This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you:

• Visit or interact with fedlegacy.com or another website that links to this Privacy Policy;
• Submit a form or request information;
• Register for an event, webinar, appointment, or consultation;
• Communicate with us by email, telephone, SMS, MMS, or another channel;
• Receive services or otherwise interact with us; or
• Participate in one of our marketing, informational, or customer-care programs.

Please review this Privacy Policy together with our Terms of Use.

1. Scope of This Policy

This Privacy Policy applies to personal information collected through our websites, forms, communications, events, appointment processes, and related business activities.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with an individual or household.

Personal information does not include information that has been aggregated, deidentified, or made publicly available in a manner recognized by applicable law.

Certain financial or insurance relationships may be governed by separate privacy notices required under federal or state financial-privacy laws. If you receive a separate privacy notice from us, that notice will control with respect to the information and services it covers.

2. Personal Information We Collect

The information we collect depends on how you interact with us.

2.1 Information You Provide Directly

We may collect the following information when you submit a form, schedule an appointment, register for an event, request materials, communicate with us, or receive services:

• Contact information: Name, mailing address, email address, telephone number, and ZIP code.
• Inquiry information: Questions, comments, goals, interests, requested services, preferred contact methods, and other information you include in a message.
• Appointment and event information: Appointment dates and times, registration status, attendance information, scheduling preferences, webinar participation, and related communications.
• Professional and demographic information: Occupation, employer, federal employment status, retirement timeframe, age range, or similar information you voluntarily provide.
• Financial, insurance, and retirement-planning information: Information about income, assets, benefits, insurance needs, retirement objectives, or other financial circumstances that you provide when requesting or receiving relevant services.
• Sensitive information: In limited circumstances, and only when reasonably necessary for a requested service or legal requirement, we may collect information such as a Social Security number, government identifier, financial account information, or other sensitive personal information.
• Communication information: Email correspondence, telephone-call information, SMS or MMS messages, customer-service communications, and information contained in those communications.
• Consent and preference information: Marketing preferences, SMS consent selections, consent timestamps, opt-in source, opt-out requests, and communication-channel preferences.
• Other information: Any other information you voluntarily provide.

Do not submit Social Security numbers, financial account information, medical information, or other highly sensitive information through a general website form unless we specifically instruct you to use that form for that purpose.

2.2 Information Collected Automatically

When you visit or interact with our website, we and our service providers may automatically collect:

• Internet Protocol address;
• Browser type and version;
• Device type and operating system;
• General or approximate location derived from an IP address;
• Referring and exit pages;
• Pages viewed and links selected;
• Date, time, and duration of visits;
• Website navigation and interaction information;
• Cookie identifiers and similar online identifiers;
• Error, performance, and diagnostic data; and
• Other information concerning how the website is accessed and used.

2.3 SMS and Messaging Information

When you participate in an SMS or MMS program, we may collect:

• Your mobile telephone number;
• The messaging program and category to which you consented;
• The date, time, method, and source of consent;
• Message content;
• Sent, received, delivery, and failure timestamps;
• Opt-in, opt-out, and HELP requests;
• Carrier and device information made available through the messaging service;
• Customer-support interactions; and
• Other records reasonably necessary to operate the messaging program and document compliance.

2.4 Information From Other Sources

We may receive personal information from:

• Service providers that operate forms, scheduling tools, communications, analytics, customer-relationship management systems, or other business technology;
• Insurance carriers, financial professionals, or other organizations involved in providing a service you requested;
• Event, webinar, or referral sources;
• Professional advisers and business partners;
• Publicly available sources; and
• Other parties when you direct or authorize them to provide information to us.

We use information received from other sources in accordance with this Privacy Policy and any restrictions imposed by the source.

3. How We Use Personal Information

We may use personal information to:

• Respond to questions, requests, and inquiries;
• Provide materials, resources, products, or services you request;
• Schedule and manage appointments, consultations, events, and webinars;
• Communicate appointment confirmations, reminders, changes, and service updates;
• Provide customer service and Help Desk support;
• Personalize communications and interactions;
• Send marketing messages when you have provided the required consent;
• Administer SMS, MMS, email, telephone, and other communication programs;
• Record and manage communication preferences and consent;
• Process STOP, unsubscribe, and other opt-out requests;
• Maintain customer, prospect, and business records;
• Evaluate eligibility for or interest in products and services;
• Support insurance, retirement, or financial-services processes you request;
• Operate, maintain, secure, troubleshoot, and improve our website and systems;
• Analyze website performance and general usage trends;
• Detect, investigate, and prevent fraud, misuse, security incidents, and unlawful activity;
• Protect our rights, property, systems, users, and business operations;
• Comply with legal, regulatory, licensing, recordkeeping, and contractual obligations;
• Establish, exercise, or defend legal claims;
• Complete a merger, acquisition, financing, reorganization, or other business transaction; and
• Fulfill another purpose disclosed when the information is collected or authorized by you.

