Privacy Policy

Effective Date: October 28, 2026
Last Updated: October 26, 2026

At PharosLife, Inc. (“PharosLife”, “we,” “us” or “our”), we are building a platform designed to help individuals and families navigate complex life moments — planning ahead, supporting loved ones, and managing what happens when life changes.

We understand that this involves deeply personal information. Protecting that information is fundamental to how we operate.

This Privacy Policy explains how we collect, use, share and protect personal information when you visit mypharoslife.com, use the PharosLife web app (including Ask Pharos, our AI assistant), or otherwise interact with us (together, the “Services”). Our Consumer Health Data Privacy Policy supplements this Policy for health-related information and controls where the two differ. The Services are offered only to adults in the United States.

1. Our Approach to Privacy

PharosLife is built on three core principles:

• Minimization — We collect only what is necessary to provide our services to you
• Protection — We apply safeguards aligned with modern security practices
• Respect — Your data is never sold, rented, or exploited

We do not sell your personal information, we do not share it for targeted advertising, and we do not use it to train artificial intelligence models.

2. Information We Collect

We collect information in the following categories:

A. Information You Provide Directly

• Name and email address (e.g., waitlist, account creation), and your password, which we store only in hashed form, or basic profile details from Google if you sign in with Google
• Profile and planning inputs (e.g., information you record across the ten Life Systems, such as where important documents are kept, notes, To-Dos, comments and checklists)
• Details about a life event you are managing, such as the date of a loss and your role
• Information about other people you add, such as family members, beneficiaries, advisors, household members, delegates and your Backup (see Sections 6 and 7)
• Messages you send to Ask Pharos, our AI assistant (see Section 9)
• Your answers to our consent requests, which we keep as a record (see Section 2E)
• Your acknowledgment of our purchase terms each time you buy something, which we keep as a record together with the date and time, the terms and wording you were shown, what you bought and the amount, and the IP address and browser you used
• Your consent to automatic renewal when you subscribe, which we keep as a record together with the date and time and the terms and wording you were shown
• Billing details needed to process payment. Card details are collected and stored by our payment processor; we do not store full card numbers. If you pay with a service such as Apple Pay, Google Pay, Link, Amazon Pay or Cash App Pay, that provider's own privacy policy also applies to the information it handles
• Survey responses, interview participation, or product feedback
• Communications with our support team

B. Account & Platform Data

• Preferences and settings, including your planning rhythm, reminder setting and cookie choices
• Activity within the platform (e.g., task completion, workflow progress, guided sessions, and a history of changes made to a plan)
• Delegation and sharing settings, if you choose to use those features, including household membership, roles and invitations
• Subscription status, plan type, trial dates and AI credit usage
• Records of the billing notices we send you, such as renewal reminders and price-change notices
• Security information, such as sign-in history, two-factor authentication settings, recovery codes (stored in hashed form) and trusted devices

C. Device & Usage Information

• IP address, browser type, device type
• Pages visited, session duration, interactions
• General geographic location inferred from IP address

When you access or use the Services, we automatically collect technical identifiers — such as IP address, browser type, and general location — through first-party technologies. Analytics and behavioral data, including pages visited, session duration, and interactions, are collected via cookies only if you opt in, as described in Section 8.

D. Information From Other Sources

We may receive information about you from other people who use PharosLife — for example, when someone invites you to a household or a plan, names you as their Backup, or records your name and contact details in their plan. We also receive limited information from service providers that help us operate the Services, such as confirmation that a payment succeeded, and from Google if you choose to sign in with Google.

E. Sensitive Information and Your Two Consents

Some information you can record in PharosLife is sensitive under state privacy laws, such as identifying and financial information, personal traits, information about health, wellness and care, and, in sections such as funeral wishes, information that may reveal religious or philosophical beliefs. We process it only with your consent. When you create an account, we ask two separate, optional questions. Neither is pre-selected:

• Consent 1 — Sensitive Personal Data: identifying information, financial information and personal traits.
• Consent 2 — Health Data: health, wellness and care-related information. Our Consumer Health Data Privacy Policy explains how we handle this information.

You can say no to either. Saying no does not block your account; the sections that rely on that consent stay visible but locked until you agree. You can give a consent later, or withdraw it, at any time in Settings, under Security & Privacy. Withdrawing a consent permanently deletes the information you recorded under it, and it cannot be restored, even if you consent again. We keep a record of each choice, including the wording you were shown and when you made it.

