Privacy Policy

This document forms part of your agreement with Filumio. Download a PDF copy for your records.

Version: 2026-v2

Filumio (Pty) Ltd (“Filumio”, “we”, “us”) respects your privacy. This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use our digital legacy platform.

Data controller: Filumio (Pty) Ltd · 25 Redstone Crescent · support@filumio.com

This policy should be read with our Terms and Conditions and Acceptable Use Policy.

1. Scope

This policy applies to:

visitors to our marketing website;
registered users and account holders;
trusted contacts and others who interact with vault invitations or tiered access; and
individuals whose information is stored in a user’s vault by that user.

Filumio primarily serves users in South Africa, the United Kingdom, the United States, Australia, and the European Economic Area. Applicable laws may include POPIA (South Africa), GDPR / UK GDPR, the Australian Privacy Act, and US state privacy laws.

2. Information we collect

2.1 Account and profile data

email address, country preference, locale, and time zone;
authentication data (password hash, WebAuthn credentials, MFA settings);
optional profile fields (display name, avatar, encrypted ID number where provided);
subscription tier and billing-related metadata (payment card details are processed by future payment providers, not stored by Filumio in plain text).

2.2 Vault and legacy content

documents, files, and structured data you upload or create;
passwords, credentials, and final wishes you store;
trusted-contact designations, access tiers, and delegation rules;
will drafts, readiness checklist progress, and related metadata.

Depending on the feature, content may be encrypted such that Filumio cannot read it without your keys or authorised release.

2.3 Life events and verification

death reports, attestations, and supporting notes;
verification document metadata (and uploaded official documents where provided);
audit-trail entries for access, login, and vault events.

2.4 Technical and usage data

IP address, browser type, device signals, and approximate region (for pricing and regional copy);
session identifiers, sign-in timestamps, and security logs;
error reports and performance diagnostics.

For public content discovery, we keep daily totals of requests claiming to be recognised search crawlers or AI assistants. These totals contain the crawler name, public page path, date and request count, without visitor identifiers, IP addresses, query strings or raw browser headers. We retain these aggregate totals for 90 days.

2.5 Communications

support enquiries and email notifications we send you;
estate-notification templates you choose to send via Filumio.

2.6 Optional website analytics

If you allow analytics, we use Google Analytics to measure public-page visits, article reading and scrolling, campaign sources, verified account signups and paid subscriptions. This includes a browser identifier, session information, approved public page titles and paths, and campaign codes. We use this information to understand which content is useful and which sources lead to a signup or subscription.

We do not send Google Analytics your name, email address, phone number, account ID, document contents or private vault details. Private dashboards, vaults, documents, billing screens, and partner consoles do not load the analytics tag. Partner-branded domains are excluded from Filumio’s Analytics property.

Analytics is optional. Essential service access does not depend on accepting analytics. We do not use Google Signals, advertising personalisation or automatic collection of user-provided details.

2.7 Information about others

You may store personal information about family members, executors, beneficiaries, or advisers. You are responsible for ensuring you have a lawful basis to provide that information to Filumio.

3. How we use information

We use personal information to:

provide, secure, and improve the Services;
authenticate users and enforce tiered access;
detect fraud, abuse, and suspicious death attestations;
process subscriptions and send service communications;
comply with legal obligations and respond to lawful requests;
analyse aggregated, de-identified usage to improve the product; and
obtain your consent where required (for example, cross-border storage at registration).

We do not sell your personal information.

Where GDPR or UK GDPR applies, we rely on:

Contract: processing necessary to provide the Services you request;
Consent: for optional website analytics and other processing where you explicitly agree; accepting our service terms does not turn analytics on;
Legitimate interests: security, fraud prevention, and service improvement, balanced against your rights; and
Legal obligation: where we must retain or disclose information by law.

5. Encryption and security

We implement technical and organisational measures including:

encryption in transit (TLS) and at rest (AES-256);
access controls, tiered release, and tamper-evident audit logging;
WebAuthn / MFA support;
infrastructure hardening and monitoring.

No system is perfectly secure. You are responsible for safeguarding your master password and devices.

