Privacy Policy
Last updated: June 2026 — Draft, pending legal review
1. Who we are
Sapian ("we", "us") provides a zero-knowledge digital inheritance vault. This policy explains what personal data we process, why, and the rights you have under the EU General Data Protection Regulation (GDPR).
2. Zero-knowledge by design
The contents of your vault — crypto asset details, instructions, documents and legacy messages — are encrypted on your device before they reach our servers. We hold only ciphertext and cannot read, recover or disclose your vault contents. If you lose your encryption passphrase, we cannot restore access to encrypted data.
3. Data we process
Account data: name, email address, hashed authentication credentials and two-factor settings. Billing data: plan, payment status and invoices, processed by our payment provider; we do not store full card numbers. Vault metadata: item titles, timestamps and storage usage, needed to operate the service. Executor data: the email addresses and roles of people you designate, processed to deliver invitations and release workflows. Technical data: IP address, device and log data used for security, fraud prevention and service reliability.
4. Why we process it
We process data to provide the service (contract performance, Art. 6(1)(b) GDPR), to secure it and prevent abuse (legitimate interest, Art. 6(1)(f)), to comply with legal obligations such as tax and accounting rules (Art. 6(1)(c)), and, where you consent, to send product updates (Art. 6(1)(a)). You can withdraw consent at any time.
5. Sharing and processors
We share data only with service providers needed to run Sapian (hosting, email delivery, payment processing) under data processing agreements, with your designated executors as instructed by your release rules, and with authorities where the law requires. We never sell personal data.
6. International transfers
Where data is transferred outside the EU/EEA, we rely on adequacy decisions or Standard Contractual Clauses with supplementary safeguards.
7. Retention
Account and vault data are kept while your account is active. After account deletion, encrypted vault data is permanently erased within 30 days; billing records are retained as required by law.
8. Your rights
You have the right to access, rectify, erase and port your data, to restrict or object to processing, and to lodge a complaint with your supervisory authority. Contact privacy@sapian.io to exercise these rights.
9. Changes
We may update this policy. Material changes will be notified by email or in-app at least 30 days before they take effect.