Privacy Policy

Last updated 7 October 2026

Draft, pending legal review. Text in [square brackets] is still to be filled in.

Who we are

[Company legal name], [registered address] (“Heirloom”, “we”). For anything in this policy, contact support or write to [privacy contact email].

Your vault

Your vault is encrypted in your browser or the Heirloom app before it reaches us, with a key that only your password or your recovery phrase unlocks. We store your vault only in that encrypted form, and we don’t have your password or your recovery phrase.

So that your beneficiaries can open the vault after a release, its key is also split into three key fragments, one for each of them. Any two fragments together open the vault; one alone reveals nothing. We keep the fragments, and give each one to its beneficiary only during a release, after they’ve answered the security question you set.

What we keep

  • Your account: your email address, a one-way hash of your password, the secret for your authenticator app, a one-way hash of your recovery phrase, and when you last used Heirloom.
  • Your vault: the encrypted vault, and its key, itself encrypted with your password and, separately, with your recovery phrase.
  • Your beneficiaries: each one’s name, email address, phone and WhatsApp numbers (if you give them), the trust phrase you write for them, your security question and its answer, and their key fragment.
  • Your plan: which plan you’re on and when it ends. [Payment details, once online payment is live, are handled by the payment provider.]
  • Support: the messages you send us, and the email address you send them from.
  • The Heirloom app: a notification token for your device, to send you notifications.
  • Security records: IP addresses and records of account activity, to limit abuse and look into problems.

How we use it

  • To run your account and vault, and to email you what you need to know.
  • To watch for inactivity and, if the time comes, release your vault to your beneficiaries.
  • To contact your beneficiaries about a release of your vault, and to check their answers to your security question.
  • To answer support requests, keep Heirloom secure, and fix problems.

We don’t sell your data, and we don’t use it for advertising.

How we protect it

  • Your vault is encrypted with AES-256-GCM, with keys derived from your password and recovery phrase by Argon2id, before it leaves your device.
  • Your beneficiaries’ details, their trust phrases, your security questions and answers, and your authenticator secret are encrypted on our servers with keys we manage.
  • [How access to production systems is limited and logged.]

Your beneficiaries' information

You give us your beneficiaries’ details on their behalf. You should have their agreement, though we can’t check that. A beneficiary can contact support to see, correct or remove their details.

Who we share it with

  • The services that send our email, phone and WhatsApp messages, and app notifications. [Name them.]
  • Our hosting provider. [Name and region.]
  • Sentry, which receives error reports from our website with personal details and secrets removed. No reports are sent from vault pages or the pages beneficiaries use.
  • Authorities, when the law requires it.

How long we keep it

  • Until you delete your account. Deleting it from Settings removes your vault, your beneficiaries and your account. [How long deleted data stays in backups.]
  • If your plan ends, your account is frozen, not deleted, so you can come back. [How long a frozen account is kept.]
  • [How long data is kept after a release closes, and how long support messages are kept.]

Your rights

Depending on where you live, for example under the EU’s GDPR or Ghana’s Data Protection Act, 2012, you can ask to see, correct, move or delete your data, and object to how we use it. Your vault is encrypted with your own key, so only you can read or export what’s in it; we can give you everything else we hold about you. To ask, contact support. You can also complain to your data protection authority, such as Ghana’s Data Protection Commission.

Where your data is

[Where Heirloom’s servers are, and how transfers outside your country are protected.]

Changes

We’ll email you about significant changes to this policy before they take effect.