Legacy

Last Updated January 1, 2020

I. ABOUT THIS PRIVACY STATEMENT
II. HOW WE COLLECT, USE AND SHARE PERSONAL INFORMATION
III. ADDITIONAL INFORMATION ABOUT ONLINE INFORMATION
IV. CHOICES RELATED TO HOW WE USE PERSONAL INFORMATION
V. HOW WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
VI. CALIFORNIA CONSUMER PRIVACY ACT – RIGHTS FOR CALIFORNIA CONSUMERS

Legacy Finance and Realty Inc. and its Affiliates (as defined below) (collectively "LEGACY," "we," "us," or "our") respect your privacy and are committed to treating and using Personal Information (as defined below) about you responsibly.

I. ABOUT THIS PRIVACY STATEMENT

This Privacy Statement ("Statement") explains how LEGACY collects, uses and shares Personal Information, from or about you in connection with LEGACY products and services, as well as when you use LEGACY’s websites or mobile applications that link to this Statement (each, a “Site”, and collectively, “Sites”).

Throughout this Statement, we refer to "Personal Information", which means information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with you or your household. Personal Information does not include Public Information (for example, information from federal, state or local government records), Aggregated Information (information relating to multiple individuals that has been combined and grouped together, resulting in a data set that contains no personal information) or De-identified Information (information that is not attributable to an identified or identifiable individual).

This Statement also describes certain rights that California Consumers have under the California Consumer Privacy Act of 2018 (“CCPA”) with respect to their Personal Information. A “California Consumer” is a natural person who resides in California. For further information, please reference the “VI. CALIFORNIA CONSUMER PRIVACY ACT – RIGHTS FOR CALIFORNIA CONSUMERS” on page 4.

LEGACY operates general audience Sites that are accessible to the public. Our Sites are not intended for children under 16 years of age. We do not knowingly market our products or services to children, nor do we knowingly collect or sell Personal Information from children under 16 years of age.

II. HOW WE COLLECT, USE AND SHARE PERSONAL INFORMATION

How we collect Personal Information

The types of Personal Information we collect depends on your interaction with us, including the types of products or services you applied for or use. We, or entities that we contract with to provide services to support our business and delivery of our products and services (“Service Providers”), may collect Personal Information:

• Directly from you, such as when you apply for or obtain one of our products or services, or if you apply for a job with LEGACY;
• From financial and non-financial companies related by common ownership or control (our “Affiliates”), based on your relationship with them and as permitted by law; and/or
• From other entities that we work with who are not Service Providers (“Third Parties”), such as credit bureaus.

We (or our Service Providers) may also collect Online Information, such as IP address, browser or device information, or other information about you indirectly through interactions with our Sites or ads, such as:

• The types of devices you use to visit our Sites and interact with us;
• Your device’s browsing history on our Sites;
• Information about the ads or content from us (or our service providers) that you view, access or click on; or
• The location of the device you use to visit our Sites (with your consent)

Though Online Information may not, alone, reveal your specific identity, some of this information may be used or associated with Personal Information, or may itself be considered Personal Information. Please see Section III for more information.

How we use Personal Information

We (or our Service Providers) may use Personal Information for the following business purposes:

• To deliver products, information, or services, that you may request, including to:
  • complete transactions;
  • provide account services;
  • recognize and remember you when you visit our Sites;
  • improve our Sites and make them easier to use;
  • notify you about updates to your accounts, products, and/or services;
  • perform quality assurance activities that maintain the quality of services provided to you; or
  • respond to your inquiries.
• To provide advertising about our products and services including:
  • sending marketing materials inclusive of special offers, email notifications, or other notices regarding LEGACY’s products, services, or news; or
  • presenting personalized content or tailored ads that may relate to your interests and/or location.
• To manage security risks and prevent fraudulent activity, including to:
  • detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities;
  • debug to identify and repair errors that may impair existing intended functionality;
  • verify your identity such as when you apply for an account or access our online/mobile services; or
  • assess your creditworthiness, including obtaining credit reports if you apply for credit or apply for a financial product or service.
• To conduct employment-related activities at LEGACY, including to:
  • perform background checks;
  • deliver employee benefits programs; or
  • contact references you provide during your application process.
• To perform other activities, as permitted or required by law including:
  • to perform internal research;
  • in connection with litigation;
  • to comply with regulatory record retention requirements; or
  • for audit purposes within our organization. 

