Risk Free Retirement Co.
Risk Free Retirement Co.

Privacy Policy

Last updated: January 27, 2026

1. Introduction

This Privacy Policy describes how Marco Palumbo dba Risk Free Retirement Co ("Company," "we," "us," or "our") collects, uses, and shares personal information when you visit our websites, watch our videos, submit forms, or schedule calls with us.

As a New York–licensed life and health insurance producer, we are subject to federal and state privacy laws governing the collection and handling of personal and financial information, including the Gramm-Leach-Bliley Act (GLBA), the New York Stop Hacks and Improve Electronic Data Security Act (SHIELD Act), and applicable New York Department of Financial Services regulations.

By accessing our website or providing your information (for example, through a form, Calendly booking, or phone call), you agree to this Privacy Policy.

2. Information We Collect

We may collect the following types of information directly from you:

  • Contact details: name, email address, phone number, mailing address.
  • Demographic information: age range, marital status, state of residence.
  • Financial profile information: approximate assets, retirement savings, business sale proceeds, risk tolerance, investment objectives, and time horizon.
  • Appointment details: date and time of calls, notes you provide when scheduling, and your responses on any pre-call questionnaire.
  • Communications: emails, messages, and notes from calls or meetings.
  • Insurance application data: if you choose to apply for a product, we may collect additional information required by the issuing insurance carrier, including health history, beneficiary designations, existing policy information, and financial suitability data.

Certain information you provide — including financial data, health-related information, and insurance application details — constitutes "nonpublic personal information" (NPI) as defined under the Gramm-Leach-Bliley Act. We treat all NPI with heightened safeguards as described in this policy.

We may also automatically collect:

  • Device and usage data: IP address, browser type, pages visited, time on site, referring URL.
  • Cookies and similar technologies to analyze site usage and improve performance.

3. How We Use Your Information

We use your information to:

  • Provide information about retirement strategies, annuities, and related life and health insurance products.
  • Schedule and conduct calls or meetings, including the "Risk-Free Retirement Blueprint" call.
  • Analyze your situation and prepare personalized retirement income illustrations and product proposals.
  • Conduct suitability and best-interest analyses as required under New York Regulation 187.
  • Communicate with you about appointments, follow-up, and related offers.
  • Operate, maintain, and improve our website, funnels, and marketing campaigns.
  • Comply with legal, regulatory, and record-keeping obligations under New York Insurance Law and applicable regulations.

4. How We Share Your Information

We may share your information with the following categories of recipients:

  • Service providers and vendors who help us operate our website, scheduling tools (such as Calendly), CRM, email systems, or advertising platforms. These providers are contractually obligated to use your information only for the purposes we specify.
  • Insurance carriers and marketing organizations as needed to evaluate, underwrite, place, or service annuity and life/health insurance products that you request or authorize. Once an application is submitted to a carrier, that carrier's own privacy policy governs its handling of your data.
  • Compliance partners and intermediaries as necessary to satisfy regulatory requirements, including suitability reviews, anti-money laundering checks, and continuing education or licensing obligations.
  • Government and regulatory bodies when required by law, regulation, subpoena, or government request, including requests from the New York State Department of Financial Services.
  • Business transfer in connection with a merger, acquisition, or sale of assets, in which case your information would be among the transferred assets and the successor entity would be bound by this policy.

We do not sell your personal information for unrelated third-party marketing purposes.

5. Gramm-Leach-Bliley Act (GLBA) Notice

As an insurance producer, we are a "financial institution" under the Gramm-Leach-Bliley Act (15 U.S.C. §§ 6801–6809). We deliver our initial GLBA privacy notice to you by mail at or before the time we establish a customer relationship. The information below mirrors the content of that mailed notice and is provided here for your convenience.

Categories of NPI we collect: We collect the categories of nonpublic personal information described in Section 2 above, including information you provide on forms, during phone calls, and through the insurance application process.

Categories of NPI we disclose: We may disclose NPI to the categories of third parties described in Section 4 above, including insurance carriers, marketing organizations, and service providers, as necessary to process your insurance applications, service your policies, and comply with legal requirements.

Your opt-out rights: Before we share your nonpublic personal information with any non-affiliated third party for purposes other than processing your insurance transaction or as otherwise permitted by law, we will provide you with a reasonable opportunity to opt out of such sharing. You may exercise your opt-out right at any time by contacting us using the information in the "Contact Us" section below. If you opt out, we will continue to share information as necessary to process and service any insurance products you have requested or purchased, and as otherwise required or permitted by law.

Former customers: We apply the same privacy protections to information about former customers as we do to information about current customers.

Confidentiality and security: We restrict access to your NPI to those employees, agents, and service providers who need it to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with applicable federal and state standards to protect your NPI.

