Privacy Policy

In detail

Who we are

Willful Inheritance ("Willful", "we", "us") provides the Willful app and related services. For the purposes of India's Digital Personal Data Protection Act, 2023, we are the Data Fiduciary for the personal data described below, and you are the Data Principal.

Registered address:
9th Floor, No. 94, Primrose Block,
L & T Serene County, Telecom Nagar, Gachibowli,
Hyderabad, Rangareddy, Telangana 500032, India

What we can read

A small set of account details is stored in ordinary readable form, because the service cannot function otherwise:

• Your phone number — it is how you register, sign in, and receive one-time codes.
• Your name, city, country and chosen language — used to address you, to price and deliver the optional physical-will service, and to show the app in your language.
• Subscription and referral records — your plan, its dates, your referral code and the codes you have redeemed.
• The date you last opened the app, so we know an account is still in use.
• A record of your consent to these terms — the version shown to you, the language, the time and the IP address it came from.

What we cannot read

Everything you actually store — your assets, account details, policy and property records, wishes, nominee details, uploaded photographs and nominee identity documents — is encrypted on your device before it leaves it, using AES-256-GCM under a key derived from your passphrase. We receive and store only the resulting ciphertext.

We never receive your passphrase, and there is no recovery. This is a deliberate design choice, not an omission: a recovery mechanism we could operate would also be a mechanism an attacker, or a court order, could compel us to operate. If you forget your passphrase, the vault cannot be opened by anyone, including us. You can reset the account and start again, which erases the vault contents.

The one exception: the physical-will service

If you request a drafted physical will, the app builds a document from your vault on your device and uploads it so that our team can draft from it. That document is readable by us. It is disclosed only because the service cannot be provided otherwise, only after you give a separate, explicit consent at that moment, and the exact wording you agreed to is recorded. The finished will is encrypted to your device's own key before it is stored, so we cannot read the delivered document afterwards. If you reset your vault, any open request is cancelled and the drafting document is deleted.

Release to your nominees

Willful exists so that the people you name can reach your records after you die. A release happens only when a person presents a nominee key you issued, a death certificate, and identity proof that matches the nominee record you created. If the name or the identity number does not match, the request is refused outright. Every release is logged with who performed it, when, and on what evidence.

Who else processes your data

• Amazon Web Services — hosting and file storage, in the Mumbai (ap-south-1) region. Your data is stored in India.
• MSG91 — delivers your one-time codes over WhatsApp. They receive your phone number and the code, nothing else.

We do not sell personal data, share it with data brokers, or use it for advertising or profiling. We may disclose data where a law, a court or a regulator requires it — but we can only ever disclose what we can read, which is the readable account details above, never your vault.

Payments

We do not operate a payment gateway and we never see or store card, bank-account or UPI credentials. Subscriptions are activated by our team and any physical-will fee is collected separately.

How long we keep it

Account details are kept while your account exists. Vault contents are kept until you delete them, reset the vault, or ask us to delete the account. Server logs are retained for 180 days, as Indian cyber-security directions require. Consent records are retained for as long as we may need to evidence them.

One thing outlives a deleted account. If the account held a paid membership, we keep a record that a particular phone number had a plan and the date that plan runs to. The number is stored only as a keyed hash, not in a readable form, and the record holds nothing else — no name, no vault contents, no nominees, no payment details. We keep it so that if you register again with the same number, the remainder of the membership you already paid for is returned to you rather than charged twice, and because the underlying payment has to remain in our accounting records regardless. Everything else about a deleted account is destroyed and cannot be recovered by anyone, including us. The deletion screen in the app says the same thing before you confirm.

Your rights

Under the Digital Personal Data Protection Act, 2023 you may:

• ask what personal data we hold about you and how it is processed;
• have inaccurate or incomplete data corrected or completed;
• have your data erased, and your account closed;
• nominate another person to exercise these rights if you die or become incapacitated — which is, in a sense, the whole point of Willful;
• raise a grievance with us, and escalate to the Data Protection Board of India if we do not resolve it.

Most of these you can do yourself in the app. To close your account and have everything erased, write to us at the address below. Note that we can only correct or produce data we can read — we cannot recover, correct or produce vault contents, because we cannot open them.

Children

Willful is not intended for anyone under 18, and we do not knowingly create accounts for children. If you believe a child has registered, tell us and we will delete the account.

Security

Vault data is encrypted on your device with AES-256-GCM; the key is derived from your passphrase and never leaves the device. We store only a hash of your login credential, never the credential itself. Traffic is HTTPS only. Screenshots and screen recording are blocked inside the app. Documents are stored as ciphertext. No system is perfect, and if a breach affects you we will notify you and the Data Protection Board as required.

Changes

If this policy changes we will update this page and the date at the top, and tell you in the app where the change is significant.

Grievance Officer

In accordance with the Information Technology Act, 2000 and the rules made under it, and with the Digital Personal Data Protection Act, 2023:

Arti Nagpal
Grievance Officer, Willful Inheritance
9th Floor, No. 94, Primrose Block,
L & T Serene County, Telecom Nagar, Gachibowli,
Hyderabad, Rangareddy, Telangana 500032, India
Email: privacy@willful.in

We acknowledge grievances within 24 hours and aim to resolve them within 15 days. If you are not satisfied with the outcome, you may complain to the Data Protection Board of India.