Effective Date: May 2026
Last Updated: May 2026
This Privacy Policy describes how Propulsa LLC, doing business as Coinlegacy (collectively, including its subsidiaries and affiliates, the "Company," "we," "us," or "our"), collects, uses, shares, and protects personal information from individuals ("you," "your," or "User") who visit our Websites, sign up for our communications, purchase or use our Services, or otherwise interact with us.We are committed to protecting your privacy and handling your personal information transparently and in accordance with applicable data protection laws, including the European Union General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), and other applicable privacy laws.By accessing our Websites or using our Services, you acknowledge that you have read and understood this Privacy Policy.
Article 1 — Who We Are1.1 Data Controller.The data controller responsible for your personal information is:Propulsa LLC, doing business as Coinlegacy651 N Broad StMiddletown, DE 19709, USAEmail: hello@coinlegacy.com1.2 Scope of This Policy.This Privacy Policy applies to:a. Our Websites, including www.coinlegacy.com, go.coinlegacy.com, app.coinlegacy.com, and any other domain or subdomain operated by the Company;b. Our Services, including the Sovereign Wealth Masterclass, the HODL Method™ educational platform, group coaching programs, community access, and related offerings;c. Any communications you receive from us, including emails, SMS messages, or other digital communications;d. Any in-person or virtual events organized by the Company.This Privacy Policy does not apply to third-party websites, applications, or services that may be linked from our Websites. We encourage you to review the privacy policies of those third parties.
Article 2 — Information We Collect2.1 Information You Provide Directly.We collect personal information that you provide voluntarily when you interact with us, including:a. Identity Information: first name, last name, date of birth (where requested), and any other identifying information you submit through our forms.b. Contact Information: email address, phone number, postal address, country of residence.c. Account Information: username, password (stored in encrypted form), account preferences, and profile information.d. Financial Information: billing address, payment card information (processed and stored by our third-party payment processors, not by us directly), purchase history, and refund records.e. Communication Information: content of emails, support requests, survey responses, testimonials, and any other communications you send to us or post within our community platform.f. Application Information: responses to qualification questionnaires submitted through our application or strategy call booking forms, including information about your savings, investment goals, time horizon, risk tolerance, and similar financial context.g. Customer Content: content you upload or post within the Services, including community posts, comments, questions, and shared materials.2.2 Information Collected Automatically.When you visit our Websites or use our Services, we and our service providers may automatically collect certain information through cookies, pixels, and similar technologies, including:a. Device Information: IP address, device type, operating system, browser type and version, language preferences, and screen resolution.b. Usage Information: pages visited, time spent on pages, links clicked, referring URLs, search terms used to reach our Websites, and navigation paths.c. Location Information: approximate geographic location derived from your IP address (city or country level).d. Engagement Information: video viewing behavior (start, pause, completion), email open and click rates, scroll depth, and form interactions.For more details on cookies and tracking technologies, please refer to our Cookie Policy.2.3 Information from Third Parties.We may receive information about you from third parties, including:a. Advertising Platforms: Meta (Facebook), Google, YouTube, TikTok, and other advertising networks may share aggregated or pseudonymized data about your interaction with our advertisements.b. Analytics Providers: Google Analytics, Meta Pixel, and similar services may share information about your behavior on our Websites.c. Payment Processors: Stripe, PayPal, or other payment service providers may share confirmation of payment, billing address verification, and fraud prevention signals.d. Email Service Providers: systeme.io and similar marketing platforms may share email engagement data and delivery information.e. Public Sources: if you have publicly shared information on social media or professional networks (such as LinkedIn) that is relevant to your interaction with us.2.4 What We Do Not Collect.We do not collect, store, or process:a. Your private wallet keys, seed phrases, or any cryptographic credentials related to your digital asset holdings;b. Your wallet addresses or transaction history (unless you voluntarily share them in a community context);c. Your bank account credentials or login information for any third-party financial institution;d. Sensitive categories of personal data (such as racial or ethnic origin, religious beliefs, health data, sexual orientation, or political opinions), unless you voluntarily provide such information in a specific context (e.g., dietary preferences for an in-person event).
