This policy is effective as of August 21, 2024.

‍This policy was last updated on April 23, 2026.

Trusty's Privacy Policy

1. Introduction

Your privacy is important to us. This Privacy Policy explains how Trusty Estate Inc. ("Trusty," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with the Trusty mobile or web app application (the "App"), the Trusty advisor web portal (the "Portal"), our website at https://www.withtrusty.com (the "Website"), and related products, features, and services (collectively, the "Services").

This Privacy Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy legislation. By using the Services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

The Services may also be accessible through domain aliases, including mytrusty.ai, which redirect to withtrusty.com. This Privacy Policy governs our handling of personal information regardless of the domain through which you access the Services.

If the Services contain links to third-party websites or services, please be aware that those third parties have their own privacy policies. We are not responsible for the privacy practices of any third party.

2. Definitions

"Personal Information" means information about an identifiable individual, including name, contact details, device identifiers, asset and estate information, financial account details, Uploaded Plans, Wishes, and chat history.

"Sensitive Information" means personal information that is given a higher level of protection under applicable law, such as detailed financial information, estate planning documents, and other categories described in Section 3.5.

"Consent" means voluntary agreement to the collection, use, and disclosure of personal information for the identified purposes.

"Trusty Advisor" means a licensed or credentialed professional (or their firm) who uses the Portal to support clients.

Capitalized terms used but not defined in this Privacy Policy have the meaning given in the Terms of Service.

3. Information We Collect

3.1 Information You Provide

We collect personal information that you voluntarily provide when using the Services. Because the Services are designed to help you organize and manage your wealth and estate planning, the categories of information you may provide include:

• Account information: name, email address, phone number, date of birth, and mailing address.
• Asset inventory: descriptions, locations, estimated values, photographs, and category-specific details for a wide range of asset types, including real property, vehicles, investments, collectibles, and other personal and business assets.
• Financial account and insurance details: bank and investment account names, institution identifiers, account references, insurance policy details, and related records.
• Estate planning documents: wills, trusts, powers of attorney, beneficiary designations, and similar documents uploaded through the App, the Portal, or via a secure email link.
• Trusted contact information: names, email addresses, phone numbers, relationships, and other contact details for individuals you designate as Heirs, Co-Owners, Trusty Advisors, or other roles.
• Wishes: notes and video recordings you create within the App, together with associated metadata (recipient, trigger conditions, delivery instructions).
• Chat and assistant history: your interactions with Trusty AI's conversational assistant, including prompts, responses, and related context.
• Support and correspondence: information you provide when contacting us for support.

3.2 Information Collected Automatically

When you use the Services, certain information is collected automatically, including:

• device information (device type, operating system, unique device identifiers);
• usage data (features accessed, time and date of use, session duration);
• IP address and approximate location; and
• log data and analytics information.

3.3 Device Permissions and Their Purposes

The App may request access to certain features on your device. The list  below summarizes each permission and its purpose.

Device Permission — Purpose

Camera — To photograph assets, documents, and record Wishes
Microphone — To record audio in Wishes
Photo Library / Storage — To upload images and documents from your device
Contacts — To help you select Heirs, Co-Owners, Trusted Contacts, Trusty Advisors, and other individuals from your address book
Location — To tag asset locations and for fraud prevention (with your consent)
Notifications — To deliver in-app reminders, security alerts, and other user-initiated or system notifications
Face ID / Touch ID — For biometric sign-in; handled entirely by your device operating system. Trusty does not collect or store biometric templates.
Background Refresh / Mobile Data — To keep your data synchronized and deliver timely notifications

You may manage these permissions at any time through your device settings. Disabling a permission may limit the functionality of the corresponding feature.

3.4 AI-Processed Information

The Services include Trusty AI, which provides automated asset categorization, verification, and a conversational assistant. When you use Trusty AI, relevant Content and conversation inputs - including asset data submitted for categorization and messages exchanged through the conversational assistant - are processed by our AI provider under contractual terms that prohibit the use of your data, including chat conversation data, to train the provider's generative models.

Chat and assistant history is retained within the Services for the duration of your Account to enable continuity of conversation and to support feature improvement. Chat history is deleted or anonymized following Account deletion in accordance with Section 7.5. You may request deletion of your chat history at any time by contacting us at privacy@withtrusty.com.

3.5 Biometric Authentication

If you enable biometric sign-in (Face ID, Touch ID, or equivalent), the biometric matching is performed entirely by your device operating system. Trusty does not receive, collect, or store any biometric templates or biometric identifiers. We receive only a confirmation from your device that authentication has succeeded or failed.

