Privacy Policy

**Effective Date: August 20, 2026**

Genders Law & Legacy, PLLC (“GLL,” the “Firm,” “we,” “us,” or “our”) respects the privacy and confidentiality of information entrusted to it.

This Privacy Policy describes how GLL may collect, use, maintain, protect, process, and disclose information obtained through its websites, forms, communications, payment systems, scheduling systems, downloads, subscriptions, legal-service intake processes, and other interactions.

This Privacy Policy applies to Genders Law & Legacy, PLLC.

It does **not** automatically govern the activities of Investment Counsel Exchange, LLC or any other separately organized entity.

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## 1. LAW-FIRM CONFIDENTIALITY AND PRIVILEGE

This Privacy Policy describes GLL’s general privacy practices.

It does not replace, diminish, waive, or modify any obligation arising under:

* applicable rules of professional conduct;

* attorney-client confidentiality;

* prospective-client confidentiality;

* attorney-client privilege;

* work-product protection;

* applicable privacy law; or

* other legal or ethical duties.

Where information is protected by an attorney-client relationship, prospective-client relationship, professional-responsibility rule, attorney-client privilege, work-product doctrine, or other applicable law, GLL will handle that information in accordance with the obligations governing that information.

Nothing in this Privacy Policy is intended to constitute a waiver of any privilege, confidentiality protection, work-product protection, right, or professional obligation.

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## 2. INFORMATION WE MAY COLLECT

Depending upon how a person interacts with GLL, the Firm may collect information including:

* name;

* email address;

* telephone number;

* mailing address;

* business address;

* employer or company;

* professional title;

* entity information;

* property information;

* transaction information;

* federal tax-related information;

* information submitted through intake forms;

* information submitted through an Easy Button or similar form;

* documents voluntarily submitted to GLL;

* appointment and scheduling information;

* communications with the Firm;

* purchase information;

* billing information;

* payment status;

* transaction identifiers;

* newsletter preferences;

* referral source;

* IP address;

* browser information;

* device information;

* website usage information;

* pages accessed;

* dates and times of website activity; and

* other information voluntarily provided to the Firm.

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# 3. INFORMATION SUBMITTED FOR A LIMITED PRELIMINARY FEDERAL LEGAL AND TRANSACTIONAL REVIEW

When a person or entity requests or purchases a **LIMITED PRELIMINARY FEDERAL LEGAL AND TRANSACTIONAL REVIEW** (“Limited Review”), GLL may collect and process information reasonably necessary to evaluate, administer, accept, decline, and perform the requested Limited Review.

Such information may include:

* names and contact information;

* business and entity information;

* ownership information;

* transaction information;

* property information;

* contracts;

* agreements;

* correspondence;

* transaction summaries;

* tax-related information;

* exchange-related information;

* closing or settlement documents;

* title-related documents;

* financing information;

* identification documents;

* transaction timelines;

* statutory or contractual dates;

* information regarding counterparties;

* information regarding professional advisers;

* information regarding qualified intermediaries, title companies, financial institutions, brokers, sponsors, accountants, or other transaction participants;

* documents uploaded or transmitted to GLL; and

* other information reasonably relevant to the requested review.

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## 4. HOW LIMITED REVIEW INFORMATION MAY BE USED

Information submitted in connection with a Limited Review may be used to:

* determine whether GLL can ethically and legally undertake the matter;

* conduct conflicts analysis;

* conduct jurisdictional analysis;

* determine whether the matter falls within the Firm’s authorized scope;

* understand the proposed transaction;

* perform the requested preliminary federal legal and transactional analysis;

* evaluate documents supplied to the Firm;

* identify issues requiring additional inquiry;

* identify matters outside the Limited Review;

* communicate questions or preliminary observations;

* communicate findings;

* recommend additional professional consultation where appropriate;

* administer the engagement;

* process payment;

* maintain appropriate Firm records;

* comply with professional-responsibility obligations;

* comply with applicable law;

* protect the security and integrity of Firm systems; and

* establish, exercise, or defend legal rights where permitted.

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## 5. LIMITED REVIEW INFORMATION DOES NOT EXPAND THE ENGAGEMENT

The Firm’s receipt, possession, or review of information does not automatically expand the scope of a Limited Review.

The fact that information submitted to GLL reveals additional legal, tax, financial, state-law, local-law, investment, title, regulatory, accounting, or other issues does not mean GLL has undertaken responsibility for those issues.

The scope of the Firm’s legal work remains governed by the applicable written scope of representation.

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## 6. ACCURACY OF INFORMATION

The person submitting information is responsible for providing information that is reasonably complete, accurate, and current.

Unless expressly agreed otherwise, GLL may rely upon information provided to it without independently verifying every fact, document, statement, valuation, record, representation, or third-party communication.

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## 7. SENSITIVE INFORMATION

Because GLL is a law firm, information submitted in connection with legal matters may be sensitive.

