Privacy Policy

1.  Who We Are

My Land Trustee is the trade name under which Land Trust Service Corporation and TRSTE LLC provide trustee services for Florida land trusts, together with registered agent service and related business compliance services. We hold title to real property as trustee for the benefit of the people and entities who direct us. Both companies operate from 1901 W Colonial Drive, Orlando, FL 32804.

For the purposes of state privacy laws, Land Trust Service Corporation and TRSTE LLC are joint controllers of the information described in this Policy. A request made to either is treated as a request made to both, and one answer covers you for both.

2.  What a Land Trust Keeps Private, and What It Does Not

That is a real and durable privacy benefit, and it is also a narrower one than people sometimes assume. Three things follow, and we would rather you hear them from us than discover them later.

What is not in the public record

Your name as beneficiary, the terms of the trust agreement, the identity of successor beneficiaries, and the internal instructions you give us are not recorded and are not searchable by a member of the public browsing county records. A person running a property search sees the trustee.

What we know, and hold

We know everything the public record does not. We hold the trust agreement, your identity and contact details, your taxpayer identification number where the trust requires one, your instructions, and the closing file. A land trust moves your name out of the public record and into our files. That is the trade, and protecting those files is the substance of our obligation to you. Section 14 describes how we do it.

When we would have to hand it over

A land trust is not a shield against a court. If we receive a subpoena, court order, garnishment, levy, or other valid legal process that reaches the information we hold, we will comply with it. We are not your lawyers and we cannot assert a privilege on your behalf that does not exist. What we will do:

• Check it before we act on it. We review the demand for validity and scope, and we do not produce more than it actually requires.
• Tell you. Where the law permits us to notify you of a demand for your information, we will, and we will do it in time for you to seek relief if you choose to.
• Object where there is a basis to object. Where a demand is defective, overbroad, or improperly served, we say so.
• Refer you to counsel. If you want the demand challenged, that is a legal question and you will need a lawyer. We can tell you what we received; we cannot advise you on what to do about it.

Anyone who tells you a land trust makes your assets untraceable to a determined creditor with a judgment and a subpoena is selling you something we do not sell.

3.  We Are Not a Law Firm

My Land Trustee provides trustee and administrative services. We are not a law firm, we do not practice law, and we do not give legal, tax, or investment advice. Nothing you tell us is protected by the attorney-client privilege. Information you give a lawyer for the purpose of obtaining legal advice may be privileged; the same information given to a trustee generally is not.

Aspire Legal Solutions PLLC is a separate, affiliated law firm. If you engage that firm, your communications with the firm are covered by its own privacy policy and by the confidentiality duty Florida lawyers owe under Rule 4-1.6 of the Rules Regulating The Florida Bar. Engaging one company does not engage the other, and information does not move between us automatically. Section 12 explains what moves and when.

4.  Information We Collect

We collect the following categories of personal information:

• Identifiers and contact information: name, business name, postal address, email address, and telephone and mobile numbers.
• Identity verification information: government-issued identification, date of birth, and, where a trust or a filing requires one, a Social Security number or other taxpayer identification number.
• Trust and beneficial interest information: the identity of settlors, beneficiaries, successor beneficiaries, and holders of a power of direction; the trust agreement and any amendments; assignments of beneficial interest; and the instructions you give us as trustee.
• Property and transaction information: the legal description and address of the property, the deed and recording information, purchase and sale documents, closing statements, title commitments and policies, mortgage and lien information, insurance information, and tax bills.
• Entity and registered agent information: the entities you form or maintain through us, their officers, managers, members, and registered agent details.
• Financial and payment information: billing details, the amount and timing of payments, funds we receive or disburse in connection with a trust, and the last four digits and expiration date of a payment card. Full payment card numbers are collected and stored by our third-party payment processor, not by us.
• Communications and meeting content: emails, text messages, letters, call and meeting notes, and, where you have consented, audio-visual recordings and written transcripts of meetings.
• Voice profiles: because our meeting-transcription tool identifies who is speaking, it creates and stores a voice profile that distinguishes your voice from other participants'. A voice profile is a biometric identifier under the law of Illinois, Texas, and certain other states. We collect it only with your consent, and Section 9 explains it in full.
• Website and device data: IP address, browser type, device identifiers, pages visited, referring URL, and similar information collected through cookies and comparable technologies.
• Inferences: conclusions we draw from the above in order to administer the trust and serve you.

