SMARTEDTECH SL (مالک) کی منظور شدہ· نفاذ: 1 نومبر، 2026
AfterToMe Privacy Notice
1. Controller
1. SMARTEDTECH SL, tax ID B66970831, Carrer Agricultura, 16, 1º, 9ª, 08320 El Masnou (Barcelona), Spain, is the controller of the personal data described in this notice. Privacy contact: legal@aftertome.com. Rights form: /legal/privacy-rights.
2. The Operator has not appointed a Data Protection Officer; the privacy contact above is the Operator's data protection contact for every request.
2. Data roles
1. Platform data. The Operator is the controller of personal data processed to operate the platform: account, identity verification, acceptance records, payments, security, support, communications and analytics.
2. Provider supply data. Where a provider supplies services to a customer through the platform, the provider is an independent controller of the data it needs for that supply (booking, order, clinical, educational or professional records), and the Operator is a controller of the platform-level record of the transaction. Each party complies with its own obligations; neither acts for the other.
3. Processor services. Where the Operator processes personal data on behalf of a business customer under the customer's instructions (for example an enterprise tenant's employee data), the Data Processing Agreement (DAT-01) applies and governs; it is signed as part of the order.
4. Sharing between SET platforms. Personal data is not shared with any other platform operated by the Operator or its group unless you enable the specific destination in your settings. Enabling one destination does not enable others, and you may disable it at any time.
5. International transfers. Personal data is stored in the European Economic Area (or, for wellbridge.uk, the United Kingdom). Where a processor outside those areas is used, the transfer is covered by Standard Contractual Clauses or the UK Addendum/IDTA, listed in the subprocessor annex.
6. AfterToMe-specific roles. The Operator is the controller of owner accounts, vault metadata, recipient designations, trigger-event evidence and release records. Content you place in your vault is processed only to store it, to verify its integrity, to release it under your instruction (LEG-01) and to operate the features you enable. A recipient who receives released content becomes an independent controller of what they receive.
3. What we process, why, and on what legal basis
| Data class | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Account data (name, email, password hash, locale, plan) | Create and operate your account; authenticate you | Art. 6(1)(b) contract | Life of account + 90 days (C16.1) |
| Identity-verification data of the owner and of recipients claiming a release | Verify capacity to create instructions; verify a recipient's identity and the trigger event before release | Art. 6(1)(b) contract; Art. 6(1)(c) where a legal duty applies; Art. 6(1)(f) fraud prevention | Until release is completed or refused, then 5 years as acceptance/release evidence |
| Vault content (documents, messages, media, recordings) and instructions | Store, integrity-check and release under your instruction | Art. 6(1)(b) contract | Life of the plan; released content for the period stated in your plan (C21.4); deleted within 90 days after closure |
| Recipient contact details you enter | Notify recipients at release; verify their identity at claim | Art. 6(1)(f) legitimate interest of the owner and the recipient in the release working; recipients are informed at first contact | Life of the instruction; deleted with it |
| EchoSoul inputs and outputs (text, voice, transcripts) | Operate the AI simulation you configured; label it as AI | Art. 6(1)(b) contract; separate permission for voice/likeness (ACC-02) | Deleted no later than 12 months after last interaction unless linked to an active plan (C16.2) |
| Trigger-event evidence (inactivity signals, death certificate, recipient declarations) | Human verification of the trigger event (C21.2) | Art. 6(1)(b) contract; Art. 6(1)(f) prevention of wrongful release; Art. 9(2)(f) where a claim is contested | Until the release decision is final, then 5 years as evidence |
| Payment and invoicing data | Charge the plan; issue invoices; handle refunds | Art. 6(1)(b) contract; Art. 6(1)(c) tax law | 6 years (tax and accounting) |
| Acceptance and consent records | Prove which version you accepted and which purposes you granted | Art. 6(1)(c) and 6(1)(f) evidence of compliance | 5 years after the end of the relationship |
| Security and audit logs, hashed IP and user-agent | Security, abuse prevention, incident response | Art. 6(1)(f) | 12 months |
| Support correspondence | Answer your requests and complaints | Art. 6(1)(b) and 6(1)(f) | 12 months after the case closes |
| Optional analytics | Measure use of the website | Art. 6(1)(a) consent via the cookie banner (purpose analytics_optional) | Per the Cookies Notice (PUB-03) |
| Marketing email | Send product news | Art. 6(1)(a) consent (purpose marketing_email), separate unticked control | Until withdrawn |
Mandatory fields are marked on each form. Accepting the terms is not consent to optional processing; each optional purpose has its own control and its own withdrawal route in your account settings.
