Legacy FortressDraft for legal review, 3 November 2026. Not yet in force. Items in [brackets] need confirming.
Privacy and data protection
Your Vault holds some of the most personal information you have. This policy explains what we collect, why, who can see it, how long we keep it and your rights under UK data protection law.
Who we are
Legacy Fortress is run by [COMPANY NAME], [REGISTERED ADDRESS], company number [NUMBER]. We are the data controller for the information in this policy. ICO registration: [NUMBER]. Data protection contact: [NAME], [PRIVACY EMAIL].
The principle we work to
Your Vault is private by default. Nobody, including our staff, sees your records, documents or values unless you share them. Our admin tools show counts and statuses only. Being connected to your Vault or verifying an ID never opens anything on its own.
What we collect and why
| Information | Why | Legal basis |
|---|---|---|
| Your account: name, email, phone number | To run your account and keep it secure | Contract |
| What you put in your Vault: records, documents, wishes | To store it and share it only as you choose | Contract |
| People you add: names, emails, relationships | So you can invite them and they can be told, without record details | Legitimate interests |
| ID checks: a photo of your ID, a live selfie and the match result | To confirm who someone is before they join a Vault, and again before a Vault is released | Explicit consent (biometric data) |
| Death reports, certificates and Powers of Attorney | To release access safely after a death or loss of capacity | Legitimate interests; legal obligation where it applies |
| Payment details | To take Premium payments. Handled by Stripe; we never see or store your card number | Contract |
| Activity records: sign-ins, connections, uploads, approvals | Security and a record of who did what, without record content | Legitimate interests; legal obligation |
ID checks and your face
An ID check compares your selfie with the photo on your ID. It happens at two moments only: when you accept an invitation to someone's Vault, and when you ask for a Vault to be opened after a death or loss of capacity. The comparison runs on our own servers; no outside ID company receives your photos. We don't keep a face template. Photos are deleted as soon as the check is decided, and in any case within 14 days. We keep only the result and its date. You can refuse, but then you can't be connected to a Vault.
Who else handles your data
- Hosting and storage: [PROVIDER], servers in [REGION, believed Ireland].
- Email delivery: Resend, for sign-in and notification emails, which never include record details. [REGION]
- Payments: Stripe, for Premium subscriptions.
- People you choose: only what you share, with the people you share it with.
We don't sell your data, use it for advertising or share it with anyone else unless the law requires it. Where data is processed outside the UK, it is protected by UK adequacy regulations or approved contract terms [TO CONFIRM].
How long we keep it
- ID photos and selfies: deleted within 14 days of the check being decided. The result lasts a year.
- Your Vault: until you delete it or close your account, then [PERIOD TO DECIDE].
- Suggested documents that aren't added: deleted when rejected or withdrawn.
- Activity records and history: [PROPOSED 6 YEARS] after the account closes, without record content.
Your rights
You can ask to see, correct, download, restrict or delete your information, object to how we use it, and withdraw consent for ID checks at any time. Most of this you can do in Settings; for anything else, email [PRIVACY EMAIL]. We reply within one month. If you're unhappy, you can complain to the Information Commissioner's Office at ico.org.uk.
After you die
UK data protection law covers living people, but we keep treating your Vault with the same care: it is released only to the people you chose, after evidence is reviewed by a person and their ID is checked again.
Cookies
We use only what's needed to keep you signed in and secure. [CONFIRM: no analytics or advertising cookies.]
Changes
We'll tell you by email before any important change to this policy. Last updated: [DATE].