Privacy Policy

Escendant Ltd
Last Updated: 22/10/2025
Status: Published

Escendant Ltd (Company No. 13914686) provides digital memory preservation and AI-powered legacy services through our app and website at escendant.ai. We help you capture, organize, and share your life stories and memories with others across generations.

Who We Are

We are Escendant Ltd, a UK company providing digital legacy and memory preservation services. This Privacy Policy explains how we collect, use, and protect your personal information when you use our Services.

Definitions

“Biometric Identification” means processing of biometric data for the purpose of uniquely identifying, authenticating, or verifying a natural person, including voice or facial recognition used for identity verification.

“Text-Processing Purposes” means operations performed on text content provided by, or derived from, user inputs (for example, transcriptions of audio), including analysis to attribute content to individuals within the text, tagging, organisation, search, recommendations, and similar functionality. It excludes identity verification, authentication, or other biometric identification.

What Information We Collect

When you create an account:

  • Name and email address
  • Date of birth
  • Payment information
  • Account preferences and settings

When you use our services:

  • Personal memories, stories, and life experiences you share
  • Photos, videos, documents, and audio recordings you upload
  • Conversations with our AI assistants and other users
  • Voice recordings for AI voice recreation features and voice input of memories/stories
  • Facial photos for digital avatar creation
  • Profile information you choose to share (occupation, location, family details, etc.)
  • Sensitive personal information you explicitly consent to share (religion, ethnicity)

Information shared by other users:

  • Profile information other users share with you in conversations
  • Memories and content others share with you privately or in groups
  • Voice recordings where you are a participant (subject to recording consent)

Automatically collected:

  • Basic app usage information
  • Device type and operating system
  • Error logs for technical support

Legal basis: We process your personal data as necessary to perform our contract with you (Article 6(1)(b)), including AI processing of your content, use of your basic profile information for personalisation, and core service delivery. We request your consent (Article 6(1)(a)) at the point you first use features that require it, including voice input processing, AI voice and avatar creation, and internet publication. We rely on our legitimate interests (Article 6(1)(f)) for in-app community sharing (with opt-out), optional AI analysis features (with opt-out), and marketing and adverising use of Public Engrams that you have explicitly made Public, with clear global and per‑item controls. We rely on your explicit consent (Article 9(2)(a)) for any sensitive profile information you choose to share, collected when you first access those profile fields.

How We Use Your Information

Core Services:

  • Organize and preserve your digital memories
  • Enable AI-powered conversations through our AI assistants
  • Create voice and facial recreations for your digital legacy
  • Facilitate sharing with family, friends, and the broader community
  • Process content for The Human Archive (external website publication if you choose)

AI Processing:

We use AI services (see our sub-processor list at https://thehumanarchive.com/sub-processors) to:

  • Analyze and organize your content
  • Power AI assistant conversations
  • Generate insights from your memories
  • Improve content searchability and organization
  • Process voice recordings for transcription and speaker separation (with your consent obtained when you first use voice features); any identification is performed on the transcribed text for Text-Processing Purposes, not for Biometric Identification
  • Voice transcription may be performed by AssemblyAI, Groq and Fireworks (see our Sub‑Processors list).

For detailed information about how AI processes your information, please see our AI Transparency Notice at https://thehumanarchive.com/ai-transparency.

Service Delivery:

  • Send important account notifications
  • Provide customer support
  • Ensure platform security and prevent fraud

App Analytics

We use Firebase Analytics to improve our app performance and user experience. This helps us:

  • Fix bugs and crashes
  • Understand which features are most useful
  • Improve app performance
  • Plan future improvements

Data used for analytics is pseudonymous and does not identify individual users. We configure Firebase to avoid collecting precise location and advertising identifiers and to truncate IP addresses where possible. You can opt out of analytics at any time in your device or in‑app settings, and we will honour such opt‑outs promptly.