6. Where we store data

Filumio uses cloud infrastructure that may be located outside your home country, including:

DigitalOcean: application hosting and managed PostgreSQL (London region);
DigitalOcean Spaces: encrypted file storage (EU region);
Postmark: transactional email;
OpenAI: optional document parsing and advisor features (content sent only when you use those features);
Google Analytics: optional website analytics, only after you allow it; Google may process analytics data outside your country, including in the United States. See how Google uses information from sites that use its services;
IP geolocation providers: approximate country detection on marketing pages.

Cross-border transfers are protected through encryption, contractual safeguards, and your consent where required under POPIA Section 72, GDPR Chapter V, or equivalent laws.

7. Retention

We retain personal information for as long as your account is active or as needed to provide the Services. After account closure:

we delete or anonymise data within a reasonable period, subject to legal retention requirements;
encrypted vault content may be irrecoverably deleted when encryption keys are destroyed;
audit and security logs may be retained longer for fraud prevention and legal compliance.

Our cookie-choice record expires after 180 days. If you sign in, we also save that choice to your account with the same expiry. Google Analytics cookies are configured for up to 180 days, without renewing their expiry on each visit; your browser may shorten this period. Detailed Analytics event and user data is set to two months, without extending the user-data period on new activity. Google applies deletion on its retention schedule. Aggregated reports can remain longer and are not covered by that two-month setting.

You may request deletion as described in Section 9. Withdrawing analytics consent stops future collection and queued conversion delivery; it does not automatically erase previously collected Analytics data. Contact us for a deletion request.

We share information only:

with service processors listed above, under written data-processing terms;
with trusted contacts and executors according to your vault rules and verified tiers;
when required by law, court order, or regulator;
to protect rights, safety, and security of users and Filumio; or
with your explicit direction (for example, emails you send through the platform).

We do not share vault content with advertisers.

9. Your rights

Depending on your jurisdiction, you may have the right to:

access personal information we hold about you;
correct inaccurate data;
delete your account and associated data;
object to or restrict certain processing;
withdraw consent where processing is consent-based;
lodge a complaint with a supervisory authority (for example, the Information Regulator in South Africa, or your local data protection authority).

To exercise these rights, contact support@filumio.com. We will respond within the timeframe required by applicable law.

10. Breach notification

If we become aware of a personal-information breach that poses a risk to your rights, we will notify you and relevant regulators as soon as reasonably practicable, in line with POPIA Section 22, GDPR Articles 33–34, and equivalent requirements.

11. Children

Filumio is not intended for users under 18. We do not knowingly collect information from children. Contact us if you believe a minor has created an account.

12. Cookies and your choices

Essential cookies and settings support secure sign-in, request protection and preferences you choose, including language, appearance and text size. They also remember your cookie choice. Sign-in cookies remain until expiry or sign-out; browser preferences remain until changed or cleared. These are separate from optional analytics.

Analytics cookies (including _ga and _ga_*) help distinguish browsers and sessions. We load the Google tag and send analytics data only after an explicit opt-in. We do not send tracking requests to Google before a choice or after rejection, and we do not backfill visits made without consent. We do not use advertising cookies.

Choose Essential only, Allow analytics, or Choose cookies in the banner. You can reopen Cookie settings from the footer and change your choice at any time. Turning the analytics switch on or off only changes the selection; use Save preferences to confirm it. Choosing Essential only immediately requests that optional analytics stop.

Your choice is stored in an encrypted cookie and, when signed in, on your account. A rejection in the current browser takes precedence over a saved account permission. Choices expire after 180 days; we may ask again when a choice expires or our analytics purposes change. Clearing browser storage or using a different browser may also make the banner appear again. When you sign in, a valid account choice can be restored.

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified at least 30 days before they take effect where practicable. You may be asked to acknowledge updated policies on sign-in. Continued use or acknowledgement of this notice does not constitute consent to optional analytics.

14. Contact

Privacy enquiries: support@filumio.com

Postal address: 25 Redstone Crescent

Filumio (Pty) Ltd