Terms of Service

1. Acceptance of Terms

By accessing and using Lumis Life (“the Service”), you accept and agree to be bound by the terms and conditions of this agreement. If you do not agree to these terms, you should not use the Service.

2. Description of Service

Lumis Life provides analytical tools and mortality projections for life settlement analysis. The Service is designed for use by licensed financial professionals, insurance advisors, and institutional investors. The Service does not provide financial, legal, tax, or investment advice.

3. User Accounts and Eligibility

You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to immediately notify us of any unauthorized use of your account. You represent that you are at least 18 years old and have the legal authority to enter into this agreement on behalf of yourself or the entity you represent.

4. Acceptable Use

You agree not to use the Service for any unlawful purpose or in violation of any applicable regulations, including but not limited to insurance and securities regulations. You agree not to attempt to gain unauthorized access to the Service or its related systems.

5. Analytical Disclaimer

Mortality projections and financial analyses provided by the Service are based on actuarial models and publicly available mortality tables. Actual outcomes may differ materially from projected outcomes. Past performance and statistical projections do not guarantee future results. All models involve assumptions and simplifications that may not reflect individual circumstances.

6. Health Data and Medical Information

The Service collects health-related information (including medical conditions, tobacco use, and biometric data) solely for the purpose of generating mortality projections. The Service does not provide medical advice, diagnosis, or treatment. Health data entered into the Service is not a substitute for professional medical evaluation.

HIPAA Non-Coverage: Lumis Life is not a covered entity or business associate under HIPAA. The Service does not provide HIPAA-compliant data storage or handling. You should not use the Service as a repository for Protected Health Information (PHI) subject to HIPAA requirements.

Third-Party Data Responsibility: If you enter health or personal data about a third party (such as an insured individual), you represent and warrant that you have obtained appropriate consent or authorization to do so and that your use complies with all applicable privacy laws. Lumis Life is not responsible for your compliance with privacy regulations governing the data you submit.

7. Intellectual Property

The Service and its original content, features, and functionality are owned by Lumis Life and are protected by international copyright, trademark, and other intellectual property laws. Reports generated through the Service may be used by subscribers for their professional purposes.

8. Disclaimer of Warranties

9. Limitation of Liability

In no event shall Lumis Life, its directors, employees, partners, or affiliates be liable for any indirect, incidental, special, consequential, or punitive damages, including without limitation, loss of profits, data, use, or goodwill, arising from your use of the Service. Our total liability shall not exceed the amount you paid for the Service in the twelve (12) months prior to the claim.

This limitation applies regardless of the theory of liability (contract, tort, strict liability, or otherwise) and even if Lumis Life has been advised of the possibility of such damages. Some jurisdictions do not allow the exclusion of certain warranties or limitation of liability for consequential or incidental damages, so the above limitations may not apply to you in their entirety.

10. Indemnification

You agree to indemnify, defend, and hold harmless Lumis Life, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

• Your use of the Service or any activity under your account;
• Your violation of these Terms or any applicable law or regulation, including state insurance and life settlement regulations;
• Your submission of data about third parties (including insureds) without proper authorization or consent;
• Any claim by a client, insured, beneficiary, or third party arising from your use of the Service, including claims related to the adequacy of your suitability analysis, fiduciary duties, or disclosure obligations;
• Your violation of the data use restrictions, non-circumvention provisions, or broker/advisor obligations described in these Terms;
• Any content you submit through the Service, including broker reviews.

Lumis Life reserves the right to assume the exclusive defense and control of any matter subject to indemnification by you, in which event you will cooperate with Lumis Life in asserting any available defenses.

11. Reports, Billing, and Payments

Report Packs: The Service uses a report-based system. Each assessment submission consumes one (1) report. Reports may be purchased individually or in packs at the prices displayed at the time of purchase. Report purchases are processed through Stripe and are non-refundable except as required by applicable law. Reports do not expire and have no cash value.

Firm Report Pools: Users who are members of a firm share a firm-level report pool. Reports purchased by firm members are added to the firm pool. Report consumption draws from the firm pool first, then from any personal reports.

Settlement Upgrade Fee: Advisors who upgrade a longevity report to a full settlement assessment are charged a one-time $99 upgrade fee via Stripe, in addition to consuming one (1) report from their balance. The upgrade fee covers policy strategy analysis, marketability scoring, suitability assessment, and marketplace eligibility determination. Settlement upgrade fees are non-refundable once the assessment has been processed.

Lead Fees: Brokers are charged a per-connection lead fee when an advisor accepts their interest in a marketplace listing. Lead fee amounts are determined by the face amount range of the listed policy and are displayed to the broker before interest is expressed. Lead fees are charged via Stripe and are subject to the refund policy in Section 14.

