SIMPLYTRUST — PRIVACY POLICY

1. Introduction

SimplyTrust Software Inc. ("SimplyTrust," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our estate planning platform, including our website at simplytrust.com, our mobile applications for iOS and Android, our free document tools, and related services (collectively, the "Service").

By using our Service, you consent to the data practices described in this policy. If you do not agree with our policies and practices, please do not use our Service.

2. How the Service Works

2.1 Free Document Tools (Website)

Our free document tools on the website process your form entries entirely within your browser. Your form inputs and generated documents are never transmitted to or stored on SimplyTrust servers.

2.2 Mobile Application and Subscription Platform

Our mobile application and subscription platform require account creation and store your information on our servers to provide trust creation, document storage, trust administration, and related features. Data entered in the mobile app is transmitted to and stored on our servers.

3. Information We Collect

3.1 Information You Provide

When you create an account or use our subscription services, we collect:

• Account Information: Name, email address, phone number, and password
• Profile Information: Date of birth, marital status, state of residence
• Trust and Estate Planning Data: Information about your assets, beneficiaries, trustees, and other individuals you include in your estate planning documents
• Documents: Trust documents, wills, and other estate planning documents you create or upload
• Payment Information: Billing address and payment method details (credit card information is processed by our payment processors and not stored on our servers)

3.2 Information Collected Automatically

When you use our Service, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Data: Features you use, screens you view, actions you take, and time spent in the app
• Log Data: IP address, browser type, access times, and referring URLs
• Approximate Location: City or region-level location based on IP address (we do not collect precise GPS location)

3.3 Free Document Tools

When you use our free document tools and download a document, we may collect basic contact information you voluntarily provide, device and browser information, and IP address. We do not collect, transmit, or store form entries or documents generated through our free tools.

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Service
• Create and manage your account
• Process payments and subscriptions
• Generate and store your estate planning documents
• Send you transactional communications (account confirmations, payment receipts, document updates)
• Send push notifications about your account or documents (with your consent)
• Analyze usage patterns to improve our Service
• Detect, prevent, and address technical issues and security threats
• Comply with legal obligations

5. How We Share Your Information

We do not sell, rent, or trade your personal information.

We may share your information in the following circumstances:

• Service Providers: With third-party vendors who assist us in providing the Service (see Section 6)
• Legal Requirements: When required by law, subpoena, court order, or government request
• Safety and Security: To protect the rights, property, or safety of SimplyTrust, our users, or the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you direct us to share information with third parties
• Aggregated Data: We may share anonymized, aggregated data that cannot identify you

6. Third-Party Services

We use the following third-party services to operate our Service:

6.1 Supabase (Data Storage and Authentication)

We use Supabase to store your account information, documents, and application data. Supabase processes data in accordance with their Privacy Policy.

6.2 Stripe (Payment Processing)

We use Stripe to process payments for subscriptions purchased directly through our website. Stripe collects payment information including credit card details. We do not store your full credit card number on our servers. Stripe processes data in accordance with their Privacy Policy.

6.3 Google Analytics for Firebase (Analytics)

We use Google Analytics for Firebase to understand how users interact with our mobile application. This service collects device information, app usage data, and crash reports. Data is collected in accordance with Google's Privacy Policy. You can opt out of analytics collection in your device settings.

6.4 Customer.io (Push Notifications and Communications)

We use Customer.io to send push notifications and email communications. Customer.io receives your email address, device tokens, and engagement data. Data is processed in accordance with their Privacy Policy.

6.5 Apple and Google (App Store Payments)

Subscriptions purchased through the Apple App Store or Google Play Store are processed by Apple and Google respectively. These purchases are subject to Apple's Privacy Policy and Google's Privacy Policy.

7. Biometric Authentication

Our mobile application supports biometric authentication (Face ID, Touch ID, or fingerprint) for convenient and secure access to your account.

Important: Your biometric data (facial geometry, fingerprint data) is processed entirely on your device using your device's secure hardware (Apple Secure Enclave or Android Trusted Execution Environment). SimplyTrust never receives, transmits, or stores your biometric data. We only receive a confirmation that authentication was successful.

You can enable or disable biometric authentication at any time in the app settings.

8. Push Notifications

With your permission, we may send push notifications to your mobile device about:

• Important updates to your account or documents
• Reminders related to your estate planning
• Security alerts
• New features and service updates

You can manage your notification preferences or disable push notifications entirely through your device settings or within the app.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication mechanisms
• Access controls limiting employee access to personal data
• Regular security assessments and monitoring
• Secure cloud infrastructure with industry-standard protections

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

10. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes described in this policy:

• Active Accounts: We retain your data while your account is active
• After Subscription Cancellation: You have 90 days of read-only access to download your documents, after which your data may be deleted
• After Account Deletion: We delete your personal data within 30 days, except as required for legal compliance
• Legal Requirements: We may retain certain data longer if required by law or to resolve disputes

11. Account Deletion

You may delete your account at any time through the app settings or by contacting us at privacy@simplytrust.com.

When you delete your account:

• Your personal information will be permanently deleted within 30 days
• Your documents and trust data will be permanently deleted
• This action cannot be undone

Important: If you have an active subscription through the Apple App Store or Google Play Store, you must cancel your subscription separately through that platform before deleting your account to avoid continued billing.

We may retain certain information as required by law, such as records of transactions for tax and accounting purposes.

12. Children's Privacy

Our Service is not intended for children under 18 years of age. You must be at least 18 years old to create an account or use our Service.

We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

If you believe we have collected information from a child under 18, please contact us at privacy@simplytrust.com.

13. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

13.1 All Users

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your account and personal information
• Data Portability: Request your data in a portable format
• Opt-Out: Unsubscribe from marketing communications

13.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know what personal information we collect, use, and disclose
• Right to delete your personal information
• Right to opt-out of the sale or sharing of personal information (we do not sell your data)
• Right to non-discrimination for exercising your privacy rights
• Right to limit use of sensitive personal information

13.3 European Users (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

• Right to withdraw consent at any time
• Right to restrict processing of your data
• Right to object to processing based on legitimate interests
• Right to lodge a complaint with a supervisory authority

13.4 Exercising Your Rights

To exercise any of these rights, contact us at privacy@simplytrust.com. We will respond to your request within 30 days (or sooner if required by applicable law). We may need to verify your identity before processing your request.

14. International Data Transfers

Your information may be transferred to and processed in the United States and other countries where our service providers operate. These countries may have different data protection laws than your country of residence.

When we transfer data internationally, we implement appropriate safeguards to protect your information, including standard contractual clauses and other legally recognized transfer mechanisms.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. We will notify you of material changes by email or through a notice in the app before the changes take effect.

Your continued use of the Service after changes become effective constitutes your acceptance of the revised policy.

16. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us: