Privacy Policy

1. Information We Collect

1.1 Account and Organization Data

When your firm creates a Ledgr account, we collect:

• Firm name, billing address, and contact information
• User names, email addresses, and role assignments (admin, advisor, viewer)
• Authentication credentials (passwords are hashed; we never store plaintext passwords)
• Microsoft Entra ID / Azure AD identity tokens for enterprise SSO users
• Multi-factor authentication (MFA) configuration and backup codes (stored encrypted)
• Login history, device and browser information, and IP addresses

1.2 Client Financial and Personal Data

Ledgr is designed to manage records for ultra-high net worth (UHNW) wealth advisory clients. Your firm may enter and store the following categories of client data:

• Personal identifiers: Full legal names, dates of birth, Social Security Numbers (SSN), taxpayer identification numbers
• Contact information: Home addresses, email addresses, phone numbers
• Financial data: Net worth figures, asset values, investment portfolio information, beneficiary designations
• Insurance policy data: Policy numbers, carrier names, coverage amounts, premium schedules, beneficiary information, policy documents (life insurance, disability, long-term care, liability)
• Loan and liability data: Loan balances, interest rates, repayment schedules, collateral descriptions, lender information
• Entity structure data: Trust structures, LLC/partnership formations, family office details
• Documents: Policy certificates, financial statements, estate planning documents, uploaded by your firm
• Planning scenarios: Financial projections, stress-test models, planning notes

1.3 Usage and Technical Data

• Pages visited, features used, and session durations
• API request logs (for security and debugging)
• Error reports and performance metrics
• Browser type, operating system, and device type

1.4 Third-Party Integration Data

If your firm connects optional integrations, we may receive:

• Airtable: CRM records, contact data, and custom fields you specify in the integration configuration
• Egnyte: Document metadata and file access tokens (file contents are fetched on-demand; not stored permanently in Ledgr)
• Microsoft Teams: Webhook URL for notifications only; no Teams data is stored in Ledgr

2. How We Use Your Information

We do not sell your data or your clients' data to third parties. We do not use client financial data for advertising, profiling, or any purpose beyond operating the platform for your firm.

3. Data Storage and Security

3.1 Encryption

• In transit: All data transmitted between your browser and Ledgr servers is encrypted using TLS 1.2 or higher (HTTPS enforced; HTTP is not supported)
• At rest: Database data is encrypted at rest by Neon (AES-256). OAuth tokens and integration credentials are additionally encrypted at the application layer using AES-256-GCM before storage
• Documents: Files stored in Cloudflare R2 are encrypted at rest (AES-256)
• Passwords: Hashed using bcrypt (cost factor 12) — never stored in plaintext

3.2 Access Controls

• Role-based access control (RBAC): Super Admin, Admin, Advisor, and Viewer roles with least-privilege defaults
• Multi-tenant isolation: Each firm's data is strictly isolated; no cross-organization data access is possible by design
• Multi-factor authentication (MFA) available for all users; enforceable by organization policy
• Account lockout after 5 failed login attempts (15-minute lockout)
• Session timeout configurable by organization (default: 8 hours)
• All privileged actions (user creation, role changes, org settings changes) are logged with before/after state

3.3 Infrastructure Security

• Hosted on Render (SOC 2 Type II certified) in US-West (Oregon)
• Database hosted on Neon (SOC 2 Type II certified) in US-East
• No production database access without explicit authorization and logging
• Security headers deployed: X-Frame-Options (SAMEORIGIN), X-Content-Type-Options (nosniff), Referrer-Policy (strict-origin-when-cross-origin), Permissions-Policy

4. Data Retention

We retain data in accordance with applicable financial regulations and your firm's configuration:

Your firm can request deletion of specific records at any time through the platform's deletion workflow. Regulatory-minimum retention periods apply and cannot be shortened for data subject to GLBA or SEC recordkeeping requirements.

5. Third-Party Processors (Subprocessors)

We use the following subprocessors to provide the Ledgr platform. Each has been evaluated for data security and compliance posture:

An up-to-date subprocessor list is maintained in the Ledgr Security Center. We will notify subscribed firms of any material changes to subprocessors with at least 30 days' notice where practicable.

6. GLBA Financial Privacy Disclosures

Ledgr serves Registered Investment Advisors (RIAs), insurance professionals, and other financial service providers subject to the Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule (16 C.F.R. Part 314).

6.1 Our Role as a Service Provider

Under GLBA, Ledgr operates as a service provider to financial institutions (your firm). We receive and process "nonpublic personal information" (NPI) about your clients on your behalf and under your direction.

As your service provider, Ledgr:

• Maintains safeguards to protect NPI consistent with GLBA and the Safeguards Rule
• Does not disclose NPI for any purpose other than providing services to your firm
• Does not use NPI for its own marketing or analytics
• Maintains a Written Information Security Program (WISP) addressing the requirements of § 314.4
• Designates a qualified individual responsible for our information security program

6.2 Your Firm's GLBA Obligations

Your firm, as the financial institution, remains responsible for:

• Providing required privacy notices to your clients
• Ensuring this use of Ledgr is disclosed in your firm's own privacy notice
• Maintaining a WISP that covers Ledgr as a service provider
• Implementing appropriate technical controls at your firm level (device security, employee training, etc.)

7. Your Rights (CCPA and State Privacy Laws)

For users and clients in states with applicable privacy laws (including California under CCPA/CPRA), the following rights apply:

7.1 Rights for Firm Administrators and Users

• Right to Know: Request a summary of personal information we hold about you
• Right to Delete: Request deletion of your personal information (subject to legal retention requirements)
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt Out: We do not sell personal information; this right is not applicable
• Non-Discrimination: We will not discriminate against you for exercising these rights

7.2 Rights for Clients Whose Data Is Managed by Your Firm

If you are an individual whose data has been entered into Ledgr by a wealth advisory firm, your rights requests should be directed to that firm, not to Ledgr. We are a processor on their behalf. Upon verified instruction from your firm, we will assist with data access, correction, or deletion requests.

To exercise your rights, contact us at: privacy@ledgr.com

8. Data Sharing and Disclosure

We share data only in these circumstances:

• Subprocessors: As listed in Section 5, for the specific purposes described
• Legal requirements: When required by law, regulation, court order, or valid legal process from a government authority
• Safety: To protect the safety, rights, or property of Ledgr, its users, or the public
• Business transfers: In connection with a merger, acquisition, or sale of assets, with appropriate data protection continuity
• With your consent: Any other sharing requires your explicit, informed consent

We do not:

• Sell personal information or client financial data
• Share data with data brokers
• Use client data for advertising targeting
• Disclose data to any third party without a legitimate basis

9. International Data Transfers

Ledgr's primary infrastructure is located in the United States. If your firm is located outside the United States, data you enter into Ledgr will be transferred to and processed in the US.

For firms subject to GDPR or other international data protection frameworks, please contact us at privacy@ledgr.com to discuss appropriate data transfer mechanisms (Standard Contractual Clauses or equivalent).

10. Children's Privacy

The Ledgr platform is a professional B2B service intended for use by wealth advisory firms and their staff. It is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. Client records in Ledgr may include minor beneficiaries in the context of estate planning data; such data is subject to the same protections as all other NPI.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Notify organization administrators via in-app banner and email
• Provide at least 30 days' notice before material changes take effect for existing subscribers
• Maintain a version history of significant policy changes

Continued use of Ledgr after the effective date of changes constitutes acceptance of the revised policy.

12. Contact Us