How and why we obtain personal information

LegacyWay takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. LegacyWay may collect public and non-public personal information about you from any of the following sources:

  • You or your representative on applications or forms (e.g., name, address, Social Security number, birth date, assets, and income)
  • Transactional activity in your account
  • Other interactions with LegacyWay (e.g., discussions with our staff, or information you enter into our websites)
  • Information from other third-party data services
  • You or your representative regarding your preferences (e.g., your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
  • To apply or enforce agreements between you and LegacyWay
  • Other sources with your consent or with the consent of your representative (e.g., from other institutions)

Please note that information by which you cannot be identified (e.g., anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

How we protect information about you

LegacyWay considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology. At LegacyWay, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.

How we share information about you with third parties

LegacyWay does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

  • Government agencies, other regulatory bodies or law enforcement officials (e.g., for tax purposes)
  • Other organizations as permitted or required by law (e.g., for fraud prevention or to respond to a subpoena)

How we share information about you within LegacyWay

We may share personal information about you with various LegacyWay affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Information collected from our customers is not shared with LegacyWay affiliates for marketing purposes, except with your consent and as allowed by law.

Your digital privacy

Privacy, security, and service in LegacyWay’s online operations are just as critical as in the rest of our business. We may use firewall barriers, encryption techniques, and authentication procedures, among other controls, to maintain the security of your online session and to protect LegacyWay accounts and systems from unauthorized access.

When you interact with us by using our websites, online services or mobile applications that are owned and controlled by LegacyWay (“our digital offerings”), LegacyWay manages personal information in accordance with all of the practices and safeguards described previously.

When you use our digital offerings, we may collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the LegacyWay website design and functionality, and personalizing your experience.

Cookies and similar technologies

LegacyWay and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device (e.g., computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. LegacyWay cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You may be able to refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may experience difficulty signing in and accessing your account, or we may not be able to recognize you, your device, or your online preferences.

Protecting children’s privacy online

LegacyWay websites are not directed to individuals under the age of 13. LegacyWay does not intentionally collect information on LegacyWay websites from those we know are under 13, and we request that these individuals do not provide personal information through the sites.

Other information

Our Web servers automatically log the IP/Internet address of your computer, the browser type, and browser version you are using. Forms you submit to us may also automatically log this information, as well as the date and time the form was submitted. Under no circumstances does this information identify you personally. You remain anonymous unless you have otherwise provided this website with personal information.

The personal data we collect

Here are the kinds of personal data we may collect when you create an account or use our services:

  1. Information that identifies you, for example:
    • First and last name
    • Address
    • Phone number
    • Email
    • IP address
    • Information collected from cookies or other tracking technologies
  2. Records and financial information, for example:
    • Social Security Number
    • Government-issued identification
    • Bank account and routing numbers
    • Credit and debit card information
    • Financial information
  3. Personal characteristics, for example:
    • Age
    • National origin
    • Disability
    • Citizenship
    • Military status
  4. Geolocation data, for example:
    • Global Positioning System (GPS) information when you give us permission through your device settings
    • IP-based geolocation
  5. Professional or employment information, for example:
    • Business information, contact emails and phone numbers
    • Tax IDs

Why we collect personal data

We collect personal data for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal data include:

  • Run our sites and provide better services, including to help you send or request money, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date
  • Manage and improve our business. For example, we may do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected
  • Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants
  • Send you marketing information about our products and services. We use personal data to better understand and cater to your interests
  • Contact you when you need us, such as answering a question you sent to our customer service team
  • Comply with laws and enforce our agreements with you and other people who use our services

How and why we share personal data

We may share personal data with:

  • Financial institutions
  • Credit reporting and collections agencies
  • Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires LegacyWay or members of our corporate family to respond
  • People involved in a transaction, such as other users or merchants and their service providers
  • Third parties that you asked us to connect with, such as other financial or social media apps. If you want us to stop sharing information with a third party, disconnect your account from that third party
  • Third-party tools used to help fight spam and abuse

Notice to residents of EU.

If you are a European resident, you have certain rights under the European Union General Data Protection Regulation (“GDPR”).

Your rights under the GDPR:

  • Right to access: You have the right to request access to any of your personal data that LegacyWay has collected
  • Right to rectify: If we have collected inaccurate personal data relating to you, you have a right to ask to have it rectified or completed
  • Right to delete: You have the right to request that LegacyWay delete any personal data we have collected
  • Right to restrict: You have the right to restrict the way that LegacyWay processes your information and utilizes any personal data we have collected
  • Right to data portability: You have the right to receive your personal data in a format that is structured and machine-readable
  • Right to object: You may have the right to request that LegacyWay stop processing your personal data

If you would like to exercise any of these rights, please contact us at [email protected]. Please include your contact information and which rights you are exercising.

Additionally, if you are a European resident, please note that we will be processing your information in order to respond to requests that you make to us (e.g., if you ask us through the website to contact you), or otherwise to pursue our legitimate business interests. Also please note that your information will be transferred outside of Europe to the United States.

Effective date and updates

The effective date of this Privacy Policy is November 1, 2021.

LegacyWay reserves the right to change the organization’s Privacy Policy at any time by posting a new or revised Privacy Policy on its website. An individual’s continued use of LegacyWay’s website or other LegacyWay services after a new or revised Privacy Policy is posted on the website constitutes acceptance of any such changes to the Privacy Policy.