Privacy Policy

Our privacy promise, in plain words

WillWolf is an Indian digital estate-planning vault. You create a will, store your estate in an encrypted vault, and name the people who matter to your plan: beneficiaries, executors, guardians and witnesses.

The most sensitive parts of your plan (your asset details, your will text, your home address, and the identities of your executor, guardian and witnesses) are encrypted inside your own browser. We have no technical means to read them. We call this your Tier-3 content.

To run the service and to follow Indian law, some information is readable by us: your contact details, your Aadhaar and KYC identity data, your beneficiaries' identity, and the documents, photos and signatures you upload. We are honest about this throughout the policy, rather than promising more privacy than we can actually deliver.

We never sell your data and we never use it for advertising. If something is wrong, you can write to us at support@willwolf.in or raise a formal complaint with our Grievance Officer.

Who we are

The data fiduciary responsible for your personal data is White Wolf Technologies Private Limited, Shop No. 47, Ground Floor, Royal Residency, Sector-79, World Street, Faridabad - 121006, Haryana, India. Under India's Digital Personal Data Protection Act 2023, this is the entity that decides how and why your personal data is processed, and that is accountable to you for it.

For any question about your data or this policy, write to support@willwolf.in.

If you want to make a formal complaint, our Grievance Officer is there for exactly that. You will find their name and contact details in the Grievance Officer section further down this policy.

The information we hold, and how it is protected

Everything we hold sits in one of three tiers. The tier decides how strongly the data is protected and, crucially, who can read it. This is the honest map of what we can and cannot see.

• Tier 1 Operational, plain form · Data we need in the clear so the service can run. · Your name and country · your estate structure (how many assets sit in each category, and coarse non-content labels such as a value band, but never the detailed contents) · your activity and audit log (sign-in events, a hashed record of your IP address, coarse location, device information) · the plain-text file names of documents · the uploaded files themselves (documents, photos and signature images) held on our cloud storage. · WillWolf servers and staff, as needed to operate the service.
• Tier 2 Server-readable under our key · Personal and identity data, encrypted at rest under a single application key that our servers hold. · Your email and phone number · your full Aadhaar number, KYC demographics (name, date of birth, gender, address) and face photo received from UIDAI · each beneficiary's display name, email, full Aadhaar number, and a snapshot of their UIDAI details captured at claim time · your recovery-sentence hint, if you chose to set one. · You, and WillWolf when it is operationally needed. We can decrypt this data.
• Tier 3 Encrypted in your browser · Your most sensitive estate content, encrypted inside your own browser under your Vault Master Key. · Your asset details (values, descriptions, account numbers and so on) · your will text · your home address · your executor, guardian and witness identities · the beneficiary private-detail blob · your per-asset messages and notes. · Only you. We have no technical means to decrypt it.

The uploaded files themselves (documents, photos and signature images) are stored with our cloud storage provider and reached by our servers through signed links. They are operational data, not Tier-3 content, so they are not covered by the "only you can read it" guarantee.

What 'only you can read it' really means

When we say only you can read it, we mean something specific and technical. Your Tier-3 content is encrypted inside your browser under a key derived from your own credentials, and our servers never hold that key in usable form. Because of this, we have no technical means to decrypt your Tier-3 content: not our staff, not on request, not by mistake.

This promise covers Tier-3 content only. The following data is server-readable, because the service and the law need it to be:

• Your contact details, meaning your email and phone number.
• Your Aadhaar and KYC identity data, and your beneficiaries' identity captured at claim time.
• Your recovery-sentence hint, if you chose to set one.
• The documents, photos and signatures you upload, which live on our cloud storage and are reachable by our servers.

We hold the personal data above under a single application key that our servers keep, which means we can decrypt it when it is operationally needed. Being clear about this is the whole point: the strong promise is real, and it is scoped precisely to your Tier-3 content.

Your Vault Master Key is wrapped under both your login password and your chosen recovery sentence. If you lose both your password and your recovery sentence, your Tier-3 content is permanently unrecoverable. We have no backdoor and we cannot reset it for you. By the same design, anyone who holds either your password or your recovery sentence can read your vault, so please guard them both carefully.

Identity verification with Aadhaar

Verifying your identity with Aadhaar is entirely voluntary and you can skip it. If you choose to verify, we perform an Aadhaar e-KYC with your explicit consent through a licensed Aadhaar e-KYC provider, which connects to UIDAI under UIDAI's authentication regulations. You can use WillWolf without ever completing this step, and doing so does not make a will legally valid.

When you complete e-KYC, we receive from UIDAI your full Aadhaar number along with your name, date of birth, gender, address and face photo. If you are named as a beneficiary and later verify at claim time, the same details are captured then.

We store this information in our server-readable tier: it is encrypted at rest under a single application key that our servers hold, which means WillWolf can decrypt it when operationally needed, and you can reveal it to yourself from your account at any time. We want to be plain about this: we currently store your full Aadhaar number, not a masked or truncated version.

Under Indian law, Aadhaar and other government identifiers, biometrics and financial information are treated as sensitive personal data (IT Act SPDI Rules 2011). We handle these categories with corresponding care and only for identity verification.

If you use WillWolf as a beneficiary to make a claim, the same applies to you: we verify your identity with an Aadhaar one-time code and store a snapshot of your Aadhaar details for that claim, held in the same server-readable way. You are a data principal in your own right and have the same rights over your data set out in this policy.