Price Changes: We reserve the right to change report pack prices and lead fee tiers upon thirty (30) days' notice. Price changes do not affect reports already purchased or lead fees already displayed on active listings.

12. Broker Marketplace

Platform Role: Lumis Life operates a marketplace that connects financial advisors with life settlement brokers. Lumis Life is not a life settlement broker, dealer, or provider. We do not buy, sell, facilitate, or participate in the sale of life insurance policies. The marketplace provides anonymized case data and introductions only.

Anonymized Data: Case listings display anonymized policy data only (face amount ranges, life expectancy ranges, age bands, carrier letter ratings). Insured personal information, including name, date of birth, exact amounts, health conditions, and carrier name, is never disclosed through the marketplace. Advisors may share additional details at their discretion after a connection is established.

Broker Obligations: Brokers must maintain all required state licenses and comply with applicable life settlement regulations. Brokers agree not to solicit insureds directly and acknowledge that all contact must be initiated through the connected advisor. Brokers shall not attempt to re-identify insured individuals from anonymized listing data, cross-reference marketplace data with external databases, or use any information obtained through the marketplace to contact insureds or their families without the advisor's explicit written authorization.

Advisor Obligations: Advisors are responsible for obtaining appropriate client consent before listing a case on the marketplace and for ensuring any subsequent engagement with a broker is in the client's best interest. Advisors must maintain documentation of client consent and are encouraged to use the platform-provided consent template. Advisors are responsible for evaluating broker suitability using the reputation and review data available on the platform.

13. Non-Circumvention

Restriction: For a period of twenty-four (24) months following any introduction made through the marketplace, both advisors and brokers agree not to conduct transactions on cases introduced through the Service while bypassing the platform to avoid lead fees. This includes referring the case to a third party for the purpose of circumventing marketplace fees.

Scope: This restriction applies only to specific case introductions made through the marketplace (i.e., where a broker expressed interest and was connected to an advisor for a particular listing). It does not restrict advisors or brokers from conducting unrelated business with each other or from using other channels for cases that were never listed on the platform.

Liquidated Damages: In the event of circumvention, the circumventing party agrees to pay liquidated damages equal to three (3) times the applicable lead fee that would have been charged through the marketplace, plus reasonable attorneys' fees and costs incurred in enforcement. The parties agree this amount is a reasonable estimate of damages that would be difficult to calculate precisely.

14. Lead Fee Refund Policy

General Rule: Lead fees are non-refundable. The fee is charged for the introduction between advisor and broker, not for the outcome of any subsequent settlement transaction. A refund will not be issued because a case does not result in a completed settlement.

Exceptions: A refund may be issued at Lumis Life's sole discretion in the following circumstances: (a) the advisor provided materially inaccurate case data that rendered the listing fundamentally misrepresentative; (b) a verified platform error caused an unintended connection or duplicate charge; or (c) the advisor's account is found to have been compromised and the connection was unauthorized. Refund requests must be submitted within fourteen (14) days of the connection date.

15. Suitability Assessments and Compliance Documentation

Suitability Score: The Service generates suitability assessments that evaluate whether a life settlement may be appropriate for a given client based on factors including settlement value uplift, strategy comparison, beneficiary dependency, coverage replaceability, tax efficiency, and premium burden. These scores are analytical tools and do not constitute a recommendation, endorsement, or determination of suitability under any state or federal regulation.

Compliance Documentation: The Service generates fiduciary checklists, decision trees, tax treatment summaries, and conversation guides as educational tools for advisors. These documents are designed to support — not replace — the advisor's independent professional judgment and fiduciary analysis. Advisors remain solely responsible for determining suitability and for complying with all applicable regulations, including state life settlement act requirements.

Audit Trail: The platform maintains timestamped records of assessment creation, client consent attestation, marketplace activity, and broker interactions. These records are available to advisors through their account and may be useful for regulatory compliance documentation. However, Lumis Life does not warrant that use of the platform satisfies any specific regulatory requirement.

16. Broker Reviews and Reputation

Review System: After a marketplace connection, advisors may rate brokers on responsiveness, professionalism, and offer quality. Reviews are public to other advisors on the platform and are intended to help advisors make informed decisions when selecting brokers.

Review Guidelines: Reviews must be truthful, based on the advisor's actual experience with the broker, and may not contain defamatory, discriminatory, or harassing content. Lumis Life reserves the right to remove reviews that violate these guidelines. Brokers may report reviews they believe are inaccurate or retaliatory.

No Guarantee: Reputation scores and review data reflect the subjective assessments of individual advisors and are not verified by Lumis Life. A high reputation score does not constitute an endorsement or guarantee of broker performance, licensing status, or regulatory compliance.