We will not use personal information for a materially different purpose without providing any notice or obtaining any consent required by applicable law.

4. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, tags, scripts, and similar technologies to operate the website and understand how it is used.

These technologies may include:

• Essential technologies: Necessary for website operation, security, forms, and user-requested functions.
• Functional technologies: Used to remember selections and improve website functionality.
• Analytics technologies: Used to measure visits, traffic, navigation, performance, and engagement.
• Advertising or campaign-measurement technologies: Used, where implemented, to measure campaign effectiveness or understand how visitors reached the website.

You can control many cookies through your browser settings. Blocking or deleting cookies may affect website functionality.

Some browsers offer a “Do Not Track” setting. Because there is no uniform industry standard for responding to Do Not Track signals, the website may not respond to those signals in every instance.

Where applicable law requires recognition of an opt-out preference signal, such as the Global Privacy Control, we will process a recognized signal as required for the browser or device from which it is received.

5. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

5.1 Service Providers

We may provide information to companies that perform services on our behalf, including providers of:

• Website hosting and maintenance;
• Forms and appointment scheduling;
• Customer-relationship management systems;
• Email, telephone, SMS, and MMS communications;
• Data storage, backup, and security;
• Analytics and website measurement;
• Event and webinar platforms;
• Document management and electronic signatures;
• Customer service and administrative support; and
• Professional, compliance, audit, or technology services.

Service providers may use personal information only as necessary to provide contracted services or as otherwise permitted by applicable law.

5.2 Affiliates and Business Partners

We may disclose personal information to affiliated companies, licensed professionals, insurance carriers, or other business partners when reasonably necessary to fulfill a request, evaluate or provide a requested product or service, manage a client relationship, or comply with legal obligations.

The strict mobile-information restrictions in Section 7 apply notwithstanding this general provision.

5.3 Professional Advisers

We may disclose information to attorneys, accountants, auditors, consultants, compliance professionals, insurers, and other professional advisers when reasonably necessary for their services.

5.4 Legal, Compliance, and Safety Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with a law, regulation, court order, subpoena, or lawful government request;
• Cooperate with a regulatory, licensing, law-enforcement, or legal investigation;
• Protect the rights, property, security, or safety of the Company, our clients, users, or others;
• Detect or prevent fraud, misuse, unlawful conduct, or security incidents; or
• Establish, exercise, or defend a legal claim.

5.5 Business Transactions

Personal information may be reviewed, transferred, or disclosed as part of a proposed or completed merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction, subject to applicable legal requirements.

5.6 At Your Direction

We may disclose information to another party when you direct us to do so or provide consent.

6. Sale, Targeted Advertising, and Financial Incentives

We do not sell personal information for monetary consideration.

Based on the practices described in this Privacy Policy, we do not knowingly sell personal information or share it for third-party cross-context behavioral advertising.

If these practices change, we will update this Privacy Policy and provide any notice and opt-out mechanism required by applicable law before using personal information for that purpose.

We do not offer financial incentives in exchange for the collection, sale, or sharing of personal information.

7. SMS, MMS, and Mobile Information

This section applies notwithstanding any other information-sharing provision in this Privacy Policy.

7.1 No Marketing Sharing of Mobile Information

Mobile telephone numbers, SMS or MMS opt-in information, messaging consent records, and the origin or method of consent will not be sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes.

All other categories of information sharing described in this Privacy Policy exclude text-messaging originator opt-in data and consent.

7.2 Messaging Service Providers

We may disclose mobile information to service providers that assist us in delivering and administering our messaging programs, including messaging platforms, telecommunications providers, customer-support providers, and technology vendors.

These providers may receive mobile information only as necessary to perform services on our behalf and may not use that information for their own marketing or promotional purposes.

7.3 Messaging Categories and Consent

We may offer separate messaging categories, including:

• Marketing messages, such as educational resources, webinars, events, service information, promotions, and invitations to schedule a consultation; and
• Informational or customer-care messages, such as appointment reminders, requested updates, scheduling communications, and Help Desk responses.

Consent to one messaging category does not constitute consent to another category.

7.4 SMS Choices

You may unsubscribe from recurring SMS or MMS messages at any time by replying STOP. You may request assistance by replying HELP.

After an opt-out request, we may send one final confirmation message. Message frequency varies per user. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages.

Additional SMS program terms are available in our Terms of Use.

8. Data Retention

We retain personal information only for as long as reasonably necessary to:

• Fulfill the purposes described in this Privacy Policy;
• Provide requested services;
• Maintain business and client records;
• Document consent and communication preferences;
• Satisfy legal, regulatory, licensing, tax, accounting, insurance, and recordkeeping obligations;
• Resolve disputes;
• Enforce agreements; and
• Protect against fraud, misuse, and security incidents.

Retention periods vary based on the type of information, the context in which it was collected, applicable requirements, and our legitimate business needs.

