Privacy Policy for SR Legacy LLC
Effective Date: March 1, 2024
Last Updated: March 3, 2025
At SR Legacy LLC ("we," "us," "our"), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with us, including through our website, mobile applications, SMS messaging services, or other services (collectively, "Services"). It also outlines your rights and choices regarding your information. Please read this policy carefully. By using our Services, you agree to the practices described herein.
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1. Information We Collect
We collect information you provide directly to us, information generated through your use of our Services, and information from third parties, as described below:
- Personal Information: This includes your name, email address, phone number, mailing address, date of birth, Social Security Number (SSN), financial account details, payment card information, credit history, and other identifiers you provide when applying for credit, enrolling in SMS messaging, or using our Services.
- Usage Information: We collect data about your interactions with our Services, such as IP address, device type, browser settings, operating system, mobile network details, and timestamps of your activities.
- Financial Information: For credit card or financial service applications, we may collect income details, employment information, credit scores, transaction history, and other data required to assess creditworthiness.
- Consent Data: For SMS messaging, we collect records of your opt-in consent, including the date, time, and method of consent (e.g., web form, text response).
We collect this information when you:
- Register for an account or apply for credit.
- Enroll in our SMS messaging program.
- Contact us for support.
- Use our website or mobile app.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.
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2. How We Use Your Information
We use your information for the following purposes, based on our legitimate business interests, contractual obligations, legal requirements, or your consent:
- To Provide and Improve Our Services: To process credit applications, deliver SMS notifications (e.g., account alerts, promotions), and enhance user experience.
- Credit Evaluation: To assess your eligibility for credit cards or financial products, including analyzing creditworthiness and verifying identity, in compliance with banking regulations.
- Communication: To send you transactional messages (e.g., payment confirmations), marketing messages (with your consent), and responses to inquiries via email, SMS, or phone.
- Security and Fraud Prevention: To protect against unauthorized access, monitor for suspicious activity, and comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations.
- Legal Compliance: To meet obligations under applicable laws, such as the Gramm-Leach-Bliley Act (GLBA), Fair Credit Reporting Act (FCRA), and Telephone Consumer Protection Act (TCPA).
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3. SMS Messaging Program
Program Description: SR Legacy LLC offers an SMS messaging service to provide you with account updates, promotional offers, and customer support. Message frequency may vary based on your account activity or preferences.
- Opt-In Consent: We only send SMS messages to individuals who have provided explicit consent. You may opt in by submitting your phone number via our website, texting a keyword (e.g., "JOIN") to our designated number, or agreeing during account setup. Upon opting in, you will receive a confirmation message, such as:
"Welcome to SR Legacy LLC! You’ve subscribed to receive SMS updates. Msg frequency varies. Reply HELP for help, STOP to cancel. Msg & data rates may apply."
- Opt-Out: You may cancel SMS messaging at any time by texting "STOP" to our number. After replying "STOP," you will receive a confirmation message and no further messages unless you opt in again.
- Help: For assistance, text "HELP" to our number or contact us at [email protected].
- Carriers: We are not liable for delayed or undelivered messages, which may depend on your mobile carrier.
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4. How We Share Your Information
We do not sell or share your mobile information or SMS opt-in data with third parties for marketing or promotional purposes. We may share your information as follows:
- Service Providers: With trusted vendors (e.g., payment processors, SMS providers, credit bureaus) who assist us in delivering Services, subject to confidentiality agreements.
- Legal Requirements: When required by law, court order, or government request, such as to comply with tax reporting or fraud investigations.
- Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to you as required by law.
- Banking Partners: With financial institutions to process credit applications or transactions, ensuring compliance with banking standards.
Note: Your SMS opt-in data and consent records are not shared with any third parties except as necessary to deliver our messaging services (e.g., with our SMS platform provider).
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5. Your Choices and Rights
- Opt-Out of Marketing: You may unsubscribe from marketing emails by clicking "unsubscribe" in the email or texting "STOP" for SMS messages.
- Credit Information: Under the FCRA, you may request details about your credit data we’ve shared with credit bureaus by contacting us.
- Data Access: You may request access to, correction of, or deletion of your personal information, subject to legal retention requirements, by emailing [email protected].
- Do Not Share: You can limit certain sharing of your financial information for non-service purposes by email [email protected], as outlined in our GLBA Consumer Privacy Notice.
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#### 6. Data Security
We implement industry-standard security measures, including encryption, firewalls, and secure servers, to protect your information from unauthorized access, loss, or misuse. For credit card processing, we comply with Payment Card Industry Data Security Standards (PCI DSS). However, no system is 100% secure, and we cannot guarantee absolute protection.
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7. Data Retention
We retain your information only as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations (e.g., tax or banking records), or resolve disputes. SMS opt-in records are kept for at least 12 months to ensure compliance with A2P 10DLC renewal requirements.
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8. Third-Party Links
Our Services may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies.
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9. Children’s Privacy
Our Services are not intended for individuals under 18. We do not knowingly collect information from minors. If we learn we have such data, we will delete it.
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10. Compliance with Laws
We comply with applicable privacy and financial regulations, including:
- A2P 10DLC Guidelines: Ensuring SMS campaigns meet carrier and CTIA standards.
- GLBA: Protecting consumer financial information.
- FCRA: Governing use of credit reports.
- TCPA: Requiring consent for SMS and calls.
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11. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes via email or a website notice. The "Last Updated" date will reflect the latest revisions.
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12. Contact Us
If you have questions about this Privacy Policy or our practices, please contact us:
- Email: [email protected]
- Mail: SR Legacy LLC, 771 Arizona Ave, Fort Lauderdale FL 33312