3. What We Intentionally Do Not Collect

PharosLife has implemented data minimization controls designed to limit the collection and processing of sensitive personal information. The platform is designed not to collect or store the following. We ask you not to enter them, and we automatically block common formats of some of them:

• Social Security numbers
• Full financial account or card numbers
• Passwords or login credentials for other accounts, such as bank, email or social media accounts
• Government-issued identification numbers

PharosLife records awareness — for example, that a policy exists and where its documents are kept — rather than the documents or credentials themselves.

4. How We Use Your Information

We use your information to:

• Provide and operate the platform and our services
• Generate structured workflows, checklists, and planning guidance
• Personalize your experience across planning and life events
• Make your plan available to the people you choose, and carry out your instructions for your Backup (see Section 7)
• Send transactional messages and notifications, such as invitations, assignments, security alerts, deletion notices and, if you keep them turned on, session reminders
• Process payments, manage your subscription and AI credits, and prevent fraud
• Improve product performance and usability
• Communicate with you about your account or updates, and, where permitted, send product news you can unsubscribe from at any time
• Detect, prevent, and address security or misuse
• Comply with legal obligations, keep records of consent, and establish or defend legal claims

We use sensitive information only to provide the Services you ask for, keep them secure and comply with the law, and not to infer characteristics about you. We do not use your information for targeted advertising, and we do not make decisions about you that have legal or similarly significant effects based solely on automated processing.

We may also use aggregated or de-identified data to understand usage patterns, improve product design, and conduct internal analysis. This data cannot reasonably identify you. We maintain it in de-identified form and do not attempt to re-identify it.

5. How We Share Information

We do not sell personal information or share it for targeted advertising. We disclose personal information only in the following circumstances:

A. People You Choose

When you invite someone to your household or a plan, assign them a section or task, or mark details as shared with your household, those people can see what you have shared with them and, depending on the role you give them, edit it. Joining a household doesn't show your plan to anyone. Household members see only the details you mark as shared. The exception is a plan the household owner created for you, which they can see until they hand it over to you. Actions people take, such as completing tasks or adding comments, are visible to others with access to that plan.

B. Your Backup

If you name a Backup, we email that person to tell them you named them and ask them to confirm their details from time to time. A Backup has no access to your information while you are alive and able. If your Backup reports your death or incapacity and you do not object within 7 days, ownership of your account passes to them, as described in Section 7.

C. Notices to Other People

Some features send messages to people other than you, such as invitations; a notice to an adult whose health information you recorded (see Section 6); an invitation to the person a plan is about, if you choose to send one; and notices to household members, delegates and Backups if you delete your account or a plan they can access. These messages include your name and only the information needed for the notice.

D. Service Providers

We work with trusted third-party providers (e.g., hosting and data storage, email delivery, payment processing, sign-in, address lookup, AI processing for Ask Pharos, customer support, analytics) that process data on our behalf, are contractually required to protect it, and cannot use it for their own purposes. A list of our current service providers is available on request.

E. Legal & Safety Obligations

We may disclose information to comply with applicable law, legal processes, or regulatory requests, or to protect the rights, safety, or property of users, PharosLife, or others.

F. Business Transfers

In the event of a merger, acquisition, or restructuring, user information may be transferred as part of that transaction. Any successor will be required to honor this Policy for the information transferred, and consumer health data will be transferred only as the law allows.

G. With Your Consent

We may share information for other purposes when you ask us to or give your consent.

6. Information About Other People

PharosLife helps you organize information about the people in your life. When you add someone else's information, you are responsible for having the right to share it. How we handle it depends on the kind of information:

• Basic details. A name, contact details and relationship to you can be saved without notice to that person.
• Health information about another adult. You must first confirm that you have their consent or legal authority. Unless you hold a declared legal authority, such as a power of attorney, we hold the information as pending and email that person a plain-language notice with a one-click way to object. We keep it only if they confirm. If they object, do not respond within 14 days, or cannot be reached, we permanently delete it and let you know.
• Plans about another adult. If you create a plan about someone else, you tell us the basis, for example that they asked you or that you hold a power of attorney. Unless you declare a legal authority, the plan's sensitive, financial and health sections stay locked until that person accepts an invitation to claim the plan or approve your managing it. If they object, the plan is erased.
• Children. Parents and legal guardians may record information about their children. Before saving a child's information, you must confirm that you are the child's parent or legal guardian. We use it only to provide the planning service you requested, and never for marketing, targeted advertising or commercial sharing.
• People who have died. When you manage affairs after a loss, you may record information about the person who died. We protect it in the same way.

If your information appears in someone else's PharosLife plan, you can email privacy@mypharoslife.com to ask to access, correct or delete it. We will respond as the law requires.

