Privacy Policy

1. Introduction

The Winners Circle Group ("we," "us," or "our") operates an invitation-only consortium platform for elite financial professionals. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, whether as a licensed agent, a prospect submitting a Personal Financial Review (PFR), or a visitor to our public pages.

By accessing or using the platform, you consent to the data practices described in this policy. If you do not agree, please do not use the platform.

2. Data We Collect

2.1 Agent Data (Platform Members)

• Identity & Contact: Name, email address, phone number, profile photograph.
• Authentication: Password hash (bcrypt), WebAuthn credentials. We never store plaintext passwords.
• Professional: Agent code, license number, National Producer Number (NPN), licensed states, organization and team membership.
• Activity: Login timestamps, IP addresses, user agent strings, session data — retained on a 12-month rolling basis for security auditing.
• Production & Compensation: Sales records, commission entries, weekly goals, milestones.
• Communications: Notification preferences, email delivery metadata (send/open events) — retained on a 12-month rolling basis.

2.2 Prospect & Client Data (Collected via PFR)

• Identity & Contact: Full name, email, phone, state of residence.
• Demographics: Age or date of birth, marital status, number of dependents — used for PFR financial scoring.
• Financial: Income, debt, savings, investments, retirement accounts, insurance coverage, credit score range, cash flow — used across 48 PFR scoring metrics.
• Insurance: Policy numbers, policy types, carriers, face amounts, premiums — used for insurance application tracking.
• Partial SSN: Last 4 digits only — used solely for insurance application identification.

2.3 Data We Do NOT Collect

• Full Social Security Numbers — we only store the last 4 digits.
• Credit card or banking details — all payment processing is handled by Stripe (PCI DSS Level 1 compliant). Card data never touches our servers.
• Medical records — no protected health information (PHI) is stored.
• Investment account numbers or tax returns — not collected.

3. How We Use Your Data

• PFR Scoring & Reports: Financial data submitted through the PFR system is analyzed using our proprietary scoring engine (48 metrics) and, where applicable, processed by the Anthropic Claude API to generate AI-powered financial insights. PFR reports are informational only and do not constitute financial advice.
• Pipeline & Client Management: Prospect and client data is used to track engagement through the sales pipeline, manage client relationships, and facilitate insurance application workflows.
• Communication: Email addresses are used for transactional notifications (submission confirmations, report delivery, account updates) and platform communications. We do not sell your email address to third parties.
• Security & Compliance: Login activity, IP addresses, and session data are used for anomaly detection, audit logging, and regulatory compliance.
• Platform Improvement: Aggregated, de-identified usage data may be used to improve platform features and performance.

4. Anthropic Claude API Usage

Our PFR scoring engine may transmit financial data to the Anthropic Claude API for AI-powered analysis and report generation. When data is sent to Anthropic:

• Data is transmitted over encrypted connections (TLS 1.2+).
• We send only the financial metrics necessary for scoring — no full names, email addresses, or SSN digits are included in API requests unless required for report personalization.
• Anthropic's data usage policies apply to data processed through their API. We recommend reviewing Anthropic's Privacy Policy for details on their data handling practices.

5. Third-Party Services

We share data with the following third-party service providers, each for a specific operational purpose:

• Stripe — Payment processing for PFR gate fees. Stripe receives email addresses and payment amounts. Stripe is PCI DSS Level 1 compliant and maintains its own privacy policy.
• SMTP Provider — Transactional email delivery. The provider receives recipient email addresses and names for message routing.
• Anthropic (Claude API) — AI-powered financial scoring and report generation. See Section 4 above.
• Neon — PostgreSQL database hosting (AWS us-east-1). All platform data is stored in Neon-managed databases with AES-256 encryption at rest.
• Netlify — Application hosting and serverless function execution. Netlify processes HTTP requests and serves static assets.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

6. Data Storage & Security

We implement technical and organizational measures to protect your data:

