Privacy Policy

This Privacy Policy is effective as of April 1, 2025, and represents the Privacy Policy of The Money School LLC (“The Money School LLC,” “we,” “our,” or “us”).

This Privacy Policy addresses the privacy rights of individuals who:

visit our Websites 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, or who interact with us via the use of online meeting or seminar platforms including (but in no way limited to Zoom, Google Meet, or Microsoft Teams).

This 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

“Company Personnel” means any party or parties that is or are employees, agents, contractors, or otherwise authorized representatives of The Money School LLC, including but in no way limited to Independent Insurance Agents.

“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.

“Independent Insurance Agent(s)” A licensed insurance professional who is not an employee, of The Money School 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 Websites 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 sale 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.

“Websites” means all of the websites and applications maintained by us that display a link to the Privacy Policy, including (but in no way limited to) www.chrisnaugle.com, www.beyourownbanker.com, www.beyourownbank.com, www.companionbook.com, www.moneyschooltraining.com, and www.moneyschoolrei.com, along with other websites that we maintain and on which we display this Privacy Policy or a link to this Privacy Policy.

“Website Visitor” means an individual who visits the Websites.

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, financial information, financial goals and debt information and any other necessary information for effectively providing our services) 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 or Company Personnel, we may collect your Personal Data when you visit, browse, or register on our Websites, when you submit an application for employment or other engagement, when you provide additional Personal Data during the application and interview process, when you speak to our Company Personnel 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 but not limited to 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 or other engagement as Company Personnel;
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 compliance@beyourownbanker.com.

SMS Campaign Data Processing

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages. Your mobile information will not be sold or shared with third parties for promotional or marketing purposes.

AI-Driven Communications (SMS and Calling)

We may utilize artificial intelligence (AI), automated dialing systems, and synthetic or prerecorded voice technologies to facilitate inbound and outbound communications, including text messages (SMS/MMS) and telephone calls. When you interact with our communication channels or utilize our Services, these AI-driven systems may process your phone number, call recordings, text transcripts, and the inputs you provide. We may engage third-party service providers to facilitate AI-powered communications and related services. Such providers may process personal information on our behalf solely for the purpose of providing and improving these services and are contractually obligated to maintain the confidentiality and security of such information. We process this data to deliver customer support, manage account notifications, personalize your experience, and improve our automated services. All interactions remain subject to the data protection terms outlined in this policy, and your text messaging opt-in data will not be shared with third parties for promotional or marketing purposes. You may opt out of receiving automated text messages by replying “STOP” to any SMS message, subject to applicable legal and operational requirements. Opting out of marketing communications will not affect our ability to send transactional, service-related, or legally required communications

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;
Incident response protocols for unauthorized access or data breaches.

Cookies and Other Technologies

We automatically collect information about your use of our Websites 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 Websites and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Websites and Service. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session on our Websites. 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 Websites 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 Websites 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 Websites and Services who disable cookies will be able to browse certain areas of the Websites, but some features may not function as efficiently following such disabling.

We use third-party browser and mobile analytics services like Google Analytics in connection with the Services. These third-party 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 occurring in connection with using the Services and Websites, usage and performance data, and where data 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 compliance@beyourownbanker.com and we will take immediate steps to delete it.

Changes to Privacy Policy

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

Inquiries/Contact Us

You may have rights regarding your Personal Data depending on where you are located, your country of origin, and where your Personal Data is Processed. Please contact us at compliance@beyourownbanker.com if you have questions in this regard or if you wish to update your Personal Data.

Compliance with NYDFS Regulations

As a company operating under New York Insurance Law, we comply with applicable regulations, including (but not limited to):

Maintaining cybersecurity policies;
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 Websites 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 Category	Sources
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 to us directly or through your interactions with our Websites and 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 Websites 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 or through your interactions with our Websites and Services.
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)	Information you provide to us directly or through your interactions with our Websites and Services.
Professional or Employment-Related Information	Information you provide to us directly or through your interactions with our Websites and Services.
Inferences	Information you provide to us directly or through your interactions with our Websites and Services. Information provided by your current or former employer.
Audio, electronic, visual or similar information	Information you provide to us directly or through your interactions with our Websites and 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 have actual knowledge that we sell the personal information of minors under 16 years of age.

From time to time, we may sell or transfer certain data that you provide to us, including your name, address, and certain financial information that is not “Sensitive Information” under New York or California Law and which you have provided to us through one or more of the “Sources” set forth in the table above. This information is sold or transferred to our third party affiliated in order to facilitate marketing and lending opportunities that we believe could potentially be in your interests based upon the information provided. We do not and will not ever transfer or sell sensitive personal information such as account numbers or other information defined as sensitive personal information under applicable law. We do not and will not ever transfer or sell sensitive personal information such as account numbers or other information defined as sensitive personal information under applicable law. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

You have the right to opt out of the sale of your personal information by emailing such an opt-out request to compliance@beyourownbanker.com. You may also opt out of the sale of your personal information by emailing us at compliance@beyourownbanker.com

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 to exercise these rights as applicable under the CCPA by sending an email to compliance@beyourownbanker.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 we have made such a decision.

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.

If you have any questions or concerns regarding this Privacy Policy, please email compliance@beyourownbanker.com.