PRIVACY POLICY

Legacy Sphere Group LLC (“Legacy Sphere Group”, “LSG”, “we”, “our”, or “us”) is committed to protecting your privacy and ensuring the security of your personal information.
This Privacy Policy describes how we collect, use, store, and protect information when you use our website, platform, financial systems, educational programs, and related services (the “Services”).

This policy is designed to comply with the Gramm-Leach-Bliley Act (GLBA) and all applicable U.S. privacy and information security regulations.

1. Information We Collect

We may collect the following categories of information:

1.1 Personal Information

  • Full name

  • Address

  • Email

  • Phone number

  • Date of birth

  • Identification information (for verification)

  • Social Security Number or EIN (for investor onboarding and CIP compliance)

  • Payment-related information (processed by partner banks)

1.2 Financial Information

  • Bank account details (held by our partner bank)

  • Transactions, deposits, distributions, and statements

  • Investment participation and project allocations

  • ROI calculations and project milestones

1.3 Technical & Usage Information

  • IP address

  • Device information

  • Browser type and version

  • Activity logs

  • Session data

  • Cookies and similar technologies

1.4 Project & Program Information

  • Enrollment data

  • Educational progress

  • Certification records

  • Masterclass and mentorship participation

  • Investor agreements

2. How We Use Your Information

We use your information to:

2.1 Provide and Improve Our Services

  • Create and manage your account

  • Process investments and distributions

  • Maintain financial and construction reporting accuracy

  • Deliver educational programs and progress tracking

2.2 Regulatory & Compliance Obligations

As required under GLBA and partner bank rules:

  • KYC/AML screening

  • CIP verification

  • OFAC/PEP checks

  • Fraud prevention

  • Regulatory reporting and audits

2.3 Communication & Support

  • Respond to inquiries

  • Provide weekly investor updates

  • Send reports, alerts, and operational notices

2.4 Security & Risk Management

  • Protect against unauthorized access

  • Monitor system activity

  • Maintain platform integrity

We do not sell or rent your personal information to third parties.

3. Information Sharing & Disclosure

We only share information when necessary and permitted:

3.1 Partner Bank

All deposit accounts and financial transactions are held at our FDIC-insured partner bank.
We share required information so the bank can:

  • Verify identity

  • Maintain regulatory compliance

  • Process deposits, transfers, and distributions

3.2 Service Providers

Vendors supporting:

  • KYC verification

  • Payment processing

  • Data storage

  • Analytics

  • Security monitoring

3.3 Legal & Regulatory Requirements

We may disclose information to comply with:

  • Law enforcement requests

  • Court orders

  • Regulatory audits

  • Fraud investigations

3.4 Business Transfers

If LSG undergoes a merger, acquisition, or corporate restructuring, data may be securely transferred as part of that transaction.

4. Data Security

We maintain a comprehensive information security program aligned with GLBA requirements, industry standards, and bank-level controls, including:

  • Encryption in transit (TLS 1.3) and at rest (AES-256)

  • Multi-factor authentication (MFA)

  • Least-privilege access controls

  • 24/7 security monitoring

  • Regular penetration testing

  • Annual SOC 2 Type II compliance

We implement administrative, technical, and physical safeguards to protect your data from unauthorized access, alteration, or loss.

5. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal data we hold

  • Request corrections or updates

  • Request deletion (subject to regulatory retention requirements)

  • Opt out of certain communications

For security, we may require identity verification before processing your request.

6. Data Retention

We retain personal information only as long as necessary to:

  • Provide services

  • Meet regulatory requirements

  • Maintain accurate business and financial records

Some data must be retained for legally mandated retention periods (e.g., AML, financial, and audit records).

7. Cookies & Tracking

We use cookies and similar tracking technologies to:

  • Enhance user experience

  • Analyze traffic

  • Maintain session security

Users can manage cookie preferences through their browser settings.

8. Third-Party Websites

Our website may link to external sites.
We are not responsible for the privacy practices of third-party websites.
We recommend reviewing their privacy policies before sharing information.

9. Children’s Privacy

Our Services are not intended for individuals under 18.
We do not knowingly collect information from minors.

10. International Users

Our systems operate primarily in the United States.
If you access the Services from another country, your information may be transferred to and processed in the U.S.

11. Changes to This Privacy Policy

We may update this policy periodically.
Revisions will be posted on this page with an updated “Last Updated” date.
Continued use of our Services indicates acceptance of any changes.

12. Contact Us

If you have questions about this Privacy Policy or your data, contact us at:

Legacy Sphere Group LLC
Email: [your email]
Phone: [your phone]
Address: [your address]

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