PRIVACY POLICY

Last Updated: July 29, 2026 | Effective Date: July 29, 2026

INTRODUCTION

LifeKeys Shepherd™ ("LifeKeys Shepherd," "we," "us," or "our") operates the web-based platform available at www.LfeKeys-Shepherd.com (the "Platform"). We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, protect, and retain your personal information when you use our Platform and services.

LifeKeys Shepherd is a personal document organization platform — not a law firm, estate planning attorney, financial advisor, or legal service of any kind. Nothing on this Platform constitutes legal advice.

1. INFORMATION WE COLLECT

1.1 Highly Sensitive Personal Information

Because of the nature of our service, LifeKeys Shepherd collects and stores highly sensitive personal information that you provide voluntarily, including but not limited to:

Full legal name, date of birth, Social Security number, and government-issued identification details
Financial account numbers, bank names, investment account details, retirement account information, and approximate balances
Life insurance policy numbers, policy details, insurance company names, and beneficiary designations
Digital passwords, account credentials, and login information for online accounts and services
Real estate property details, mortgage information, and deed locations
Healthcare information, medical directives, healthcare proxy designations, and physician contact information
Personal wishes, funeral and burial preferences, and messages to loved ones
Family relationship information and contact details for family members and trusted contacts
Business ownership information, partnership agreements, and professional account details
KeyHolder™ designations — the names, contact information, and access levels of individuals you designate to receive access to your Letter of Last Instruction

1.2 Account and Profile Information

When you create an account we collect your name, email address, password (stored in encrypted form only), and billing information for paid subscriptions.

1.3 Usage and Technical Information

We automatically collect certain technical information when you use the Platform, including: IP address, browser type and version, device type, operating system, pages visited, time and date of access, and session duration. This information is used solely for security monitoring, fraud prevention, and Platform improvement.

1.4 KeyHolder™ Information

When you designate a KeyHolder™ — your chosen guardian, entrusted to protect and pass on the keys to your life and legacy — we collect the KeyHolder's name, email address, phone number, and relationship to you. We use this information solely to facilitate the KeyHolder™ access system as described in this Policy and in our KeyHolder™ Agreement.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes only:

To provide, operate, and maintain the LifeKeys Shepherd Platform and your Letter of Last Instruction
To authenticate your identity and protect your account from unauthorized access
To facilitate the KeyHolder™ access system when triggered by verified circumstances
To send you service communications, security alerts, and account notifications
To send quarterly check-in emails as part of our account monitoring system
To process payments for paid subscription plans
To comply with applicable laws and legal obligations
To investigate and prevent fraud, unauthorized access, and other harmful activities
To improve the Platform based on aggregated, anonymized usage patterns

We do NOT sell, rent, or trade your personal information to any third party for marketing purposes. We do NOT use your sensitive personal information for any purpose other than providing the LifeKeys Shepherd service.

3. HOW WE SHARE YOUR INFORMATION

3.1 KeyHolder™ Access

By designating a KeyHolder™, you explicitly authorize LifeKeys Shepherd to grant that individual access to the specific categories of your stored information assigned to them, under the verified trigger conditions described in our KeyHolder™ Agreement. You acknowledge that once access is granted through our verified trigger system, LifeKeys Shepherd is not liable for how your designated KeyHolder™ uses the information they are authorized to access.

3.2 Service Providers

We share information with trusted third-party service providers who assist us in operating the Platform, including: cloud hosting providers, payment processors, email service providers, and security monitoring services. All service providers are bound by contractual data protection obligations and may not use your information for any other purpose.

3.3 Legal Requirements

We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to: comply with a legal obligation, protect the rights or property of LifeKeys Shepherd, prevent or investigate possible wrongdoing, protect the personal safety of users or the public, or protect against legal liability.

3.4 Business Transfer

If LifeKeys Shepherd is acquired, merged, or transferred to another entity, your information may be transferred as part of that transaction. You will be notified via email and a prominent notice on the Platform prior to any such transfer, and you will have the opportunity to download your complete data before the transfer is completed.

3.5 What We Never Share

We will NEVER sell your personal information. We will NEVER share your sensitive financial, medical, or personal information with advertisers. We will NEVER use your information for targeted advertising.