• Encryption at rest: All database contents are encrypted with AES-256 (managed by Neon).
• Encryption in transit: All connections use TLS 1.3 (enforced via sslmode=require for database connections; HTTPS enforced for all web traffic).
• Password security: Passwords are hashed using bcrypt (12 rounds) and checked against known breach databases (HIBP) at registration.
• Access controls: Role-based access control (RBAC) restricts data visibility. Agents see only their own clients and submissions. Admins access broader data as needed for platform operations.
• Audit logging: Administrative actions, role changes, impersonation sessions, and data exports are logged in an immutable audit trail retained for 7 years.
• Security headers: X-Frame-Options: DENY, X-Content-Type-Options: nosniff, strict Referrer-Policy, and restrictive Permissions-Policy are enforced on all responses.
• Environment isolation: Development, staging, and production environments use separate databases and credentials.
• Rate limiting: Public endpoints (registration, PFR submission, invitation requests) are rate-limited per IP address.

7. Cookies & Session Management

We use cookies and similar technologies for essential platform operations:

• Authentication cookies: Database-backed session tokens (httpOnly, SameSite=lax) that identify your logged-in session. These are strictly necessary and cannot be disabled.
• Theme preference: A cookie storing your light/dark mode selection to prevent visual flash on page load.
• Locale preference: A cookie storing your language selection (English, Spanish, or French).
• Cookie consent: A cookie recording your cookie consent preferences.

We do not use third-party advertising or tracking cookies. We do not use Facebook Pixel, Google Analytics, or similar marketing trackers.

8. Data Retention & Deletion

We retain data for the following periods:

• Active user accounts: Retained for the lifetime of the account.
• Deactivated accounts: Profile data retained for 90 days after deactivation, then eligible for permanent deletion.
• PFR submissions & client records: Soft-deleted (not permanently erased) to support insurance compliance and potential audit requirements.
• Audit logs: Retained for 7 years per financial services regulatory guidance.
• Session data: Expired 30 days after last use.
• Email delivery logs: Retained on a 12-month rolling basis.
• Failed login attempts: Retained for 90 days for security monitoring.

When data is "soft-deleted," it is marked as inactive and excluded from normal platform operations, but may be retained in the database for compliance purposes. Permanent deletion is available upon explicit request to a Super Admin.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Export: Request a full export of your data in CSV format. Admins can generate exports via the platform; individual requests can be made via email.
• Correction: Request that we correct inaccurate personal information.
• Deletion: Request deletion of your account and associated data, subject to our retention obligations for compliance (e.g., audit logs, insurance records).
• Consent withdrawal: Withdraw consent for data processing at any time. Note that withdrawing consent may prevent you from using certain platform features.
• Opt-out: Opt out of non-essential communications at any time via your notification preferences.

To exercise any of these rights, contact us at support@thewinnerscirclegrp.com. We will respond to verified requests within 30 days.

10. Consent Tracking

We maintain verifiable records of consent for data processing:

• Agent consent: Tracked via the UserConsent model — records what was consented to, when consent was granted, and when (if ever) it was withdrawn.
• Prospect consent: Before submitting financial data through the PFR system, prospects are presented with a compliance disclaimer and must explicitly agree. Each agreement is recorded with the signee's email, name, IP address, user agent, timestamp, and linked PFR submission ID.

11. Children's Privacy

The Winners Circle Group platform is designed for licensed financial professionals and their adult clients. We do not knowingly collect personal information from individuals under the age of 18. If we learn that we have inadvertently collected data from a minor, we will take steps to delete that information promptly. If you believe a minor has provided us with personal data, please contact us at support@thewinnerscirclegrp.com.

12. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify affected users via email or in-platform notification. Continued use of the platform after changes are posted constitutes acceptance of the revised policy.

13. Contact

If you have questions about this Privacy Policy, wish to exercise your data rights, or have concerns about our data practices, please contact us:

• General & Data Requests: support@thewinnerscirclegrp.com
• Security Concerns: security@thewinnerscirclegrp.com
• Mailing Address: 70 E Sunrise Highway, Ste 501, Valley Stream, NY 11581