This Privacy Policy describes how Always Here (the "Service") processes personal data of users when they use the app and/or website.
Via Vira, 2
6805 Mezzovico Vira
Switzerland
1. Data We Process
During registration and use of the Service, the following data may be processed:
- Account Data: name, surname, email, login credentials and/or OAuth identifiers (Google/Apple).
- Content: text messages, audio, video, and attachments created by the user.
- Recipients: data necessary for message delivery (e.g., email/contacts entered by the user).
- Trustees: name, surname, email, and phone number of the 3 designated trustees.
- Technical Data: IP address, device, operating system, access logs, security events.
- Heartbeat: periodic signals sent from the app to the server to attest activity.
- Cookies/equivalent technologies (for the website, if present).
2. Purposes
- Account creation and management.
- Service delivery and content preservation.
- Trustee management and death confirmation procedure.
- Delivery of messages to recipients when the procedure is completed.
- Security, abuse prevention, and technical maintenance.
- Compliance with applicable legal obligations.
3. Privacy Policy Acceptance
Upon first access, users are required to accept this Privacy Policy to use the Service.
4. Content Encryption
Upon first launch, the app generates a key pair (private and public) for the user. The user's public key, together with the server's public key, is used to encrypt content sent to the server.
The server's private key is held exclusively by the DPO of Swissvoip SA and is used only and exclusively when the user's death has been confirmed according to the established procedure, to decrypt content before sending it to recipients.
5. Death Determination Procedure
The Service receives daily heartbeat signals and records access events. In case of absence of signals (heartbeat and access) for 90 days, the system contacts the three trustees to request death confirmation.
If at least 2 trustees confirm the death, the system proceeds to send messages to the designated recipients.
6. Legal Basis
- Service execution (account management, message preservation and delivery).
- Consent when required (e.g., non-strictly technical communications, if applicable).
- Legitimate interest for security and abuse prevention.
- Legal obligations applicable.
7. Data Retention
Data is retained for the time necessary to provide the Service and as long as the account remains active, unless there are legal obligations or technical security requirements.
8. Account Deletion
If the user requests account deletion, content and associated data will be permanently deleted.
9. Recipients and Service Providers
Data may be processed by technical providers (e.g., hosting/infrastructure) as data processors, limited to what is necessary for Service delivery and with adequate security measures.
10. User Rights
Users may request access, rectification, deletion, and additional rights provided by applicable regulations by contacting the Data Controller.
11. Contact
Swissvoip SA
Via Vira, 2 – 6805 Mezzovico Vira – Switzerland
Email: privacy@always-here.app