Legal documents

Privacy Policy

Version: draft — aligned with GDPR and Dutch law. To be reviewed by legal counsel before final publication.

1. Who is Custodi?

Custodi Life B.V. (hereinafter: Custodi) is the controller for personal data processing as described in this privacy policy. Custodi operates a platform for recording and (optionally) executing wishes regarding digital estates. Custodi acts in accordance with the General Data Protection Regulation (GDPR).

2. What personal data do we process?

Custodi processes only personal data necessary for the delivery of its services. This includes: name, email address and contact details; account overview (names of platforms/services); recorded wishes per account; contact person details; and support communications. Custodi does not store passwords and does not log into user accounts.

3. Purposes and legal bases

Custodi processes personal data for the following purposes:

  • Contract performance (Art. 6(1)(b) GDPR)
  • Compliance with legal obligations (Art. 6(1)(c) GDPR)
  • Legitimate interests, including security and fraud prevention (Art. 6(1)(f) GDPR)
  • User consent, where required (Art. 6(1)(a) GDPR)

4. Processing after death

After death, Custodi processes personal data solely on the basis of pre-recorded wishes of the user and after verification of the death. Custodi does not share personal data with third parties outside agreed procedures. Data of deceased persons is handled with heightened care, even though the GDPR formally does not apply to deceased individuals.

5. Sharing personal data

Custodi shares personal data only with:

  • Third-party platforms where necessary to execute recorded wishes
  • Professional partners (e.g. notaries or funeral directors), where agreed
  • Processors supporting Custodi (hosting, security)

6. Retention periods

Custodi retains personal data no longer than necessary:

  • Account data: for the duration of the agreement
  • Dossier data after death: maximum 24 months after completion
  • Legal data: in accordance with statutory retention obligations

7. Security

Custodi implements appropriate technical and organisational measures, including:

  • Encryption of data
  • Restricted access rights (role-based access)
  • Logging and audit trails
  • Regular security updates

8. Rights of data subjects

Users and data subjects have the right to: access, rectification, erasure, restriction of processing, data portability, and objection. Requests can be submitted via sognosalentinohome@gmail.com.

9. Complaints

If you have complaints about the processing of personal data, you may contact Custodi or lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

10. Changes

Custodi may amend this privacy policy. The most current version is always available via the platform.

Terms & Conditions

Read the full terms of our service.

Terms & Conditions