Effective Date: June 2026
TOLIReview is operated by Financial Planner AI, LLC ("FPAI," "we," "us," or "our"), a New Jersey limited liability company. This Privacy Policy describes how we collect, use, and protect information when authorized users access TOLIReview.
Important Clarification:This Privacy Policy does not govern data processed within TOLIReview under an executed Enterprise Pilot Agreement, Master Services Agreement, Order Form, or similar written agreement (each, an "Enterprise Agreement"). Platform data processing is addressed separately through the applicable Enterprise Agreement, including its security, data protection, and AI governance provisions. In the event of a conflict, the Enterprise Agreement controls.
TOLIReview is designed for authorized professional and enterprise users involved in trust-owned life insurance review, fiduciary documentation, and trust administration support. It is not a consumer product and is not offered for general public or self-service direct access.
Account and access information: Email address, name, firm or organization name, professional role, and access credentials, collected when your organization provisions access under an applicable Enterprise Agreement.
Uploaded documents: Carrier in-force policy illustrations you upload for analysis. These documents may contain personal identifying information about trust beneficiaries, insureds, or policy owners. See Section 3 for how uploaded documents are handled.
Intake responses: Your answers to the seven trust context questions that shape each review, including trust purpose, authority model, obligation period, and funding status. These are used to generate your review and stored with your account.
Generated content: Fiduciary review findings, duration analysis, and PDF reports generated from your uploaded illustration and intake responses.
Usage and communications data: Basic interaction data including timestamps, session information, and access logs, used for platform maintenance and improvement. Any correspondence you send us, including support inquiries and feedback.
TOLIReview applies automated best-effort technology to identify and remove common personal identifiers from uploaded policy illustrations before AI processing. This redaction is not architecturally enforced client-side and does not provide the same level of certainty as a client-side redaction architecture. Automated redaction is not perfect and may fail to identify all personal information.
You are solely responsible for determining whether to redact sensitive information before upload and for compliance with applicable privacy and confidentiality obligations, including GLBA, state trust privacy laws, and professional conduct rules.
Document data is processed by AI services through enterprise API endpoints where providers are contractually restricted from using submitted data for model training. AI providers may retain submitted inputs and outputs for limited periods for service operation, abuse monitoring, security, or legal compliance in accordance with their applicable API data processing terms. FPAI will not opt in to model training or data-sharing programs. Processing is configured for United States-based infrastructure where supported by providers.
We use collected information to create and manage accounts, process uploaded illustrations and generate fiduciary review reports, send transactional communications, maintain and improve TOLIReview, respond to inquiries, and comply with legal obligations.
We do not sell personal information to third parties, use data for targeted advertising, train AI models on uploaded documents or generated reports, share data with data brokers or marketing aggregators, or use third-party advertising trackers.
We use a limited number of enterprise-grade third-party providers for essential services including authentication, database hosting, AI analysis, and web infrastructure. These providers are selected for their security certifications and contractual commitments regarding data protection. For enterprise users, a list of current sub-processors is provided in the applicable Enterprise Agreement or available upon request.
We may disclose information if required by law, court order, or government request, or to protect the rights, property, or safety of FPAI or others. In connection with a merger, acquisition, or sale of assets, information may be transferred to the successor entity with prior notice.
Uploaded illustrations, intake responses, and generated reviews are stored while your account remains active, subject to the applicable Enterprise Agreement. You or your organization's administrator may delete or request deletion of data where deletion controls are available, or by contacting rpc@financialplanner-ai.com.
Infrastructure providers may retain deleted data in backup systems for up to 90 days. After applicable backup-retention periods, deleted data is intended to be purged in accordance with provider processes. For enterprise users, data retention and deletion are governed by the applicable Enterprise Agreement.
We implement commercially reasonable security measures including encryption of data in transit and at rest, access controls, and vendor security due diligence. Infrastructure providers maintain enterprise-grade security certifications. No security measures are perfect or impenetrable. You are responsible for maintaining the confidentiality of your account credentials.
Depending on your location, you may have rights under applicable privacy laws, including the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), or equivalent regulations. These may include rights to access, correct, delete, or port your data. We do not sell personal information. For authorized users, certain requests may need to be coordinated with your organization's administrator or handled according to the applicable Enterprise Agreement. To exercise any privacy rights, contact rpc@financialplanner-ai.com. We will respond within 30 days.
TOLIReview uses only essential cookies required for authentication and session management. We do not use tracking cookies, advertising cookies, or third-party analytics cookies.
TOLIReview is intended for business professionals and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children.
We may update this Privacy Policy from time to time. Material changes will be reflected by updating the effective date above. For users operating under an executed Enterprise Agreement, amendments to this Privacy Policy do not modify the data protection, security, or privacy terms of that agreement without mutual written consent.
Financial Planner AI, LLC
Email: rpc@financialplanner-ai.com
Last Updated: June 2026
© 2026 Financial Planner AI, LLC. All rights reserved. TOLIReview and Financial Planner AI are proprietary designations of Financial Planner AI, LLC.