Sensitive information

Taxpayer identification numbers and government identification numbers are sensitive, and unlike most businesses we cannot avoid collecting them. A trust needs a taxpayer identification number, a closing requires identity verification, and federal reporting rules described in Section 8 require identifying numbers for certain individuals. We collect that information because the service requires it, we use it only for the purposes in Section 6, we do not use it to infer characteristics about you, and we do not sell or share it.

We limit our use of your voice profile to identifying who is speaking in a meeting you have consented to record. We do not use it to infer anything about you, and we do not use it to identify you anywhere else. Apart from the categories above we do not seek, and ask that you not send us, sensitive information such as health data, precise geolocation, racial or ethnic origin, religious beliefs, sexual orientation, or union membership. If such information reaches us incidentally, we use it only for the purpose for which you provided it and delete it when that purpose is spent.

5.  Where the Information Comes From

We collect information directly from you, when you complete an order form, book an appointment, speak with us, or engage us as trustee or registered agent. We collect it automatically from your device when you use our website. We receive it from service providers acting on our behalf, such as our scheduling platform, payment processor, e-signature provider, and email and meeting tools.

We also receive it from other participants in a transaction, including title agents, closing agents, lenders, real estate brokers, accountants, and attorneys, in each case where the transaction requires it or where you have authorized it. And we obtain information from public records, including county property and official records, the Florida Division of Corporations, and court dockets.

6.  How We Use Information

We use personal information only for the purposes listed below, and for purposes reasonably compatible with them:

• To act as trustee, including holding title, executing documents at your direction, and administering the trust according to its terms.
• To provide registered agent service and the business compliance services you have ordered, including making the filings those services require.
• To verify your identity and the authority of anyone who directs us on a trust.
• To communicate with you about your trust, your entities, your account, and your bill, and to respond to your questions and requests.
• To schedule and confirm meetings, including appointment reminders.
• To process payments and to receive and disburse funds in connection with a trust or a closing.
• To comply with our legal, regulatory, tax, and reporting obligations, including those described in Section 8.
• To establish, exercise, or defend legal claims, and to respond to legal process.
• To improve our services, materials, website, and client experience.
• To protect against fraud, unauthorized access, and misuse of our services.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects about you, and we do not profile you for that purpose. We will not use your information for a materially different purpose than those described here without first telling you and, where required, obtaining your consent.

7.  We Do Not Sell or Share Your Personal Information

My Land Trustee does not sell personal information for money or other valuable consideration, and does not share it for cross-context behavioral advertising or targeted advertising, as those terms are defined under state privacy laws. We have not done so in the preceding twelve months. Given what our clients come to us for, we would regard doing so as a breach of the whole arrangement. We do not knowingly sell or share the personal information of consumers under 16 years of age.

8.  Reporting and Filing Obligations

Some of what we collect, we collect because a law requires it, and some of what we collect we are required to report or to file. Where that is the case we tell you at the time.

Public filings you should expect

Deeds and recorded instruments. A deed conveying property into a land trust is recorded in the county official records and is public. It names the trustee, not you.

Registered agent service. Where we serve as registered agent, the registered agent name and street address appear in the public records of the Florida Division of Corporations, along with the other information the annual report requires. That is the point of the service and it is public by design.

Federal residential real estate reporting

Where we are required to make such a report, or to supply information to another party who is required to make one, we collect the information the rule calls for and we report it. We will tell you when a transaction is reportable and what is being reported. This is a federal requirement placed on the transaction; it is not something we choose to do and not something we can waive.