Data Sharing Between Users

How Data Sharing Works

Our Services enable you to share information with other users through various levels:

Profile Information Sharing:

  • Basic information (name, year of birth) is shared by default for meaningful interactions
  • Additional profile details (occupation, location, family information) are optional and controlled by you
  • Sensitive information (religion, ethnicity) requires explicit consent and is disabled by default

Content and Memory Sharing:

  • Private Sharing: Share memories with specific individuals or groups
  • Community Sharing: Share publicly within the Escendant user community
  • The Human Archive: Publish selected content to the open internet
  • Conversation Sharing: Information shared in conversations becomes part of recipients’ interaction history

When You Share Information With Others

When you share information:

  • Your shared information becomes part of other users’ conversation experience
  • Shared information may appear in their chat histories and AI interactions
  • Your shared information may be included when they export their personal data
  • This reflects the collaborative nature of conversations and memory sharing

When Others Share Information With You

When other users share information with you:

  • Their shared information becomes part of your conversation experience
  • This shared data helps create meaningful, personalized interactions
  • Their shared information appears in your chat history and AI conversations
  • Other users’ shared information is included in your data exports as part of your legitimate conversation records

Controlling Your Sharing Preferences

You can control your sharing preferences at any time through your account settings. Community sharing is private by default – you must explicitly choose to share each item, and you can opt out of sharing features entirely.

What Changes Immediately:

  • Future sharing stops – no new information is shared
  • You’re removed from new conversations involving data sharing
  • Your profile becomes private for future interactions
  • AI stops using your information in responses to other users

What Cannot Be Changed:

  • Information already shared in past conversations remains in those conversations
  • Previously exported data by other users cannot be recalled
  • Existing conversation histories remain intact and complete
  • Content published to The Human Archive may persist on the internet

This approach ensures conversation histories remain coherent while respecting the permanent nature of sharing decisions.

Your Content, Voice and Image Data

Data Ownership

You own your memories. We never use your personal content, stories, or voice data to train, retrain, or improve AI models, or for any advertising or commercial purpose beyond delivering your requested services, except for marketing use of Public Engrams as described in this policy and subject to your global and per‑item controls.

Voice Processing

When you use voice features:

  • Voice Input: We process speech temporarily for transcription only
  • Voice Recreation: We create AI voice models for your digital legacy (deletable anytime)
  • Multi-Speaker Processing: When recording with others, you are responsible for obtaining appropriate consent from all speakers

We process voice data temporarily for transcription and speaker separation. Any identification is performed on text outputs for Text-Processing Purposes only; we do not use biometric templates for identification. Voice analysis data is deleted immediately after transcription completion, except for voice recreation models you choose to create.

Digital Avatars

Purpose: We store your facial photos and avatar model weights to create and generate digital avatars for your digital legacy. We do not use facial data for recognition, identification, authentication, AI model training, or product improvement—only for generating your personal avatars.

Third-Party Processing: Facial images are shared with Features & Labels, Inc. (FAL) to generate avatars and create the model. FAL does not retain your images after processing, and we have contractual measures (Standard Contractual Clauses with UK Addendum) requiring deletion from FAL’s systems after completion.

What We Store: Your facial photos, avatar model weights (enabling future avatar generation without re-uploading images), and generated avatar videos —all as part of your digital legacy content.

Retention & Deletion: Facial photos and generated avatars can be deleted anytime directly in the app. Avatar model weights are retained to enable future avatar generation and are deleted when you delete your account (processed within 30 days).

Legal Basis: Explicit consent (Article 6(1)(a) UK GDPR), obtained when you first use avatar creation.

For more information about FAL and our data processing safeguards, see our Sub-Processors List at https://thehumanarchive.com/sub-processors.

The Human Archive

Content shared publicly requires your explicit consent for each story. Published content becomes publicly available on the internet and may be difficult to remove completely once published.

Marketing and Advertising Use of Public Engrams

If you set an Engram to Public (including publication to The Human Archive), we may use that Public Engram for:

  • Targeted advertising and campaign optimisation (for example, selecting audiences or creative themes based on Public Engram topics)
  • External marketing and promotional materials

Your controls:

  • Global and per‑item controls let you disable marketing use at any time. A global disable prevents the use of any of your Engrams for marketing regardless of per‑item settings.
  • We will only use Engrams that you have explicitly set to Public; private, group, or shared‑with‑specific‑people Engrams are excluded.
  • Changes take effect for future use; materials already distributed may not be retractable, but we will stop future use once you change settings.