7. Backups and What Happens After a Death or Incapacity

You can name a Backup to take over your account if you die or become incapacitated: one on the Individual plan, and as many as you need on the Family plan. We recommend naming the executor of your will or the successor trustee of your trust.

Before anything happens, your Backup has no access to your information. We email them when you name them, ask them to confirm their details every six months, and ask you once a year whether your Backup is still the right person.

If your Backup reports your death or incapacity, we email you a one-click link to stop the transfer. If you do not stop it within 7 days, ownership of your account and its plans (or, for a household designation, the household) passes to your Backup, who can then view, change, share and delete the information as its new owner. If you do not respond, we record that you did not object, not that you consented.

After a transfer, we keep a tamper-evident record of changes the new owner makes, outside their control, and anything they delete can be restored for 90 days.

8. Cookies, Analytics, & Session Recording

We use first-party cookies, local storage, and similar technologies to maintain secure sessions, remember your preferences, and ensure core platform functionality. These strictly necessary technologies are always on.

With your permission, we use analytics services from a third-party service provider, which processes data on our behalf under contract, to understand how people use the Services and to improve performance and usability. Through these services, we collect technical identifiers — including your IP address and general geographic location (such as ZIP code) — along with behavioral data about how you use the platform.

If you have opted in to analytics, we also send a few broad details worked out from your own plan: your age range, state, language, employment status, whether you own a business, whether you already have planning in place, and which kinds of advisors you have recorded. We never send the answers you entered, and nothing from a plan about someone else.

Our analytics integration may include session replay and heatmap technologies, which record visual representations of your on-screen interactions — such as mouse movements, scrolls, clicks, and navigation pathways. These recordings are limited to behavioral interaction data only. They run only if you have opted in to analytics, and they are always switched off on pages where you enter or view health or financial information, whatever your cookie choice.

When you first visit, we ask you to choose. You can accept all cookies, reject non-essential cookies, or choose by category: Strictly necessary (always on), Functional, and Analytics & performance (including session recording and heatmaps). Until you choose, only strictly necessary cookies run, and no analytics or other non-essential tag loads. We keep a record of your choice.

You can review, approve, or withdraw your tracking preferences at any time through our Cookie Preferences link in the website footer, or in the app under Settings, then Security & Privacy, then Cookie preferences.

You can also manage cookie preferences through your browser settings. Disabling necessary cookies may impact certain functionality. Disabling analytics cookies will not impact functionality.

We do not use advertising cookies or allow third parties to collect information through our Services for targeted advertising. Because we do not sell personal information or share it for targeted advertising, opt-out preference signals such as Global Privacy Control have nothing further to switch off. We do not respond to browser “Do Not Track” signals, because we do not track you across other websites.

9. Ask Pharos (AI Assistant)

Our platform offers Ask Pharos, an AI assistant, that helps you understand how to use PharosLife, what a question in your plan means, and general topics such as what to do after a loss. The assistant is powered by a third-party provider which processes your inputs on our behalf under contract as our service provider. When you use the assistant, the information you type — including any consumer health data you choose to enter — is sent to that provider to generate responses.

Along with your message, we send limited context so the answer fits where you are in the app: your role, whether you are planning or managing a life event, your progress, tasks you recently viewed or completed, and which question you are working on. We do not send the information you have entered in your plan. Answers may draw on articles in our Knowledge Center.

The assistant does not provide legal, financial, tax, medical, or professional advice, and is not a substitute for a professional. It can be wrong, so check anything important with a qualified professional.

Your inputs to the assistant are not used to train our provider's models or ours, and are retained only as necessary to provide the feature. We do not use the assistant to make decisions about you. We keep your conversation history, including the assistant's responses, for up to 30 days so the assistant can follow the conversation and so we can check its answers for accuracy and safety. Our provider keeps inputs and outputs only for a short period for operating the service and preventing abuse.

10. Data Retention

We retain personal information only as long as necessary to provide our Services, fulfill the purposes described in this Policy, and comply with legal obligations. We consider the purpose of collection, the sensitivity of the data, and legal and regulatory requirements. In particular:

