Privacy Policy | Third Executor

1. INTRODUCTION

This Privacy Policy (“Policy”) describes how Third Executor, LLC, a Delaware limited liability company (“Third Executor,” “Company,” “we,” “our,” or “us”), collects, uses, discloses, and protects nonpublic personal information (“NPI”) and other personal data in connection with our business operations.

This Policy applies to our marketing website (www.thirdexecutor.com), our application (app.thirdexecutor.com), any mobile applications we may offer, and all related products and services (collectively, the “Services”). Third Executor provides estate settlement, financial asset organization, probate avoidance consultation, and related services, including our Assetprint, Expert Consultation, and Executor Concierge service offerings. Services offered by Third Executor do not include and do not constitute financial, accounting, legal, or tax advice. Third Executor does not act as an executor, trustee, or fiduciary in the administration of assets in connection with the Services.

You represent and warrant that you are at least eighteen (18) years of age, that you are a resident of the United States, and that you have the legal capacity to agree to this Policy. We are committed to safeguarding the privacy and confidentiality of the information you entrust to us. This Policy is provided in accordance with applicable federal and state privacy and data protection laws. We encourage you to read this Policy carefully to understand our practices regarding your personal information.

2. INFORMATION WE COLLECT

We collect information from and about you in several ways, as described below.

A. Information You Provide Directly

When you use our Services, create an account, or otherwise interact with us, we may collect the following categories of information that you voluntarily provide:

Full name and mailing address
Email address and telephone number
Beneficiary names and contact information
Financial institution names
Date of birth
Death certificates, if applicable
Professional advisor contact information (e.g., attorneys, accountants, financial advisors)
Last four (4) digits of financial account numbers
Account values and balances
Estate and probate-related documentation
Payment information (processed securely by our third-party payment processor, Stripe; card data never touches our servers)

B. Information Collected Automatically (Cookies and Tracking Technologies)

We use cookies and similar technologies on our website and applications, if applicable, to collect certain information automatically. Our website uses the following technologies.

Marketing Site (www.thirdexecutor.com)

Our marketing site, hosted by Webflow, uses the following technologies:

Google Analytics 4 (Measurement ID: G-4S5XRGKBCP): Sets first-party cookies (_ga, _ga_4S5XRGKBCP) with a two (2) year duration for site analytics purposes.
Google Ads (AW-16557633409): Sets first-party cookie _gcl_au (90-day duration), uses localStorage key _gcl_ls, and third-party cookies DoubleClick IDE (approximately 13 months) and test_cookie (15 minutes) for ad conversion measurement and remarketing.
Meta Pixel (ID: 2330610283938456): Sets first-party cookies _fbp (90-day duration) and _fbc (when a Meta click ID is present) for ad measurement and audience building. Automatic Advanced Matching is disabled. Limited Data Use is enabled.
Mailchimp (Mailchimp/Intuit): Collects newsletter form submission data only.
Adobe Fonts (Typekit): Sends a font-usage beacon to p.typekit.net. No cookie is set.
Google Fonts: IP address is logged by Google when fonts are loaded. No cookie is set.
Webflow Hosting: No visitor cookies are set by the hosting platform.

Application (app.thirdexecutor.com)

Our application uses only the following technologies, which are strictly necessary or functional:

Session Cookie: A first-party, httpOnly session cookie used for authentication. This cookie is strictly necessary for the operation of the application.
localStorage: Keys for UI preferences (assetsView, dashboardMode) used to store display settings. These are functional and do not track users.
Chart.js: Loaded from cdn.jsdelivr.net for data visualization. No cookie is set.
Plaid Link: Used for account linking. Plaid Link loads within Plaid’s own iframe, and Plaid sets its own cookies and localStorage on plaid.com for security and fraud prevention purposes. Plaid presents its own privacy consent. Plaid acts as a service provider. Account credentials do not pass through Third Executor servers.
Stripe: Used for payment processing. Checkout and the Customer Portal are hosted on Stripe’s domain. No Stripe scripts or cookies are loaded on our application pages. Stripe sets its own cookies on checkout.stripe.com during payment for fraud prevention. Stripe acts as a service provider. Card data never touches Third Executor servers.

No analytics, advertising, or session-recording technologies operate within the application.

C. Information from Third Parties

We may receive information about you from third parties, including financial institutions, brokers, advisors, or agents, in connection with the estate settlement services we provide. This information is obtained with your authorization or as otherwise permitted by law.

3. NONPUBLIC PERSONAL INFORMATION (NPI)

“Nonpublic personal information” (NPI) means personally identifiable financial information that is provided by a consumer to a financial institution, results from a transaction or service performed for a consumer, or is otherwise obtained by the financial institution, and that is not publicly available.

