Privacy Policy
Last updated: [date] ·The short version:we can’t read your vault, we don’t sell data, and we collect the minimum needed to run the service. The long version follows, written to be actually readable.
1. Who we are
EndPlan is operated by [EndPlan Ltd], a company registered in Ireland ([company number], [registered address]). For the purposes of the EU General Data Protection Regulation (GDPR), [EndPlan Ltd] is the data controller for the personal data described in this policy. You can reach us at privacy@endplan.com.
2. What we collect
- Account data: your email address and account settings, including your check-in schedule and release configuration status (but not the encrypted rules themselves).
- Encrypted vault data: the contents of your vault, which reach us only as ciphertext encrypted on your device. See section 3.
- Trusted Circle contacts: the names and email addresses (optionally phone numbers) of the Key People, Recipients, and Advisors you add, so we can contact them when your configuration requires it.
- Billing data: your plan, invoices, and payment status. Card details are processed by our payment provider ([processor]); we never store full card numbers.
- Technical data: device push tokens, IP addresses in security logs, and basic diagnostic events needed to keep the service running and abuse-free.
- Correspondence: support messages you send us, and your newsletter subscription if you opt in.
3. What we can never see
Your vault contents, assets, documents, contacts, instructions, messages, credentials, and the per-person assignments of who receives what, are encrypted on your device using keys derived from your master password. Neither your master password nor your keys are ever transmitted to us. We store and transmit ciphertext only. We cannot decrypt it for support requests, for our own purposes, or in response to legal demands, because we do not possess the means to do so.
4. How we use your data
We process the data in section 2 to: operate your account and vault (performance of contract); send check-in prompts and, when your configuration triggers it, contact your Trusted Circle and release ciphertext to your designated recipients (performance of contract); take payment and prevent fraud (contract and legitimate interest); secure the service (legitimate interest); and send you the newsletter if you asked for it (consent, withdrawable any time).
5. What we never do
- We never sell or rent personal data, to anyone, for any reason.
- We never show advertising or share data with ad networks.
- We never profile you or make automated decisions with legal effect about you.
- We never use your data, encrypted or otherwise, to train machine-learning models.
Our only revenue is your subscription. Our incentives point one way: keep your vault sealed.
6. Who we share data with
We use a small number of processors under GDPR-compliant agreements: EU-based hosting for encrypted storage, an email/notification provider to deliver check-ins and alerts, and a payment processor for billing. Each receives only what it needs to perform its function.
If we receive a legally binding demand, the only vault-related material we can produce is ciphertext and the limited account metadata described above. We will notify you of any such demand unless we are legally prohibited from doing so.
7. Your Trusted Circle’s data
When you add Key People, Recipients, or Advisors, you confirm you are entitled to share their contact details with us. We use those details solely to operate your release configuration, verification requests, and delivery of what you assigned them. Trusted Circle members can object to being contacted, and may exercise the rights in section 9 over their own data.
8. Retention & deletion
We keep your data while your account is active. If your subscription lapses, your vault enters a read-only grace period of [90 days]; export remains free throughout. If you delete your account, encrypted vault data and account data are deleted within [30 days], with residual copies purged from backups within [90 days]. Where a vault has been released, recipients’ access persists per your configuration. We retain invoices as required by tax law.
9. Your rights
Under GDPR you can: access the personal data we hold about you; correct it; delete it; receive it in a portable format (your vault is always exportable in-app); object to or restrict certain processing; and withdraw consent where processing is based on consent. Write to privacy@endplan.com, we respond within one month. You may also lodge a complaint with the Irish Data Protection Commission or your local supervisory authority.
One honest limitation: because we cannot read your vault, we cannot act on its contents, rights requests apply to the data in section 2 that we can actually see.
10. Cookies & analytics
We use strictly necessary cookies for login sessions, and privacy-respecting, cookieless analytics that collect no personal data. We do not use tracking or advertising cookies, which is why you don’t see a cookie banner.
11. International transfers
Encrypted vault data and account data are stored in the EU. Where a processor operates outside the EEA, transfers are protected by Standard Contractual Clauses or an adequacy decision, and vault contents remain ciphertext wherever they travel.
12. Children
EndPlan is not directed at children and may not be used by anyone under 16. We do not knowingly collect children’s data; if you believe a child has created an account, contact us and we will delete it.
13. Changes & contact
If we change this policy materially, we will notify you by email at least [30 days] before the change takes effect. Questions, requests, complaints: privacy@endplan.com · [Data Protection Officer / EU representative details].
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