4. Special categories and automated decisions
1. The service does not request health, biometric or other special-category data. If you place such data in your vault, it is stored as your content and is not used for any other purpose. Trigger-event evidence that reveals a death is processed under Art. 9(2)(f) only where a release is contested, and otherwise as evidence of the trigger event under Art. 6(1)(b) and 6(1)(f).
2. No decision with legal or similarly significant effect on you is taken solely by automated means. Inactivity and other signals are inputs to a human verification step; release is decided by a person (C21.2).
3. The EchoSoul feature produces AI-generated content and is labelled as such at every interaction (C07).
5. Recipients of data
1. Processors acting under the Operator's instructions: hosting and storage, authentication, transactional email, the payment service provider identified at checkout, and the AI model provider used for EchoSoul. Each processor, its function, location and transfer instrument is listed in the International Transfer Schedule (DAT-02).
2. Recipients you designate receive only the content you assigned to them, and only after release.
3. Public authorities and courts, where the law requires disclosure or a court order is served.
4. No data is sold. No data is shared with another SET platform unless you enable that destination (C13.4).
6. International transfers
Data is stored in the European Economic Area. Where a processor outside the EEA is used, the transfer is covered by the instrument listed in DAT-02 (Standard Contractual Clauses of Decision (EU) 2021/914 or an adequacy decision). You may obtain a copy of the safeguards from legal@aftertome.com.
7. Retention
1. Account data is kept for the life of the account and deleted or anonymised within 90 days after closure, except where a longer period is required by law (tax and accounting records: 6 years; acceptance and consent records: 5 years after the end of the relationship, as evidence of compliance; records subject to a legal hold: until the hold ends).
2. Conversation logs, recordings and uploads not linked to an active contract are deleted no later than 12 months after the last interaction, and earlier on your request, unless a legal hold applies.
3. Backups are rotated on a cycle not exceeding 35 days; data deleted from production is removed from backups at the end of the cycle.
4. Where a provider is an independent controller, its own retention rules apply to its records.
5. Legacy-specific retention. Released content is kept available to recipients for the period stated in your plan and then deleted (C21.4). Where the trigger event is verified, the owner's account is placed in released state and account data is deleted 90 days after the release period ends.
8. Your rights
1. You may request access, rectification, erasure, restriction, portability and object to processing based on legitimate interest, and withdraw any consent at any time with future effect, through /legal/privacy-rights or legal@aftertome.com. The Operator answers within one month, extendable by two further months for complex requests with notice of the reason.
2. The Operator verifies identity proportionately and does not require an identity document unless the request concerns vault content or a release.
3. Erasure of vault content takes effect at your request while you have capacity; a legal hold or court order notified to the Operator suspends deletion for its duration and you are informed (C21.4).
4. You may lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es) or the supervisory authority of your residence.
9. Security
The Operator applies the technical and organisational measures listed in DAT-03 §4: tenant isolation, encryption in transit and at rest, least-privilege and multi-factor access for staff, audited privileged actions, tested backups and an incident procedure with notification to the AEPD within 72 hours where required.
10. Children
The service is for persons aged 18 or over. The Operator deletes an account created by a person under 18 on becoming aware of it.
11. Changes to this notice
1. The Operator may amend these terms for legitimate reasons: changes in law, in the service, in security or fraud prevention, in the payment provider, or to clarify wording. The Operator notifies you of material changes by email and in-product at least 30 days before they take effect (immediately where required by law or security).
2. If you do not accept a material change, you may terminate before it takes effect and receive a pro-rata refund of any prepaid period affected. Continued use after the effective date is acceptance; for major changes the service asks you to confirm acceptance at your next sign-in.
3. Every version is archived with its date and content hash at /legal/privacy/v/.