3.6 Push Notifications

Where you have enabled push notifications, the App may transmit notifications to your device through your device operating system's notification services, including Apple Push Notification Service and Google Firebase Cloud Messaging. This involves the use of a device token assigned by your operating system and the transmission of notification payload content. We do not use push notifications to deliver unsolicited marketing communications unless you have opted in to receive them. You may manage push notification preferences at any time through your device operating system settings or within the App. Disabling push notifications may prevent you from receiving security alerts and other time-sensitive system communications.

4. Purposes for Collecting Personal Information

We identify our purposes for collecting personal information at or before the time of collection. We collect, use, and disclose personal information for the following purposes:

• to provide, operate, and maintain the Services;
• to create and manage your Account and the Accounts of Co-Owners, Collaborators, and Trusty Advisors you authorize;
• to enable core features, including asset cataloguing, document storage, estate planning tools, Wishes, and Trusty AI;
• to process AI-powered asset categorization, verification, and conversational assistance;
• to deliver Wishes and execute other user-configured delivery triggers;
• to communicate with you, including sending system notifications (such as password resets, security alerts, and legally required notifications);
• to present contextual, in-product offers relating to Trusty features, upgrades, paid subscriptions, and partner or referred products that may enhance your experience (see Section 4.1);
• to send marketing communications outside the Services (only where you have opted in), which you may opt out of at any time;
• for analytics, service improvement, and business development;
• for security, fraud prevention, and abuse detection;
• for internal record keeping and administrative purposes; and
• to comply with legal obligations.

4.1 In-Product Offers

We use information about your use of the Services to present contextual, in-product offers. These offers may include:

• Trusty features, upgrades, and paid subscriptions;
• referred or partner products and services that we believe may enhance your experience with the Services; and
• educational content and resources related to wealth and estate planning.

In-product offers are delivered within the Services (for example, through the App interface or Portal). They are contextual and are not delivered through unsolicited external outreach. We do not share your personal information with third-party advertising networks for the purpose of targeting advertising to you outside of the Services, except as disclosed in Section 7 (Disclosure to Third Parties).

5. Consent

We obtain your consent before or at the time of collecting your personal information. You may provide consent expressly (for example, by creating an Account or submitting information through the Services) or it may be implied by your use of the Services where the purpose of collection would be considered obvious to a reasonable person.

We will obtain your express consent before collecting, using, or disclosing Sensitive Information or for any purpose that would not be considered obvious.

You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting us using the details provided in Section 20. Please note that withdrawing consent may affect your ability to use certain features of the Services.

6. Limiting Collection

We limit the collection of personal information to what is necessary for the identified purposes. We collect personal information by fair and lawful means.

7. Use, Disclosure, and Retention

7.1 Use

We use your personal information only for the purposes identified in Section 4 or for purposes that a reasonable person would consider appropriate in the circumstances.

7.2 Disclosure to Trusty Advisors and Shared-Access Users

When you invite a Co-Owner, Collaborator, or Trusty Advisor, you authorize the disclosure of your Account data (within the scope you select) to that person, on the basis of your consent. The following categories of Account data may be accessible to a Trusty Advisor through the Portal: (a) physical asset inventory, including photographs, descriptions, current and historical valuations, appraisal records, and category-specific details such as vehicle identification numbers and gemstone grading information; (b) financial assets, including bank and investment account details, institution identifiers, account types, and supporting documents; (c) estate planning documents, including uploaded wills, trusts, powers of attorney, and other documents, together with their processing status; (d) life insurance details, including provider, coverage amounts, and beneficiary information; (e) Heir designations, including which contacts are designated as Heirs and which assets are assigned to them; (f) Wishes, including recorded video messages and configured delivery triggers, to the extent you have shared them; (g) contact information, including names, email addresses, relationships, and roles of all contacts in your Account; and (h) your estate binder, including a compiled estate planning overview and task completion status. The scope of Trusty Advisor access is determined by you and by the product configuration and limitations in effect from time to time.

Trusty Advisors are independent of Trusty. Trusty Advisors are bound by our Terms of Service to treat your data as confidential and to use it only for the purpose of providing services to you. You may revoke a Trusty Advisor's access by requesting to cancel your Account at any time. Following revocation, the Trusty Advisor is required to cease all use of Account data disclosed to them in their capacity as your Trusty Advisor and to delete or return such data, except to the extent that retention is required by applicable law or the Trusty Advisor's professional regulatory obligations. Trusty Advisors who wish to end the engagement should contact you or Trusty support; Trusty Advisors cannot currently revoke their own access.

