
  • To fulfill a legal obligation or to protect our rights;
  • To comply with applicable laws and regulations, including the NYDFS regulations;
  • To advise you of additional or new Services that may be of interest to you;
  • To administer and manage Service Providers;
  • To work with business partners;
  • To improve and protect the integrity and security of our Services and our Websites;
  • To facilitate the insurance process for consumers who engage with Independent Insurance Agents;
  • To consider job applicants for employment;
  • To send periodic communications (the contact information that you provide may be used to send you information, including marketing, respond to inquiries, and/or other requests or questions); and
  • For any other purpose for which you have been notified, and if legally required where appropriate consent has been obtained.

If you receive marketing communications from us by email, and you no longer want to receive marketing-related emails from us, you may opt out of receiving such emails by clicking the "unsubscribe" link at the bottom of any marketing email you receive from us. If you are having difficulty unsubscribing from our marketing emails using the above methods, please contact us directly at the email support@byobvault.com.

Security

We implement a variety of security measures to maintain the safety of your Personal Data when you enter, submit, or access your Personal Data, or when it is otherwise collected or Processed by us. We take reasonable and appropriate measures to secure your Personal Data. These include:

  • Secure storage and processing of Personal Data with encryption measures;
  • Role-based access controls to limit internal access to Personal Data;
  • Multi-factor authentication (MFA) for accessing sensitive systems;
  • Incident response protocols for unauthorized access or data breaches.

Cookies and Other Technologies

We automatically collect information about your use of our Site through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information.

Cookies are alphanumeric identifiers that we transfer to your device's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website and Services.

Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The "Help" portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website and Services who disable cookies will be able to browse certain areas of the Website, but some features may not function.

We use third-party browser and mobile analytics services like Google Analytics in connection with the Services. These services use data collection tools to help us analyze use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.

Collection of Personal Data from Children

Our Websites and Services are intended for individuals 18 years of age and older. They are not directed at, marketed to, nor intended for, children under 18 years of age. We do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at support@byobvault.com and we will take immediate steps to delete it.

Changes to Privacy Policy

We will provide adequate notice of any material changes and obtain your consent when legally required when making such changes to this Privacy Policy.

Inquiries/Contact Us

You may have rights regarding your Personal Data depending on where you are and where your Personal Data is Processed. Please contact us at support@byobvault.com if you have questions in this regard or if you wish to update your Personal Data.

Governing Law; Venue; Waiver of Jury Trial and Class Actions

Unless applicable data protection or data privacy laws expressly provide otherwise, (a) this Privacy Policy is governed by the laws of the State of New York, U.S.A, (b) you hereby agree that any dispute or claim raised or made by you against us relating to the Privacy Policy shall be subject to arbitration before a single arbitrator in Erie County, New York, in accordance with the Commercial Arbitration Rules of the American Arbitration Association and (c) you hereby waive all rights to bring or maintain any court action, jury trial or any class claim, class action, class arbitration, or other representative action, claim or proceeding against us in a court of law.

Compliance with NYDFS Regulations

As a company operating under New York Insurance Law, we comply with applicable regulations, including:

  • Maintaining cybersecurity policies;
  • Implementing multi-factor authentication as required for access to sensitive data;
  • Conducting periodic security risk assessments;
  • Ensuring secure data retention practices;
  • Complying with NYDFS's 72-hour breach notification requirement in the event of a data breach.

CALIFORNIA CONSUMER PRIVACY ACT NOTICE

This section addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 ("CCPA"). It applies to personal information about California residents using our Site and Services. For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

In the event of a conflict between this CCPA Notice and any of our other privacy notices, this CCPA Notice shall control only with respect to the personal information of California residents.

Personal Information Categories

Our Privacy Notice covers our personal information collection and usage more fully. The chart below describes the categories of personal information we collect and the sources from which we collect the personal information, organized into the categories specified by the CCPA.

Personal Information CategorySources
Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number)
  • Information you provide directly or through your interactions with our Services.
  • Information provided by your current or former employer.
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
  • Information you provide to us directly or through your interactions with our Site and Services.
  • Information provided by your current or former employer.
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) ("Characteristics of Protected Classifications")
  • Information you provide to us directly
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)
  • Information you provide to us directly.
  • Your interactions with our Site and Services.
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)
  • Your interactions with our Site and Services.
Geolocation Data
  • Information provided by your employer.
Professional or Employment-Related Information
  • Information you provide to us directly.
  • Information from your employer.
Inferences
  • Information you provide to us directly or through your interactions with our Site and Services.
  • Information from your employer
Audio, electronic, visual or similar information
  • Information you provide directly or through your interactions with our Services.

