Privacy Policy

My Asset Safe is a secure digital estate vault. It lets you record your financial assets and liabilities (across categories such as bank accounts, pensions, ISAs, investments, property, mortgages, loans, credit cards, life assurance, death-in-service benefits, cash, and personal belongings), together with supporting documents, in one encrypted place.

Your vault stays private to you unless you choose otherwise. Nothing is shared by default, and if you wish you may give one of your Nominated Access contacts a read-only view of your live vault once you have confirmed their identity, which you can withdraw at any time. After your death, your vault can be opened only for the people you have chosen (your Nominated Access contacts). We do not ask for a death certificate: every nominee whose identity you have verified must individually confirm your death, signed in and identity verified, and you are then given a response window during which we tell you and you can object before any access is granted. Access is never automatic.

This service is provided by My Asset Safe Ltd, a company registered in England and Wales (company number 17483872) with its registered office at 76 Glebe Lane, Barming, Maidstone, Kent, ME16 9BD ("My Asset Safe", "we", "us", "our"). We are the data controller for the personal data described in this policy.

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registering with the Information Commissioner's Office (ICO) as a data controller. That registration is currently in progress, and we will show our ICO registration number here once it has been issued.

We collect and process the following categories of personal data:

• Account and profile data: your name, email address and phone number, and the authentication information needed to secure your account.
• Vault records: the records of your financial assets, liabilities and related notes that you choose to store. These are encrypted before they reach us (see "How your vault is protected").
• Documents you upload: supporting files you add to your vault, held in encrypted form.
• Nominated Access details: the names and contact details of the people you nominate. When a nominee accepts their invitation, they take a selfie with their own device's camera at that moment, and record a short video clip of about three seconds, without sound, in which they carry out one simple action that we choose (for example, turning their head). We collect these so that the person who named them can check that it is really them. Only that person can see the selfie and the clip: our staff cannot. We delete both as soon as that person has confirmed or rejected them, or if the nominee is removed first, and otherwise automatically 30 days after they were taken. We do not ask nominees for a passport, driving licence or any other identity document, and we do not use the selfie or the clip for facial recognition or any automated check: the person who named the nominee makes that judgement. Some nominees who registered before 11 October 2026 uploaded a photo of an identity document instead. We delete each of those as soon as the person who named that nominee has confirmed or rejected it, and we do not use them for anything else.
• People of Interest and contacts: other people you choose to record (for example advisers or executors).
• Death-claim records: information submitted when a death is reported, including each nominee's confirmation (with the time, IP address and device it was made from), any evidence submitted for an exception review by our support team (which may include a death certificate), the response recorded during your response window, and the decisions taken.
• Support correspondence: the contents of support tickets and messages you send us.
• Billing and subscription data: once paid subscriptions begin, your subscription and trial status, and the customer and subscription identifiers held by our payment processor. We do not store full card numbers.
• Waitlist details: if you ask to join the pilot waitlist, your email address, your name and anything you choose to tell us about why you want My Asset Safe.
• Technical and usage data: log data such as IP address, device and browser information, and timestamps of security and service events.

We use your personal data for the following purposes:

• To provide the vault service: to set up and run your vault, store your records and documents, and make them available to you.
• To authenticate and secure your account: to sign you in, support multi-factor authentication, and detect and prevent fraud, unauthorised access and abuse.
• To process death claims: to receive and act on a report that you have died, including collecting confirmation from every nominee whose identity you have verified, contacting you during your response window, and unlocking the vault for your Nominated Access contacts once the process is complete.
• To handle billing: to manage your subscription, free trial, payments and renewals through our payment processor.
• To provide support: to answer your questions and manage support tickets and correspondence.
• To run the pilot waitlist: to consider adding you to our pilot list while sign-up is limited to people on it, and to contact you about it.
• To comply with the law: to meet our legal and regulatory obligations and to establish, exercise or defend legal claims.

Under UK GDPR, we rely on the following lawful bases:

• Performance of a contract: most of our processing is needed to provide the service you have signed up for, including running your vault, processing death claims, and managing billing.
• Legitimate interests: to keep the service secure, prevent fraud and abuse, and run and improve our business, where those interests are not overridden by your rights and freedoms.
• Consent: for any optional marketing communications. We do not use non-essential cookies today; if we ever do, we will ask for your consent first. You can withdraw your consent at any time.
• Legal obligation: where the law requires us to keep or disclose certain information, for example retaining death-claim records.

Your vault contents are protected with envelope encryption. Each record is encrypted and decrypted using AES-256-GCM. The key that protects your vault (your User Master Key) is generated for you, then wrapped (encrypted) by AWS Key Management Service (KMS) and stored in that wrapped form on our servers. There is no separate vault password. After you sign in and complete any multi-factor step, your wrapped key is released to you so that your records can be decrypted.