7.3 Disclosure to Third-Party Service Providers

We disclose personal information to third-party service providers who assist us in delivering the Services. The list below identifies our current sub-processors.

Amazon Web Services (AWS)
Service: Cloud infrastructure and storage
Data Handled: Account data, content, uploaded plans, wishes

Google CloudService: Cloud infrastructure and storage
Data Handled: Account data, content, uploaded plans, wishes

Firebase (Google)
Service: Authentication, database, and App Check
Data Handled: Account credentials, session data, device integrity signals

Google Gemini
Service: AI processing for asset categorization and Trusty AI chat
Data Handled: Asset data and chat conversation inputs (not used to train models)

Mailgun
Service: Transactional email and secure document upload email links
Data Handled: Emails for account verification and document uploads

Customer.io
Service: Marketing automation and transactional email
Data Handled: User contact information, account activity events, marketing and transactional email engagement data

Lulu.com
Service: Print-on-demand fulfillment of estate binders (where requested)
Data Handled: User-provided estate binder content, shipping address

Meta
Service: Advertising and engagement on Meta platforms (where applicable)
Data Handled: Event data associated with advertising campaigns

Apple / Google (App Stores)
Service: In-app purchase processing and app distribution
Data Handled: Purchase records, device identifiers

We require our sub-processors to protect personal information with safeguards appropriate to the sensitivity of the information, and to use it only for the purposes for which it was disclosed.

7.4 Other Disclosures

We may also disclose personal information to:

• our affiliates, subsidiaries, and related entities;
• our employees, contractors, and professional advisors;
• business partners and potential acquirers in connection with a merger, acquisition, financing, or sale of all or substantially all of our assets;
• courts, tribunals, regulatory authorities, and law enforcement, as required or permitted by law; and
• any other party where you have provided your consent.

7.5 Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, to deliver Content in accordance with your instructions (including Wishes), or as required by law. When personal information is no longer required, we will securely delete or anonymize it.

If you delete your Account, we will delete or anonymize your personal information within a reasonable period, except where retention is required for legal, accounting, or reporting purposes, or to complete user-configured delivery (such as pending Wishes).

Retention periods for key categories of personal information are as follows. Wishes are retained for the duration of your Account and for such additional period as is necessary to complete any user-configured posthumous delivery, after which they are deleted or anonymized. Uploaded Plans are retained for the duration of your Account and are deleted or anonymized following Account deletion in accordance with Section 7.5, subject to any applicable legal hold obligations. Chat and assistant history is retained as described in Section 3.4. These periods may be extended where retention is required by applicable law, ongoing legal proceedings, or regulatory obligations.

8. No Outbound Contact to Heirs or Designated Third Parties

Trusty does not proactively contact Heirs, beneficiaries, family members, or other individuals whose names or contact details you have entered into your Account. We will not call, email, message, or otherwise reach out to these individuals for marketing, outreach, solicitation, or notification purposes.

We communicate only with individuals who:

• maintain their own active Trusty Account;
• have accepted an invitation to join the Services; and
• have enabled relevant in-app notifications or otherwise opted in to receive communications.

Trusty Advisors using the Portal are independent of Trusty and are bound by the same restriction: Trusty Advisors must not contact individuals listed within a client's Account outside of those who have their own account and have opted in, unless the client has expressly directed otherwise.

We reserve the right to introduce future features that allow you or another authorized user to initiate outbound contact with a listed individual. Any such feature will operate only through user-initiated, permission-based, or consent-driven flows. Nothing in this Section limits our ability to send system-level communications (such as security or legally required notifications) to individuals who have an existing Account with Trusty.

9. Personal Information About Non-Users

When you submit information about another individual (for example, by designating an Heir or listing a family contact), you represent and warrant that you have the authority to do so and, where required, the individual's consent. Because Trusty does not proactively contact non-users (as described in Section 8), we rely on you to inform designated individuals that their information has been stored in the Services.

A non-user whose personal information has been submitted to the Services may contact us at privacy@withtrusty.com to request access to, correction of, or deletion of their information. We will respond to such requests in accordance with applicable law. In some cases, responding to a non-user request may require us to contact the Account Owner who submitted the information.