Companies that help us run WillWolf

We rely on a few carefully chosen service providers (sub-processors) to run WillWolf. Each one receives only the specific data it needs to do its job, and nothing more.

• A licensed Aadhaar e-KYC provider (connecting to UIDAI) · Aadhaar e-KYC identity verification, only if you choose it · Your Aadhaar number and the KYC details returned by UIDAI
• An automated document-checking service · Reads a death certificate and checks it against the owner's saved details, for a WillWolf administrator to review during a beneficiary claim · The death-certificate document, plus the deceased owner's saved profile details, so the certificate can be matched to the owner
• An SMS provider · Sends SMS one-time codes · Your phone number
• Email provider · Sends transactional email and one-time codes · Your email address
• A cloud storage provider · Stores your uploaded documents, photos and signature images · The files you upload
• Cloud hosting · Runs our servers and databases · The data described across this policy

We do not sell, rent or trade your data to anyone, and we do not use it for advertising.

How long we keep your information

We keep your information only for as long as we need it. How long that is depends on the type of data:

• Account basics are kept while your account is active.
• When you delete your account, deletion is scheduled with a recovery window: your account deactivates immediately and is then permanently deleted after a set period. If you sign back in before that period ends, the deletion is cancelled and your account is restored.
• KYC Aadhaar and demographics remain stored and decryptable for as long as your account exists, so that you can reveal them to yourself. They are not deleted the instant you close the account.
• After the account is permanently purged, we retain an immutable compliance record that the deletion took place, for legal and fraud-prevention reasons.
• Retention through death: data a beneficiary may need to inherit, such as the will and the vault, is not silently deleted, so that inheritance can still function after you are gone.

Your rights over your data

Under the Digital Personal Data Protection Act 2023, the personal data you give us is yours to control. You have the right to:

• Access a copy of the personal data we hold about you.
• Correct or update data that is wrong, incomplete or out of date.
• Erase your data and close your account.
• Withdraw a consent you gave earlier, for example your consent to Aadhaar e-KYC or to marketing messages. Withdrawing is as easy as giving consent, and it does not affect anything we did lawfully before you withdrew.

To make any of these requests, email support@willwolf.in. We will respond within the timeframe the law allows. We may need to confirm your identity first, so that nobody else can act on your account.

Some data cannot be erased on request where the law requires us to keep it, for example the immutable record we retain after a deletion. The section on how long we keep your information, above, explains what stays and why.

Naming someone to act on your data (the right to nominate)

The Digital Personal Data Protection Act 2023 gives you the right to nominate another individual who can exercise your data rights on your behalf if you die or become incapacitated. This person is your data-nominee.

It is important to understand what this does and does not mean. A data-nominee is only about who can act on your data: they can make the access, correction or erasure requests that you could have made. Nominating a data-nominee is not a decision about who legally inherits your estate.

Your will and its beneficiaries and executor are what govern legal title to your assets. The data-nominee is a data-access matter only. The two roles are different, and naming one does not change the other.

If you wish to name a data-nominee, contact us at support@willwolf.in.

When the law requires us to disclose data

We disclose personal data to authorities only when we are legally compelled to by a valid legal request under Indian law, such as a court order or a lawful demand from a competent authority. We do not sell your data and we do not share it for anyone else's marketing.

What we can produce is limited by what we technically hold. We can provide the operational and server-readable data described in this policy, for example account basics, activity logs, and the Tier-2 data our servers can decrypt. We have no technical means to hand over your decrypted Tier-3 content: the will text, asset details, your home address and the other client-side items are encrypted under a key derived from your credentials that we never hold in usable form.

Where we are allowed to, we will notify you of a request affecting your data before we respond, so that you can seek your own legal advice. We will stay silent only where the law forbids us from telling you. We review each request and push back on any that is overbroad or improper.

Keeping your data secure, and telling you if something goes wrong

We use a layered set of safeguards to protect your data:

• Encryption in transit: all traffic between your device and our servers is protected with TLS.
• Encryption at rest: your sensitive identity and contact data is encrypted at rest under our application key.
• Client-side encryption for your most sensitive content: your Tier-3 content is encrypted inside your own browser before it reaches us, so we have no technical means to read it.
• Access controls that limit which staff can reach systems and data, and only for a genuine operational need.

No system can be promised to be perfectly secure. If a breach ever affects your personal data, we will notify the affected users and the Data Protection Board of India as the law requires, and tell you what happened and what you can do.

Children

WillWolf is a service for adults aged eighteen and over who are making an estate plan. It is not directed at children, and we do not knowingly collect personal data from anyone under eighteen.

If you believe a child has provided us with personal data, please contact us at support@willwolf.in and we will take steps to remove it.

Cookies and local storage

We keep our use of cookies and browser storage deliberately small. To keep you signed in, the app stores a session token inside your own browser rather than relying on a tracking cookie.

While your vault is unlocked, the app holds your Vault Master Key only in your own browser. It stays on your device and is never sent to or stored on our servers, and it is cleared when the session ends.

We do not use advertising cookies and we do not track you across other websites.

Contact and grievances

For everyday questions about your data, email support@willwolf.in. You can also call us on +91 95402 44666, Monday to Saturday, 10 AM to 7 PM IST.

If you wish to raise a formal complaint, you can contact our Grievance Officer, who is resident in India:

• Grievance Officer: [Grievance Officer name]
• Email: [grievance email]

We will acknowledge your complaint within 48 hours and aim to resolve it within about one month. If you are not satisfied with how we handle it, you may escalate the matter to the Data Protection Board of India.