Legacy Professional Trustees, Inc.
Data and Security Policy
Effective: November 3, 2026
1. Purpose and Scope
This policy explains how Legacy Professional Trustees, Inc. ("LPT") collects, uses, protects, shares, and destroys information about clients and prospective clients. It applies to LPT's owners, employees, contractors, and vendors who handle this information, and covers LPT's systems: the Hidden Risk Assessment and Family Protection Map Guide (Lovable), Google Workspace (Drive, Sheets, Gmail), Stripe, Kit, and any other tool that stores client information.
2. Our Commitments
- LPT does not sell client information, and does not share it for advertising.
- LPT complies with the EU General Data Protection Regulation (GDPR) for personal data of people in the European Economic Area and with applicable U.K. data protection law. See Section 11.
- LPT is committed to ADA compliance and digital accessibility for people with disabilities. See Section 12.
- LPT destroys questionnaire data within 30 days after the strategy session or Map delivery, as described in Section 10.
- LPT does not use client answers to train AI models.
3. What LPT Does Not Provide
LPT is an asset protection and executive fiduciary firm. LPT does not provide legal representation, and its tools do not give legal, tax, or benefits advice.
4. Data We Collect
| Category | Examples | Sensitivity |
|---|---|---|
| Contact | Name, email, phone, time zone | Moderate |
| Assessment responses | Hidden Risk Assessment answers, route assignment | Moderate to high |
| Questionnaire responses | Family, property, account types, income, insurance, documents, transfers, benefits and care status, advisors, concerns | High |
| Payment | Stripe customer and payment records (LPT does not store card numbers) | High |
| Communications | Emails, Kit engagement, scheduling notes | Moderate |
| Health and care | Care level, facility, benefit applications and denials | High |
5. Data We Do Not Collect
- Social Security numbers, full account numbers, passwords, PINs, or crypto recovery phrases.
- Original documents. Copies are requested only through an LPT-approved secure method.
- Unneeded personal details. Tools use ranges and yes/no answers where possible.
6. How We Use Data
- To prepare the client's Family Protection Map and run the strategy session.
- To deliver purchased services and process payments.
- To send requested follow-up, with consent, through Kit. Every marketing email includes an unsubscribe link.
- To improve services using de-identified or aggregate information only.
- LPT never sells client information.
7. Consent and Notices
- Clients see this policy, the Privacy Notice, and the Mutual Confidentiality Agreement before entering information, and must accept them before starting.
- Contact capture on the assessment is optional and happens after the findings preview.
- A person completing the questionnaire for a family member certifies authority to share that information.
- Special-category data (such as health and care information) is processed only with explicit consent for the stated purpose.
8. Access Controls and Technical Safeguards
- Access is limited to named LPT personnel by role, with unique logins and multi-factor authentication on data storage provider, payment processor, email service provider, AI platform, and any database. Access is reviewed at least every quarter and removed the same day a person leaves.
- Encryption in transit (TLS) and at rest wherever supported. Client records live in restricted sheets or a restricted database, never shared by open link.
- Team email notifications contain only name, status, flags, and a link, not questionnaire answers.
- Client links are unique and expiring, with rate limiting and access logs.
- The Map Guide blocks Social Security numbers, account numbers, passwords, and recovery phrases, and does not store the blocked text.
- Devices used for client work use screen locks, updates, and disk encryption. No client data on personal USB drives or unmanaged cloud accounts.
- The Map Guide is disclosed as AI, is instructed not to give legal, tax, or benefits advice, and is reviewed by LPT personnel. Staff do not paste client information into AI tools that LPT has not approved.
9. Vendors and Sharing
LPT shares client information only with service providers needed to deliver the service and with licensed professionals when the client authorizes coordination. LPT keeps a vendor list, reviews each vendor's security and privacy terms, signs data processing agreements where GDPR applies, and requires confidentiality from contractors. Information may be disclosed when required by law, subpoena, or court order, with notice to the client where lawful.
10. Retention and Destruction (30 Days)
| Record | Retention | Then |
|---|---|---|
| Questionnaire answers, AI guide conversations, working files | Destroyed within 30 days after [the strategy session / Map delivery, whichever is later] | Permanent deletion from LPT and vendor systems; backups overwritten on their normal cycle |
| Incomplete questionnaire drafts | Destroyed within 30 days after last activity | Permanent deletion |
| Assessment responses with name or email | Destroyed within 30 days after [trigger]; de-identified results may be kept | Delete or de-identify |
| Payment records | As required by law and payment processors | Per law |
| Record of destruction | 1 year | Date, record type, method; no client content |
| Marketing contacts | Until unsubscribe | Remove from sequences |
Exceptions: LPT may keep information (a) required by law or by Stripe, (b) subject to a legal hold or needed to defend a claim, or (c) that a client separately authorizes in writing, for example under an implementation agreement. Clients may request earlier deletion by emailing [privacy email].
11. GDPR
- Lawful basis: LPT documents the lawful basis for each purpose, such as consent (Questionnaire, special-category data, and marketing email) and contract (delivering the purchased session and Map).
- Rights: individuals may request access, correction, deletion, restriction, portability, and objection, and may withdraw consent at any time. LPT responds within one month, with a possible extension for complex requests as the law allows.
- Transfers: data is stored in the United States. Where GDPR applies, LPT relies on an appropriate transfer mechanism, such as standard contractual clauses or the EU-U.S. Data Privacy Framework for certified vendors.
- Processors: LPT signs data processing agreements with vendors that handle personal data.
- Breach notification: LPT notifies the competent supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of a breach likely to result in a risk to individuals, and notifies affected individuals without undue delay when the risk is high.
- Records and assessments: LPT keeps a record of processing activities and completes a data protection impact assessment for high-risk processing such as the Map Guide.
- Representative and contact: [EU/UK representative, if required] and [privacy contact]. Individuals may complain to their supervisory authority.
12. Accessibility (ADA)
- LPT designs and maintains its websites, assessment, Map Guide, forms, checkout pages, and documents to be accessible to people with disabilities, and targets conformance with WCAG 2.1 Level AA, the benchmark most often used in ADA Title III matters.
- This includes keyboard access, screen-reader support, sufficient color contrast, text alternatives for meaningful images, captions or transcripts for video (including the VSL and Lives), and accessible forms and error messages.
- The Map Guide offers a non-AI alternative: clients may complete the Questionnaire with a team member by phone or in another format at no extra charge.
- LPT audits accessibility before launch and after major changes, fixes issues, and keeps a record of its efforts.
- Anyone who has trouble using an LPT page or tool can contact Irish Panotes at 1 307-312-8846 and will receive a response within two (2) business days.
13. Incident Response
- Anyone who suspects unauthorized access, loss, or disclosure must report it to Leoby Montero at opman@legacyprofessionaltrustees.info immediately.
- Within 24 hours: contain, preserve logs, and reset affected credentials. Within 72 hours: assess scope and the notification duties that apply.
- Notify affected clients and regulators as required by applicable law, and counterparties as required by their agreements. Document the cause, response, and corrective actions, and review within 14 days.
14. Personnel, Special Situations, and Review
- Everyone with access signs a confidentiality agreement and is trained on this policy at onboarding and annually.
- Route C matters and signs of elder exploitation or crisis trigger an immediate team alert and documented response.
- Information about persons lacking capacity is handled only through an authorized family member or representative.
- The policy owner is [name/title]. The policy is reviewed at least annually and after any incident or major system change.
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