User-Generated Content: Reviews are user-generated content. Lumis Life is not the author or publisher of broker reviews and does not adopt, endorse, or verify the opinions expressed in them. Pursuant to Section 230 of the Communications Decency Act (47 U.S.C. § 230), Lumis Life shall not be treated as the publisher or speaker of any review submitted by a user. Users who submit reviews are solely responsible for the content of those reviews and any liability arising from them.

17. Account Termination

Termination by You: You may close your account at any time by contacting us at support@lumislife.com or through your account settings. Upon closure, your access to the Service will cease immediately. Unused reports are non-refundable and non-transferable.

Termination by Lumis Life: We may suspend or terminate your account with or without cause upon written notice (which may be sent via email) in the following circumstances:

• For cause (immediate): Violation of the data use restrictions (Section 12), non-circumvention provisions (Section 13), acceptable use policy (Section 4), or any fraudulent, abusive, or illegal activity;
• For material breach (with cure period): Violation of other terms, with fourteen (14) days' written notice and an opportunity to cure the breach;
• Without cause: Upon thirty (30) days' written notice for any reason, with a pro-rata refund of any unused report packs purchased within the prior ninety (90) days.

Effect of Termination: Upon termination: (a) all active marketplace listings will be withdrawn; (b) any pending broker interests will be auto-declined; (c) assessment data will be retained for ninety (90) days and then deleted, unless earlier deletion is requested; (d) existing lead connections and associated advisor/broker contact information already revealed will not be revoked; (e) unused reports are forfeited unless the termination is without cause, in which case the pro-rata refund described above applies.

18. Dispute Resolution

Informal Resolution: Before initiating formal proceedings, the parties agree to attempt to resolve any dispute arising from these Terms or the Service through good-faith negotiation. The complaining party shall send written notice describing the dispute to the other party. The parties shall have thirty (30) days to resolve the dispute informally.

Arbitration: If informal resolution fails, any dispute shall be resolved by binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules. The arbitration shall be conducted by a single arbitrator in Delaware. Each party shall bear its own costs, except as otherwise provided in these Terms.

Class Action Waiver: To the fullest extent permitted by law, you agree that any dispute resolution proceeding will be conducted on an individual basis and not as part of a class, consolidated, or representative action.

Governing Law: These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law provisions.

Injunctive Relief: Notwithstanding the arbitration clause above, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to prevent the actual or threatened infringement or misappropriation of intellectual property rights, violation of data use restrictions, or breach of the non-circumvention provisions, without first engaging in arbitration.

19. Force Majeure

Lumis Life shall not be liable for any failure or delay in performing its obligations under these Terms (including but not limited to Service availability, marketplace listing expiration, email delivery, or payment processing) where such failure or delay results from circumstances beyond its reasonable control, including but not limited to: acts of God, natural disasters, epidemics, government actions, war, terrorism, labor disputes, power failures, Internet or telecommunications failures, cyberattacks, or failures of third-party service providers (including Stripe, cloud hosting providers, and email delivery services).

In the event of a force majeure event lasting more than thirty (30) consecutive days, either party may terminate the affected portion of the agreement upon written notice. Where a force majeure event causes a marketplace listing to expire without the advisor's ability to extend it, Lumis Life will make reasonable efforts to restore or re-list the affected listing once the event has resolved.

20. Changes to Terms

We reserve the right to modify these terms at any time. We will provide at least fifteen (15) days' notice of material changes via email or through the Service before they take effect. Your continued use of the Service after the effective date of such modifications constitutes acceptance of the updated terms. If you do not agree to the modified terms, you must stop using the Service before the changes take effect.

21. General Provisions

Entire Agreement: These Terms, together with the Privacy Policy and any other policies referenced herein, constitute the entire agreement between you and Lumis Life regarding the use of the Service and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, whether written or oral.

Severability: If any provision of these Terms is held to be unenforceable or invalid by a court of competent jurisdiction, that provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect. The unenforceable provision shall be modified to the minimum extent necessary to make it enforceable while preserving its original intent.

Survivability: The following sections shall survive any termination or expiration of these Terms: Disclaimer of Warranties (Section 8), Limitation of Liability (Section 9), Indemnification (Section 10), Non-Circumvention (Section 13), Dispute Resolution (Section 18), and this General Provisions section (Section 21), as well as any other provisions that by their nature should survive.

Waiver: The failure of Lumis Life to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver must be in writing and signed by an authorized representative of Lumis Life.

Assignment: You may not assign or transfer these Terms or your rights hereunder without the prior written consent of Lumis Life. Lumis Life may assign these Terms without restriction in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets.

Notices: All notices required or permitted under these Terms shall be in writing and shall be deemed given when sent to the email address associated with your account (for notices to you) or to legal@lumislife.com (for notices to Lumis Life).

22. Contact

If you have questions about these Terms of Service, please contact us at legal@lumislife.com.