Last updated: July 2026  |  Effective: March 2025

1. Information We Do NOT Collect

We want to be completely transparent. The following data is never collected by us:

• Your vault contents, documents, wills, or files
• Your master password or biometric data
• Your 12-word recovery phrase
• Your payment card details stored in the app
• Your emergency contact information
• Your location or device identifiers
• Your browsing or app usage behavior
• Any personally identifiable information from inside the vault

2. How Your Data Is Stored

All data you enter into Digital Will Locker is stored exclusively on your device:

• AES-256 military-grade encryption for all vault data — AES is the encryption algorithm standard approved by the US National Institute of Standards and Technology (NIST)
• PBKDF2 password hashing with 10,000 iterations
• Biometric data handled by your device secure enclave only
• Zero cloud storage — no servers, no backups by us
• 100% offline — no internet connection required for core features

3. App Permissions We Request

The app may request the following device permissions:

• Biometrics: For fingerprint/face ID login — handled by your device only
• Storage: To save and access encrypted files locally on your device
• Microphone: Only for the optional AI Voice Chat feature
• Notifications: For Dead Man's Switch check-in reminders only
• Camera: Optional — for scanning documents to store in vault

4. AI Features & Third-Party Services

The optional AI features — including AI Voice Chat, AI Emergency Assistant, and Document Organizer AI — use a third-party AI service provider for voice transcription and AI responses. When you use any of these features:

• Your voice audio is sent to our AI service provider for transcription (opt-in only)
• Audio is processed by our provider under their own privacy policy
• No vault data is ever sent to any AI service provider
• You can use the entire app without ever using the AI features

5. GDPR Compliance (European Users)

If you are located in the European Economic Area (EEA), UK, or Switzerland, the following applies under the General Data Protection Regulation (GDPR):

• Data Controller: Digital Will Locker acts as the data controller only for the minimal data described below — we are not a data controller for your vault contents, which never leave your device
• Lawful Basis for Processing: Where any processing occurs (e.g. optional AI Voice Chat), it is based solely on your explicit, opt-in consent. You may withdraw consent at any time by simply not using that feature
• Your GDPR Rights: Right to access, rectify, erase, restrict, or port any data we hold about you; right to object to processing; right to withdraw consent at any time; right to lodge a complaint with your local Data Protection Authority
• International Transfers: If you use the optional AI Voice Chat feature, your voice audio may be processed outside the EEA by our third-party AI service provider under their own GDPR-compliant safeguards. No vault data is ever transferred internationally
• Data Retention: We do not retain any vault data. Any data processed via optional features (e.g. voice audio) is handled per our provider's retention policy, not stored by us

6. Asia-Pacific Privacy Law Compliance

Digital Will Locker also complies with the following Asia-Pacific data protection frameworks. Because the app is offline-first and does not collect vault data, compliance under each of these laws follows the same core principle: there is minimal to no personal data for us to protect, because we never receive it in the first place.

• Malaysia — Personal Data Protection Act (PDPA) 2010, as amended 2024: We process no personal data from your vault. Where any data is processed (e.g. optional AI Voice Chat), it is done only with your explicit consent, and you may request access, correction, or withdrawal of consent at any time by contacting us below
• Singapore — Personal Data Protection Act (PDPA): We follow the same consent, purpose limitation, and data minimisation principles for any Singapore-based users. No personal data is collected, used, or disclosed without your consent, and none of your vault contents are ever transmitted to us
• India — Digital Personal Data Protection Act (DPDP) 2023: As a Digital Personal Data Fiduciary where applicable, we process only the minimal data described in Section 4 (AI Features) on an opt-in basis. You retain the right to access, correct, and erase any such data, and to withdraw consent at any time
• China — Personal Information Protection Law (PIPL): We do not collect, store, or transfer any personal information from users in mainland China. If this changes in future, any processing will be limited to what is strictly necessary and disclosed with clear consent
• Japan — Act on the Protection of Personal Information (APPI): We handle any voluntarily provided data (e.g. for optional AI features) in line with APPI's purpose-specification and consent requirements, and do not share data with third parties beyond what is disclosed in Section 4
• South Korea — Personal Information Protection Act (PIPA): The same minimal-data principle applies — no vault data is collected, and any optional feature data is processed only with informed consent

If you are located in any of these jurisdictions and have questions about your specific rights under local law, contact us using the details at the bottom of this page.

7. CCPA/CPRA Compliance (California, US Users)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) give you the following rights:

• We do not sell your personal information. We have never sold, and will never sell, any user data
• Right to know what personal information we collect (we collect none from your vault)
• Right to delete personal information we hold about you
• Right to opt out of any data sale or sharing (not applicable — we do not sell or share data)
• Right to non-discrimination for exercising your privacy rights

8. In-App Purchases

Subscriptions and payments are processed securely through PayPal. This app does not use Google Play billing for subscriptions. We never see or store your full payment card details. All billing is handled by PayPal under their own privacy policy at paypal.com/privacy.

9. Dead Man's Switch

If you enable this feature, the app monitors your check-in activity based on the inactivity period you choose. If you don't open the app and check in before that period ends, your designated trusted contact receives an emergency email notification. To gain vault access, they must call you twice and wait 24 hours — giving you a final chance to cancel if you're simply unreachable. Only if this process completes without any response from you, does the trusted contact receive full access to your complete vault — including your stored.documents, digital inheritance information, and any final messages you have prepared for them.Outside of this specific emergency workflow, your vault data is never transmitted anywhere. Your data stays completely private and encrypted on your device at all times.

10. Children's Privacy

Digital Will Locker is not intended for use by children under 13 years of age. We do not knowingly collect any information from children.

11. Cookie Policy

This website (digitalwilllocker.com) does not use tracking cookies, analytics cookies, or advertising cookies of any kind. We do not track your browsing behavior on our site or across other websites.

12. Third-Party Links

Our app and website may contain links to third-party services, including PayPal, app stores (APKPure, OPO Store, Indus App Store, and others), and our AI service provider. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies independently.

13. Data Breach Notification

In the unlikely event of a data breach affecting any data we process (such as data related to optional AI features), we will notify affected users and relevant authorities without undue delay, and in accordance with the notification timelines required under applicable law (including GDPR, PDPA Malaysia, and PDPA Singapore). Because your vault contents are never transmitted to us or stored on our servers, they cannot be affected by any breach on our end.

14. Governing Law

This Privacy Policy is governed by the laws of Malaysia. Any disputes arising from this policy will first be addressed through our support contact below before pursuing formal resolution.

15. Changes to This Policy

We may update this privacy policy from time to time. We will notify users of any significant changes through the app. Continued use of the app after changes constitutes acceptance of the new policy.

16. Your Rights

• Right to know what data we hold (we hold none)
• Right to access any data we do hold about you
• Right to rectify inaccurate data we hold about you
• Right to delete your data (uninstall the app)
• Right to restrict or object to any processing
• Right to data portability (export your encrypted vault)
• Right to opt out of AI features at any time
• Right to lodge a complaint with your local Data Protection Authority (EU/UK/Swiss users)