LEGACY-LOOP SECURITY POLICY

Incident Response Plan

Version 1.0 · Effective May 16, 2026

Owner: Ryan Hallee, Founder & CEO

Entity: Legacy-Loop Tech LLC · EIN 42-1834363 · Maine Charter 202609949DC

Review Cadence: Quarterly or upon material change

1. Purpose

This document defines how Legacy-Loop Tech LLC (“Legacy-Loop”) detects, contains, investigates, and reports security incidents affecting user data, platform integrity, or third-party data received through APIs including Meta Platform Data, Google OAuth profile data, payment processor data, and any other personally identifiable information (“PII”) processed by the platform.

This plan applies to all systems operated by Legacy-Loop, including:

2. Definitions

Security Incident — Any unauthorized access, disclosure, alteration, destruction, or loss of user data, system integrity, or service availability. Includes confirmed or reasonably suspected events.

Personal Data — Any information that identifies or could identify an individual user, including email addresses, names, profile pictures, listing photos, IP addresses, payment information, and OAuth provider identifiers.

Platform Data — Data received from Meta Platform APIs (Facebook Login: email, public_profile fields including user ID, display name, profile picture).

Breach — A Security Incident that involves confirmed unauthorized acquisition, access, use, or disclosure of Personal Data.

3. Response Team

Legacy-Loop is a single-member LLC. The Founder & CEO serves as the Incident Response Lead. External vendors are engaged as needed.

RoleHolderResponsibilities
Incident Response LeadRyan Hallee, CEODecision authority, communication, escalation
Technical Lead (Engineering)Ryan Hallee + contracted senior developersContainment, forensics, remediation
Communications LeadRyan HalleeUser notifications, regulatory reporting, vendor coordination
Legal CounselRetained as neededRegulatory compliance, disclosure obligations

4. Detection Sources

Security incidents may be detected through any of the following:

5. Response Phases

Phase 1 — Detection & Triage (Within 1 Hour of Detection)

Phase 2 — Containment (Within 4 Hours)

Phase 3 — Investigation (Within 24 Hours)

Phase 4 — Notification (Within 72 Hours)

4.1 — User Notification. Affected users receive direct email notification including: description of the incident; categories of data involved; date or date range of the incident; steps taken in response; recommended user actions (password reset, monitoring, etc.); contact for questions at support@legacy-loop.com.

4.2 — Regulatory Notification. Where legally required:

4.3 — Platform Notification. If Meta Platform Data is involved: notify Meta via the Data Incident Reporting form within 72 hours, including incident scope, affected fields, and remediation status. If Google OAuth data is involved, notify Google via Google Developer Console security contact. If Stripe payment data is involved, notify Stripe per the Stripe Connected Account Agreement.

Phase 5 — Remediation & Recovery (Within 7 Days)

Phase 6 — Post-Incident Review (Within 30 Days)

6. Severity Matrix

SeverityDefinitionResponse TimeExamples
CriticalConfirmed breach of user PII or Platform Data affecting > 100 usersImmediate (< 1 hour)Database exfiltration, mass credential leak
HighConfirmed breach affecting < 100 users OR critical service outage< 4 hoursSingle account takeover, API key leak
MediumSuspected breach pending investigation OR partial service disruption< 24 hoursSuspicious access pattern, individual user data exposure
LowVulnerability discovered but no evidence of exploitation< 7 daysCode-level security finding, scanner alert

7. User Right to Deletion (Independent of Incidents)

Users may request deletion of their data at any time via:

Deletion is processed within 30 days. For Meta Platform Data specifically: Facebook OAuth-linked accounts can revoke access at any time via Facebook Settings → Apps and Websites. Legacy-Loop honors deletion requests received from Meta on behalf of users. Deletion includes purging Platform Data from production databases and any backups within 30 days.

8. Sub-Processor Incident Coordination

Legacy-Loop uses the following sub-processors. If any of them experience a security incident affecting Legacy-Loop user data, the Incident Response Lead will coordinate joint response and forward user notifications as required.

Sub-ProcessorData HandledNotification Contact
Vercel Inc.Application hosting, request logssecurity@vercel.com
Chiselstrike Inc. (Turso)User account database (encrypted at rest)Per Turso ToS
Cloudinary Ltd.User-uploaded photossecurity@cloudinary.com
Stripe Inc.Payment processingPer Stripe DPA

Legacy-Loop reviews each sub-processor's security posture during onboarding and at least annually thereafter.

9. Communication Templates

9.1 — User Breach Notification (Template)

Subject: Important: Security Notice from Legacy-Loop

Dear [User Name], On [Date], Legacy-Loop became aware of a security incident affecting [scope]. We are writing to inform you of what happened, what data was involved, and what we are doing about it. What happened: [Brief description]. Data involved: [Specific data categories]. What we have done: [Actions taken]. What you should do: [Recommended user actions]. More information: support@legacy-loop.com. We sincerely apologize for this incident and the concern it may cause. — The Legacy-Loop Team

9.2 — Meta Platform Data Incident Report (Template)

App ID: 871910582591145 · Business: Legacy-Loop Tech LLC · Incident Date: [Date] · Detection Date: [Date] · Affected Permissions: [email, public_profile, etc.] · Estimated Affected Users: [Number or “Under investigation”] · Root Cause: [Description] · Containment Status: [Actions taken] · Remediation Plan: [Next steps] · Contact: support@legacy-loop.com

10. Plan Maintenance

This Incident Response Plan is reviewed and updated:

Most recent review: May 16, 2026. Next scheduled review: August 16, 2026.

11. Acknowledgment

By operating Legacy-Loop Tech LLC, the Founder & CEO accepts responsibility for the maintenance and execution of this Incident Response Plan.

Signed: Ryan Hallee, Founder & CEO

Date: May 16, 2026

Entity: Legacy-Loop Tech LLC

Last updated: May 16, 2026 | Return to Security & Trust