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Passings
Privacy & Data Protection

Your privacy is part of
how we care for you

We handle some of the most sensitive information a person can share — about a life lived, and a death prepared for. Here is exactly what we collect, why we collect it, and how we protect it.

Effective date

July 24, 2026

Version 1.1

Replaces all prior versions

Your data is encrypted at rest and in transit
We don’t sell your data for marketing
You can request deletion of your data at any time
CCPA-aligned user rights

What we collect

Account details, planning information, health context, billing data, and provider interactions — used only to power your plan.

How we protect it

AES-256 encryption at rest, TLS in transit, strict access controls, and regular third-party security audits.

Your control

Access, correct, export, or delete your data at any time. We honor all requests within 30 days, no questions asked.

01

Overview

Who we are and what this policy covers

Passings, Inc. (“Passings,” “we,” “us,” or “our”) operates the Passings funeral planning platform available at passings.io and through our mobile application. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our services.

We take privacy seriously — especially given the nature of the information you trust us with. End-of-life planning involves details that are deeply personal: wishes for your own passing, information about a loved one who has died, health context, and financial decisions. We have designed this platform and this policy with that sensitivity in mind.

By using Passings, you agree to the practices described in this policy. If you have questions at any time, please reach out to [email protected].

Plain-language summary: We collect what we need to help you plan. We protect it with care. We don’t sell it for marketing purposes. You can ask us to delete it at any time.

02

Information We Collect

A complete breakdown of data collected by category

We collect information you provide directly, information generated by your use of our platform, and certain technical information automatically collected by our systems.

CategoryExamplesWhen collected
Account informationFull name, email address, phone number, password (hashed)Account registration
Planning dataFuneral preferences, service type, obituary content, family contacts, wishes for remainsAs you build your plan
Deceased person's detailsFull name, date of birth, date of death, relationship to user, life history for obituaryWhen planning for a loved one
Health & medical contextMedical conditions relevant to final arrangements, advance directive preferences, organ donation wishesWhen you choose to share it
Payment & billingPayment method type, last 4 digits, billing address, transaction records (full card numbers never stored)At subscription or purchase
Location dataCity/state for provider matching, approximate location for local service recommendationsWhen using provider search
Provider interactionsInquiry details, messages sent to funeral homes, quotes receivedWhen you contact providers
Legacy locker notification dataRecipient name, plan principal's name, number of messages, locker unlock date, access expiry date, unique access link, opt-out linkWhen a plan author unlocks their legacy locker to notify designated recipients
Usage & technical dataPages visited, features used, session duration, browser type, IP address, device identifiersAutomatically, during use

Age verification:When you create an account we ask your date of birth solely to confirm you are 18 or older. We use it only for that check and do not store it. A date of birth you enter as part of a plan principal's details (above) is separate and is kept for your plan.

03

Sensitive Data

How we handle data that requires extra care

Some information you share with Passings is particularly sensitive. This includes health and medical information, details about deceased individuals, and financial data. We apply additional protections to these categories above and beyond our standard practices.

You are always in control of sensitive data. You may choose what sensitive details to include in your plan. None of this information is required to use the platform. If you choose to include it, it is encrypted, access-restricted, and never used for advertising or shared with third parties without your explicit consent.

Health & medical information

We collect health information only when you voluntarily share it in the context of planning. This may include conditions relevant to end-of-life care preferences, advance directive details, organ donation wishes, or hospice considerations. This information is used solely to support your plan and is never shared with health insurers, employers, or advertising networks.

Information about deceased individuals

When you use Passings to help plan arrangements for a loved one who has passed, you may provide personal details about that individual. This information is treated with the same privacy protections as your own personal data, and is used exclusively to generate planning documents, obituaries, and service coordination.