Unless GLL specifically requests information through an appropriate channel, users should avoid transmitting through a general public-facing website form:

* Social Security numbers;

* complete financial-account credentials;

* passwords;

* security codes;

* private cryptographic keys;

* seed phrases;

* authentication credentials;

* unrelated medical information; or

* other unnecessary highly sensitive information.

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## 8. HOW INFORMATION MAY BE COLLECTED

GLL may collect information:

* directly from users;

* through website forms;

* through legal intake forms;

* through email;

* through telephone communications;

* through video or in-person meetings;

* when an appointment is scheduled;

* when a service is purchased;

* when materials are downloaded or requested;

* through documents submitted to the Firm;

* automatically through website technologies;

* through service providers acting for the Firm;

* through lawful public sources where appropriate; and

* through other persons where authorized or reasonably appropriate.

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## 9. GENERAL USE OF INFORMATION

In addition to providing legal services, GLL may use information to:

* respond to inquiries;

* evaluate requests for services;

* administer client and prospective-client relationships;

* schedule meetings;

* process payments;

* send receipts;

* maintain accounting records;

* maintain conflicts records;

* secure Firm systems;

* detect unauthorized activity;

* prevent fraud;

* operate and improve its website;

* provide requested publications;

* communicate concerning requested services;

* comply with legal or professional requirements; and

* establish or defend legal rights.

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## 10. PAYMENT INFORMATION AND STRIPE

GLL may use **Stripe** or another third-party payment processor to process electronic payments.

When a user submits payment information, certain payment information may be transmitted directly to the applicable processor rather than being processed exclusively through GLL systems.

GLL may receive transaction-related information including:

* purchaser name;

* billing information;

* payment amount;

* transaction date;

* payment status;

* payment method;

* limited card information made available by the processor;

* transaction identifiers;

* refund information;

* chargeback information; and

* payment-dispute information.

Stripe maintains its own terms and privacy practices and may act as a controller, processor, or service provider depending upon the processing activity.

GLL does not control every independent data-processing activity undertaken by Stripe or another third-party payment processor.

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## 11. COOKIES AND WEBSITE TECHNOLOGIES

GLL and its service providers may use cookies, analytics technologies, log files, pixels, or similar technologies for purposes such as:

* operating the website;

* maintaining security;

* remembering preferences;

* understanding traffic;

* measuring website performance;

* determining referral sources;

* identifying technical problems; and

* improving website functionality.

Where applicable law requires consent or preference controls, GLL may provide appropriate mechanisms for non-essential technologies.

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## 12. ANALYTICS AND MARKETING

GLL may use third-party technologies to understand website usage, evaluate communications, and measure marketing effectiveness.

Depending upon the technologies deployed, these services may process:

* IP addresses;

* device information;

* browser information;

* referral information;

* pages viewed;

* interactions; and

* related usage information.

GLL does not authorize analytics or advertising providers to use confidential client information for their own independent advertising purposes.

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## 13. DISCLOSURE TO SERVICE PROVIDERS

Subject to applicable legal and professional obligations, GLL may use third-party providers for:

* website hosting;

* cybersecurity;

* payment processing;

* email;

* communications;

* scheduling;

* document management;

* cloud storage;

* customer-relationship management;

* analytics;

* accounting;

* professional support; and

* information technology.

Such providers may receive information reasonably necessary to perform their functions.

Use of a service provider does not waive GLL’s professional obligations regarding protected client or prospective-client information.

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## 14. SEPARATION FROM INVESTMENT COUNSEL EXCHANGE, LLC

**Genders Law & Legacy, PLLC and Investment Counsel Exchange, LLC are separate legal entities.**

Information submitted to GLL is not automatically deemed submitted to Investment Counsel Exchange, LLC.

Information submitted to Investment Counsel Exchange, LLC is not automatically deemed submitted to GLL.

Common ownership, management, referrals, branding, overlapping personnel, business relationships, or commercial affiliation do not eliminate the distinction between the entities.

Information may be disclosed between separate entities only when an appropriate:

* legal;

* professional;

* operational;

* contractual; or

* consent-based

basis permits the disclosure.

Nothing in this Privacy Policy creates a partnership, joint venture, agency, alter-ego relationship, or common legal enterprise between GLL and Investment Counsel Exchange, LLC.

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## 15. NO SALE OF CONFIDENTIAL CLIENT INFORMATION

GLL does not sell confidential client information.

GLL does not sell confidential prospective-client information.

Information protected by applicable professional obligations will be handled consistently with those obligations.

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## 16. OTHER PERMITTED DISCLOSURES

Subject to applicable legal and professional obligations, GLL may disclose information to:

* Firm attorneys;

* Firm personnel;

* contractors assisting the Firm;

* co-counsel where appropriate;

* professionals engaged in a matter where authorized or legally appropriate;

* professional advisers;

* accountants;

* insurers;

* auditors;

* information-technology providers;

* courts;

* governmental authorities; or

* other persons when authorized or required by law.