When personal information is no longer reasonably necessary, we will delete, destroy, deidentify, or securely dispose of it in accordance with our retention practices and applicable law.

Backup copies may remain for a limited period until they are overwritten or deleted through ordinary backup processes.

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, disclosure, or access.

These safeguards may include:

• Access controls and authentication;
• Role-based or need-to-know access restrictions;
• Encryption or secure transmission where appropriate;
• System monitoring, logging, backup, and recovery processes;
• Security requirements for relevant service providers;
• Workforce privacy and security practices; and
• Procedures for responding to suspected security incidents.

No website, network, storage system, or electronic transmission is completely secure. We therefore cannot guarantee absolute security.

If a security incident involving personal information occurs, we will investigate and provide any notice required by applicable law.

10. Your Privacy Choices

10.1 Email Marketing

You may unsubscribe from marketing emails by selecting the unsubscribe link in an email or contacting us.

Even after opting out of marketing emails, you may continue to receive nonmarketing communications relating to appointments, requested services, transactions, account administration, security, or legal notices.

10.2 SMS and MMS

You may unsubscribe from recurring SMS or MMS messages by replying STOP. Reply HELP for assistance.

10.3 Cookies

You may manage cookies through your browser settings and any privacy or cookie controls we make available on the website.

10.4 Updating Information

You may contact us to request correction of inaccurate contact information or changes to your communication preferences.

11. Privacy Rights

Depending on where you reside and whether an applicable privacy law covers our processing, you may have the right to:

• Confirm whether we process your personal information;
• Request access to personal information;
• Request correction of inaccurate information;
• Request deletion of personal information;
• Obtain a portable copy of certain information;
• Opt out of the sale of personal information;
• Opt out of certain targeted advertising;
• Opt out of certain profiling using personal information;
• Limit certain uses or disclosures of sensitive personal information;
• Withdraw consent where processing is based on consent; and
• Appeal a decision concerning a privacy request.

These rights may be subject to exceptions, limitations, identity verification, and legal or regulatory retention requirements.

11.1 Submitting a Request

To submit a privacy request, contact us using the information in Section 18 and include “Privacy Request” in the subject line.

Please describe the right you wish to exercise and provide enough information for us to identify the relevant records. We may request additional information to verify your identity and protect against fraudulent requests.

We will respond within the period required by applicable law.

11.2 Authorized Agents

Where permitted by law, you may authorize another person to submit a request on your behalf. We may require proof of the agent’s authority and may contact you directly to verify the request.

11.3 Appeals

If applicable law gives you a right to appeal a decision concerning your privacy request, you may submit an appeal using the contact information in Section 18 and include “Privacy Appeal” in the subject line.

11.4 Nondiscrimination

We will not unlawfully discriminate against you for exercising an applicable privacy right.

12. California Residents

If the California Consumer Privacy Act, as amended, applies to our processing of your information, California residents may have the rights described in Section 11, including rights to know, access, correct, delete, and opt out of the sale or sharing of personal information, subject to applicable exceptions.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

The categories of personal information we may collect, the sources of that information, our purposes for using it, and the recipient categories to which it may be disclosed are described in Sections 2 through 7.

13. Colorado and Other State Residents

If the Colorado Privacy Act or another applicable state privacy law covers our processing, residents may have rights to access, correct, delete, or obtain a portable copy of personal information and to opt out of certain sales, targeted advertising, or profiling.

Applicable rights may be exercised as described in Section 11.

14. Children’s Privacy

The website and our services are not directed to children under 13, and we do not knowingly collect personal information online from children under 13.

We do not knowingly market our products or services to minors.

If we learn that we collected personal information from a child in a manner prohibited by law, we will take reasonable steps to delete it. A parent or guardian who believes a child provided personal information may contact us using the information in Section 18.

15. Third-Party Websites and Platforms

Our website may link to or integrate with third-party websites, applications, scheduling systems, webinar platforms, social networks, or other services.

We do not control the privacy or security practices of those third parties. Information you provide directly to a third party is governed by that party’s privacy policy and terms.

We encourage you to review the applicable third-party policies before providing personal information.

16. Visitors Outside the United States

FedLegacy operates in the United States. If you access the website from outside the United States, your information may be transferred to, stored in, and processed in the United States or other locations where our service providers operate.

Data-protection laws in those locations may differ from the laws of your jurisdiction.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, services, technology, or legal obligations.

When we make changes, we will update the “Last Updated” date at the top of this page. If required by law, we will provide additional notice or obtain consent before a material change takes effect.

We encourage you to review this Privacy Policy periodically.

18. Contact Information

Questions, concerns, and privacy requests may be directed to:

1717 K Street NW, Suite 900
Washington, DC 20006
Phone: 240.393.1284
Email: marketing@legacyempower.com

For a privacy-rights request, include “Privacy Request” in the subject line.