4. DATA PROTECTION AND SECURITY

LifeKeys Shepherd implements the following security measures to protect your information:

AES-256 encryption for all data stored on our servers
TLS 1.3 encryption for all data transmitted between your device and our servers
Zero-knowledge architecture ensuring only you and your authorized KeyHolders™ can access your information
Two-factor authentication available for all accounts
Regular security audits and penetration testing
Access controls limiting employee access to user data
Immutable audit logs recording all KeyHolder™ access activity

Despite these measures, no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

5. DATA BREACH NOTIFICATION

In the event of a data breach that affects your personal information, LifeKeys Shepherd will:

Notify affected users within 72 hours of discovery of the breach
Notify appropriate Maryland state authorities as required by the Maryland Personal Information Protection Act
Notify applicable federal authorities where required by law
Provide a clear description of what information was affected and what steps we are taking
Offer appropriate remediation measures to affected users

6. DATA RETENTION

6.1 Active Accounts

We retain your information for as long as your account is active and for a reasonable period thereafter to comply with our legal obligations.

6.2 After Account Closure

If you close your account, we will retain your information for 90 days to allow you to reopen your account if desired. After 90 days, your data will be permanently deleted.

6.3 After Verified Death

Following verified notification of your death, your data will be retained for 36 months to allow your designated KeyHolders™ adequate time to access and download your Letter of Last Instruction. Prior to deletion, all active KeyHolders™ will receive written notice and an opportunity to download the complete Letter of Last Instruction in PDF format.

6.4 Legal Hold

We may retain certain information beyond the periods described above if required by law, court order, or for the establishment, exercise, or defense of legal claims.

7. YOUR RIGHTS AND CHOICES

You have the following rights regarding your personal information:

RIGHT TO ACCESS: You may request a copy of all personal information we hold about you at any time
RIGHT TO CORRECT: You may update or correct inaccurate information through your account settings or by contacting us
RIGHT TO DELETE: You may request deletion of your personal information, subject to our legal retention obligations
RIGHT TO EXPORT: You may download your complete Letter of Last Instruction and all stored data at any time in PDF or JSON format
RIGHT TO RESTRICT PROCESSING: You may request that we limit how we use your information in certain circumstances
RIGHT TO WITHDRAW CONSENT: Where processing is based on consent, you may withdraw consent at any time
RIGHT TO OBJECT: You may object to certain types of processing of your information

To exercise any of these rights, contact us at legal@lifekeys-shepherd.com. We will respond to all requests within 30 days.

8. CALIFORNIA RESIDENTS — CCPA RIGHTS

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) including the right to know what personal information we collect, the right to delete your personal information, the right to opt out of the sale of your personal information (we do not sell personal information), and the right to non-discrimination for exercising your CCPA rights.

9. KEYHOLDER™ SPECIFIC PRIVACY TERMS

The KeyHolder™ system — your chosen guardian, entrusted to protect and pass on the keys to your life and legacy — involves sharing your personal information with third parties you designate. The following specific terms apply:

KeyHolders™ must create their own LifeKeys Shepherd credentials and accept the KeyHolder™ Agreement before accessing any information
KeyHolders™ are granted read-only access — they cannot edit, delete, or modify your stored information
All KeyHolder™ access is logged with timestamp, IP address, and actions taken
You may add, change, or revoke KeyHolder™ designations at any time while your account is active
LifeKeys Shepherd is not responsible for the actions of your designated KeyHolders™ once access is properly granted through our verified trigger system

10. COOKIES AND TRACKING

LifeKeys Shepherd uses essential cookies necessary for the Platform to function, including authentication cookies and security cookies. We do not use advertising cookies or tracking cookies for marketing purposes. You may disable cookies in your browser settings, but doing so may affect Platform functionality.

11. CHILDREN'S PRIVACY

LifeKeys Shepherd is not directed to children under the age of 18. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected information from a child under 18, we will promptly delete that information.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by: posting the updated Policy on the Platform, sending an email notification to your registered email address, and displaying a prominent notice on the Platform for 30 days after the change takes effect. Continued use of the Platform after changes take effect constitutes acceptance of the updated Policy.

13. CONTACT US

For questions, concerns, or to exercise your privacy rights, contact us at:

LifeKeys Shepherd™ — Privacy Officer

5457 Twin Knolls Road, Suite 300 #1159

Columbia, MD 21045 USA

Support@LifeKeys-Shepherd.com

YOUR MOST SENSITIVE INFORMATION, PROTECTED