6. Insurance Application and Carrier Data

If you decide to apply for an annuity or other insurance product, your application data will be submitted to one or more insurance carriers for underwriting and approval. Once submitted:

  • The issuing carrier becomes an independent data controller with respect to your application and policy data.
  • The carrier's own privacy policy — which will be provided to you with your policy documents — governs how the carrier collects, uses, stores, and shares your information.
  • We retain copies of application materials and related correspondence in accordance with New York record-keeping requirements (generally no fewer than six years after the termination of the business relationship).

We encourage you to review the privacy policy of any carrier whose products you are considering.

7. Cookies and Tracking Technologies

We may use cookies, pixels, and similar technologies to:

  • Remember your preferences and improve user experience.
  • Measure performance of our VSL, landing pages, and advertising.
  • Run retargeting or look-alike advertising campaigns on platforms such as Google, Facebook, or others (subject to their terms).

You can usually control cookies via your browser settings, but disabling cookies may affect site functionality.

8. Data Security

We maintain physical, electronic, and procedural safeguards designed to protect your personal information from unauthorized access, use, alteration, or disclosure. These safeguards are designed to comply with the requirements of the New York SHIELD Act (N.Y. Gen. Bus. Law § 899-bb) and include:

  • Reasonable administrative safeguards, such as designating employees to coordinate security practices and assessing risks to the confidentiality of private information.
  • Reasonable technical safeguards, such as encryption of private information transmitted over public networks and secure access controls.
  • Reasonable physical safeguards, such as secure storage and disposal of records containing private information.

Breach notification: In the event of a breach of the security of your private information, we will notify you and the appropriate state authorities in accordance with the NY SHIELD Act and any other applicable breach notification laws. Notification will occur in the most expedient time reasonable and without unreasonable delay, consistent with the legitimate needs of law enforcement and any measures necessary to determine the scope of the breach.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security of your information.

9. Retention of Your Information

We retain your personal information for as long as necessary to provide services, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. Under New York Insurance Law and regulations, we are required to maintain certain records for a minimum period (typically six years) following the conclusion of a transaction or business relationship. We will securely dispose of personal information that is no longer needed for these purposes.

10. Your Rights and Choices

As a New York resident or customer of a New York–licensed insurance producer, you have the following rights:

  • Access and correction: You may request access to the personal information we hold about you and ask us to correct any inaccuracies. We will respond to such requests within a reasonable timeframe.
  • Deletion: You may request deletion of certain personal information, subject to our legal and regulatory obligations to retain records (including New York Insurance Law record-keeping requirements and the GLBA).
  • Opt-out of NPI sharing: As described in Section 5, you may opt out of certain sharing of your nonpublic personal information with non-affiliated third parties.
  • Marketing opt-out: You may opt out of marketing communications at any time by using the unsubscribe link in our emails, replying "STOP" to any text message, or contacting us directly. Opting out of marketing does not affect transactional communications related to your existing insurance products or pending applications.
  • Do-not-call: You may request to be placed on our internal do-not-call list at any time. We honor the National Do Not Call Registry and New York State do-not-call requirements.

To exercise any of these rights, contact us using the information in the "Contact Us" section below. We will not discriminate against you for exercising your privacy rights.

11. Communication Preferences

When you submit a form or book a call through our website, you consent to receive communications from us related to your inquiry, including by phone, email, and text message. You may adjust your communication preferences at any time:

  • Email: Unsubscribe using the link at the bottom of any marketing email. Transactional emails related to your appointments or active applications are not subject to marketing opt-out.
  • Text messages (SMS): Reply "STOP" to any text message to opt out. Standard message and data rates may apply. We will not send marketing text messages without your prior consent.
  • Phone calls: Request to be added to our internal do-not-call list by calling (917) 663-6562 or emailing info@financialfreedomhub.net. We comply with the Telephone Consumer Protection Act (TCPA), FTC Telemarketing Sales Rule, and New York General Business Law Article 29-A (do-not-call provisions).

12. Third-Party Links and Tools

Our website or funnels may link to third-party sites or use third-party tools (such as Calendly, Zoom, payment processors, or advertising platforms). We are not responsible for the privacy practices of those third parties, and their policies will govern your use of their sites and services. We encourage you to review the privacy policies of any third-party services you access through our website.

13. Children's Privacy

Our services and content are intended for adults and are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18, and if we learn that we have done so, we will delete such information promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. If we make material changes to how we handle your nonpublic personal information, we will provide you with a revised GLBA privacy notice by mail. Your continued use of our sites or services after any changes means you accept the revised policy.

15. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise any of your privacy rights, contact:

Marco Palumbo
dba Risk Free Retirement Co
3189 Judith Dr.
Bellmore, NY 11710
Phone: (917) 663-6562
Email: info@financialfreedomhub.net