Tax reporting

We make the tax filings and information returns that our role requires, which may include reporting a taxpayer identification number to the Internal Revenue Service or to a closing agent.

9.  Recording and Automated Transcription of Meetings

Because we work with clients remotely, we may record videoconference meetings and calls, and we may use automated tools to transcribe them, generate summaries, or take notes. The following applies to every such recording. Our full retention schedule is published separately as our Recording Retention Schedule, which this Policy incorporates by reference. The wider internal policy it forms part of is not published.

• Consent first. We operate from Florida, which requires the consent of all parties to intercept a private communication. Section 934.03(2)(d), Florida Statutes, provides that “[i]t is lawful under this section and ss. 934.04-934.09 for a person to intercept a wire, oral, or electronic communication when all of the parties to the communication have given prior consent to such interception.” Roughly ten other states require the same. We disclose at the start of the meeting that recording or automated transcription is taking place, we identify any automated notetaking tool that is present, and we obtain your affirmative consent before recording begins.
• Declining is free of consequence. If you do not consent, we will not record or transcribe, and you will receive exactly the same service. You may withdraw consent at any point during a meeting and we will stop recording from that point forward.
• What we do with them. Recordings and transcripts are used to administer your trust accurately, to let you or your account manager revisit what was discussed, to confirm the instructions you gave us, for internal training and quality review, and to establish or defend legal claims. They are not sold, not used to build advertising profiles, and not published or shared externally without your separate written permission.
• Who can access them. Access is limited to our personnel who need it for the purposes above, and to the meeting and transcription vendors that process the recording on our behalf under written confidentiality and data-protection obligations. Two-factor authentication is required for the systems that hold recordings and transcripts.
• Written notice before we record. Before a recorded meeting we give you written notice of what is collected, why, and how long it is kept, and we ask for your signed consent. You can give or refuse that consent when you book.
• A recording is a record. A recorded instruction is discoverable in the same way a written one is, and a recording is subject to the same legal process described in Section 2. If you would rather a particular conversation not be recorded, say so and it will not be.
• How long we keep them. We delete audio and video recordings, and the voice profile derived from them, twelve (12) months after the meeting. Written transcripts are kept for the periods in Section 13. You may ask us to delete any of it sooner, at any time.

10.  SMS and Text Messaging

My Land Trustee uses SMS text messaging primarily to remind clients of scheduled appointments and to pass along time-sensitive information about a closing or a filing deadline. When you provide your mobile number, you consent to receive informational, transactional text messages of that kind. We do not use this program to send marketing or promotional messages. Your mobile number and SMS consent status are never sold, shared, or disclosed to third parties or affiliates for their own marketing or promotional purposes, and this remains true if any other part of this Policy is changed.

Message frequency varies with your transactions and appointments. Message and data rates may apply. Text is not a secure channel and is not the right place for trust detail or identifying numbers. You may revoke consent and opt out at any time by any reasonable means, including replying “STOP” to any message or contacting us using the details in Section 19. We honor opt-outs promptly and do not require a particular word or channel. Reply “HELP” for assistance. Carriers are not liable for delayed or undelivered messages.

11.  Cookies, Tracking, and Universal Opt-Out Signals

Our website may use cookies and similar technologies to operate the site, remember your preferences, and understand how visitors use our content. You can control cookies through your browser settings; disabling them may affect some functionality.

Global Privacy Control. Where your browser or a browser extension sends a universal opt-out signal such as Global Privacy Control, we treat that signal as a valid request to opt out of any sale, sharing, or targeted-advertising use of your personal information, and we honor it automatically for that browser without requiring you to take any further step. Because we do not sell or share personal information in the first place, this signal does not change how we handle your data. We honor it regardless.

We also honor browser “Do Not Track” signals to the same effect.

