Privacy Policy

Last updated: 24 May 2026 · Version 2.0 · Data controller: Digital Relative, registered in England and Wales · ICO registration: pending

This Privacy Policy explains how Digital Relative collects, uses, stores, and protects your personal data when you use our digital legacy vault service at digitalrelative.co.uk.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Key facts: Your vault data is end-to-end encrypted. We cannot read it. All personal data is stored in the UK. We do not sell your data or use it for advertising.

1. Who we are

Digital Relative is the data controller. Contact us for any data protection query at privacy@digitalrelative.co.uk. For security issues: security@digitalrelative.co.uk.

2. What data we collect

CategoryExamplesWhy
Account dataName, email address, encrypted password hashTo create and manage your account
Vault dataAccount credentials, notes, secure notes, addresses, documentsCore service — all fields encrypted with AES-256-GCM before leaving your device. We cannot read this data.
Beneficiary dataNames, email addresses, relationship, group labelTo send invitations and grant access per your instructions
Identity verificationPhoto ID, death certificate (Onfido)To verify beneficiary identity and process emergency access requests
Payment dataSubscription status, Stripe customer IDSubscription management. We never store card numbers — Stripe handles all card data.
Security and audit dataSign-in timestamps, device type, approximate location (from Cloudflare headers), IP addressDetecting unauthorised access; new device alerts
CommunicationsEmails you send to usTo respond to your queries
Phone number (optional)Mobile number in E.164 formatSMS check-in reminders only, if you provide it

3. How we use your data

PurposeLegal basis
Delivering the vault service (storing encrypted data, triggering beneficiary access on check-in failure)Contract performance
Authentication, MFA, session managementContract performance
Payment processing and subscription managementContract performance
Security monitoring, device logging, fraud preventionLegitimate interests
Retaining transaction recordsLegal obligation (UK financial regulation, 7 years)
Marketing emails and partner offersConsent (opt-in only, withdraw any time in Settings)
SMS check-in remindersConsent (you provide your number)

4. How we protect your data

Your vault contents are encrypted on your device using AES-256-GCM before transmission. The encryption key is derived from your vault PIN using PBKDF2 with 600,000 iterations and a random per-user salt. Your PIN is never transmitted or stored. Neither Digital Relative nor our infrastructure providers can read your vault data.

Access to your account is protected by a separate login password and mandatory multi-factor authentication (MFA) for email/password users. We maintain a comprehensive audit log, device activity alerts, and an inactivity auto-lock.

5. Where your data is stored

We are committed to keeping your data in the UK. The following table describes exactly where data goes and why.

ProviderLocationPurpose
Supabase UKLondon (AWS eu-west-2)Primary database, authentication, file storage, and edge functions. All vault data lives here.
Onfido UKLondon HQIdentity verification and death certificate processing for emergency access
GetAddress.io UKUKPostcode lookup for address fields. Only a postcode is sent — no personal data.
Stripe UKUK entity (Stripe Payments UK Ltd, FCA-authorised)Payment processing. No card data passes through our servers.
Resend UK/EUUK entityTransactional email (OTP codes, notifications, invitations). Contains your name and notification content but never vault data.
Twilio OptionalUSSMS check-in reminders, only if you provide a mobile number. Only your phone number and a plain-text reminder message are sent.
Cloudflare Global CDNGlobalServes the application's static files only. No personal data. Approximate location for security alerts is derived from Cloudflare's infrastructure headers — no data is sent to Cloudflare by us.

Twilio is the only provider outside the UK/EU that receives personal data. If you do not provide a mobile number in Settings, Twilio is not used at all. Where data is transferred outside the UK, we ensure appropriate safeguards (Standard Contractual Clauses) are in place.

6. How long we keep your data

Data typeRetention period
Active account and vault dataUntil account deletion
Deleted accountsAll vault data and personal data permanently deleted within 30 days. Audit log anonymised (user ID removed).
Payment records (Stripe transaction IDs)7 years (UK financial regulation)
Device and sign-in logs90 days, then automatically deleted
Identity verification data (Onfido)Per Onfido's retention policy — deleted after verification is complete

7. Your rights under UK GDPR

RightHow to exercise it
Access — request a copy of your dataSettings → Export my data (immediate JSON download)
Rectification — correct inaccurate dataUpdate your profile in Settings at any time
Erasure — delete all your dataSettings → Delete account (permanent, requires password confirmation)
Portability — receive data in machine-readable formatSettings → Export my data
Restriction — limit processing while a complaint is investigatedEmail privacy@digitalrelative.co.uk
Object — object to processing based on legitimate interestsEmail privacy@digitalrelative.co.uk
Withdraw consent — marketing and SMS remindersSettings → Notifications & preferences

We will respond to all requests within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk.

8. Cookies

We use only essential cookies required for authentication and secure session management. We do not use advertising, tracking, or analytics cookies. No cookie consent banner is required for essential cookies only.

9. Children

Our Service is not directed at anyone under 18. We do not knowingly collect data from children. If you believe a child has provided us with data, please contact us immediately.

10. Changes to this policy

We will notify you by email at least 14 days before any material changes take effect. The current version is always available at this URL. Continued use after the effective date constitutes acceptance.

11. Contact

Privacy queries: privacy@digitalrelative.co.uk
Security issues: security@digitalrelative.co.uk
ICO complaints: ico.org.uk

Digital Relative · Registered in England and Wales · ICO Registration: pending
Version 2.0 · Effective 24 May 2026