Privacy Policy

Your Privacy Matters

Proof of Life Inc. ("we," "our," or "us") operates the Polinc platform, including the web application, mobile applications (iOS and Android), browser extensions, and this website (collectively, the "Services"). We are committed to protecting your personal information and your privacy. This Privacy Policy explains how we collect, use, store, and safeguard your information when you use our Services.

Information We Collect

We separate your information into distinct categories based on its nature and how it is processed:

A. Account Information

Data required to operate the service and verify your identity:

Identity Data: Name, email address, phone number (used for Check-In verification and account recovery).
Nominee Data: Contact details of the individuals you designate as nominees or beneficiaries.
Billing Data: Subscription status, plan type, and payment records. Payment card details are processed by our payment provider and are never stored on our servers.

B. Vault Data (Double Encrypted at Rest)

Vault Data refers to any digital assets, credentials, documents, or notes you store in the platform. This includes passwords, financial records, property documents, investment details, cryptocurrency keys, and any other items stored in your Asset Groups or Vaults. All Vault Data is double encrypted at rest: once at the application level and again by Microsoft Azure infrastructure encryption. Because of this double encryption, we cannot decrypt or access the contents of your vault, even if compelled by law enforcement or court order.

C. Financial and Household Data

When you use the Money Hub features (expense tracking, bill calendar, Smart Import), we process:

Transaction details extracted from uploaded documents (account numbers, balances, due dates, payee names).
Recurring expense categories, subscription details, and bill schedules you create or that are detected by Smart Import.

Smart Import uses automated processing to extract structured data from documents you upload (such as bank statements, invoices, and spreadsheets). During upload, the system reads and parses document content to identify and organize financial information. Once processed, this data is stored with the same double encryption applied to all Vault Data. See the "Automated Processing and AI" section below for more details.

D. Technical and Usage Data

To ensure the security of your account and prevent unauthorized access, we automatically collect:

Device Identifiers: Unique IDs stored in your browser to recognize known devices.
Log Data: IP addresses, browser type, operating system, and access timestamps.
Security Events: Login attempts, device changes, and session activity used to detect unauthorized access and alert you via email.

E. Cookies and Analytics

We use the following tracking technologies:

Google Analytics 4 (GA4): To understand how visitors use our website, including page views, session duration, and traffic sources. GA4 does not store personal identifiers.
Essential Cookies: Session cookies required for authentication and security. These cannot be disabled.
Local Storage: Used to store preferences such as your detected country for localized content. No personal data is stored in local storage.

We do not use advertising cookies or tracking pixels. We do not participate in cross-site tracking or retargeting networks.

How We Use Your Information

We use your information for the following purposes:

To provide, maintain, and improve the Polinc platform and its features.
To process and manage your subscription and billing.
To send transactional messages: account updates, Check-In verifications, security alerts, and billing notifications.
To detect, prevent, and respond to security threats, fraud, and unauthorized access.
To comply with legal obligations and respond to lawful requests from public authorities.
To analyze aggregate, anonymized usage data to improve our services.

Legal Basis for Processing (EEA, UK, and India)

If you are located in the European Economic Area (EEA), United Kingdom, or India, we process your personal data under the following legal bases:

Contract Performance: Processing necessary to deliver the services you subscribed to (account management, vault storage, Check-In protocol, nominee management).
Legitimate Interest: Processing necessary for security monitoring, fraud prevention, and service improvement, where our interest does not override your fundamental rights.
Consent: Where you have given explicit consent, such as opting in to marketing communications. You may withdraw consent at any time.
Legal Obligation: Processing required to comply with applicable laws and regulations.

Automated Processing and AI

Polinc uses automated processing in the following features:

Smart Import: When you upload documents (PDFs, images, CSV, or Excel files), our system automatically extracts structured data such as account numbers, balances, due dates, and payee names. This processing occurs during upload to organize your financial information.
Password Strength Analysis: Automated evaluation of stored credentials against known security standards.
Bill Detection: Automated identification of recurring charges and due dates from imported financial data.

No automated processing is used to make decisions that produce legal effects or similarly significant effects on you. You have the right to request human review of any automated processing result. Contact support@polinc.com to exercise this right.

Sharing Your Information

We do not sell your personal information. We do not share your data with third parties for marketing purposes. We share data only under the following specific conditions:

To Your Nominees and Shared Users: You explicitly authorize access to specific data for users you invite to Asset Groups, or for designated nominees following a completed verification protocol after a confirmed life event.
Service Providers: We use Microsoft Azure for cloud infrastructure and hosting. Azure processes data under strict contractual obligations and does not access your data for its own purposes. Payment processing is handled by our payment provider, which receives only the billing data necessary to process your subscription.
Compliance with Law: We may be required to disclose account metadata (name, email, subscription status) if compelled by a valid court order or subpoena. However, because Vault Data is double encrypted (application-level encryption and Azure infrastructure encryption), we are unable to provide law enforcement or any third party with the decrypted contents of your vault.