The categories of NPI we collect include:

The fact that you are or have been a customer of Third Executor
Name, address, email address, and other contact information provided to obtain our Services
Financial account information, including the last four (4) digits of account numbers, account values, and financial institution names
Beneficiary and estate-related information, including beneficiary names, contact information, and documentation related to estate administration
Transaction and service history related to your use of our Services

We collect NPI: (i) directly from you when you provide it to us through our website, application, or other communications; (ii) from financial institutions, advisors, and other third parties with your authorization; and (iii) in connection with performing our Services on your behalf.

4. HOW WE USE YOUR INFORMATION

We use the information we collect, including NPI, for the following purposes:

To provide and perform our Services, including Assetprint (financial asset inventory), Expert Consultation (pre-death asset organization and probate avoidance), and Executor Concierge (post-death financial asset identification, location, consolidation, and distribution)
To identify, locate, organize, consolidate, and facilitate the transfer of financial assets on your behalf
To communicate with financial institutions, brokers, advisors, and agents on your behalf and at your direction
To process payments, including recurring subscription billing, through our third-party payment processor, Stripe
To send you service-related communications, including account confirmations, service updates, and transactional notifications
To improve, maintain, and optimize our website and application
For site analytics and marketing purposes on our marketing site (www.thirdexecutor.com) only
To comply with applicable legal and regulatory obligations
To protect against fraud, unauthorized transactions, security threats, and other potentially prohibited or illegal activities
To enforce our terms of service and protect our rights, property, or safety, or that of our customers or third parties

We may disclose the categories of information described in this Policy, including NPI, under the following circumstances:

A. Disclosures to Affiliates

Third Executor does not currently have any affiliates. If we establish affiliates in the future, this Policy will be updated to describe any sharing of NPI with such affiliates.

B. Disclosures to Non-Affiliated Third Parties for Service Performance

We share NPI with non-affiliated third parties as necessary to perform services on your behalf or at your direction. These disclosures include sharing information with:

Financial institutions, brokers, advisors, and agents involved in your estate settlement, as necessary to identify, locate, consolidate, and facilitate the transfer of financial assets
Stripe for payment processing
Plaid for financial account linking and verification
Webflow for website hosting
Mailchimp (Intuit) for email communications and newsletter delivery

Each of these service providers is contractually required to protect NPI and to use it only for the specific purposes for which it was disclosed, consistent with this Policy and applicable law.

C. Disclosures for Marketing and Advertising

On our marketing site (www.thirdexecutor.com) only, certain data is shared with third parties through cookies and tracking technologies for analytics and advertising purposes. These third parties include:

Google (through Google Analytics 4 and Google Ads) for site analytics, ad conversion measurement, and remarketing
Meta (through the Meta Pixel) for ad measurement and audience building

These disclosures constitute third-party cookie disclosures and may be considered “sharing” of personal information under certain state privacy laws. No marketing or advertising technologies operate within our application (app.thirdexecutor.com). Please see Section 2.B (Information Collected Automatically) and Section 9 (Your Rights and Choices) for information about how to control these disclosures.

D. Other Disclosures

We may also disclose your information, including NPI, in the following circumstances:

As required by law, regulation, legal process, or enforceable governmental request
To protect the rights, property, or safety of Third Executor, our customers, or the public
In connection with a sale, merger, acquisition, reorganization, or transfer of all or a portion of our business assets, subject to applicable law
With your consent or at your direction

We do not sell your NPI. We do not disclose consumer account numbers to non-affiliated third parties for the purpose of telemarketing, direct mail marketing, or other marketing through electronic mail.

6. YOUR OPT-OUT RIGHTS

You have the right to opt out of certain disclosures of your NPI to non-affiliated third parties. If we propose to share your NPI with a non-affiliated third party for purposes other than those described in the statutory exceptions below, we will provide you with a reasonable opportunity to opt out before doing so.

How to Exercise Your Opt-Out Right. You may opt out of such disclosures at any time by contacting us through any of the following methods:

By email at: privacy@thirdexecutor.com

Your opt-out election will remain in effect until you revoke it. We will comply with your opt-out request as soon as reasonably practicable, and in any event within the time periods required by applicable law.

Exceptions to the Opt-Out Right. The opt-out right does not apply to disclosures of NPI that are:

Necessary to effect, administer, or enforce a transaction that you request or authorize
Made to process or service your account, including to maintain or service your account
Made with your consent or at your direction
Required to protect the confidentiality or security of our records
Required to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability
Required for institutional risk control or for resolving customer disputes or inquiries
Required or permitted by law, including disclosures to law enforcement agencies, self-regulatory organizations, or for public safety
Made to our attorneys, accountants, or auditors
Made to comply with federal, state, or local laws, rules, or regulations
Made in connection with a sale, merger, or transfer of all or part of our business, subject to applicable law

7. DATA SECURITY

We take the security of your information seriously. We maintain a comprehensive written information security program that includes administrative, technical, and physical safeguards appropriate to our size, complexity, the nature and scope of our activities, and the sensitivity of the information we handle.