Operator transitions after death

Plans on Passings may have multiple people authorized to operate them: the plan author and any collaborators the author has designated as co-authors. While the plan author is alive, all operators have equal operational authority. When a co-author reports the plan author's death and submits supporting evidence (such as a death certificate or court document), our team reviews and verifies the report. Once verified, the plan moves into post-death mode: the original author's account loses operational authority on this plan, and the operator set narrows to the co-authors. One co-author is designated by our team as the Personal Representative — the single role authorized to make fiduciary decisions about the plan, including removing other co-authors. Co-authors continue to operate the plan day-to-day. Designated legacy recipients are notified at this point and receive any materials the plan author prepared for them. If the original report is later determined to have been submitted in error, the verification is reverted and full operational authority is restored.

Financial information

We do not store full payment card numbers. Billing details are processed through our payment infrastructure and tokenized. We retain only a reference token, the last 4 digits of the card, and billing address for record purposes.

04

How We Use Your Data

Every purpose for which your information is processed

We use your information only for the purposes that are directly relevant to delivering and improving our services.

PurposeData usedLegal basis
Delivering the Passings platformAll data categoriesContract
Processing paymentsBilling & payment dataContract
Matching you with providersLocation, planning preferencesContract
Customer support & communicationsAccount info, your messagesContract
Improving our servicesAnonymized usage dataLegitimate interest
Security & fraud preventionTechnical & account dataLegitimate interest
Legal & regulatory complianceAs required by lawLegal obligation

We do not use your data for behavioral advertising, sale to data brokers, or training third-party AI systems. If this ever changes, we will notify you and obtain your consent before doing so.

05

Data Sharing

Who we share your data with, and under what circumstances

We do not sell, rent, or trade your personal information to any third party for their own commercial purposes. This is a firm commitment, not a policy footnote.

Limited sharing with service providers

To operate the platform, we work with carefully vetted third-party service providers — including cloud infrastructure (data hosting and storage), payment processing (billing and transaction security), and communications infrastructure (transactional emails and notifications). These providers access only the minimum data necessary to perform their function, and are bound by contractual data processing agreements that prohibit secondary use of your information.

Funeral home and provider partners

When you contact a funeral home or provider through Passings, we share the inquiry details you compose with that provider. You control what is included in any such inquiry. We do not share your full plan or health information with providers unless you explicitly choose to do so.

Legal requirements

We may disclose your information if required by law, court order, or in response to a valid request from law enforcement. We will notify you of such requests to the extent permitted by law.

Currently, no advertising data sharing exists. We do not share your data with advertising networks, social media platforms, data brokers, or marketing analytics companies. As Passings grows, if we add any such integrations, we will update this policy and notify users in advance.

06

Data Retention

How long we keep your information, and why

Data typeRetention periodRationale
Account & profile dataDuration of account + 30-day cooling-off period, then permanently deletedActive service delivery; 30-day window to cancel deletion request
Planning & arrangement dataDuration of account; indefinite if plan is designated as permanent recordCore service function; legal record of wishes
Billing & transaction records7 years after last transactionFinancial compliance and tax obligations
Health & medical informationDuration of account; permanently deleted at end of 30-day cooling-off periodSensitive data — minimized retention
Usage & analytics data12 months, then anonymizedService improvement; anonymized after threshold
Support communications3 years from last interactionQuality assurance and dispute resolution
Legacy locker recipient accessDuration specified by plan author (shown to recipient in notification)Access links expire on the date shown in the delivery email; no further data is retained after expiry
Death-report supporting evidence (death certificates, government IDs, court documents)7 years after the verification or revert decision, then permanently deletedRequired to verify the report and resolve any future disputes; opt-in upload by a co-author; access restricted to a small number of authorized staff under audit logging

You may request deletion of your account and all associated data at any time. After a 30-day cooling-off period during which you may cancel, your account and personal data are permanently deleted from our primary systems. Certain limited records are retained where the law requires or permits it — billing and tax records (up to 7 years), acceptance and consent records, security audit logs, and evidence that a requested deletion was actually performed — consistent with the exceptions recognized by applicable privacy laws, including CCPA §1798.105(d). Identifying information in these retained records is pseudonymized or removed wherever possible, and they are isolated from any active profile.

