Privacy Policy

Last Updated: October 28, 2024

This website, DigitalFiduciary.org, and the Digital Fiduciary Initiative, are run by Legendary Requirements.  At Legendary Requirements, we take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information about how and why we collect, store, use, and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. By using our website, you signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use this site or submit any personal information to us. 

We may update and amend this policy, so we encourage you to review it periodically. We will reflect any such changes to this Privacy Policy on our website. Your continued use of the site after any such changes constitutes your acceptance of this Privacy Policy, as revised.

Personal Data We Collect About You

In order to access our services, you may be prompted to provide some or all of the following types of information in order to sign up, register, access various content or features, submit content, contact us with questions or feedback, or access other features of our website and services. 

  • Identifiers: Contact information, such as name, email address, telephone number, username, password, decentralized identifiers, and public keys.
  • Financial Information: Banking information, credit/debit card number.
  • Commercial Information: Purchase history, transaction history; records of items considered.
  • Internet or Electronic Network Activity:  IP address, mobile device and other unique device identifiers, Mac address, browser type, activity, and language, operating system, general geolocation data, precise geolocation data, email communication interaction data, site interaction data, to include referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site, the frequency of your use of the Site, error logs, and other similar information.
  • Geolocation Data: General and geolocation data.
  • Professional Information: Employment information, such as company or title.
  • Demographic Information: Such as age or date of birth.
  • Communication Information: Communications preferences, comments or other information posted through interactive online features, including, but not limited to chat functions and message boards; and correspondence you send to us.
  • Sensitive Information: precise geolocation data, gender, and citizenship.

How We Collect Your Personal Data

We collect personal data from a variety of sources.  We collect most of this information directly from you via our website.  We also may collect certain information automatically when you use our website our services, including: 

  • Information about your operating system;
  • Your internet protocol (IP) address;
  • Browser type and language;
  • Type of mobile device used to view the website and device identifier location information;
  • Referring and exit pages and URLs;
  • Amount of time spent on particular pages;
  • What sections of our website you visit; and
  • Similar information concerning your use of our website and services.

We also may use cookies or other similar technologies to collect information about your use of our website and services.  We may use first-party cookies and other similar technologies on our websites and apps.  These technologies are used: (a) help our website function properly; (b) to improve or enhance your experience using the Site; (c) to deliver content specific to your interests; and (d) for other purposes, such as security and administrative functions. For example, cookies are used to store your preferences for certain types of information so that you do not have to input those preferences every time you use the Site. Most web browsers automatically accept cookies, though different browsers may address cookies differently. Your browser may enable you to set your device to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. If you set your browser to not accept cookies, it may result in certain personalized services or other features not being provided to you when you use that device.  You may use our preference tools to adjust your settings.

How We Use Your Personal Data

We may use the personal data we collect about you for various purposes.  The legal bases upon which we rely are: (i) your consent, (ii) in order for us to fulfill a contractual obligation or agreement with you, (iii) our legitimate interests or the legitimate interests of others,  (iv) a public interest, as authorized by law; or (v) compliance with a legal, regulatory, and administrative obligation(s).  Examples include:

  • Where use of your information is necessary to perform our obligations under a contract with you or in order to take steps at your request subject prior to entering into a contract;
  • Fulfilling your requests for services and information or otherwise providing customer service, including joining our mailing list and becoming a digital fiduciary;
  • Identifying you as a digital fiduciary once you have taken our fiduciary oath, including posting your name, company, and title on our website;
  • Enabling you to participate in interactive features, such as blogs and other forums, including identifying authors and content providers;
  • Maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, establishing and maintaining email service, hosting our website(s), or providing similar services;
  • Customizing the content displayed when you use our website;
  • Advertising or marketing;
  • Helping to ensure security and integrity and prevent fraud;
  • Undertaking activities to verify or maintain the quality or safety of our services and to improve, upgrade, or enhance them;
  • Conducting research and analysis; including understanding click rates and website behavior;
  • Auditing or monitoring of transactions;
  • Compliance with our legal and regulatory obligations; and
  • For any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

We will keep your personal data while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary to:

  • Respond to questions, complaints, or claims made by you or on your behalf;
  • Show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal data for longer than is necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal data, we will delete or anonymize it.

