Privacy Policy

Effective November 11, 2019

Thank you for using LBI Financial. We take data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 3.

1. The Basics

A. About Us

LBI Financial is an online marketing platform (the "Services") operated by Paul Horrocks ("we," "us," "our," and "LBI Financial").

B. Key Terms

In this privacy policy, these terms have the following meanings:
"Personal Information" means any information that identifies or can be used to identify a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, phone number, date of birth, email address, postal address, gender, occupation, life events or other demographic information.
"Website(s)" means any website(s) we own and operate (such as “http://www.lbifinancial.com”) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means a Visitor.

2. Privacy for Visitors

This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.

A. Information We Collect

(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to request a quote, apply for a role, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.

(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below.

B. Use of Personal Information

We may use the information we collect through our Websites for a range of reasons, including:

To provide, operate, optimize, and maintain our Websites.
To send you information for marketing purposes, in accordance with your marketing preferences.
For recruitment purposes if you have applied for a role.
To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
To manage our Websites and system administration and security.
To improve the navigation and content of our Websites.
To identify any server problems or other IT or network issues.
To process transactions and to set up online accounts.
To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
To carry out research and development to improve our products and services.
To customize content and layout of the Websites.
To carry out other legitimate business purposes, as well as other lawful purposes.
To comply with any compliance rules or investigations required by the company and agency with whom we associate.
To provide aggregate reporting on your activity and use of the Services to the company and agency with whom we associate.

In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.

C. Public Information and Third-Party Websites

Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at [email protected] If we are unable to remove your information, we will tell you why.
Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, Instagram and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

D. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our cookie policy below.

E. Other Data Protection Rights

You have the following data protection rights:

To access, correct, update, or request deletion of your Personal Information. MyNameFlow takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at [email protected]. We will consider your request in accordance with applicable laws.
In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at [email protected].
Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

3. General Information

A. How We Share Information

We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy:
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
These third-party service providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this privacy policy.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Visitors with them for this purpose. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about cookies and other tracking technologies, please see our cookie policy below.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
(v) Any other person with your consent.
(vi) To comply with any compliance rules or investigations required by the company and agency with we associate.
(vii) To provide aggregate reporting on your activity and use of the Services to the company and agency with whom we associate.

B. Legal Basis for Processing Personal Information (EEA Persons Only)

If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.

C. Your Choices and Opt-Outs

Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, annual reviews and billing information) are considered transactional and necessary if you are a client.

D. Our Security

We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at [email protected].

E. International Transfers

(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.

F. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

Whether we have a legal or contractual need to retain the data.
Whether the data is necessary to provide our Services or market to you.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

G. California Privacy

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us at [email protected].
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receives a “Do Not Track” signal from a Visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

H. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.

I. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please email us at [email protected]. You may also contact us by postal mail or email at:

For EEA Residents:
For the purposes of EU data protection legislation, Paul Horrocks is the controller of your Personal Information. Our Data Protection Officer can be contacted at [email protected].

For Non-EEA Residents:
Paul Horrocks
Attn. Privacy Officer
[email protected]
77 West 55th St. Suite 9J
New York, NY 10019

4. Acknowledgment of Consent

By using our website, you consent to our collection, retention, and use of your Personal Information as described in this Privacy Policy. Please contact us at [email protected] if you have any questions.

5. Cookie Policy

This Cookie Statement explains how we use cookies and similar technologies in the course of our business, including through our websites that link to this Privacy Policy, such as http://www.lbifinancial.com or any website or mobile application owned, operated or controlled by us (collectively, “Websites” or “websites”). It explains what these technologies are and why we use them, as well as your rights to control our use of them. This Cookie Statement is and will be treated as part of our Terms of Use, and is automatically incorporated therein.
In some cases we may use cookies and other tracking technologies described in this Cookie Statement to collect Personal Information, or to collect information that becomes Personal Information if we combine it with other information.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner or service provider (in this case, Paul Horrocks) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services.

Why do we use cookies and other tracking technologies?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites and Services to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us and the third parties we work with to track and target the interests of visitors to our Websites, and we refer to these as “performance” or “functionality” cookies. For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Websites and to otherwise improve the functionality of the Services we provide. We also enable our users to employ cookies and similar tracking technologies in connection with their use of our Services in order to allow us and our users to track their subscribers. Finally, third parties serve cookies through our Websites and Services for advertising, analytics, and other purposes. This is described in more detail below.

Cookies served through our Websites

The specific types of first and third party cookies served through our Websites and the purposes they perform are described in further detail below:

Essential Website Cookies

These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function.

Analytics and Customization Cookies

Advertising (Targeting) Cookies

These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. For further information, see the section of the Cookie Statement entitled "Targeted online advertising".

Other tracking technologies

We and our third party partners may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or, in the case of web beacons, opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to serve targeted advertisements to you and others like you, to improve site performance, and to measure the success of marketing campaigns. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair functioning of these technologies.

Targeted online advertising

We have engaged one or more third party service providers to track and analyze both individualized usage and volume statistical information from interactions with our Websites. We also partner with one or more third parties (such as advertisers and ad networks) to display advertising on our Websites and/or to manage and serve advertising on other sites.
These third parties use cookies, web beacons, pixel tags and similar tracking technologies to collect and use certain information about your online activities, either on our Websites and/or other sites or mobile apps, to infer your interests and deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests (“Interest Based Advertising”). For more information about this practice, click here: http://www.aboutads.info/choices/.
Our third party service providers may also use cookies or web beacons to collect information about your visits to our Websites and/or other sites to measure and track the effectiveness of advertisements and our online marketing activities (for example, by collecting data on how many times you click on one of our ads). The information collected by these third parties does not include personal information that enables you to be specifically identified (e.g. by reference to your name or email address).

Cookies served through the Services

Email campaigns

We automatically place single pixel gifs, also known as web beacons, in every email sent by us. These are tiny graphic files that contain unique identifiers that enable us to recognize when you have opened an email or clicked certain links. These technologies record your email address, IP address, date, and time associated with each open and click for a campaign. We use this data to create reports about how an email campaign performed and what actions users took.
Google remarketing ads: Our Google remarketing ads feature (also known as web retargeting ads) allows us to create and manage advertisements on the Google Display Network. When we elects to use this feature, we install a Google tracking pixel on our site. These technologies facilitate the placement of advertising campaigns on the Google Display Network and enable us to receive reporting about the performance of these advertising campaigns. To refuse these cookies, please click on the relevant opt-out link here: https://www.google.com/settings/ads/pluginFacebook ads: Our Facebook ads feature allows us to display ads within the Facebook platform. We installs a Facebook tracking pixel on our website. These tracking technologies facilitate the placement of advertising campaigns on the Facebook platform and enable us to receive reporting about the performance of these advertising campaigns. Facebook does not provide an opt-out link for its cookies. For more information about Facebook cookies, please click here: https://www.facebook.com/policies/cookies/.
Product retargeting emails: Our product retargeting emails feature allows us to promote products and services. When you click a link within a product retargeting email, we drop a cookie on your device. This cookie allows MyNameFlow to track attribution rates and browser activity and receive reporting regarding the success of our product retargeting emails.
Popup forms: We deploy a cookie that recognizes whether a visitor to our Site has previously viewed a popup form and ensures the same visitor does not see the form again for a period of up to one year.

How often will you update this Cookie Statement?

We may update this Cookie Statement from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Statement regularly to stay informed about our use of cookies and related technologies.
The date at the top of the Privacy Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at [email protected].