Cross-Border Data Transfers

Proof of Life Inc. is based in Austin, Texas, United States. Your data is hosted on Microsoft Azure infrastructure located in the United States.

If you access our Services from outside the United States, including the European Economic Area, United Kingdom, India, Canada, Australia, or any other jurisdiction, your personal data will be transferred to and processed in the United States.

We protect cross-border transfers through the following safeguards:

EU/EEA and UK: Transfers are governed by Standard Contractual Clauses (SCCs) as approved by the European Commission, incorporated into our data processing agreements with Microsoft Azure.
India: Transfers comply with Section 16 of the Digital Personal Data Protection Act, 2023 (DPDP). Data is transferred only to jurisdictions permitted by the Central Government or under contractual safeguards.
All Regions: All data is encrypted at rest and in transit with AES-256 encryption, providing an additional layer of protection regardless of where the data is processed.

Data Retention

We retain your data for as long as your account is active or as needed to provide you with the Services. Specific retention periods:

Account Data: Retained while your account is active. Upon account deletion, all personal data is permanently removed within 30 days.
Vault Data: Deleted immediately upon account deletion. Because of double encryption, no readable copy remains in our systems.
Billing Records: Retained for up to 7 years after account closure to comply with tax and financial reporting obligations.
Security Logs: Retained for up to 12 months for fraud prevention and security monitoring, then automatically purged.
Analytics Data: Aggregated and anonymized. Individual session data is retained by Google Analytics for up to 14 months per Google default settings.

Your Privacy Rights

Depending on your location, you have the following rights regarding your personal data:

All Users

Access your personal information and request a copy of the data we hold about you.
Correct inaccuracies in your personal information.
Request deletion of your account and all associated personal data.
Export your data using the Data Takeout feature in your account settings.
Opt out of marketing communications at any time.

EEA, UK, and Swiss Users (GDPR / UK GDPR)

Right to data portability: receive your data in a structured, machine-readable format.
Right to restrict processing of your personal data.
Right to object to processing based on legitimate interest.
Right to withdraw consent at any time where processing is based on consent.
Right to request human review of automated processing decisions.
Right to lodge a complaint with your local supervisory authority.

California Residents (CCPA / CPRA)

Right to know what personal information is collected, used, and disclosed.
Right to delete personal information held by us.
Right to non-discrimination for exercising your privacy rights.
We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

Indian Users (DPDP Act)

Right to access and correct your personal data.
Right to erasure of personal data that is no longer necessary.
Right to nominate another individual to exercise your data rights.
Right to grievance redressal. Contact support@polinc.com for any data-related concerns.

To exercise any of these rights, contact us at support@polinc.com. We will respond within 30 days (or within the timeframe required by your local law).

Marketing Communications

We distinguish between two types of communications:

Transactional Messages: Account updates, Check-In verifications, security alerts, billing notifications, and nominee activity. These are essential to the service and cannot be opted out of while your account is active.
Promotional Messages: Product updates, feature announcements, tips, and offers. You will only receive these if you opt in. You can unsubscribe at any time using the link in any promotional email or through your Notification Preferences in the app.

We will never send marketing messages without your prior consent. Unsubscribing from promotional messages does not affect transactional messages.

Children's Privacy

Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at support@polinc.com.

Data Security

We implement multiple layers of security to protect your data:

Double Encryption: All Vault Data is encrypted at the application level and again by Microsoft Azure infrastructure encryption (AES-256).
Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher.
Zero Trust Architecture: Every request is authenticated and authorized. No implicit trust is granted to any user, device, or internal system.
Data Segmentation: Different categories of data are stored in separate databases to limit the impact of any potential breach.
Infrastructure: Hosted on Microsoft Azure with SOC 2 Type II, ISO 27001, and HIPAA certifications. 24/7 monitoring, DDoS protection, and multi-region redundancy.

Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will notify you by email or through a notice on our website at least 30 days before the changes take effect. The "Last Updated" date at the top of this page indicates when this policy was last revised.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data, please contact us:

Email: support@polinc.com
Company: Proof of Life Inc.
Address: 5900 Balcones Drive, Austin, TX 78731, United States

For data protection inquiries from the EEA or UK, you may also contact your local supervisory authority.

For data protection inquiries from India, you may contact the Data Protection Board of India.