We use this personal information for the purposes outlined in the "Purpose of Personal Data Collection and Processing" set forth above. We do not sell your personal information and we do not have actual knowledge that we sell the personal information of minors under 16 years of age.

California Residents' Privacy Rights

California residents have rights to request access to or deletion of their personal information and may not be discriminated against because they exercise any of their rights under the California Consumer Privacy Act in violation of Cal. Civ. Code §1798.125. You can make requests by sending an email to support@byobvault.com with details of your specific request. We may ask that you provide certain information to verify your identity, and the information we request from you will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

You may designate an authorized agent to make a request under the CCPA on your behalf if: (1) the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (2) you sign a written declaration that you authorize the authorized agent to act on your behalf. We may ask that you provide certain information to verify your identity and that you authorized the authorized agent to act on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

California residents also have the right to opt out of the sale of their personal information; we do not provide this option as we do not sell your personal information.

If you have any questions or concerns regarding this CCPA Notice, please email support@byobvault.com.

GDPR Privacy Policy

This GDPR Privacy Policy section of our Privacy Policy (this "GDPR Privacy Policy") applies to the Processing of Personal Data by BYOB Innovations LLC in its role as a Controller, or as otherwise covered by the GDPR, when individuals:

  • visit or use our Website;
  • interact with us either on your own behalf or on behalf of a Customer in connection with the provision of our Services;
  • interact with us on behalf of a Service Provider in connection with the products and services our Service Provider provides to us;
  • interact with us on behalf of a business partner in connection with our relationship with the business partner;
  • apply to work with us;
  • receive marketing communications from us; and/or
  • interact with us by registering for, attending and/or otherwise taking part in our trade events, webinars, or conferences or communicate with us via email, phone, or in-person interactions.

This GDPR Privacy Policy does not apply to any Personal Data Processed, stored, or hosted by Customers using any of our Services or to the extent that we Process Personal Data in the role of a Processor on behalf of our Customers. Where we act as Processors on behalf of our Customers, that Processing is subject to the protections contained in our data processing agreements with Customers. We have no control over, and are not responsible for, any Personal Data that our Customers may store or host on their equipment or otherwise process while using our Services. We are not responsible for the privacy or data security practices of our Customers, which may differ from those set forth in this GDPR Privacy Policy. For information related to how our Customers Process Personal Data, please contact the respective Customer directly.

Furthermore, this GDPR Privacy Policy does not apply to any third-party website or service that may be linked to the Websites or the Services unless that website or service is controlled by us and displays this GDPR Privacy Policy. We have no control over, and are not responsible for, the data collection and/or handling practices of these third-party websites or services outside our Websites or Services. We encourage you to read the privacy statements of any third-party websites or services linking to (or linked to via) the Website or Services. In the event of a conflict between this GDPR Privacy Policy and the remainder of the Privacy Policy this GDPR Privacy Policy will prevail.

Our Contact Details

If you have any questions or concerns as to how your Personal Data is Processed, please write to us at support@byobvault.com or at ATTN: BYOB Innovations LLC,4624 Goodrich Road, Clarence, New York 14031.

BYOB Innovations LLC's Data Collection Practices

BYOB Innovations LLC collects and processes the following categories of Personal Data from Customers, Service Providers, business partners, Representatives, Website Visitors, prospective employees, individuals that receive marketing communications from BYOB Innovations LLC and individuals that interact with BYOB Innovations LLC by registering for, attending and/or otherwise taking part in BYOB Innovations LLC webinars or conferences or who communicate with BYOB Innovations LLC via email, phone or in person, in each case to operate its business for the specific purposes identified below.

  • Personal Details include data such as names, titles, company names, departments, email addresses, physical street addresses, telephone numbers, and social media usernames of individuals.
  • Login Credentials include data such as usernames and passwords of individuals needed to access our Services.
  • Unique IDs include data such as IP addresses and geolocation data that we obtain from (a) prospective employees, (b) Website Visitors, or (c) other individuals that interact with us.
  • Customer Support Records include data such as call details and other similar data regarding customer support communications and chat sessions with Representatives.
  • Website and Service Records include data related to your interactions with our Websites and Services and other online content such as log data (i.e., preferences and settings, IP addresses, technical information about the device used to visit the Websites or use the Services, and geolocation information) and traffic data (i.e., pages viewed, date stamps, time spent on a page, click through and clickstream data, queries made, search history, search results selected, comments made, type of service requested, and purchases made).
  • Employment Information includes details such as descriptions of roles performed and locations of employment.