Article 3 — How We Use Your Information3.1 Purposes of Processing.We use your personal information for the following purposes:a. Service Delivery: to create and manage your account, provide access to the Services, deliver educational content, facilitate group coaching and community access, and respond to your support requests.b. Order Processing: to process payments, issue invoices, manage subscriptions, deliver receipts, and handle refunds.c. Communications: to send transactional emails (account confirmations, billing notices, security alerts), respond to your inquiries, and provide customer support.d. Marketing and Promotional Communications: to send newsletters, educational content, masterclass invitations, product announcements, and other marketing communications, where you have opted in or where permitted by Applicable Laws. You may unsubscribe at any time.e. Personalization: to tailor the Services and communications to your interests, preferences, and previous interactions.f. Analytics and Improvement: to understand how Users interact with our Websites and Services, identify trends, measure the effectiveness of our marketing, and improve our offerings.g. Qualification and Sales Process: to evaluate whether the Services are appropriate for you based on application responses, and to schedule and prepare for strategy calls.h. Legal and Compliance: to comply with applicable laws and regulations, respond to legal requests, enforce our Terms of Service, prevent fraud, protect our rights and the rights of others, and respond to security incidents.i. Business Operations: to maintain the security of our systems, conduct audits, develop new features, and operate our business effectively.3.2 Legal Bases for Processing (GDPR).If you are located in the European Economic Area, the United Kingdom, or another jurisdiction that requires a legal basis for processing personal data, we rely on the following legal bases:a. Performance of a Contract: processing necessary to provide the Services you have purchased or to take steps at your request before entering into a contract (e.g., processing your application).b. Legitimate Interests: processing necessary for our legitimate business interests, such as improving our Services, marketing to existing customers, preventing fraud, and ensuring the security of our platform, provided these interests are not overridden by your fundamental rights and freedoms.c. Consent: where you have given us specific consent to process your personal data for a particular purpose, such as receiving marketing communications or the use of certain cookies. You may withdraw your consent at any time.d. Legal Obligation: processing necessary to comply with our legal obligations, such as tax reporting, anti-money laundering requirements, or responses to lawful requests from public authorities.
Article 4 — How We Share Your Information4.1 Service Providers.We share personal information with trusted third-party service providers who perform services on our behalf, under written agreements that require them to protect your information and use it only for the purposes we specify. These service providers include:a. Hosting and Infrastructure: systeme.io (funnel and email platform), AWS, Cloudflare, and similar providers.b. Payment Processing: Stripe, PayPal, or other payment processors who handle credit card and payment transactions on our behalf.c. Email and Communication: systeme.io, Mailchimp, ActiveCampaign, or similar email service providers.d. Analytics and Tracking: Google Analytics, Meta Pixel, and similar analytics providers.e. Customer Support: helpdesk and ticketing platforms.f. Booking and Scheduling: iClosed, Calendly, or similar scheduling platforms used for strategy calls.g. Video Conferencing: Zoom, Google Meet, or similar platforms used for group sessions and coaching calls.h. Community Platforms: Circle, Discord, Slack, or similar platforms used to host the Coinlegacy community.4.2 Legal Disclosures.We may disclose your personal information when required to do so by law, regulation, legal process, or governmental request, including:a. To comply with a subpoena, court order, or other legal process;b. To respond to lawful requests from public authorities, including national security or law enforcement;c. To protect the rights, property, or safety of the Company, our Users, or others;d. To enforce our Terms of Service or other agreements;e. To investigate, prevent, or address fraud, security, or technical issues.4.3 Business Transfers.If the Company is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your personal information may be transferred or disclosed as part of that transaction. We will notify you of any such change in ownership or control.4.4 With Your Consent.We may share your personal information with third parties for purposes not described above when you have given us your explicit consent.4.5 Aggregated and De-identified Data.We may share aggregated, de-identified, or anonymized information that cannot reasonably be used to identify you for any purpose, including for marketing, analytics, research, or business intelligence.4.6 No Sale of Personal Information.We do not sell your personal information for monetary consideration. To the extent that any data sharing with advertising partners (such as Meta or Google) constitutes a "sale" or "sharing" under the CCPA/CPRA, you have the right to opt out, as described in Article 8.
Article 5 — Cookies and Tracking Technologies5.1 Use of Cookies.Our Websites use cookies and similar tracking technologies to provide, secure, and improve our Services. Cookies are small text files placed on your device that help us recognize you and remember your preferences.5.2 Categories of Cookies We Use.a. Strictly Necessary Cookies: required for the operation of our Websites and Services (e.g., session management, security).b. Functional Cookies: allow us to remember your preferences and provide personalized features.c. Analytics Cookies: help us understand how Users interact with our Websites (e.g., Google Analytics).d. Marketing and Advertising Cookies: track your behavior across websites to deliver relevant advertising (e.g., Meta Pixel, Google Ads).5.3 Managing Cookies.You can manage cookie preferences through our cookie consent banner (where applicable) or through your browser settings. Note that disabling certain cookies may impact the functionality of our Websites.For more detailed information, please refer to our Cookie Policy.
Article 6 — Data Retention6.1 Retention Periods.We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:a. Account Information: retained for the duration of your active account and for a reasonable period thereafter to allow for reactivation, dispute resolution, or as required by law.b. Transaction Records: retained for at least seven (7) years following the transaction, in accordance with tax and accounting requirements.c. Communications: retained for the duration necessary to address your inquiry and for a reasonable period thereafter.d. Marketing Information: retained until you unsubscribe or withdraw your consent, plus a reasonable retention period to honor your preferences.e. Analytics and Usage Data: retained in identifiable form for up to twenty-six (26) months, after which it is aggregated or deleted.6.2 Deletion or Anonymization.When we no longer need your personal information for the purposes described in this Privacy Policy, we will delete it from our systems or anonymize it so that it can no longer be associated with you, except where retention is required by Applicable Laws.
