Privacy Policy

Overview

Bancroft Systems LLC ("Bancroft," "we," "us," or "our") operates a white-label estate planning software platform licensed to financial advisory practices. This Privacy Policy describes how we collect, use, store, and share information when you interact with the Bancroft platform, whether as an Advisor Firm (a practice that has licensed Bancroft) or as an end user (a client of an Advisor Firm).

By using the Bancroft platform, you agree to the collection and use of information as described in this Policy. If you do not agree, do not use the platform.

Information We Collect

We collect several categories of information in connection with the Bancroft platform:

Account and identity information: Name, email address, phone number, and professional credentials provided when an Advisor Firm registers for the platform.

Client intake information: Personal, financial, and family information entered by end users through the estate planning questionnaire. This includes names, dates of birth, addresses, asset descriptions, beneficiary designations, healthcare preferences, and other sensitive personal information necessary to prepare estate planning documents.

Usage data: Log data, IP addresses, browser type, device identifiers, pages visited, time spent on pages, and other technical information collected automatically when you use the platform.

Communications: Records of support inquiries, emails sent to Bancroft, and other communications you initiate with us.

How We Use Information

We use the information we collect to:

Operate and deliver the platform: processing intake information to generate estate planning document drafts, maintaining account access, and providing advisor dashboard functionality.

Improve the platform: analyzing usage patterns to identify bugs, improve user experience, and develop new features. We do not use client intake information for this purpose.

Communicate with Advisor Firms: sending service updates, responding to support requests, and communicating about account status, billing, and platform changes.

Comply with legal obligations: retaining records as required by applicable law and responding to lawful requests from governmental authorities.

We do not use end-user intake information to train machine learning models, for marketing purposes, or for any purpose beyond delivering the estate planning document preparation service.

Information Sharing

Bancroft does not sell personal information. We share information only in the following circumstances:

With Advisor Firms: End-user information entered through the platform is accessible to the Advisor Firm that invited the end user. The Advisor Firm's own privacy practices govern their use of that information. Bancroft is not responsible for the privacy practices of Advisor Firms.

With people the household chooses: when a household engages an attorney through the platform for a review, Bancroft makes that document, the answers behind it and the review notes available to that attorney. When a client names Digital Safe designees, each designee receives what the client releases to them, on the terms the client set.

To record a deed: for a deed recording order, the deed and the information needed to record it go to our electronic recording partner and to the county recorder. A recorded deed is a public record.

With a referral partner who introduced your firm: if an independent referral partner introduced your firm to Bancroft, we tell that partner whether your firm subscribed and when it made the payments that earn the partner's referral fee. We share nothing else, and the partner may use it only to check that fee.

With service providers: We use service providers to run the platform, each bound by contract to use information only to provide its service to Bancroft and to protect it. The categories are: cloud hosting and computing; database and encrypted file storage; email delivery; payment processing (card details go directly to the payment processor and never reach Bancroft's servers); error monitoring and session diagnostics (see Cookies and Tracking); an AI model provider for the optional in-product assistants; rate limiting and session security; optional single sign-on and address autocomplete; and an optional CRM connection that an Advisor Firm turns on. The current providers, what each processes and where, are listed at usebancroft.com/subprocessors.

With AI service providers: certain optional in-product features, such as the questionnaire help assistant, send the content you are working on to a third-party AI provider in order to return an answer. That provider processes the content solely to generate the response, is contractually prohibited from using it to train models, and keeps it only as its commercial terms allow (see Subprocessors), not for its own purposes. AI is not used to draft personalized legal language, select documents on your behalf, or provide legal advice, and you are not required to use these features. Bancroft keeps a copy of each assistant question and answer, not linked to your account, for up to 90 days so that staff can check the quality of the answers, and then deletes it.

For legal compliance: We may disclose information when required by law, subpoena, court order, or government request, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal proceeding.

In a corporate transaction: If Bancroft is acquired, merged, or transfers substantially all of its assets, client information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Data Security

Bancroft uses commercially reasonable technical and organizational measures to protect information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, and regular security reviews.

No method of transmission over the internet or method of electronic storage is completely secure. While we use commercially reasonable means to protect your information, we cannot guarantee absolute security. If a security incident affects your personal information, notice is given as the law requires. For information entered through an Advisor Firm's deployment, Bancroft notifies the Advisor Firm, which decides on and gives any notice to its clients and regulators; for information Bancroft controls directly, Bancroft gives the notice.

Data Retention

We retain Advisor Firm account information for as long as the account is active and for a period following termination sufficient to comply with legal obligations and resolve disputes.

End-user intake information and generated documents are retained for as long as the corresponding household remains active in the platform. Advisor Firms may request deletion of household data at any time through the platform or by contacting support@usebancroft.com.

We retain general usage logs and technical data for up to 24 months for security and operational purposes.

Audit and compliance records are retained separately and for longer. Records of security-relevant and account-relevant events, such as sign-ins, permission and role changes, administrative actions, document generation and release, and access to sensitive records, are retained for a minimum of seven years, together with limited technical identifiers such as IP address and browser user agent. This retention reflects financial-services recordkeeping practice and the integrity requirements of a tamper-evident audit trail, and applies notwithstanding the 24-month period above and any deletion of the related household data.