Our security measures include, but are not limited to:

TLS (Transport Layer Security) encryption for all data transmitted between your device and our servers
AES-256 encryption for data at rest
Strict access controls to limit access to personal information to authorized personnel on a need-to-know basis
Multi-factor authentication (MFA) for account access
Secure disposal practices for personal information that is no longer needed
Regular risk assessments to identify and address potential threats to the security, confidentiality, and integrity of customer information
Oversight and contractual requirements for service providers who access or maintain customer information

We employ a minimal data collection approach, collecting only the information necessary to provide our Services (for example, we collect only the last four (4) digits of account numbers rather than full account numbers).

Despite our efforts, no method of data transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

8. DATA RETENTION

We keep NPI and other personal data only as long as we need it to provide the Services (including delivering your Assetprint to your Designated Third Executor), to meet our legal and regulatory obligations, and for the other purposes described in this Policy. Specifically:

While your account is active. We keep your Assetprint, uploaded documents, and account information for as long as your account exists, so that your Assetprint can be delivered to your Designated Third Executor. Keeping this information is necessary to provide the Service you requested.

After your death. When we receive notice of your death and verify it (for example, with a death certificate or other reasonable documentation), we deliver your Assetprint to your Designated Third Executor, as you directed. We keep it for twenty-four (24) months after delivery and then securely delete it. If the estate is still open, your Designated Third Executor may ask us in writing to keep it longer, and we will keep it for as long as reasonably needed to settle the estate.

If your account becomes inactive. We do not delete your Assetprint because you cancel, your subscription lapses, or a payment fails. We keep the most recent version, and it will still be delivered to your Designated Third Executor after your death.

If you ask us to delete your data. You may ask us to delete your account and Assetprint at any time by emailing privacy@thirdexecutor.com. After we verify your identity, we will delete your data. Once deleted, your Assetprint can no longer be delivered to your Designated Third Executor or anyone else. We may keep a limited record of your request and any information the law requires us to keep.

Backups. Deleted data may remain in encrypted backups for up to thirty-five (35) days before it is permanently deleted. We do not use backup data for any other purpose during that time.

Legal obligations. We may keep information longer when the law requires it, or as needed to resolve disputes, prevent fraud, or enforce our agreements.

When we no longer need information for these purposes, we securely delete, destroy, or de-identify it using methods suited to its sensitivity. We also periodically review our retention practices to avoid keeping data longer than necessary.

9. YOUR RIGHTS AND CHOICES

A. California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), including:

Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purposes for collection or sale, and the categories of third parties with whom we share personal information.
Right to Delete: You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions.
Right to Opt Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. To the extent that our use of third-party advertising cookies on our marketing site constitutes a “sale” or “sharing” under the CCPA, you may exercise this right through our “Do Not Sell or Share My Personal Information” link or by enabling the Global Privacy Control (GPC) signal in your browser.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.

B. Residents of Other States with Comprehensive Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, or another state that has enacted a comprehensive consumer privacy law, you may have similar rights, including the right to access, correct, delete, or obtain a portable copy of your personal data, and the right to opt out of targeted advertising, the sale of personal data, and certain profiling activities. The specific rights available to you depend on the law of your state of residence.

C. Exercising Your Rights

To exercise any of the rights described above, please contact us using any of the following methods:

Email: privacy@thirdexecutor.com

We will verify your identity before responding to your request and will respond within the time periods required by applicable law. If we are unable to verify your identity, we may deny your request. You may also designate an authorized agent to submit a request on your behalf, subject to our verification requirements.

10. FORMER CUSTOMERS

If your customer relationship with Third Executor ends, we will continue to protect your NPI in accordance with this Policy and applicable law. We will not share your NPI with non-affiliated third parties except as permitted under the statutory exceptions or as otherwise described in this Policy, for as long as we retain your information.

11. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal information from children under eighteen (18). If we become aware that we have inadvertently collected personal information from a child under eighteen (18), we will take commercially reasonable steps to delete such information as promptly as practicable. If you believe we have collected information from a child under eighteen (18), please contact us at privacy@thirdexecutor.com.

12. CHANGES TO THIS POLICY

We may update or revise this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will post the revised Policy on our website and update the “Last Updated” date at the top of this Policy. Where required by applicable law, we will provide additional notice of material changes (such as by email or prominent website notice).

Your continued use of our Services after any changes to this Policy constitutes your acceptance of the revised Policy as of the date of such changes. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

13. CONTACT US

If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at:

Third Executor, LLC

PO Box 8811, Briarcliff Manor, NY 10510

Email: privacy@thirdexecutor.com (privacy inquiries); contact@thirdexecutor.com (general inquiries and legal notices)

Website: www.thirdexecutor.com