Article 7 — International Data Transfers7.1 Cross-Border Transfers.The Company is based in the United States. By using our Services, you understand that your personal information may be transferred to, stored, and processed in the United States and other jurisdictions where our service providers operate, which may have data protection laws different from those in your country.7.2 Safeguards for EU/UK Transfers.For personal information transferred from the European Economic Area, the United Kingdom, or Switzerland to the United States or other third countries, we rely on appropriate safeguards, including:a. Standard Contractual Clauses approved by the European Commission;b. Other lawful transfer mechanisms permitted under Applicable Laws.You may request a copy of the relevant safeguards by contacting us at hello@coinlegacy.com.
Article 8 — Your Privacy Rights8.1 General Rights.Subject to Applicable Laws and certain exceptions, you have the following rights regarding your personal information:a. Right of Access: to obtain confirmation of whether we process your personal information and to receive a copy of such information.b. Right to Rectification: to correct inaccurate or incomplete personal information.c. Right to Erasure (Right to Be Forgotten): to request deletion of your personal information, subject to certain legal exceptions.d. Right to Restriction: to request that we limit the processing of your personal information in certain circumstances.e. Right to Data Portability: to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another controller.f. Right to Object: to object to the processing of your personal information based on our legitimate interests, including for direct marketing purposes.g. Right to Withdraw Consent: to withdraw your consent at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.h. Right to Lodge a Complaint: to file a complaint with your local data protection authority if you believe we have violated your rights.8.2 Rights for California Residents (CCPA/CPRA).If you are a California resident, you have the following additional rights under the CCPA and CPRA:a. Right to Know: the right to know what personal information we collect, use, disclose, and sell or share.b. Right to Delete: the right to request deletion of your personal information, subject to certain exceptions.c. Right to Correct: the right to request correction of inaccurate personal information.d. Right to Opt-Out of Sale or Sharing: the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising.e. Right to Limit Use of Sensitive Personal Information: the right to limit our use of certain sensitive personal information.f. Right to Non-Discrimination: the right to not be discriminated against for exercising your privacy rights.To exercise your CCPA/CPRA rights, please contact us at hello@coinlegacy.com or use the "Do Not Sell or Share My Personal Information" link on our Website (where applicable).8.3 How to Exercise Your Rights.To exercise any of your privacy rights, please contact us at:Email: hello@coinlegacy.comMail: Propulsa LLC, 651 N Broad St, Middletown, DE 19709, USAWe will respond to your request within thirty (30) days, or within the timeframe required by Applicable Laws. We may need to verify your identity before fulfilling your request to protect against unauthorized access.8.4 Authorized Agents.You may designate an authorized agent to exercise your rights on your behalf. We may require verification of the agent's authority and your identity before fulfilling the request.
Article 9 — Data Security9.1 Security Measures.We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:a. Encryption of personal data in transit using TLS/SSL protocols;b. Encryption of sensitive data at rest where appropriate;c. Access controls limiting employee and contractor access to personal information on a need-to-know basis;d. Regular security assessments and updates;e. Use of reputable third-party service providers with appropriate security certifications.9.2 No Guarantee of Absolute Security.Despite our security measures, no method of transmission over the internet or electronic storage is one hundred percent (100%) secure. We cannot guarantee absolute security, and you acknowledge that you provide your personal information at your own risk.9.3 Notification of Data Breaches.In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by Applicable Laws.
Article 10 — Children's Privacy10.1 Age Restriction.Our Services are intended for individuals who are at least eighteen (18) years of age. We do not knowingly collect personal information from individuals under eighteen.10.2 Removal of Underage Information.If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at hello@coinlegacy.com. We will take appropriate steps to remove the information from our systems.
Article 11 — Third-Party Links and Services11.1 External Links.Our Websites and Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to such third parties.11.2 Third-Party Practices.We are not responsible for the privacy practices or content of third-party websites or services. We encourage you to review the privacy policies of any third party before providing them with your personal information.
Article 12 — Marketing Communications12.1 Opting In.By providing your email address through our forms (such as masterclass opt-ins, lead magnets, or account registration), you consent to receive marketing communications from us, where required by Applicable Laws.12.2 Opting Out.You may unsubscribe from marketing communications at any time by:a. Clicking the "unsubscribe" link in any marketing email;b. Adjusting your communication preferences in your account settings;c. Contacting us at hello@coinlegacy.com.12.3 Transactional Communications.Even if you opt out of marketing communications, we may continue to send you transactional or service-related communications, such as billing notices, security alerts, or updates to our Terms of Service.
Article 13 — Changes to This Privacy Policy13.1 Updates.We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by:a. Posting the updated Privacy Policy on our Website with a new "Last Updated" date;b. Sending you an email notification (where appropriate);c. Providing other prominent notice as required by Applicable Laws.13.2 Continued Use.Your continued use of the Services after the effective date of any updated Privacy Policy constitutes your acceptance of the changes.
Article 14 — Contact Us14.1 General Inquiries.If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:Propulsa LLC, doing business as Coinlegacy651 N Broad StMiddletown, DE 19709, USAEmail: hello@coinlegacy.com14.2 EU/UK Representative.If you are located in the European Economic Area or the United Kingdom and wish to contact a local representative, please contact us at hello@coinlegacy.com and we will provide the relevant contact information where applicable.14.3 Data Protection Authority.If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.
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