Privacy policy

1. Who we are

Afterpass is run by [legal entity name], ABN [ABN], of [postal address] ("we", "us"). We are responsible for the personal information described here.

To ask a question, make a request or complain, email [privacy contact email] or write to us at [postal address].

2. What we collect

• Your account: your name, email address and password (stored only as a one-way hash, so we cannot read it), your profile photo if you add one, your settings such as text size, your answers to the setup questions, and your plan.
• What you put in your vault: folders, entries and notes, and anything you write in them. This can include information about your health, finances and family, and about other people.
• Files and recordings: documents and photos you upload, and the video and audio memories you record.
• Key holders and recipients: the names, email addresses and relationship of the people you nominate as key holders, and the names and email addresses of the people you choose to receive a memory.
• Release requests: when a key holder asks for your vault to be released, the proof they upload (such as a death certificate or medical letter, as an image or PDF) and any reason they give.
• Payments: if you buy a plan, Stripe collects your card details. We never see or store your card number. Stripe also receives your name, email address and our reference for your account. We keep a Stripe customer reference, your plan and its status.
• Analytics: if analytics is on, the limited information described in Analytics.
• Sign-ins and logs: for each signed-in session, the IP address and browser it came from, when key holders sign in, and records of important actions (such as a release being approved) so we can investigate problems. Our hosting provider also keeps short-lived server logs of requests. We keep what you write and the names you enter out of those logs, and when something breaks we record where in our code it broke, not your vault's contents.
• Messages to us: anything you, your key holders or your recipients send us as feedback or support requests, and our notes on them.

You can use Afterpass without telling us anything about your health or other sensitive matters. When you do put sensitive information in your vault, you consent to us holding it to provide the service.

3. Why we collect it

• To run your account and keep your vault for you.
• To let your key holders reach what you have chosen to share with them, but only after a release has been verified.
• To send email you need: password resets, invitations and sign-in codes for key holders, the memories you schedule, and notices about release requests.
• To take payment for paid plans.
• To keep Afterpass secure, fix faults and answer support requests.
• To learn which pages people use so we can improve them, if analytics is on.

We do not sell your information, and we do not use it for advertising.

4. Who sees it

• Our staff see what they need to review a release request (including its proof) and to answer support requests. They also see account details such as your plan, how complete and how large your vault is, and who your scheduled memories go to and when, so they can support you and check deliveries. They do not browse vaults.
• Your key holders see nothing in your vault until a release request has been approved by our staff and the grace period has ended. You are told when a request is approved, so you can dispute it; our staff review any dispute and decide whether the release goes ahead. After release, a key holder can read, but not change, the folders you gave them, and your scheduled memories if you chose to include them.
• Recipients of a memory see only that memory, through the link we email them. The link does not expire, so anyone they pass it to can open it too.
• Service providers who process information for us:
  • Fly.io (hosting and database), Sydney, Australia.
  • Tigris (file storage), [file storage location].
  • Resend (email delivery), [email region].
  • Stripe (payments), United States and elsewhere.
  • Google (Google Analytics), United States and elsewhere, if analytics is on.
• Others only where the law requires it, such as a court order.

5. Analytics

We use Google Analytics to tell us which pages people use. It is on by default, and you can turn it off.

• It runs only on our front page, sign-up and log-in pages, this policy, and the pages you use to manage your own vault. It never runs on the pages key holders use, on a memory someone opens, or on our staff pages.
• Google gets the page's name, the site that sent you here, your browser and device, a rough location from your connection, and sets a cookie to tell visits apart. The page's name is its address with every name and number taken out (for example /sections/:id), so it never includes folder names, entry titles or who a memory is for.
• It never gets anything in your vault, your key holders' details, or anything a recipient opens.
• We do not send Google your name, email address or any account number, so it measures page views, not people.
• You can turn it off on the notice or any time on your Account page. Turning it off stops Google Analytics on that device, removes its cookies, and is remembered on that device.
• Google keeps the data for 14 months.
• Google's advertising features are off. We do not use analytics for advertising.

6. Information sent overseas

Your account and vault are stored in Sydney, and your files and recordings in [file storage location]. Some information may leave Australia: email addresses and the email we send go through Resend in [email region]; payment details go to Stripe, which processes them in the United States and other countries; and analytics data goes to Google in the United States and other countries. We choose providers that commit to protecting the information, but their countries' laws may differ from Australia's.

7. How long we keep it

• While your account is open, we keep your vault until you delete things from it. What you delete is removed from your vault straight away and from our backups within [backup retention period].
• On release, your vault is kept so your key holders can reach it, for [post-release retention period], unless your estate asks us to delete it sooner.
• On death without a release, your vault stays as it is until a key holder asks for it, your estate contacts us, or your account is closed.
• Closing your account: email us to close it. We first deactivate it so nobody can sign in, then our staff delete your vault, files, recordings and key holder details by hand within [deletion period]. We cannot close an account while a release is in progress.
• Release proofs are kept with the request, as a record of why access was given.
• Payment and tax records are kept for as long as Australian tax law requires, usually five years.

8. How we protect it

Information travels between your device and Afterpass over an encrypted connection, and our hosting and storage providers encrypt it where they store it. Only staff who need access have it, and important actions are logged. A key holder can never see your vault without a verified release.

Afterpass is not end-to-end encrypted. Because we must be able to release your vault to your key holders when you cannot, our systems can read what you store, and our access controls and staff policies are what protect it. No system is perfectly secure. If a data breach is likely to cause you serious harm, we will tell you and the Office of the Australian Information Commissioner, as the law requires.

9. Access, correction and complaints

You can see and change most of your information yourself in Afterpass. You can also ask us for a copy of what we hold about you, or to correct it, by emailing [privacy contact email]. We will reply within 30 days. If we cannot give you something, we will tell you why.

If you have a complaint, email us first and we will respond within 30 days. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

10. Children

Afterpass accounts are for adults aged 18 or over. Your vault may include information about your children, which we protect in the same way as everything else in it.

11. Changes to this policy

If we change this policy, we will update the date at the top and, for any important change, email you before it takes effect.