12.  How We Share Information

We share personal information only as described here, and never in exchange for money:

• Service providers and processors who perform functions on our behalf, including document management and storage, scheduling, videoconferencing and transcription, payment processing, e-signature, SMS delivery, email delivery, customer relationship management, and IT support. Each is engaged under a written contract that limits it to processing the information for our specified purposes and prohibits it from selling the information or using it for its own purposes.
• Parties to a transaction you have asked us to complete, including title agents, closing agents, lenders, escrow agents, surveyors, insurers, and the other side's representatives. A closing requires these disclosures and we make them because you asked us to close.
• Government offices and registries, where a recording, a filing, or a report is part of the service you ordered, including the reporting described in Section 8.
• Professional advisors to the companies, including our accountants, auditors, insurers, and our own counsel, where needed and subject to professional confidentiality duties.
• Government authorities or other parties when required by law, subpoena, or valid legal process, on the terms set out in Section 2, or where necessary to establish, exercise, or defend legal claims, or to protect the rights, safety, or property of My Land Trustee or others.
• A successor entity in connection with a merger, acquisition, financing, or sale of business assets, or a transfer of trusteeship, in which case we will require the successor to honor this Policy or give you notice and a choice before your information becomes subject to a materially different policy.

Aspire Legal Solutions and other affiliated companies

Aspire Legal Solutions PLLC is a separate, affiliated law firm. Your information does not move between us simply because the companies are affiliated. We send information to the firm, or accept it from the firm, where you have engaged both and have authorized the exchange, or where a transaction you asked us to complete requires it. If you want a copy of what has been exchanged, ask and we will tell you.

13.  How Long We Keep Information

We keep personal information only for as long as necessary for the purpose for which it was collected, on the schedule below. These periods are subject to any longer period required by law, or needed to resolve a dispute or enforce our agreements.

At the end of the applicable period we securely delete the information or de-identify it so that it can no longer reasonably be linked to you, and we do not attempt to re-identify de-identified data.

You can override much of this

These periods are our defaults, not your obligation. You may ask us at any time to delete any category of information we hold about you, including meeting recordings and transcripts. Deletion requests are handled on the timeline in Section 16, and in practice we action a straightforward one within thirty (30) days.

What we cannot delete on request: records we are required by law to keep, including those connected to the reporting in Section 8; records we need in order to act as trustee of a trust that is still in existence, because a trustee that has deleted the trust agreement cannot administer the trust; anything subject to a litigation hold, court order, or preservation demand; and anything we need in order to complete a transaction you asked us to complete. Where we cannot delete something, we will tell you which item and why.

14.  Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. These include access controls limiting information to personnel who need it for a legitimate business purpose; encryption of data both in transit and at rest; two-factor authentication required to access systems holding client information, including trust records, recordings, and transcripts; written confidentiality and data-protection obligations imposed on the vendors that process information on our behalf; and periodic review of these practices.

No method of transmission or storage is completely secure, and while we work hard to protect your information we cannot guarantee absolute security. Ordinary email is not encrypted end to end; for identifying numbers and trust documents, use the secure link or portal we provide rather than plain email.

If a breach occurs

If we discover a security breach affecting your personal information, we will investigate promptly and notify you and any required regulator in the manner and within the timeframes applicable law requires. Under section 501.171(4)(a), Florida Statutes, notice to affected individuals is made as expeditiously as practicable and without unreasonable delay, and no later than thirty (30) days after the determination of a breach or reason to believe a breach occurred. Where a breach affects 500 or more individuals in Florida, section 501.171(3)(a) requires notice to the Florida Department of Legal Affairs on the same thirty-day clock. Our notice will describe what happened, the categories of information involved, what we are doing about it, and the steps you can take to protect yourself.

15.  Your Privacy Rights

A growing number of states give residents rights over their personal information. Whether any particular state law legally applies to companies of our size depends on that state's thresholds, and most do not reach us. Florida's own statute is a good example: the Florida Digital Bill of Rights, sections 501.701 through 501.722, Florida Statutes, applies only to a controller that “[m]akes in excess of $1 billion in global gross annual revenues” and meets one of three further conditions, none of which describes these companies.