Privacy Controls and Consent Management

Types of Processing Controls

Our Services use different lawful bases requiring different types of user controls:

Contract-Based Processing (Required for Service):

  • Core AI chatbot conversations and essential content processing
  • Use of basic profile information for personalisation

Consent-Required Features (obtained when you first use each feature):

  • Voice input processing for spoken memory creation
  • Biometric recreation (voice and avatar creation)
  • Human Archive publication to the open internet

Legitimate Interests with Opt-Out:

  • In-app community sharing (private by default; opt-out available)
  • Optional AI analysis for enhanced organisation and insights

Special Category Data:

Sensitive personal information (religion, ethnicity, family details) requires explicit consent under Article 9 of UK GDPR and is always disabled by default. We request this consent when you first access these profile fields.

Managing Your Privacy Controls

  • Contract-based processing cannot be disabled as it’s necessary for service delivery
  • Consent-based features are optional and can be withdrawn at any time
  • Legitimate interests features provide opt-out controls and take effect immediately
  • You maintain granular control over each type of optional data processing
  • Some features require up to 30 days for deletion of stored models (voice recreation, avatars)
  • Core platform functionality requires only acceptance of our Terms & Conditions

Voice Recording Responsibilities

When using voice features involving other people:

  • You are responsible for informing all speakers about AI voice processing
  • You must ensure everyone understands voice analysis includes speaker separation and text-based identification (not Biometric Identification)
  • You must obtain appropriate permission before recording
  • You must stop recording if anyone objects to voice processing
  • You remain solely responsible for compliance with local recording laws

International Data Processing

Your data may be processed by our AI service providers in various countries including the USA. We maintain appropriate safeguards including Standard Contractual Clauses (SCCs) with the UK Addendum or the UK International Data Transfer Agreement (IDTA), and regularly review the security of these arrangements. Our current sub-processor list is available at https://thehumanarchive.com/sub-processors. We will provide at least 30 days’ advance notice of any addition or replacement of a sub-processor (except for urgent substitutions required for security or continuity, in which case we will notify you as soon as reasonably possible). You may object on reasonable data-protection grounds. We will work in good faith to provide a commercially reasonable alternative or to disable the affected feature. If no feasible alternative is available, you may cancel the affected Services (in whole or part) without penalty. For direct purchases from us, we will provide a pro‑rata refund of any prepaid fees for the unused period of the affected Services. For purchases made via app stores, refunds are subject to the applicable app store’s policies. For business deployments, this applies alongside our Business Data Processing Agreement.

Government and Law Enforcement Requests

If we receive a legally binding request from a public authority for access to personal data, we will:

  • Notify you (and, where applicable, your Business Customer) before disclosure unless the law prohibits notice
  • Challenge overbroad or unlawful requests where reasonable
  • Disclose only the minimum data necessary to comply with the request

How Long We Keep Your Data

Active accounts:

We keep your data for as long as you maintain your account.

Digital legacy:

After death, your account continues indefinitely as this is the core purpose of our digital legacy product. Indefinite retention is essential to preserve your memories, enable ongoing AI conversations representing you, deliver future time capsules, and maintain access for designated contacts across generations. Designated Trustees cannot directly delete or modify Content post‑death; any deletion, modification, or takedown must be requested from Escendant and may require proof of legal authority (for example, executor/administrator documentation) and, where appropriate, a court order. Verified representatives may request account closure; we will assess requests against documented wishes and applicable law.

Deleted accounts:

Most data deleted within 30 days; some backups may take up to 90 days.

Shared Information:

Information you’ve shared with other users may remain in their conversation histories and data exports even after you delete your account, reflecting the permanent nature of sharing decisions.

If a Business Customer ends its contract

If you access our Services through a business (for example, a charity, care provider, or other organisation) and that Business Customer terminates its contract with us:

  • We will invite you to continue with an individual (B2C) account. If you accept, you will be asked to accept our Terms & Conditions and, where applicable, subscribe as a normal B2C customer. Your account continues without interruption, and your digital legacy settings (including posthumous content and designated contacts) remain in effect.
  • If you choose not to continue as a B2C customer, or do not complete the conversion, your account will be treated as a terminated account and handled under “Deleted accounts” above.
  • For deceased users with active digital legacy settings, we will contact designated Trustees (where details are available) to allow them to continue the account under a B2C subscription or request closure. If they do not continue, the account will be handled under “Deleted accounts.”