How we share Personal Information

We may share your Personal Information, as permitted or required by law with:

• LEGACY Affiliates;
• Service Providers;
• Regulatory authorities or governmental agencies to meet regulatory or legal requirements; or
• Third Parties, with your consent or as permitted by law.

III. ADDITIONAL INFORMATION ABOUT ONLINE INFORMATION

Online Information

When you visit or browse our Sites, we may collect Online Information as described in Section II of this Statement. The purpose of collecting this information is to improve the effectiveness of our Sites and product offerings. The collection of this information allows for the compilation of anonymous and Aggregated Information about the usage of our Sites and can help us improve your use of our Sites, for example, providing quick login, streamlining site navigation and maintaining up-to-date content for all users. Should you configure your browser to reject Cookies, you may disable some of our online service's features.

Online Behavioral Advertising, “Cookies”, and Similar Technologies

LEGACY and our digital Service Providers (e.g. ad network or agency) may use Cookies, mobile advertising identifiers, and other information for the purposes of delivering tailored advertising to you on other party websites. “Cookies” are pieces of data stored by your browser and used by web servers to uniquely distinguish your browser from all others and remember your browser over time, including preferences and other information. We and our Service Providers may also use Web Beacons with or without Cookies for various purposes, including analytics and targeting interest-based advertising. “Web Beacons” are small image files that are loaded when a web page or other online resource is processed by your browser (including when emails are opened). If you click on one of our ads on another party’s website, Cookies may also be used to track the effectiveness of our online advertising and for the purposes of delivering ads that may be relevant to you in the future.

Links to Other Sites and Other Privacy Policies

Our Sites may contain links to other party websites. When you click on these links, you may be providing information, including Personal Information, to the other party, us, or both. LEGACY has no control over the privacy practices or content of these linked websites, so we recommend that you carefully review the privacy policies or statements of every other party website that you visit.

IV. CHOICES RELATED TO HOW WE USE PERSONAL INFORMATION

You have choices about how we use your information, including what kinds of marketing you want to receive from us.

You can opt-out of having our Service Providers use your web browsing behavior for purposes of serving interest-based advertising by opting out here. You may still see some of our untailored ads, but these will not be served to you based on your inferred interests or web browsing activity on our online services. Please note this opt-out works via Cookies, so if you delete Cookies, use a different device, or change web browsers, you will need to opt-out again.

You can also opt out of receiving marketing offers via email, telephone or direct mail. Every offer will include instructions on how to opt out, or if you prefer, please send your opt-out request to privacy.questions@legacy.com. We will still contact you for transactional purposes, such as to service your account or respond to an inquiry.

Do-Not-Track-Signals

We currently do not employ technology that changes how our servers treat your browser if our servers receive a "do-not-track" signal from your browser.

V. HOW WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

LEGACY uses reasonable physical, electronic, and procedural safeguards to protect Personal Information from unauthorized access, deletion or alteration. As part of our security practices, LEGACY does not send requests for Personal Information to our customers via e-mail or texts. Any Personal Information you request LEGACY to send you via email, such as your account balance, is encrypted. However, standard email communications are not. Therefore, you should not transmit your Personal Information to us through email. Please note that no company can guarantee perfect online security, and please remain careful and vigilant in your online activities.

VI. CALIFORNIA CONSUMER PRIVACY ACT – RIGHTS FOR CALIFORNIA CONSUMERS

The CCPA requires us to make certain additional disclosures and provides California Consumers with the ability to request additional information about their Personal Information. This section explains these rights and describes how California Consumers may submit a request to exercise those rights.