Rather than ask you to work out which law covers you, we extend the following rights to every individual in the United States as a matter of policy, regardless of where you live:

• To confirm whether we process your personal information, and to access a copy of it.
• To correct inaccurate personal information we hold about you.
• To delete personal information we hold about you, subject to the exceptions in Section 13.
• To obtain a copy of the information you provided to us in a portable, readily usable format.
• To opt out of any sale of your personal information, any sharing or processing for targeted advertising, and any profiling with legal or similarly significant effects. We do not engage in these activities, so there is nothing to opt out of, but the right stands.
• To limit our use of sensitive personal information to what is necessary to provide the services you requested.
• To withdraw a consent you previously gave, including consent to record or transcribe a meeting and consent to receive text messages.
• Not to be discriminated against, or receive a lesser level of service or a different price, for exercising any of these rights.

These privacy rights sit alongside, and do not replace, the rights you have as a settlor or beneficiary under the trust agreement and under Florida trust law. A request for a trust accounting is not a privacy request and is not subject to the timelines below.

16.  How to Exercise Your Rights

Send your request to the email address in Section 19, or write to us at the postal address there. Tell us which right you wish to exercise and give us enough information to locate your records. We will verify your identity, using information already in our possession where we can rather than asking for more than we need. Because we hold title and act on instructions, identity verification matters here more than it does at most businesses, and we would rather take an extra step than act on an instruction from the wrong person. If we cannot verify your identity we will tell you why.

We will acknowledge your request promptly and respond substantively within forty-five (45) days. Where a request is complex or numerous, we may extend that period once by a further forty-five (45) days, and we will tell you before we do so and why. There is no charge for a request unless it is manifestly unfounded or excessive, in which case we will tell you the reason and any fee before proceeding.

If we say no, you can appeal

If we decline your request in whole or in part, our response will explain why. You may appeal that decision at no cost by replying to our response or writing to the contact in Section 19 with the word “Appeal.” A person who was not involved in the original decision will review it, and we will inform you in writing of the outcome and our reasoning within forty-five (45) days. If we deny the appeal, we will give you a method to lodge a complaint with your state attorney general or other regulator.

Authorized agents

You may use an authorized agent to submit a request on your behalf. We will ask the agent for written proof of authority, and may ask you to verify your own identity directly and to confirm you granted the authority.

17.  Children's Privacy

Our services are directed to adults and are not intended for anyone under 18. We do not knowingly collect personal information from children through our website. If we learn that we have collected information through the website from anyone under 18, we will delete it promptly, and we treat information from a child under 13 as requiring immediate deletion. This is separate from information about minors that reaches us because a trust requires it, such as the name of a minor successor beneficiary; that information is collected from the person who established the trust and is kept with the trust record. If you believe a child has provided us information through the website, please contact us using the details in Section 19.

18.  Third-Party Links and Services

Our website and communications may link to third-party sites and platforms that we do not control, including our scheduling platform, payment processor, e-signature provider, and the client portal operated by Aspire Legal Solutions. This Policy does not apply to them, and we are not responsible for their privacy practices. We encourage you to read the privacy policy of any site you visit.

19.  Changes, Contact, and Complaints

We may update this Policy from time to time, and the effective date at the top reflects the most recent revision. If we make a material change, to the categories of information we collect, the purposes we use it for, who we share it with, or your rights, we will give notice on our website and, where we have your contact details and the change affects you, directly. A material change will not be applied retroactively to information already collected without your consent where consent is required.

Questions about this Policy, requests regarding your personal information, and privacy complaints may be directed to:

We will respond to a complaint within ten (10) business days. Nothing in this Policy limits your right to complain to the Federal Trade Commission, the Florida Department of Agriculture and Consumer Services, your own state's attorney general, or any other regulator with authority over us.