01Data controller
Enrique Moron Campos, domiciled at Can Sagales s/n, 08130 Santa Perpètua de Mogoda, Barcelona, Spain. Contact: soporte@aakdeveloper.com. “AAK Developer” is the trade name under which the service is provided; no company is currently incorporated under that name. The full tax identifier appears in the Legal Notice.
02What data we process, and where it comes from
From you, as the account holder: your account identifier, your Sign in with Apple link, and operational metadata (activity, your Legacy's status) — received directly from you as you use the app. From your guardians and recipients: the contact and, where applicable, verification data you provide us when designating them — we do not collect this directly from them. Your Legacy's private content is protected by a Zero-Knowledge architecture: it is encrypted on your device before it ever leaves it, and AAK cannot access your documents, memories, or instructions. Your guardians' and recipients' contact data is encrypted separately, using an operational key that AAK does control, used exclusively to manage your designations, exercise rights, and carry out the intended communications — with restricted, audited access.
03Purposes and legal bases
We process your own account data to operate your Legacy and provide the service, on the basis of performance of the contract for use (GDPR art. 6.1.b). When you designate guardians or recipients, we process the data you give us about them to manage that designation and, when the time comes, delivery, on the basis of the legitimate interest of the controller and of you as the account holder in that process working (GDPR art. 6.1.f) — a basis backed by a legitimate-interest assessment we keep on file internally. Identity verification, where it applies, is carried out so those same instructions can be executed securely. We do not base any processing on a contract with the guardian or recipient, on their consent, or on a legal obligation.
04Information for guardians and recipients (GDPR art. 14)
If you are a guardian or recipient designated by an account holder, we do not receive your data directly from you, but from them. We process it solely to manage your role in their Legacy — confirming your acceptance, coordinating you during activation, or delivering the content assigned to you — on the legitimate-interest basis described above. If the account holder chooses to inform you immediately as a recipient, you receive this full information in your first communication. If the account holder chooses to keep your designation private until delivery, your contact data is processed from that same moment, but you will not receive a direct communication until the content is delivered — which may happen much later. In the meantime, you can exercise your rights of access, correction, deletion, restriction, portability, and, in particular, objection to this processing (GDPR art. 21) at any time, without needing to have been formally invited, by writing to soporte@aakdeveloper.com. If you object or request erasure, we physically delete your encrypted name, email, and phone number; we only keep a non-reversible identifier (HMAC) of your email or phone, solely to prevent you from being added again in the future without your consent.
05Special categories of data
Your Legacy's content may include special categories of data depending on what you choose to store. It is encrypted on your device: AAK Legacy cannot read or classify it, and the responsibility for what you store is yours as the account holder.
06Whether data is required or optional
Your account data (identifier, Sign in with Apple link) is required: you cannot use AAK Legacy without it. Designating guardians or recipients, and giving us their contact details, is optional — without it your Legacy cannot be activated or delivered automatically, but you can still use the app to organize content.
07Automated decisions and profiling
AAK Legacy does not make automated decisions with legal effects on you, and it does not build profiles from your data.
08Providers and possible international transfers
Apple (Sign in with Apple; CloudKit for encrypted content): under its global Privacy Policy, personal data of individuals in the EEA, UK, and Switzerland is controlled by Apple Distribution International Limited (Ireland), with transfers covered by Standard Contractual Clauses. Cloudflare (Workers and D1, infrastructure and operational metadata): states it uses Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework; its public sub-processor list is at cloudflare.com/gdpr/subprocessors. Stripe Identity (identity verification, only when applicable): to complete verification it may rely on specialised providers outside the EEA — its public list includes entities in Canada, the United States, the United Kingdom, and Australia — also under Standard Contractual Clauses and, where applicable, the Data Privacy Framework. Resend (transactional email only; no SMS are sent): likewise under Standard Contractual Clauses and the Data Privacy Framework; public list at resend.com/legal/subprocessors.
09Location of operational data and jurisdiction
Cloudflare D1 currently reports running_in_region: WEUR (Western Europe), and the jurisdiction parameter reads null — checked directly against the real production configuration. Per Cloudflare's official documentation, WEUR is a run-location preference, not a legal guarantee of residency. Without jurisdiction: eu, storage and execution exclusively within the European Union cannot be guaranteed. Transfers and applicable safeguards are detailed provider by provider above.
10Retention and deletion
Your data remains for as long as your account exists. Deleting it makes the backend erase your account immediately, cascading across virtually all associated data (see Delete account for the full breakdown by system). After deleting your account, a minimal, pseudonymized record of decisions already executed about death-certificate submissions is kept for up to five years, exclusively for the establishment, exercise, or defence of possible claims. It does not contain the certificate or its content. Once the period expires it is deleted automatically, unless an active claim requires its limited retention until the procedure concludes.
11Your rights
Access, correction, deletion, objection, restriction, and portability: write to soporte@aakdeveloper.com. Deleting your account from within the app (see Delete account) is the most direct way to exercise deletion over your own data. If you believe we have not handled your request properly, you can file a complaint with the Spanish Data Protection Agency (aepd.es).
12Scope
This service is offered from Spain. Anything not covered by this page is governed by applicable Spanish and European data protection law.
13Last updated
This page was last updated on 23 September 2026.