Privacy Policy

The short version

Hold My Will is built so that we cannot read your will. Your documents are encrypted on your device before upload; we store ciphertext and never possess a key that can open it. This policy covers the personal data we do process to run the service around that vault.

1. Who is responsible

Hold My Will — Growpad Limited, registered in England & Wales, company no. 13979536 is the data controller. Contact: support@holdmywill.com.

2. What we collect, and why

• Account data — your email address, optional phone number, chosen check-in schedule and timezone. Basis: performing our contract with you.
• Nominee and verifier details you provide — their names, email addresses, phone numbers, and relationship to you. We contact them at designation (so they can accept) and at release. Basis: performing our contract with you; their acceptance record. You are responsible for telling them before you name them.
• The deposit attestation — the statement you confirm before depositing, with its timestamp, IP address, and browser identifier. Basis: legitimate interest in deterring and evidencing fraudulent deposits; it is disclosed to nominees at release by design.
• Liveness and audit records — check-in timestamps, escalation events, release access logs (including nominee IP addresses at access). Basis: performing the contract; these records are the tamper-evident history your nominees receive.
• Billing data — handled by Stripe. We receive your subscription status and payment references, never your card details. Basis: contract and legal (accounting) obligations.
• Technical logs — standard server logs for security and abuse prevention, retained briefly. Basis: legitimate interests.

3. What we never hold

• The readable content of your will or any deposited document.
• Your passphrase or 24-word recovery code, or any key derived from them.
• Your card number (payments are Stripe-hosted end to end).

4. Who processes data for us

Carefully chosen processors, each doing one job:

• Stripe — payments (Stripe is an independent controller for card processing).
• Postmark — sending our emails (check-ins, receipts, escalation notifications).
• Twilio — sending our text messages (urgent check-in prompts and verification codes).
• Hostinger — running our servers (UK data centre).
• Backblaze — encrypted backups.
• Cloudflare — DNS and network security in front of the service.
• Vercel — hosting this public website (it holds no account or vault data).

Some processors are US companies; where data leaves the UK we rely on the UK Extension to the EU–US Data Privacy Framework or the ICO’s International Data Transfer Agreement, as applicable to each provider.

5. How long we keep things

• Account and vault data: for the life of your account.
• After a release: 7 years (evidentiary retention), then cryptographic destruction.
• Account deletion: 14-day cooling period, then your wrapped keys are destroyed — ciphertext without keys is permanently unreadable, including in backups as they rotate out.
• Refund under the 30-day guarantee: same cryptographic destruction, promptly.

6. Cookies

The app uses essential cookies only: a session cookie and a long-lived device identifier that lets us warn you about sign-ins from new devices. No advertising or cross-site tracking cookies, ever. This marketing site currently sets no cookies at all.TODO before launch: if analytics are added to this marketing site, choose a cookie-less option (e.g. Cloudflare Web Analytics) or add a consent banner and update this section.

7. Your rights

You have the usual UK GDPR rights: access, rectification, erasure, restriction, objection, and portability. Note one honest limitation: we cannot “show you” the content of your encrypted documents (we cannot read them), and erasure of documents is performed by key destruction as described above. To exercise any right, email support@holdmywill.com. You can complain to the Information Commissioner’s Office at ico.org.uk — we’d appreciate the chance to fix things first.

8. Changes

Material changes will be notified by email at least 30 days before they take effect.