Privacy Policy
Last updated: 25 September 2026
The short version
- Your will contains some of the most personal information you'll ever share. We treat it that way.
- We only use your information to provide OpenWill to you and the people you choose. We never sell it.
- The people you invite (executors, beneficiaries, witnesses) only see what you choose to share with them. Beneficiaries only see their own allocations.
- You can download or delete your information at any time.
- We give every user the same core privacy rights, wherever you live.
- You can complain to the data protection regulator where you live, such as the ICO in the UK.
1. Who we are
OpenWill is operated by NEOCR LTD, registered in England and Wales under company number 15664816, operating as a digital-only business. We do not offer a public visitor address. We are the data controller for the personal information described in this policy. We will publish our Information Commissioner registration number here when registration is confirmed.
For anything about your privacy, contact privacy@openwill.app. We have not appointed a Data Protection Officer; privacy enquiries are handled by NEOCR LTD.
2. Who this policy covers
- Account holders: people who create an account to make a will.
- Invited people: executors, beneficiaries and witnesses whose details an account holder adds.
- Visitors: people who visit our website or contact us.
3. Information we collect
From account holders
| Type | Examples |
|---|---|
| Identity and contact | Name, email address, phone number, date of birth, address, country |
| Account | Login details, account settings, check-in preferences |
| Will and estate information | Your wishes, the assets you describe, how you want them divided, guardianship wishes, funeral wishes |
| Documents | Files you upload to your vault (for example property deeds, policy documents, account statements) |
| People you add | Names, contact details and roles of your executors, beneficiaries and witnesses |
| Membership and payments | Plan, billing history, payment status. Card details are handled by our payment provider; we never see or store your full card number |
| Check-in activity | When you checked in, missed check-ins, reminders sent |
| Technical | IP address, device and browser type, log data, cookies (see our Cookie Policy) |
| Communications | Emails and support messages you send us |
About invited people
When an account holder invites you, we receive your name, contact details and your role from them. If you accept an invitation and create access, we also collect your confirmation, login details and activity. For executors involved in a Live Will release, we collect your confirmation of the account holder's death and any evidence you provide, including an official death certificate or the equivalent document in the relevant country and, where needed, a certified English translation.
Sensitive information
Wills and funeral wishes can reveal "special category" information, such as your health, religious or philosophical beliefs, or details about your relationships. We only process this because you choose to include it, and we rely on your explicit consent to do so. You can withdraw consent by deleting that information, although this may affect your will.
4. How we use information, and our legal basis
| What we do | Legal basis (UK GDPR / EU GDPR) |
|---|---|
| Create and run your account, and help you create your will | Contract |
| Organise your asset descriptions into an inventory using AI | Contract |
| Send invitations to people you name, and track their confirmations | Contract (with you); legitimate interests (for invited people, so the account holder's plans can work) |
| Run Live Will check-ins, reminders and escalation to executors | Contract |
| Release documents to beneficiaries after two executors confirm | Contract (with you); legitimate interests (for beneficiaries and executors) |
| Process special category information you include | Explicit consent |
| Take payments and manage memberships | Contract; legal obligation (accounting records) |
| Send service emails (security alerts, renewal reminders, changes to terms) | Contract; legal obligation |
| Send product news and offers | Consent (you can unsubscribe at any time) |
| Keep the Service secure and prevent fraud, including false death reports | Legitimate interests; legal obligation |
| Understand how the Service is used, using analytics | Consent, where cookies are involved |
| Respond to support requests and complaints | Contract; legitimate interests |
| Comply with the law and respond to lawful requests | Legal obligation |
Where we rely on legitimate interests, we've balanced our interests against your rights. You can ask us for more detail about this. Where other countries' laws apply to you, we rely on the equivalent legal grounds under those laws, including your consent where required.
5. AI processing
We use a third-party AI provider to help organise the assets you describe. Only the information needed for that task is sent through our AI inference provider to an OpenAI model, with provider storage disabled. The provider is not permitted to use this information to train its models.
AI suggestions are there to help you. They don't make decisions about you, and nothing is added to your will without you reviewing it.
6. Automated decisions
We don't make decisions that have legal or similarly significant effects on you based solely on automated processing. Missed check-ins trigger reminders and notifications automatically, but documents are only released after two human executors have independently confirmed and OpenWill staff have reviewed the death evidence.
7. Who we share information with
People you choose. Executors, beneficiaries and witnesses only see what you've chosen to share with them and what their role requires. Beneficiaries only see their own allocations and documents.