Who We Share Your Personal Data With

We may share the personal data we collect about you with:

  • Our affiliates and partners, including companies within the Legendary Requirements group;
  • Service providers we use to help deliver our services to you, such as payment service providers;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
  • Credit reporting agencies;
  • Our insurers and brokers;
  • Our banks; and 
  • External auditors.

We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Transfers of Your Personal Data

Data that is collected through our website and services may be stored and processed in the U.S. or any other country in which we or our service providers maintain facilities. We may transfer data that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries and jurisdictions.  Not all of these countries or jurisdictions may have the same data protection laws as your jurisdiction.  By using our website and services and providing us with your data directly or indirectly, you consent to the transfer of information to the U.S. or to any other country for processing by us in accordance with this Privacy Policy.

We will take steps to ensure that your personal data receives an equivalent level of protection in accordance with this Privacy Policy and applicable law. Here are the specific safeguards we rely on for international data transfers:

  • Standard Contractual Clauses (SCCs): We may use Standard Contractual Clauses approved by a relevant data protection regulator, such as the European Commission’s SCCs. These are legally binding agreements that set out specific data protection obligations for both us and the recipient of your information. 
  • Adequacy Decisions: We may transfer your data to countries that have been deemed to provide adequate protection for personal information by a relevant data protection regulator (e.g., an adequacy decision).
  • Other Safeguards: In some cases, we may use other appropriate safeguards, such as encryption or pseudonymization of your personal information, to ensure its protection.

Keeping Your Personal Data Secure

We have adopted reasonable technical, administrative, and physical procedures to help protect your data from loss, misuse, alteration, or unauthorized disclosure. Please note that no data transmission or storage can be guaranteed to be 100% secure. 

If you have any concerns about the security of you information you may contact us at admin@digitalfiduciary.org.

How to Contact Us About Concerns Regarding Your Personal Data

Depending on your jurisdiction, you have the right to:

  • Confirm whether or not we are processing your personal data and to access such data.
  • Correct inaccuracies in your personal data.
  • Delete personal data provided by or obtained about you.
  • Obtain a copy of your personal data processed by us in a portable format.
  • Opt-out of the processing of your personal data for targeted advertising.
  • Opt-out of the sale of your personal data.
  • Opt-out of profiling performed in furtherance of solely automated decisions that produce legal or similarly significant effects.
  • Limit the use of sensitive personal information.
  • Designate another person to serve as your authorized agent to act on your behalf and opt out of processing for targeted advertising, the sale of your data, and profiling as listed above.
  • Non-discrimination or retaliation for exercising any of these rights.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.  

If we decline to act regarding your request, we must notify you without undue delay and will provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.

If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: https://digitalfiduciary.org/contact. You may also email us at admin@digitalfiduciary.org.

Children’s Privacy

Our website and the services offered on our website are directed toward adults over the age of 18 and are not directed to children under the age of 13 or between the ages of 13 and 17.  We adhere to the Children’s Online Privacy Protection Act (COPPA) and do not knowingly collect personal data about a child under the age of 13. If you are a user under the age of 17, please do not send any personal information or data to us if we have not obtained prior consent from your parent or guardian.

Changes to This Privacy Policy

This privacy notice was published on October 28, 2024.

We may revise this Privacy Policy from time to time, for example, to reflect changes in the law, our practices, or the features of our services.  These changes will be effective immediately upon posting on our website.  As such, we encourage you to periodically review the Privacy Policy so that you are up to date on our most current policies and practices.  By continuing to use our website and services, you agree to the terms and conditions of this Privacy Policy.