• Your account and plans: while your account is open.
• A plan you delete: recoverable for 30 days, then permanently deleted.
• Your account, if you delete it: we wait 7 days so you can change your mind, then permanently delete your account and the plans you own. Comments you added to other people's plans remain there, shown as from “a deleted account.”
• Locked plans: if your trial ends without a subscription, a payment is not made within the 14-day grace period, or your subscription ends, your plans are locked for 30 days. You can't open them, but you can export them or subscribe again. After that they are permanently deleted.
• Plans transferred to a Backup: if the new owner does not subscribe when the paid time ends, the plans are locked and kept for 12 months, then permanently deleted. The new owner can export them during that time.
• Information under a consent you withdraw: deleted immediately.
• Health information about another adult that they have not confirmed: deleted after 14 days.
• Information a Backup deletes after a transfer: restorable for 90 days, then deleted.
• Ask Pharos conversation history: up to 30 days.
• Consent records and security audit records: 7 years, then deleted, even if your account is deleted sooner. We keep them as evidence of your choices and of ownership changes.
• Purchase acknowledgments and automatic-renewal consents: at least 3 years, or 1 year after your subscription ends, whichever is longer. We keep them as evidence of the terms you accepted.
• Records of billing notices we send, such as renewal reminders and price-change notices: for the same period as purchase acknowledgments.
• Backups of our systems: kept for 30 days on a rolling basis. Deleted information may remain in them until they expire, but it is never restored to an individual account.
• Billing records: as long as tax and accounting law requires.

11. How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed to protect your information, including:

• Encryption of data in transit and at rest
• Secure infrastructure and hosting
• Access controls and authentication measures, including optional two-factor authentication
• Consent locks and sharing permissions enforced by our servers on every request
• A tamper-evident record of ownership transfers and of changes made after a transfer
• Monitoring for unauthorized access or misuse

While no system is completely secure, we design PharosLife to minimize both the likelihood and impact of unauthorized exposure of personal information. If a security incident affects your personal information, we will notify you as the law requires.

12. Your Rights and Choices

Depending on where you live, you may have the right to:

• Access your personal information
• Update or correct your data
• Request deletion
• Receive a copy of your information in a portable format
• Withdraw a consent you have given
• Manage communication preferences
• Appeal our decision on your request

For residents of California, these rights are protected under the California Consumer Privacy Act (as amended by CPRA), including:

• Right to know what data is collected
• Right to delete personal information
• Right to correct inaccurate information
• Right to non-discrimination
• Right to limit the use of sensitive personal information. We use sensitive personal information only for the purposes the law allows without offering this choice, such as providing the Services you request, so we do not offer a separate “Limit” link.

We do not sell personal information or share it for targeted advertising, and have not done so in the past 12 months, so there is no sale or sharing to opt out of.

Residents of other states with consumer privacy laws, including Connecticut, Colorado, Oregon, Texas and Virginia, have similar rights. Residents of Connecticut, Nevada and Washington have additional rights over consumer health data, described in our Consumer Health Data Privacy Policy.

How to make a request. Many choices are self-service in the app: you can give or withdraw a consent, delete a plan, delete your account, and change your cookie preferences. For anything else, email privacy@mypharoslife.com. We will verify your identity, usually by confirming details associated with your account, and respond within the time the law requires (generally 45 days). You may use an authorized agent, who must show proof of their authority. A copy of your personal information in response to a privacy request is free.

Appeals. If we decline your request, you can appeal by emailing privacy@mypharoslife.com with “Appeal” in the subject line. If we deny your appeal, you may contact your state attorney general.

To exercise your rights: privacy@mypharoslife.com

13. Children's Privacy

The Services are intended solely for adults 18 years of age or older. Nobody under 18 may create an account or accept an invitation. PharosLife does not knowingly collect personal information from individuals under the age of 18, and strictly prohibits any person under the age of 13 from using the Services. Parents and legal guardians may record information about their children in a plan, as described in Section 6. That information comes from the parent or guardian, not the child. It is used only to provide the planning service, and it is never used for marketing or targeted advertising or sold.

If PharosLife becomes aware that personal information has been collected from a child under the age of 13 without verifiable parental consent, we will promptly take steps to delete or otherwise render inaccessible all such information. If you are a parent or guardian and believe your child has provided personal information through the Services, please contact us at privacy@mypharoslife.com.

14. Additional Disclosures

Where we operate. The Services are offered only in the United States, and we store information in the United States. Members of our team and contractors, some of whom work outside the United States, may access it only as needed to operate and support the Services, under confidentiality obligations.

California “Shine the Light.” We do not disclose personal information to third parties for their own direct marketing purposes.

15. Changes to This Policy

We may update this Privacy Policy as the platform evolves. The date at the top shows when it was last updated. If changes are material, we will notify you by email or in the app before they take effect, and we will ask for your consent where the law requires it. Your continued use of the platform after the effective date of any update constitutes your acceptance of the revised policy.

Questions

If you have any questions about this Privacy Policy or how we handle your information, please contact us at: privacy@mypharoslife.com or PharosLife, Inc., Attn: Privacy, 1311 Park St, Unit #676, Alameda, CA 94501.