In normal operation, your vault contents are not decrypted on our servers, and your key is not released to us in a readable form. As a result, our staff cannot read your vault contents through the application.

We do, however, retain a strictly limited and audited recovery capability. The ability to unwrap your key in AWS KMS is restricted to two named internal roles: one used only to release your key to you after you authenticate, and one used only to unlock a vault as part of an approved death claim. This is a deliberate design choice so that we can support account recovery and the death-unlock process. It means My Asset Safe is not a "zero-knowledge" service: there is a controlled, logged path that could in principle decrypt vault data, even though no member of staff can do so through the ordinary application.

Your account is secured by Amazon Cognito sign-in. We support multi-factor authentication (MFA) using an authenticator app (a one-time TOTP code) or an SMS code. We strongly recommend keeping MFA switched on. It is optional and can be turned off from your security settings. We also protect data in transit with TLS, encrypt data at rest with customer-managed keys, and audit access to production systems.

We use a small number of service providers (sub-processors) to run the service. They process personal data on our behalf under contracts that require UK GDPR-compliant protections. Our active sub-processors are:

• Amazon Web Services (AWS): cloud hosting, storage and database services, the sending of transactional email (via Amazon SES) and the sending of sign-in text message codes. Hosted in AWS data centres in London, in the United Kingdom.
• Microsoft (Microsoft 365): hosts our company email inboxes, such as support@myassetsafe.com and privacy@myassetsafe.com. If you email us, or we email you from one of those inboxes, that correspondence is held in Microsoft 365. Our automated emails, such as sign-in codes and notifications, are sent through AWS, not Microsoft.

Stripe will process payments for subscriptions once paid subscriptions begin. Stripe will handle card details directly, and we will not receive or store full card numbers. During the current pilot there is nothing to pay, so Stripe does not process any of your personal data on our behalf yet.

We do not use any other sub-processors. We are evaluating an additional provider for a future feature: an identity-verification provider (Onfido). This is planned and is not yet in use. We will update this policy and our records before any such provider begins processing your data.

All personal data is stored and processed in the United Kingdom, in AWS data centres in London. Some of our providers are part of international groups. If any processing of your personal data takes place outside the UK, we put appropriate safeguards in place, such as the UK International Data Transfer Agreement, Standard Contractual Clauses (SCCs), or reliance on a UK adequacy decision, as required by UK GDPR.

We keep your personal data only for as long as we need it:

• Account and vault data: kept while your subscription is active. If you cancel, your personal data and vault contents are permanently deleted 90 days after cancellation.
• Death-claim records: kept for 7 years to meet legal and regulatory obligations and to support any later dispute.
• Waitlist details: deleted automatically 365 days after you last asked to join the waitlist. You can ask us to delete your waitlist details sooner at any time.
• Nominee selfies and video clips: deleted when the person who named the nominee confirms or rejects them, or when the nominee is removed, and otherwise automatically 30 days after they were taken (removal from our storage can take up to two further days to complete). A copy may remain in our encrypted backups for up to 30 days more before it expires. Photos of identity documents uploaded by nominees before 11 October 2026 are deleted in the same way once they have been checked.
• Backups: held on a rolling basis and expire automatically over time. Data deleted from the live service is removed from backups as they cycle.

Under UK GDPR you have the following rights in relation to your personal data:

• The right to be informed about how we use your data (this policy).
• The right of access to a copy of your personal data.
• The right to rectification of inaccurate or incomplete data.
• The right to erasure (the "right to be forgotten") where it applies.
• The right to restrict our processing of your data.
• The right to data portability.
• The right to object to processing based on our legitimate interests.
• The right to withdraw consent where our processing is based on consent.

To exercise any of these rights, or to make a data subject access request (DSAR), email us at the address in Section 13. We will respond within one month, and we may ask you to verify your identity first. These rights have some limits: for example, we may need to keep certain data to meet a legal obligation.

We do not use analytics, advertising or tracking cookies. We only store what is strictly necessary in your browser to sign you in, keep your account secure and remember choices you make in the service. See our Cookie Policy for full details, including how this is governed by the UK Privacy and Electronic Communications Regulations (PECR).

My Asset Safe is intended for adults. The service is only for people aged 18 or over, and it is not designed for or directed at anyone under 18. We do not knowingly collect personal data from under-18s. If you believe a child has provided us with personal data, please contact us and we will delete it.

We may update this policy from time to time. If we make material changes, we will let you know by email or by posting a notice in the service, and we will update the "Last updated" date at the top of this page.

For any privacy question, to exercise your data protection rights, or to make a complaint, contact us at privacy@myassetsafe.com. For general help, contact support@myassetsafe.com.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or via their helpline. We would welcome the chance to address your concerns first.