Adopted November 09, 2022
How We Collect Information
The Information We Collect
If you are a client using our online wealth management platform, we will collect your user ID and password or other similar authentication information. In other sections of our website, we may capture additional information you may specifically supply including your name, address, email address, phone number and other personal information, in order to enable us to process your request.
Generally speaking, we do not consider information that has been anonymized or aggregated to be personal information because it can no longer be used to identify a specific person.
As you navigate through our website, we may automatically collect anonymous information about you and your usage of our website during your visit, which is referred to as “Usage Data”. This information includes navigational data and web server logs, and may include information such as your IP address, the version of both your browser and operating system, and the URL of the website visited previously.
How We Use the Information We Collect
We use the information we collect to respond to your requests for information and to improve the quality of our digital products and services. With respect to Usage Data, we do not link this automatically collected data to other information that could be used to identify you, except as may be required to prevent and detect fraud and abuse in order to protect the security of our customers and systems, and in such case we use this identifiable Usage Data only for this limited purpose, and we treat it as your personal information.
We may also disclose your personal information to protect your safety or the safety of others, investigate fraud, or to any other third party with your prior consent to do so. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified of such change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Technologies such as cookies, tags and scripts may be used by us, our affiliates, and our analytics and service providers. These technologies are used in analyzing trends, administering the website, tracking movements around the website, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies on both an individual and an aggregated basis.
Strictly necessary cookies: These cookies are necessary for our website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but doing so will cause parts of our website to work improperly. These cookies do not store any personally identifiable information.
Performance and analytics cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and to determine how visitors move around our website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our website and will not be able to monitor and improve its performance.
Functional cookies: These cookies enable our website to provide enhanced functionality and personalization, such as remembering choices you make on our website. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Managing Cookie Usage
You may block the installation of cookies by certain settings provided by your browser software. We would like to inform you, however, that in this case you may find using our portal may be hampered. You can prevent the compilation of data (including your IP address) through cookies and website use by downloading and installing the browser plug-in available through the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
How We Protect Your Personal Information
We have implemented information security standards designed to protect your data by putting in place physical, technical, and administrative safeguards. These safeguards are reviewed and improvements are implemented, as needed.
Authorized employees and representatives are permitted to access and use data about you for approved business purposes, subject to a requirement that they at all times adhere to applicable laws and our established policies relating to the protection of your data.
Your information may be accessible by third party providers of services to us for purpose of enabling them to perform those services. These third-party service providers have an obligation to maintain the confidentiality of the information, except where disclosure is required by law.
The website may include links to other websites that are not operated or controlled by us. If you submit personal information to any of those sites, your information is governed by their privacy policies. We cannot control and are not responsible for the privacy practices or the content of these websites.
Legacy Trust Company, N.A.
1415 Louisiana St., Suite 1900
Houston, TX 77002-7360
Notice to California Residents
This Notice to California Residents applies to the use, collection, and disclosure of personal information relating to residents of the state of California that are subject to the California Consumer Privacy Act (the “CCPA”).
Under the CCPA, “Personal Information” is, among other things, information that identifies, relates to, or could reasonably be linked directly or indirectly with, a particular California resident. It does not apply to information subject to the Gramm-Leach-Bliley Act (“GLBA”).
In connection with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
Collection and Disclosure of Personal Information
In the past 12 months we have collected for our business purposes the following categories of personal information:
- Identifiers, such as name, e-mail address, or other similar identifiers;
- Personal information categories such as address or telephone number;
- Classifications such as sex and marital status;
- Commercial information, such as transaction records or purchase history; and
- Employment-related information, such as current or past work history.
The categories of sources from whom we collected this personal information are:
- Directly from a California resident or the individual’s representatives;
- Consumer data providers;
- Public records;
- Our website; and
- Information from third parties directed by the subject individual.
The categories of third parties to whom we disclosed such personal information are:
- Our vendors and service providers who provide services to us, such as website hosting, data analysis, information technology and related infrastructure, auditing, and marketing research activities;
- Third parties who provide services such as communication infrastructure, storage, legal expertise, and tax expertise;
- Governmental agencies as may be required by applicable laws.
Use of Personal Information
In the past 12 months, we have used personal information to operate, manage, and maintain our business, to provide our products and services, including the following:
- Performing services, including maintaining or servicing accounts, providing client service, processing or fulfilling orders and transactions, verifying client information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
- Detecting security incidents, and protecting against malicious, deceptive or illegal activity, or to prevent and detect fraud and abuse in order to protect the security of our customers and systems;
- Short-term, transient, transactional use;
- Auditing related to transactions;
- To verify or maintain the quality or safety of a service controlled by us;
- Complying with laws and regulations.
Sale of Personal Information
In the past 12 months, we have not “sold” personal information subject to and as provided under the CCPA, including personal information of minors under the age of 16.
Rights under the CCPA
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 month period preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed, and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
- Request that we delete personal information we collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA.
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of personal information will require additional information to verify your identity.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information that we maintain about you is not subject to the CCPA’s access or deletion rights.
We will advise you in our response if we are not able to honor your request. We will not provide specific identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
We will work to process all verified requests within 45 days. If we require time (up to an additional 45 days) in order to process your request, we will provide you with an explanation for the delay.
Ways to exercise your rights under the California Consumer Privacy Act
California residents can request details about personal information collected and shared by calling 713- 651-8800 or 800-651-2811.
Client Privacy Notice
Rev. 11/20 FACTS
WHAT DOES LEGACY TRUST COMPANY, N.A. DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your financial information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our client, we continue to share your information as described in this notice.
All financial companies need to share client personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons Legacy Trust Company chooses to share; and whether you can limit sharing.
|Reasons we can share your personal information||Does Legacy Trust Company share?||Can you limit this sharing?|
|For our everyday business purposes –
Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For our marketing purposes –
To offer our products and services to you
|For joint marketing with other financial companies||No||N/A|
|For our affiliates’ everyday business purposes – Information about your transactions and experiences||Yes||No|
|For our affiliates’ everyday business purposes – Information about your creditworthiness||No||N/A|
|For nonaffiliates to market to you||No||N/A|
|To limit our sharing||Call 713-651-8800 or 800-651-2811|
|Questions?||Call 713-651-8800 or 800-651-2811|
|Who we are|
|Who is providing this notice?||This notice is being provided by Legacy Trust Company, N.A.|
|What we do|
|How does Legacy Trust Company protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.|
|How does Legacy Trust Company collect my personal information?||
We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
|Why can’t I limit all sharing?||
Federal law gives you the right to limit certain, but not all, sharing, such as:
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
|What happens when I limit sharing for an account I hold jointly with someone else?||Your choices above apply to everyone on your account.|
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.|
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
|Other Important Information|
|Special Notice for California Residents||In accordance with California law, we will not share information we collect about you with nonaffiliated third parties, except as permitted by law. California residents are also provided a California-specific privacy notice.|
|Special Notice for Vermont Residents||
In accordance with Vermont law, we will not share information we collect about you with nonaffiliated third parties, except as permitted by applicable law. We may share information about your transactions or experiences with our affiliates without your consent.
Customer Identification Program Notice
Important Information about Procedures for Opening a New Account:
To help the government fight the funding of terrorism and money laundering activities, financial institutions are required by Federal law to obtain, verify and record information that identifies each individual or entity that opens an account.
What this means for indiviuals:
When an indiviual opens an account, we will ask for their name, residence address, date of birth, tax identification number, and other information that allows us to identify them. We may also ask to see a driver’s license, passport, or other identifying documents.
What this means for other legal entities:
When a corporation, partnership, trust or other legal entity opens an account, we will ask for the entity’s name, physical address, tax identification number and other information that will allow us to identify the entity. We may also ask to see other identifying documents, such as certified articles of incorporation, partnership agreements, or a trust instrument.