07

Security

The technical and organizational measures we use to protect your data

We implement security measures proportionate to the sensitivity of the data we hold. Given that we process health information and end-of-life planning details, we apply a high standard.

AES-256 Encryption

All data encrypted at rest using AES-256 standard

TLS in Transit

All data transmissions secured with TLS 1.3

Access Controls

Role-based access; no employee reads your data without cause

Continuous Monitoring

24/7 anomaly detection and security alerting

Regular Audits

Periodic third-party security audits and penetration testing

Breach Response

Documented incident response plan; user notification within 72 hours

Despite these measures, no system is completely secure. If you discover a vulnerability, please report it responsibly to [email protected].

08

Your Rights

What you can ask us to do with your information

You have meaningful control over your personal information. All rights below apply to all Passings users, regardless of location. California residents additionally have rights under the CCPA (see below).

Right to Access

Request a copy of all personal information we hold about you, in a portable format.

Right to Correct

Update or correct any inaccurate personal information. Most data is editable directly in your account.

Right to Delete

Request deletion of your account and personal data. A 30-day cooling-off period follows, after which your data is permanently deleted from our primary systems. Limited records are retained where the law requires or permits — see Data Retention above.

Right to Portability

Export your planning data in a structured, machine-readable format (JSON or PDF).

Right to Opt Out

Opt out of any non-essential data processing, including analytics and service communications.

CCPA Rights (California)

Know, delete, and opt out of the sale of personal information. We do not sell data, but honor all CCPA requests.

To exercise any of these rights, email [email protected] or use the data controls in your account settings. We will acknowledge your request within 5 business days and complete it within 30 days.

09

Cookies & Tracking

How we use cookies and what you can control

We use a minimal set of cookies — only those necessary to operate the platform and understand how it is being used at an aggregate level.

Cookie typePurposeCan be disabled?
Essential / FunctionalSession management, authentication, security tokens, preference storageNo — required for platform to function
AnalyticsAggregate usage patterns, performance monitoring, feature engagement (no individual tracking)Yes — via cookie settings
Preference cookiesRemember your display settings, language, and interface preferencesYes — clearing these resets preferences

We do not use third-party advertising cookies or tracking pixels. You can manage cookie preferences at any time via the Cookie Settings link in the footer, or through your browser's privacy settings.

10

Children's Privacy

Our platform is not intended for users under 18

Passings is designed for adults making end-of-life planning decisions. We do not knowingly collect personal information from individuals under the age of 18. If you are under 18, please do not use this platform or submit any information to us.

If we learn that we have inadvertently collected personal information from a minor, we will delete that information promptly. If you believe a minor has provided us with personal information, please contact us immediately at [email protected].

11

Changes to This Policy

How we communicate updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

Notify you by email at the address associated with your account at least 14 days before the changes take effect. Update the “Last updated” date at the top of this policy. Maintain an accessible archive of previous versions for your review.

Your continued use of Passings after changes take effect constitutes your acceptance of the updated policy. If you disagree with any changes, you may close your account and request deletion of your data before the effective date.

12

Contact Us

How to reach our privacy team

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us:

Contact methodDetails
Privacy inquiries[email protected]
Data deletion requests[email protected] — subject line: “Data Deletion Request”
Security vulnerabilities[email protected]
General support[email protected] or via the Contact page
Mailing addressPassings, Inc. · Privacy Team · [Address]

We aim to respond to all privacy-related requests within 2 business days and to complete requests within 30 days. If you are unsatisfied with our response, you have the right to file a complaint with your state's Attorney General office or consumer protection agency.

Questions about this policy?

We'll answer them
directly.

Our privacy team is made up of real people who care about getting this right. Send us a message — no auto-replies, no bots.