Effective date: 04/07/2020
Table of Contents
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share your Personal Information
- Your Choices
- Other sites, mobile applications and services
- Security practices
- International data transfers
- How to Contact Us
- Your California Privacy Rights
- Notice to European Users
Personal Information We Collect
Information you provide to us. Personal information you provide to us through the Services or otherwise includes:
- Contact information, such as your first and last name, email and mailing addresses and phone number.
- Content you choose to upload to the Services, whether or not specifically required by the Services, such as text, images, audio, and video, and information regarding your assets, such as asset types and descriptions, and information regarding your Notice Recipients (defined below), such as first and last name, phone numbers, email and mailing addresses, and related notes, along with the metadata associated with the files you upload.
- Profile information, such as your email address, cell phone number, first and last name and password that you may set to establish an online account with us, your photograph, and preferences.
- Registration information, such as information that may be related to a Service or an account.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Transaction information, such as information about payments to and from you and other details of Services you have purchased from us.
- Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our activities and publications, and details about how you engage with our communications.
If you choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on a third-party platform or network to your account through the Services, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.
Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our Services. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our Mobile App, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our Mobile App.
Users of the Services may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.
The Services allow our customers to upload information regarding certain individuals (e.g., beneficiaries, trustees, etc.) and/or institutions (e.g., banks, insurance companies, etc.) designated by the Customer through the Services (collectively, “Notice Recipients”) to receive notices generated by the Services upon the occurrence of an Unforeseen Event (as described in our “Heartbeat Protocol” of our “How It Works” page). If you have been designated as a Notice Recipient by our customer, that customer may provide us with certain of your personal information, such as first and last name, phone numbers, email and mailing addresses, and related notes. It is the Company’s policy and a condition for use of the Services that each customer obtain each Notice Recipient’s prior written consent to the provision of their personal information to the Company and the receipt of notice regarding an Unforeseen Event.
How We Use Your Personal Information
To operate the Services. We use your personal information to:
- provide, operate and improve the Services
- provide information about our Services
- establish and maintain your user profile on the Services
- contact Notice Recipients and provide them with information regarding the applicable assets per the intended use of the Services
- facilitate your login to the Services via third-party identity and access management providers, such as Facebook
- enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
- facilitate social features of the Services, such as by identifying and suggesting connections with other users of the Services and providing chat or messaging functionality
- communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages
- understand your needs and interests, and personalize your experience with the Services and our communications
- provide support and maintenance for the Services
- respond to your requests, questions and feedback
For research and development. We analyze use of the Services to improve the Services and to develop new products and services, including by studying user demographics and use of the Services.
To send you marketing and promotional communications. We may send you Company-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law and/or as a condition to your use of the Services. We will only contact Notice Recipients after a customer has obtained all required consents (which the customer must obtain before providing their information to us). This also applies when you ask us to contact partners through which we provide the Service on behalf of a Notice Recipient (e.g. when you request us to provide legal support for a beneficiary).
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
How We Share your Personal Information
Third-party platforms and social media networks. If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by logging in to the Services using your account with the third-party, providing your access token for the Services to a third-party, or otherwise linking your account with the Services to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of the Company’s business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of the Company’s assets, or in the event of bankruptcy or dissolution.
In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.
Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our Mobile App may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the Services via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Services using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.
Other sites, mobile applications and services
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfers
Your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy
laws may not be as protective as those in your state, province, or country.
European Union users should read the important information provided below about transfer of personal information outside of the European Union.
As a general rule, children are not allowed to use the Services. The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If a customer submits any information regarding a minor Notice Recipient to the Services, it is the customer’s sole responsibility to comply with all applicable laws and regulations regarding such information. If a parent or guardian becomes aware that his or her child has provided us with information without the parent’s or guardian’s consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
How to Contact Us
Your California Privacy Rights
Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at email@example.com. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
Notice to European Users
We have appointed a Data Protection Officer, whose contact information is: firstname.lastname@example.org.
| Processing purpose (click link for details)|
Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.
| · To operate the Services|
· To provide information about the assets to the beneficiaries and trustees
· To provide information about the Services
· To establish and maintain your user profile on the Services
· To facilitate your login to the Services
· To enable security features of the Services
· To enable social features of the service
· To provide support and maintenance for the Services
· To respond to your requests, questions and feedback
|Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.|
| · For research and development|
· To display advertisements
|These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|· To comply with law||Processing is necessary to comply with our legal obligations.|
| · To send you marketing communications|
· To tailor advertisements to your interests
· With your consent
|Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.|
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information out of the European Economic Area to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:
- Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
- Pursuant to the consent of the individual to whom the personal information pertains.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.
What types of cookies and similar tracking technologies does Company use on the Sites?
|Type||Description||Who serves the cookies |
|How to control them|
|Advertising||These cookies are used by advertising companies to collect information about how you use our Sites and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Service and elsewhere, and to measure how the ads perform.||Facebook|
|See ‘your choices’ below.|
|Analytics||These cookies help us understand how our Services are performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.||Google Analytics|
|See ‘your choices’ below.|
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.
|Essential||These cookies are necessary to allow the technical operation of our Services (e.g., they enable you to move around on a website and to use its features).||Google Tag Manager|
|See ‘your choices’ below.|
In addition to cookies, our Sites may use other technologies, such as Flash technology and pixel tags to collect information automatically.
Browser Web Storage
We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Mobile Application Software Development Kits (SDKs)
We may use third-party software development kits (“SDKs”) in our mobile applications. A SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our App.
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
EU users will only receive targeted advertising with their prior consent. Otherwise, you will still see advertisements online but they may not be relevant to you. We will also not drop analytics cookies on your device without your prior consent.
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.