Any disclosure involving confidential legal information remains subject to applicable professional-responsibility requirements.

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## 17. LEGAL PROCESS AND PROTECTION OF RIGHTS

Subject to applicable professional confidentiality requirements, GLL may preserve, use, or disclose information where reasonably necessary to:

* comply with law;

* respond to lawful process;

* comply with professional obligations;

* protect Firm systems;

* investigate fraud;

* investigate unauthorized transactions;

* address cybersecurity threats;

* respond to payment disputes;

* resolve contractual disputes;

* establish legal rights;

* exercise legal rights; or

* defend legal claims.

Nothing in this provision authorizes disclosure prohibited by applicable attorney-confidentiality rules.

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## 18. DATA SECURITY

GLL uses reasonable administrative, technical, physical, and organizational safeguards appropriate to the nature of information under its control.

No internet transmission, email service, website, cloud platform, payment system, or electronic storage system can be guaranteed to be completely secure.

Users should exercise reasonable care when transmitting sensitive information electronically.

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## 19. DATA RETENTION

GLL may retain information for periods reasonably necessary for:

* legal representation;

* prospective-client administration;

* conflicts management;

* professional-responsibility requirements;

* legal recordkeeping;

* tax requirements;

* accounting requirements;

* payment records;

* fraud prevention;

* cybersecurity;

* dispute resolution;

* legal claims;

* enforcement of agreements; and

* applicable law.

Different categories of information may be retained for different periods.

Client-file retention may also be governed by engagement terms, professional duties, Firm policies, and applicable law.

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## 20. LIMITED REVIEW RECORD RETENTION

Information submitted for or generated in connection with a Limited Review may be retained as reasonably necessary to document:

* the request for services;

* the scope of the review;

* conflicts analysis;

* jurisdictional analysis;

* materials reviewed;

* work performed;

* communications;

* findings;

* payment;

* completion of the engagement; and

* compliance with professional obligations.

A request to delete information may therefore be subject to exceptions where GLL reasonably needs to retain the information for conflicts, legal, ethical, evidentiary, accounting, security, insurance, or professional-responsibility purposes.

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## 21. EMAIL AND MARKETING COMMUNICATIONS

A person who subscribes to a newsletter, requests educational materials, or separately consents to marketing communications may receive communications concerning:

* Firm services;

* legal developments;

* educational information;

* publications;

* events; and

* related professional topics.

Recipients may opt out of marketing emails through the unsubscribe mechanism provided.

Opting out of marketing does not necessarily prevent transactional, security, engagement-related, legal-service, or payment-related communications.

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## 22. PRIVACY RIGHTS AND REQUESTS

Depending upon an individual’s location and applicable law, the individual may possess certain rights concerning personal information.

Those rights may include rights to request:

* access;

* correction;

* deletion;

* information concerning processing;

* restriction of certain processing; or

* other rights provided by applicable law.

Such rights are not absolute.

Requests may be subject to exceptions concerning:

* attorney confidentiality;

* privilege;

* conflicts records;

* professional obligations;

* legal claims;

* record retention;

* security;

* fraud prevention;

* tax obligations;

* accounting obligations; and

* applicable law.

GLL may verify identity before responding to certain requests.

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## 23. CHILDREN’S PRIVACY

GLL’s website and professional services are not directed toward children under 13.

GLL does not knowingly use its website to solicit personal information directly from children under 13 for commercial purposes.

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## 24. THIRD-PARTY WEBSITES

The GLL website may contain links to websites or services operated independently by third parties.

GLL is not responsible for the privacy, security, content, or practices of independent third-party websites.

Users should review the privacy practices of third-party services before submitting information to them.

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## 25. BUSINESS OR ORGANIZATIONAL CHANGES

If GLL undergoes a lawful succession, reorganization, restructuring, merger, transfer of practice assets, or similar event, information may be transferred where legally and professionally permissible.

Information subject to professional confidentiality obligations remains subject to those obligations.

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## 26. NO WAIVER OF PRIVILEGE OR CONFIDENTIALITY

Nothing in this Privacy Policy constitutes an agreement by GLL or a client to waive:

* attorney-client privilege;

* work-product protection;

* confidentiality obligations;

* prospective-client protections;

* legal defenses;

* professional obligations; or

* other protections recognized by applicable law.

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## 27. CHANGES TO THIS PRIVACY POLICY

GLL may update this Privacy Policy from time to time to address changes in:

* law;

* technology;

* professional obligations;

* Firm practices;

* service providers; or

* Firm services.

The Effective Date above identifies the current version.

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## 28. CONTACT

Questions or privacy requests may be directed to Genders Law & Legacy, PLLC using the contact information provided on the Firm’s official website.

**© 2026 Genders Law & Legacy, PLLC. All Rights Reserved.**