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Privacy Policy

Updated September 25, 2025

Data Privacy and Collection

Childfree Trust is committed to protecting your privacy and complying with all applicable data protection laws. We collect, use, and store personal information solely for the purposes of delivering and improving our Services, maintaining account records, and fulfilling contractual and legal obligations.

Information We Collect

We may collect the following categories of personal information:

  • Identifiers (e.g., name, email address, phone number, IP address)
  • Protected classification characteristics (e.g., age or gender, if voluntarily provided)
  • Health-related care planning information (e.g., medical, financial, and personal care preferences)
  • Professional or employment-related information (e.g., trustee or executor contacts)
  • Internet or other electronic activity information (e.g., usage data, account activity)

By using the website, you consent to our use of cookies and similar tracking technologies in accordance with this Privacy Policy section of the Terms and Conditions.

How Your Personal Information is Collected.

We collect most of this personal information directly from you via our website, email, or use of our apps. However, we may also collect information from the following categories of sources:

  • Publicly accessible sources (e.g., property records);
  • Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);
  • Third party with your consent (e.g., your bank);
  • Cookies on our website;
  • Automated information collection;
  • Our IT systems, including:
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

How We Use Your Information

We use your information to:

To provide products AND/OR services to you: For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or Childfree Trust: For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity / Screening for financial and other sanctions or embargoes / Other processing necessary to comply with professional, legal and regulatory obligations: To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies: To comply with our legal and regulatory obligations

Ensuring business policies are adhered to: For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training, and quality control: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information; To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems: For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you; To comply with our legal and regulatory obligations

Updating and enhancing customer records: For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party

Statutory: To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments: To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party

Marketing our services: For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

Credit reference checks via external credit reference agencies: For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks: For our legitimate interests or a those of a third party; To comply with our legal and regulatory obligations

Your Rights

You have the right to:

  • Request to know what personal information we collect, use, or disclose
  • Request deletion of your personal information (subject to legal exceptions)
  • Opt out of the sale or sharing of your personal data (Note: Childfree Trust does not sell personal information)
  • Correct inaccurate personal information
  • Limit use and disclosure of sensitive personal information

To exercise your rights, please contact us at support@childfreetrust.com with your request. We will verify your identity and respond in accordance with applicable law.

We do not discriminate against individuals for exercising their privacy rights under applicable law.

No Sale of Personal Information

Childfree Trust does not and will not sell your personal information to third parties for monetary or other valuable consideration.

Who We Share Your Personal Information With.

In the preceding 12 months, we have shared consumers’ personal information with:

  • Our affiliates, including companies within the Childfree Trust group;
  • Service providers we use to help deliver our services to you, such as payment service providers;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Third parties approved by you, including third-party trust provider that you choose to link your account to or third-party payment providers;
  • Credit reporting agencies;
  • Our insurers and brokers;
  • Our bank or banks; or
  • External auditors.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Data Security

Childfree Trust maintains reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information. However, no method of transmission over the internet or method of electronic storage is 100% secure. Accordingly, while we strive to use commercially reasonable means to protect your data, we cannot guarantee absolute security.

By using the Services, you acknowledge and agree that Childfree Trust shall not be liable for any unauthorized access, disclosure, loss, or breach of your personal information resulting from circumstances beyond our reasonable control, including cyberattacks, system failures, or third-party actions.

How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Supplement for California consumers

We are required to provide additional notice to End Users and Customers residing in California under the California Consumer Privacy Act and the California Privacy Rights Act (together, the “California Privacy Law”). We have included this California-specific information below.

Personal information. Consistent with Section—Information we collect, within the past 12 months, we collected the categories of Personal Information listed from California residents. In addition, we may collect from employees: (i) the personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) that is not already listed above, including insurance policy number, education, employment history, and medical information; and (ii) protected classification characteristics under California or federal law, including but not limited to race, national origin, religion, marital status, medical condition, disability, sexual orientation, veteran or military status, and genetic information.

Sources. We obtain the categories of Personal Information listed above from the following categories of sources: (i) Directly from you, e.g. from information you provide through the Platform and through any payments or transactions, or through any correspondence, such as when you request to receive information or support; (ii) Indirectly from you, e.g. from observing your actions on our Websites through the use of automated data collection tools or through our Customers acting on your behalf if you are an End User; or (iii) from our third-party service providers, e.g., through their independent collection efforts, or through your interactions with third-party platforms and partners, including through our integrations with them.

Deidentified information. We are committed to maintaining and using any deidentified (as defined under California Privacy Law) information we possess in deidentified form, and to avoid attempting to reidentify such deidentified information.

Disclosure of information. We may disclose your Personal Information as described in this Privacy Policy.

Retention. See Section—Information Retention for more information about our retention of your Personal Information.

California consumer rights. Subject to certain exceptions, as a California resident, you have the right to:

  • Request to know and/or access the Personal Information we have collected about you, including specific pieces of the Personal Information we have collected about you.
  • Request deletion of your Personal Information.
  • Request information about the Personal Information about you that we have shared (as such term is defined under California Privacy Law) to third parties.
  • Request the correction of inaccurate Personal Information.
  • Request the categories of your Personal Information disclosed for a business purpose.
  • Request information about the categories of your Personal Information about you that we have shared or sold within the past 12 months and the categories of third parties to whom your Personal Information was shared or sold.
  • Opt out of the sale or sharing of your Personal Information.

Other California privacy rights. California Civil Code Section 1798.83 permits California residents to request and obtain a list of any of their Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by contacting us at the details provided below.

Exercising your California consumer rights. Should you wish to request the exercise of your rights as detailed above with regard to your Personal Information, please contact us as set forth below. We will not discriminate against you by offering you different pricing or products or by providing you with a different level or quality of products, based solely upon this request. Please note that you are limited by law in the number of requests you may submit per year.

In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you. To verify your requests, we may ask that you provide information required to match the request with the consumer about whom information has been collected or utilize the authentication practices for your password-protected account. We may verify requests by matching information you provide to information that we maintain in our records.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. In other instances, we may decline to honor your request where an exception under California Privacy Laws applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer.

Authorized agent. You also have the option of designating an authorized agent to exercise your rights on your behalf. To authorize an agent to act on your behalf with respect to the rights contained in this Privacy Policy, we may require proof from the agent that you have provided the authorized agent written permission to do so, and we may require that you verify your own identity directly with us. If you have provided the agent with power of attorney, that may be sufficient.