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.
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.
| Category | Examples | Why |
|---|---|---|
| Account data | Name, email address, encrypted password hash | To create and manage your account |
| Vault data | Account credentials, notes, secure notes, addresses, documents | Core service — all fields encrypted with AES-256-GCM before leaving your device. We cannot read this data. |
| Beneficiary data | Names, email addresses, relationship, group label | To send invitations and grant access per your instructions |
| Identity verification | Photo ID, death certificate (Onfido) | To verify beneficiary identity and process emergency access requests |
| Payment data | Subscription status, Stripe customer ID | Subscription management. We never store card numbers — Stripe handles all card data. |
| Security and audit data | Sign-in timestamps, device type, approximate location (from Cloudflare headers), IP address | Detecting unauthorised access; new device alerts |
| Communications | Emails you send to us | To respond to your queries |
| Phone number (optional) | Mobile number in E.164 format | SMS check-in reminders only, if you provide it |
| Purpose | Legal basis |
|---|---|
| Delivering the vault service (storing encrypted data, triggering beneficiary access on check-in failure) | Contract performance |
| Authentication, MFA, session management | Contract performance |
| Payment processing and subscription management | Contract performance |
| Security monitoring, device logging, fraud prevention | Legitimate interests |
| Retaining transaction records | Legal obligation (UK financial regulation, 7 years) |
| Marketing emails and partner offers | Consent (opt-in only, withdraw any time in Settings) |
| SMS check-in reminders | Consent (you provide your number) |
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.
We are committed to keeping your data in the UK. The following table describes exactly where data goes and why.
| Provider | Location | Purpose |
|---|---|---|
| Supabase UK | London (AWS eu-west-2) | Primary database, authentication, file storage, and edge functions. All vault data lives here. |
| Onfido UK | London HQ | Identity verification and death certificate processing for emergency access |
| GetAddress.io UK | UK | Postcode lookup for address fields. Only a postcode is sent — no personal data. |
| Stripe UK | UK entity (Stripe Payments UK Ltd, FCA-authorised) | Payment processing. No card data passes through our servers. |
| Resend UK/EU | UK entity | Transactional email (OTP codes, notifications, invitations). Contains your name and notification content but never vault data. |
| Twilio Optional | US | SMS check-in reminders, only if you provide a mobile number. Only your phone number and a plain-text reminder message are sent. |
| Cloudflare Global CDN | Global | Serves 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.
| Data type | Retention period |
|---|---|
| Active account and vault data | Until account deletion |
| Deleted accounts | All 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 logs | 90 days, then automatically deleted |
| Identity verification data (Onfido) | Per Onfido's retention policy — deleted after verification is complete |
| Right | How to exercise it |
|---|---|
| Access — request a copy of your data | Settings → Export my data (immediate JSON download) |
| Rectification — correct inaccurate data | Update your profile in Settings at any time |
| Erasure — delete all your data | Settings → Delete account (permanent, requires password confirmation) |
| Portability — receive data in machine-readable format | Settings → Export my data |
| Restriction — limit processing while a complaint is investigated | Email privacy@digitalrelative.co.uk |
| Object — object to processing based on legitimate interests | Email privacy@digitalrelative.co.uk |
| Withdraw consent — marketing and SMS reminders | Settings → 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.
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.
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.
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.
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