Please note that the rights under the CCPA do not apply to Personal Information collected, processed, sold or disclosed pursuant to:

• Gramm-Leach-Bliley Act (Public Law 106-102), the federal privacy regulation. Generally, this will apply to any Personal Information obtained in connection with LEGACY financial products or services that are used primarily for personal, family or household purposes; or
• Fair Credit Reporting Act (12 CFR 1022). Generally, this will apply to Personal Information related to credit history or credit worthiness.

Categories of Personal Information We Collected Recently

In the 12-month period prior to the date of this Privacy Statement, LEGACY or our Service Providers have collected the following categories of Personal Information, which we may have shared for a business purpose, as permitted or required by law:

Category of Personal Information collected in the previous 12-months	Was the Personal Information shared for a business purpose*?
Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes
Certain, sensitive types of Personal Information, such as gender, age, marital status	Yes – only with our Service Providers to the extent necessary for a business purpose
Commercial information, such as records of personal property, products or services purchased	Yes
Audio, electronic, visual, thermal, olfactory, or similar information, such as phone recordings; ATM and in-branch video monitoring	Yes
Internet or other electronic network activity information, including, but not limited to browsing history, search history, geolocation data (with your consent) and information regarding your interaction with our Sites, collectively “Online Information”	Yes
Professional or employment-related information, such as job title, employer name, or languages	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), such a school name, number of years attended	Yes – only for applicants of employment and employees
Inferences drawn from Personal Information to create a consumer profile that may reflect consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Yes

*For more information on our sharing practices and the related business purposes, please reference Section II of this Privacy Statement above.

Your rights under the CCPA

The CCPA grants California Consumers various rights around the Personal Information that is collected about them. The rights are explained in further detail below:

• A. Right to Know About Personal Information Collected and/or Disclosed
  California Consumers have the right to request information about their Personal Information that LEGACY has collected in the preceding 12 months. Upon our receipt of a verifiable request from you, we will disclose the following information:
  1) The categories of Personal Information we have collected about you.
  2) The categories of sources from which the Personal Information was collected.
  3) The business or commercial purpose for collecting your Personal Information.
  4) The categories of third parties with whom we share your Personal Information.
  5) The specific pieces of Personal Information we have collected about you.

The CCPA allows California Consumers to submit a maximum of two (2) requests in any 12-month period.

• B. Right to Request Deletion of Personal Information
  California Consumers have the right to request that LEGACY (and any Service Provider) delete any Personal Information about you which we have collected from you. This right to request deletion does not apply to any of your Personal Information that is subject to an exception in the CCPA, for example, where we need to retain the Personal Information to complete a transaction for which the Personal Information was collected, to prevent fraud or to comply with a legal obligation.


• C. Right to Opt-Out of the Sale of Personal Information
  LEGACY does not sell Personal Information and will not sell Personal Information without providing you with prior notice and an opportunity to opt-out, as required by law.


• D. Right to Non-Discrimination
  LEGACY does not discriminate against any California Consumer who exercises any of the rights described above. This includes denying goods or services; charging different prices or rates; or providing a different level of service or quality of goods or services.

How to Submit a Request

California Consumers can submit a request, by either completing the Online Request Form or by calling us Monday through Friday from 8:00 a.m. to 4:30 p.m. PST.

Submitting a Request through Your Authorized Agent

California Consumers have the option to designate an authorized agent to submit a request on their behalf. To do this, the authorized agent must select “authorized agent” in the Online Request Form and provide all of the required information, along with proof of authorization in the form of a notarized authorization form, signed by the California Consumer who is the subject of the request. We will also contact the California Consumer directly to verify the request.

We will respond to requests within 45 days and will notify the requester if we need additional time.

Changes to this Statement

This Statement is subject to change. If we make changes to this Statement, we will revise the “Last Updated” date at the top of this Statement. Your use of the Site means that you accept the terms of this Statement.

Any dispute related to this Statement will be governed by our Terms of Use.

Contact for More Information

If you have questions or concerns about LEGACY’s privacy practices or this Statement, please email us at privacy.questions@legacy.com.