Privacy Policy

Niki Staben, doing business as Legacy AI

This Privacy Policy explains how Niki Staben, an individual doing business as "Legacy AI" (a California sole proprietorship) ("LEGACY AI," "we," "us," or "our") collects, uses, discloses, and protects personal information when you use our website, the LEGACY FOUNDERS ACADEMY curriculum, the "LEGACY" AI mentor feature, the Win Wall community feature, and related services (collectively, the "Service"). This Policy is designed to address disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), and general privacy best practices. It should be reviewed and finalized by a licensed attorney before publication, and updated to reflect the actual data practices of the Service once built.

1.1 Information You Provide

• Account information: name, email address, password (stored in hashed form), and profile details you choose to add.

• Payment information: billing name and address, and limited payment details; full card numbers are collected and processed directly by our payment processor and are not stored on our servers.

• Curriculum activity and submissions: your responses to lesson exercises, self-reported progress, uploaded Business Builder Portfolio documents, and other content you submit within the curriculum.

• AI mentor conversations: messages you send to and receive from the "LEGACY" AI mentor feature.

• Win Wall / community content: posts, comments, and any content you choose to share publicly or semi-publicly within the Service.

• Communications: messages you send us for support or feedback.

1.2 Information Collected Automatically

• Usage data: pages viewed, lessons completed, features used, timestamps, and similar interaction data.

• Device and log data: IP address, browser type, operating system, and device identifiers.

• Cookies and similar technologies: used for authentication, preferences, analytics, and (if applicable) advertising, as described in Section 7.

1.3 Information from Third Parties

• Payment confirmation data from our payment processor.

• Analytics data from providers such as Google Analytics (or successor tools), to the extent used.

• To provide, operate, and maintain the Service, including tracking your curriculum progress, Legacy Score, and badges.

• To process payments and manage subscriptions.

• To operate the "LEGACY" AI mentor feature, including sending your conversation inputs to our AI service provider(s) to generate responses.

• To communicate with you about your account, updates, and (with your consent where required) marketing.

• To personalize your experience and improve the Service, including analyzing aggregate usage trends.

• To maintain the security and integrity of the Service, including detecting fraud or abuse.

• To comply with legal obligations and enforce our Terms of Service.

We do not sell your personal information for money. We may share personal information as follows:

• Service providers: with vendors who perform services on our behalf, such as hosting providers, payment processors (e.g., Stripe), AI model/API providers (e.g., for the LEGACY mentor feature), email delivery services, and analytics providers, under contracts that restrict their use of the data to providing services to us.

• Other users: content you post to the Win Wall may be visible to other users of the Service, consistent with the Win Wall's community design.

• Legal and safety: to comply with applicable law, respond to lawful requests, or protect the rights, property, or safety of LEGACY AI, our users, or others.

• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

"Sharing" for cross-context behavioral advertising: if we use analytics or advertising cookies that constitute "sharing" of personal information under the CPRA's broad definition (e.g., pixels used for ad targeting), we will disclose this and provide a "Do Not Sell or Share My Personal Information" mechanism as required, described in Section 6. If the Service does not use such technologies, this section should be updated to state that clearly.

When you interact with the "LEGACY" AI mentor, your messages are sent to our third-party AI model provider — currently Anthropic, via the Claude API — to generate a response. We do not knowingly instruct our AI provider to use your conversation content to train their general-purpose models where an opt-out or business-tier no-training terms are available. If we change AI providers, we will update this section to reflect the new provider's data-use terms. Do not share sensitive information (such as government ID numbers, financial account numbers, or health information) in AI mentor conversations.

We retain personal information for as long as your account is active and as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. You may request deletion of your account and associated personal information as described in Section 6, subject to legal retention requirements (e.g., financial records for tax purposes).

If you are a California resident, the CCPA, as amended by the CPRA, gives you the following rights with respect to your personal information, subject to certain exceptions:

• Right to Know / Access: the categories and specific pieces of personal information we have collected about you, the sources, purposes, and categories of third parties with whom it is shared.

• Right to Delete: request deletion of personal information we have collected from you, subject to legal exceptions.

• Right to Correct: request correction of inaccurate personal information.

• Right to Opt Out of Sale/Sharing: opt out of the "sale" or "sharing" (as those terms are broadly defined under the CPRA) of your personal information, to the extent applicable.

• Right to Limit Use of Sensitive Personal Information: to the extent we collect "sensitive personal information" as defined by the CPRA, request that we limit its use to purposes necessary to provide the Service.

• Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights.

To exercise these rights, submit a request to support@legacyfoundersacademy.com. We will verify your identity before fulfilling requests involving specific personal information, consistent with CCPA regulations, and will respond within the timeframes required by law (generally 45 days, extendable once by an additional 45 days with notice).

You may also designate an authorized agent to make a request on your behalf, subject to verification requirements.

Note on applicability: the CCPA/CPRA's full obligations formally apply to businesses meeting certain thresholds (e.g., over $26.625 million in annual gross revenue, or handling personal information of 100,000+ California consumers/households, or deriving 50%+ of revenue from selling/sharing personal information). Even where LEGACY AI does not yet meet these thresholds, we intend to honor the rights described in this Section 6 as a matter of policy and good practice; this should be confirmed with counsel as the business scales.

We use cookies and similar technologies for authentication (keeping you logged in), remembering preferences, and analytics (understanding how the Service is used). We do not currently use advertising or cross-context behavioral advertising cookies or pixels. If that changes, we will update this section and provide the opt-out mechanism required by law (such as a "Do Not Sell or Share My Personal Information" link or support for Global Privacy Control). You can control cookies through your browser settings, though disabling some cookies may affect Service functionality.

The Service is intended for users 18 and older and is not directed to children under 13. We do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (COPPA). If you believe a child under 13 has provided us with personal information, contact us at support@legacyfoundersacademy.com so we can delete it.

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

The Service is operated from the United States. If you access the Service from outside the United States, your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.

We may update this Privacy Policy from time to time. We will post the updated Policy with a revised "Last Updated" date, and, for material changes, provide additional notice as appropriate (such as by email or in-app notice).

Questions about this Privacy Policy or requests regarding your personal information may be directed to:

Niki Staben d/b/a Legacy AI
4265 Enchanted Cir, Roseville, CA 95747
support@legacyfoundersacademy.com