1. Introduction

AfterlifeWill.com ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our digital will service.

This policy complies with the General Data Protection Regulation (GDPR) and Czech data protection laws. We operate on a zero-knowledge encryption principle, meaning we cannot access the content of your encrypted wills.

2. Data Controller Information

Company: AfterlifeWill.com
Location: Czech Republic
Contact: privacy@afterlifewill.com
Data Protection Contact: dpo@afterlifewill.com

3. Information We Collect

3.1 Information You Provide

Account Information: Email address, name, password (hashed)
Will Information: Encrypted will content, emergency contact email, activity check interval
Communication Data: Messages you send through our contact form
Payment Information: If applicable, processed securely through third-party providers

3.2 Information Automatically Collected

Technical Data: IP address (anonymized), browser type, device information, operating system
Usage Data: Login times, activity verification timestamps, page views, session duration
Cookies: Session cookies for authentication, analytics cookies (with consent)
Analytics Data: Website traffic patterns, user interactions, referral sources (with consent)
Log Data: Server logs for security and troubleshooting

3.3 What We DON'T Access

Due to our zero-knowledge encryption:

We CANNOT read your will content
We CANNOT decrypt your messages
We CANNOT access your files or attachments
We CANNOT recover your access password

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

Contract Performance: To provide our digital will service (Article 6(1)(b) GDPR)
Legal Obligations: To comply with applicable laws (Article 6(1)(c) GDPR)
Legitimate Interests: For security, fraud prevention, and service improvement (Article 6(1)(f) GDPR)
Consent: For marketing communications, where applicable (Article 6(1)(a) GDPR)

5. How We Use Your Information

5.1 Primary Purposes

Create and manage your account
Store your encrypted will securely
Send activity verification emails
Deliver your will to emergency contacts when triggered
Provide customer support
Ensure service security and prevent fraud

5.2 Secondary Purposes

Improve our service and user experience
Send service-related communications
Comply with legal obligations
Analyze usage patterns (anonymized)

6. Data Sharing and Disclosure

6.1 We DO NOT Sell Your Data

We never sell, rent, or trade your personal information to third parties.

6.2 Limited Sharing Scenarios

We may share your data only in these specific circumstances:

Emergency Contacts: Your email address, will content, attached files, and creation date when your will is activated due to inactivity
Service Providers: Trusted partners who help operate our service (under strict confidentiality)
Legal Requirements: If required by law, court order, or government request
Business Transfers: In case of merger, acquisition, or sale (with continued protection)
Protection of Rights: To protect our rights, safety, or property

7. Data Storage and Security

7.1 Where We Store Data

Primary servers located in the European Union
Encrypted backups in secure, geographically distributed locations
All data transfers use encrypted connections (TLS/SSL)

7.2 Security Measures

Encryption: AES-256-GCM for will content, TLS for data transmission
Access Controls: Strict authentication and authorization systems
Infrastructure: Firewalls, intrusion detection, regular security audits
Zero-Knowledge: Technical inability to access your encrypted content
Regular Updates: Continuous security patches and improvements

8. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

8.1 Right to Access (Article 15)

Request a copy of your personal data we hold

8.2 Right to Rectification (Article 16)

Request correction of inaccurate personal data

8.3 Right to Erasure (Article 17)

Request deletion of your personal data ("right to be forgotten")

8.4 Right to Restrict Processing (Article 18)

Request limitation of processing in certain circumstances

8.5 Right to Data Portability (Article 20)

Receive your data in a structured, machine-readable format

8.6 Right to Object (Article 21)

Object to processing based on legitimate interests

8.7 Rights Related to Automated Decision-Making (Article 22)

Not be subject to solely automated decision-making

To exercise any of these rights, contact us at: privacy@afterlifewill.com

9. Data Retention

We retain your data for different periods based on the type and purpose:

Account Data: As long as your account is active
Encrypted Wills: Until you delete them or close your account
Activity Logs: 90 days for security purposes
Deleted Account Data: Up to 90 days after account closure for recovery purposes
Legal Records: As required by applicable laws (typically 5-10 years)

Note: Due to zero-knowledge encryption, deleted encrypted content cannot be recovered.

10. Cookies and Tracking

10.1 Essential Cookies

We use essential cookies required for the service to function:

Session Cookies: To maintain your login session
Security Cookies: To prevent CSRF attacks

10.2 Analytics Cookies (With Your Consent)

With your explicit consent, we use Google Analytics to understand how users interact with our website:

Google Analytics 4: To analyze website traffic, user behavior, and improve our service
Cookie Consent: Analytics cookies are only loaded after you accept our cookie banner
Data Collection: Page views, session duration, traffic sources, device information
Data Retention: Analytics data is retained for 26 months as per Google's policy
IP Anonymization: Your IP address is anonymized to protect your privacy

10.3 Your Cookie Choices

Accept: You can accept analytics cookies to help us improve our service
Decline: You can decline analytics cookies - our service will work fully without them
Change Mind: Clear your browser's localStorage to reset your cookie preferences
Browser Settings: You can also disable cookies in your browser settings

10.4 What We DON'T Use

We do not use:

Advertising cookies or remarketing
Social media tracking pixels
Cross-site tracking
Cookies to identify you across other websites

10.5 Google Analytics Information

Google Analytics is provided by Google LLC. To learn more about Google's privacy practices:

Google Privacy Policy: https://policies.google.com/privacy
Google Analytics Terms: Analytics Terms of Service
Opt-out: Google Analytics Opt-out Browser Add-on

11. International Data Transfers

Your data is primarily stored within the European Union. If we need to transfer data outside the EU, we ensure:

Adequate protection through EU Standard Contractual Clauses
Transfer only to countries with adequate data protection laws
Additional security measures for sensitive data
Transparency about any international transfers

12. Children's Privacy

Our service is not intended for children under 18 years of age. We do not knowingly collect personal data from children. If we discover that a child has provided us with personal information, we will delete it immediately.

13. Third-Party Services

We use limited third-party services to operate AfterlifeWill.com:

Email Service: For sending notifications (cannot read encrypted content)
Hosting Provider: For server infrastructure (with data processing agreement)
Payment Processor: If applicable, for handling payments securely
Google Analytics: For website analytics (with your consent only, IP anonymized)

All third parties are carefully selected and bound by strict data protection agreements. Google Analytics operates under Google's privacy policy and standard terms.

14. Data Breach Notification

In the unlikely event of a data breach:

We will notify affected users within 72 hours of discovery
We will inform relevant supervisory authorities as required by GDPR
We will provide information about the breach and steps to protect yourself
Your encrypted will content remains secure even in a breach due to zero-knowledge encryption

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. When we do:

We will update the "Last updated" date
We will notify you via email for significant changes
We will request new consent where required by law
The updated policy will be available on our website

16. Contact Information

For privacy-related questions or to exercise your rights:

Email: privacy@afterlifewill.com
Data Protection Officer: dpo@afterlifewill.com
General Support: support@afterlifewill.com
Website: afterlifewill.com/contact

Supervisory Authority

You have the right to lodge a complaint with the Czech data protection authority:

Úřad pro ochranu osobních údajů (ÚOOÚ)
Pplk. Sochora 27
170 00 Praha 7
Czech Republic
Website: www.uoou.cz