Advisor Firm Responsibilities

Advisor Firms that deploy the Bancroft platform collect personal information from their clients in the context of their advisory relationship. Advisor Firms are independently responsible for:

Providing their own privacy disclosures to clients describing how information entered into the Bancroft platform will be used and shared.

Obtaining any consents required under applicable law for the collection and processing of client personal information through the platform.

Complying with all applicable privacy laws, including but not limited to state privacy statutes and any applicable federal financial privacy regulations, in connection with their use of the platform.

Bancroft is a data processor with respect to end-user information entered through white-labeled Advisor Firm deployments. The Advisor Firm is the data controller for that information.

The data protection terms between Bancroft and an Advisor Firm, including processing instructions, security measures, subprocessor authorization, and a commitment to notify the Advisor Firm of a security incident immediately, and in any event within 72 hours, are set out in the Bancroft Data Processing Addendum at usebancroft.com/dpa. The providers that process personal data on Bancroft's behalf are listed at usebancroft.com/subprocessors.

Your Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to access, correct, or delete information we hold about you, or to object to or restrict certain processing.

If you are an end user of an Advisor Firm's deployment, please contact your Advisor Firm directly to exercise rights related to your estate planning information. Your Advisor Firm controls access to and deletion of that information within the platform.

For information that Bancroft controls directly (such as account information for Advisor Firms), contact us at support@usebancroft.com, or by mail at Bancroft Systems LLC, 5799 S. Main St., Unit #174, Clarkston, MI 48347, to submit a request. We will respond within the timeframe required by applicable law.

California Residents

California residents. For estate planning information entered through an Advisor Firm's deployment, the Advisor Firm is the "business" under the California Consumer Privacy Act, as amended (CCPA), and Bancroft is its "service provider". Bancroft processes that information only on the firm's behalf and under contract terms that meet the CCPA's requirements for service providers. To exercise a right to know, delete or correct that information, contact your Advisor Firm. If you send the request to Bancroft, we will tell you to contact your firm and let the firm know you asked.

To the extent the CCPA applies to information Bancroft controls directly, such as Advisor Firm account information, California residents may request to know what personal information we collect, use and disclose; to delete it; and to correct it, and will not be discriminated against for doing so. Email support@usebancroft.com with the subject line "California privacy request". We will verify the request before acting on it and respond within the time the law requires. You may use an authorized agent, and we may ask for proof of the agent's authority.

Bancroft does not sell or share personal information, as the CCPA defines those terms, and uses sensitive personal information only to provide the services you request, so we do not offer an opt-out of sale or sharing or a right to limit. We do not disclose personal information to third parties for their own direct marketing purposes (Civil Code section 1798.83).

Cookies and Tracking

The Bancroft platform uses cookies and similar technologies to maintain session state, remember preferences, and collect usage analytics. We do not use third-party advertising cookies or sell data to advertising networks.

Our marketing site (usebancroft.com) uses Google Analytics 4 to collect anonymous usage data such as pages visited, time on site, and general geographic region. This data is used to understand how visitors interact with the site and to improve the experience. Google Analytics uses first-party cookies to distinguish unique users and sessions. No personally identifiable information is collected or shared with Google for advertising purposes.

Error monitoring and session diagnostics: when an error occurs, the platform sends a diagnostic report (the error, the page, and browser and device details) to an error-monitoring service so we can fix it. If you allow analytics in the cookie banner, the platform may also record a reconstruction of a browser session (pages viewed, navigation and interactions) when an error occurs, and for a small sample of other sessions. That recording masks all text, form inputs and images, so the personal and financial information on your screen and what you type are not captured. If you choose essential cookies only, no session is recorded. Diagnostics are used only to find and fix technical problems, never for advertising or profiling.

Do Not Track: Some browsers send a "Do Not Track" signal. There is no common standard for how a website should respond to it, and the platform does not change its behavior when it receives one. The platform does not track you across other websites and does not use advertising cookies, and you can turn off optional analytics and session diagnostics at any time from the cookie banner.

Tracking by other parties: We do not allow other parties to collect personally identifiable information about your online activities over time and across different websites when you use the platform. On our marketing site, Google Analytics collects usage information as described above, with Google signals and ad personalization turned off.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Some features of the platform may not function properly if cookies are disabled.

Children's Privacy

The Bancroft platform is not directed to children. Platform accounts are for adults only, and we do not knowingly permit anyone under 18 to create an account or enter information directly. If we become aware that a minor has created an account or submitted information directly through the platform, we will take steps to delete that account and information.

Estate planning necessarily involves information about minors. An adult using the platform may enter information about their own children or other minor dependents, such as names, dates of birth, guardianship nominations, and beneficiary designations, because that information is required to prepare the requested documents. This information is provided by the adult account holder, not collected from the child, and is used only to generate and administer the estate planning documents and related workflows. It is handled under the same protections as all other intake information described in this Policy.

Changes to This Policy

We may update this Privacy Policy from time to time. The date of the most recent revision appears at the bottom of this page. Material changes will be communicated to Advisor Firms via email or in-platform notice. Continued use of the platform after the effective date of any change constitutes acceptance of the revised Policy.