10. Safeguards

We protect personal information with security safeguards appropriate to the sensitivity of the information. These safeguards include:

• encryption of data in transit and at rest;
• secure storage through Google Cloud, AWS, and Firebase;
• two-factor authentication (2FA) enforced at registration (users may choose to disable this at their own risk);
• access controls limiting employee and contractor access to personal information on a need-to-know basis;
• contractual safeguards with sub-processors and Trusty Advisors; and
• regular security assessments and monitoring.

While we implement commercially reasonable security measures, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute data security. If you request physical fulfilment of an estate binder, please note that once the binder exists in printed form it is outside the security perimeter of the Services.

11. International Transfers

Your personal information may be stored and processed in Canada, the United States, or other jurisdictions where we or our service providers maintain facilities. These jurisdictions may have different data protection laws than your jurisdiction of residence.

Where we transfer personal information outside of Canada, we take steps to ensure that the information is protected in accordance with this Privacy Policy and applicable law.

12. Accuracy

We take reasonable steps to ensure that personal information in our possession is accurate, complete, and up to date for the purposes for which it is used. You are responsible for informing us of any changes to your personal information.

13. Individual Access, Correction, and Portability

Access. You have the right to request access to the personal information we hold about you. Upon receiving a written request and verifying your identity, we will provide you with your personal information, subject to any applicable legal exceptions.

Correction. If you believe that any personal information we hold about you is inaccurate, incomplete, or out of date, you may request that we correct it. We will take reasonable steps to correct any information found to be inaccurate or incomplete.

Deletion. You may request deletion of your Account and associated personal information at any time, subject to legal retention obligations and the completion of user-configured delivery.

Portability. You have the right to export the personal information you have provided to the Services in a commonly used, machine-readable format. You may initiate an export through the App or by contacting us.

14. Cookies and Similar Technologies

We use cookies and similar technologies to recognize your device, provide core features of the Services, track usage and performance, personalize your experience, and present contextual in-product offers. Cookie data is transmitted between your device and our servers in a secure environment.

You may manage your cookie preferences through your device or browser settings. Please refer to our Cookie Policy for further details.

15. Children's Privacy

The Services are not directed at children and are intended for users who are at least eighteen (18) years of age (or the age of majority in their jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete that information promptly.

16. Breach Notification

In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm to affected individuals, we will:

• notify the Office of the Privacy Commissioner of Canada as required under PIPEDA;
• notify affected individuals as soon as feasible; and
• keep records of all breaches of security safeguards, regardless of whether they meet the threshold for notification.

17. Business Transfers

In the event that Trusty or substantially all of its assets are acquired, or in the event of insolvency or bankruptcy, personal information may be among the assets transferred. Any acquiring party will be required to comply with this Privacy Policy with respect to your personal information.

18. Death and Posthumous Data Handling

Certain features of the Services operate after the death of the Account Owner, including Wishes delivery and Heir notification. We handle personal information in that context as follows:

• Triggering posthumous features. We will not initiate posthumous delivery or provide access to another individual's Account until we have received what we reasonably consider to be credible notice of death. Credible notice may include a death certificate, statutory declaration, notarial certificate, or equivalent documentary evidence submitted by a designated Heir, executor, estate trustee, legal personal representative, or other authorized person. We reserve the right to require additional verification before activating any posthumous feature. Trusty is not liable for delays in activating posthumous features caused by failure to provide timely or sufficient notice of death.
• Post-death retention. We may retain Account Content after the Account Owner's death to deliver Wishes, complete other posthumous features, and comply with legal obligations. Thereafter, we will delete or anonymize the Content in accordance with this Privacy Policy.
• Heir access. Designated Heirs have no automatic right to access the Account or its Content. Any access following the Account Owner's death is subject to applicable estate law, the Account Owner's instructions, and Trusty's operational policies.
• No outbound contact. Consistent with Section 8, Trusty will not proactively contact Heirs or other listed individuals following the Account Owner's death, except to the extent required to deliver user-configured Wishes or as required by law.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you by posting the updated Privacy Policy on the Website, through the App, through the Portal, or via the email address associated with your Account.

Your continued use of the Services following the posting of changes constitutes your acceptance of the revised Privacy Policy.

20. Complaints and Contact

If you believe that we have not handled your personal information in accordance with this Privacy Policy or applicable law, you may file a complaint with our Privacy Officer using the contact information below. We will investigate your complaint and respond in writing within a reasonable time.

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H3

Toll-free: 1-800-282-1376

Website: https://www.priv.gc.ca

Privacy Officer Contact: 

Trusty Estate Inc.

Attention: Privacy Officer

Email: privacy@withtrusty.com 

Website: https://www.withtrusty.com