Service providers who process data on our behalf under contract, only on our instructions:
| Provider type | Purpose | Provider | Location |
|---|---|---|---|
| Hosting and database | Storing and running the Service | Cloud infrastructure and database provider | Secure cloud infrastructure, which may process data in the EEA and United States |
| Payments | Taking membership payments | Paddle | United Kingdom, EEA, United States and other locations used by Paddle |
| Invitations, check-ins, reminders | Transactional email delivery provider | Secure cloud infrastructure, which may process data in the EEA and United States | |
| AI | Organising asset inventories | AI inference provider and OpenAI | United States and other locations covered by appropriate transfer safeguards |
| Analytics | Not currently used | — | — |
| Customer support | Handling support requests | OpenWill email support | United Kingdom and secure cloud infrastructure |
Independent legal reviewers, only if you ask us to arrange a review, and only the information needed for it.
Professional advisers such as lawyers, accountants and insurers, where needed.
Authorities, where we're legally required to, or to prevent fraud or protect someone's safety.
A buyer of our business, if OpenWill is sold or merged. They would have to respect this policy.
We never sell your personal information, and we don't share it with advertisers.
8. International transfers
OpenWill serves people around the world. Your information is stored and processed using secure cloud infrastructure that may be located in the EEA and the United States, and may be accessed by our providers in other countries, including the United States.
Whenever information moves across borders, we protect it with the safeguards required by the law that applies to you. These include adequacy decisions (such as the UK-US Data Bridge, where the provider is certified), standard contractual clauses, the UK International Data Transfer Agreement, and equivalent mechanisms under other countries' laws. You can ask us for details.
9. How long we keep information
We keep information only as long as we need it. Our Data Retention & Deletion policy sets out the specific periods.
10. Keeping information secure
We use encryption, access controls and other safeguards to protect your information. Our Security page explains more. No system is completely secure, so if we ever have a data breach that's likely to put you at risk, we'll tell you and the ICO as the law requires.
11. What happens to your information after you die
Many data protection laws, including UK data protection law, don't apply to information about people who have died. We still treat it with the same care and confidentiality. We'll only share it according to your instructions on OpenWill, our Executors & Bereavement Support process, or where the law requires.
12. Your rights
Depending on where you live, the law gives you some or all of these rights. We aim to offer them to every user, wherever you are. You can ask to:
- access a copy of your information;
- correct information that's wrong;
- delete your information;
- restrict or object to how we use it;
- receive your information in a portable format;
- withdraw consent at any time, where we rely on consent; and
- complain to a regulator.
We won't treat you differently for using any of these rights.
You can download or delete most of your information yourself from your account settings. For anything else, email privacy@openwill.app. We'll respond within one month. There's usually no charge.
If you've been invited by someone else, you can ask us to remove your details. Please be aware this may affect the account holder's plans, so we may let them know you've asked for removal.
13. Complaints
If you're unhappy with how we've handled your information, please contact us first at privacy@openwill.app. You also have the right to complain to a data protection regulator. In the UK, that's the Information Commissioner's Office, at ico.org.uk or on 0303 123 1113. If you live elsewhere, see section 14 for your local regulator.
14. If you live outside the UK
We handle your information in line with this policy wherever you live, and with the local laws that apply to us. Here are some of the main ones:
| Where you live | Main law | Regulator you can complain to |
|---|---|---|
| European Union / EEA | General Data Protection Regulation (GDPR) | Your local data protection authority |
| United States | State privacy laws, such as the California Consumer Privacy Act, where they apply to us | Your state's privacy regulator or Attorney General |
| Canada | PIPEDA and provincial privacy laws | Office of the Privacy Commissioner of Canada |
| Nigeria | Nigeria Data Protection Act 2023 | Nigeria Data Protection Commission |
| South Africa | Protection of Personal Information Act (POPIA) | Information Regulator |
| Kenya | Data Protection Act 2019 | Office of the Data Protection Commissioner |
| Ghana | Data Protection Act 2012 | Data Protection Commission |
| India | Digital Personal Data Protection Act 2023 | Data Protection Board of India |
| Singapore | Personal Data Protection Act 2012 | Personal Data Protection Commission |
| Australia | Privacy Act 1988 | Office of the Australian Information Commissioner |
| Brazil | Lei Geral de Proteção de Dados (LGPD) | Autoridade Nacional de Proteção de Dados (ANPD) |
We have not appointed an EU representative. If this becomes legally required, we will update this policy before offering the affected processing.
United States: we don't sell personal information, and we don't share it for cross-context behavioural advertising. You can ask to know, correct or delete the information we hold about you by emailing privacy@openwill.app.
Anywhere else: contact privacy@openwill.app, and we'll explain how your local rights apply.
15. Children
OpenWill is only for adults aged 18 and over, or the minimum age for making a will where they live, if that's higher. We don't knowingly collect information from children, except where an adult account holder includes a child's details in their will (for example, naming them as a beneficiary or in guardianship wishes). We don't contact children directly.
16. Cookies
We use cookies and similar technologies. See our Cookie Policy, and change your choices at any time using "Cookie settings" in the footer.
17. Changes to this policy
We'll update this policy when things change. If a change is significant, we'll tell you by email or in the app before it takes effect.
18. Contact us
NEOCR LTD Digital-only contact: privacy@openwill.app privacy@openwill.app