Your Rights

You can:

  • Access all your personal data
  • Correct inaccurate information
  • Delete your account and data at any time
  • Export your data in standard formats (including information others have shared with you)
  • Object to AI processing (though this will significantly restrict service features)
  • Withdraw any consent you’ve given for optional features
  • Lodge complaints with the ICO (ico.org.uk)

Data Export Rights

When you request a data export:

  • Your export includes your complete conversation history
  • This includes information other users have shared with you in conversations
  • Other users’ shared information becomes part of your legitimate conversation records
  • This ensures your data export provides a complete record of your Escendant experience

If you object to AI processing:

You can still use basic storage features, but the following will no longer be available: all AI chatbots, voice recreation, avatar creation, and advanced text/document/image analysis. While the app remains usable, it will be very restricted compared to the full service experience.

To exercise these rights, contact us at support@escendant.ai

Business Deployments

Controller-Processor Relationship: When you access the Services through a Business Customer (for example, a charity, care provider, or other organisation), that Business Customer acts as the “Controller” under UK GDPR, and Escendant acts as a “Processor.” This means:

Your Business Customer is Responsible For:

  • Obtaining proper consent for your participation in digital legacy services
  • Ensuring residents have appropriate capacity to consent to digital legacy services or that proper legal authority exists for participation in care settings
  • Managing family communications about your account and digital legacy decisions
  • Ensuring your wishes regarding posthumous content are respected and documented
  • Providing appropriate support for your digital legacy choices
  • Acting as the primary contact for any data protection enquiries or requests

Escendant’s Role:

  • Processing your personal data only according to your Business Customer’s instructions
  • Providing the technical platform and AI services as directed
  • Implementing appropriate security measures to protect your information
  • Supporting your Business Customer in responding to any data protection requests

Your Rights: You maintain all the same data protection rights as other users. However, requests should typically be directed to your Business Customer first, who will coordinate with us as needed.

Data Processing Agreement: Your Business Customer has signed a comprehensive Data Processing Agreement with Escendant that governs how we handle personal information and ensures compliance with UK GDPR requirements.

If your Business Customer ends its contract

If your Business Customer ends its contract with Escendant, we will contact you (and, where appropriate, your designated Trustees) to offer the option to continue with an individual (B2C) account. If you accept, you will be asked to accept our Terms & Conditions and subscribe as a normal B2C customer.

Controller changes on conversion

When you continue as a B2C customer, Escendant becomes the data controller for your personal data going forward, and requests should be directed to us. If you do not continue, your account will be treated as terminated and handled under “Deleted accounts.”

Data Security

We use reasonable and proportionate technical and organisational measures to protect your information. We continually assess and improve our security controls in light of evolving risks and industry practices. Our measures include:

  • Encryption of data in transit and at rest
  • Secure cloud storage with AWS
  • Security updates to our systems
  • Limited employee access on a need-to-know basis
  • Appropriate safeguards for international data transfers

Breach Notification

If we become aware of a personal data breach that affects your personal information, we will notify the UK Information Commissioner’s Office (ICO) and, where required, affected individuals without undue delay and, in any event, within 72 hours of becoming aware of the breach, unless a delay is permitted or required by law. Our notifications will describe the nature and scope of the breach, the likely consequences, the measures taken or proposed to address it, and a contact point for further information.

Contact Us

Data Protection queries: privacy@escendant.ai
Security enquiries: security@escendant.ai
General support: support@escendant.ai
Address: Escendant Offices, Blisworth Hill Farm, Stoke Road, Blisworth, Northamptonshire, NN7 3DB

Changes to This Policy

We’ll notify you of significant changes via email or app notification. Your continued use constitutes acceptance of updates. When we make material changes to this Privacy Policy, we will provide clear summaries of what changed and why, to help you understand how updates affect you.

We maintain records of policy versions and significant changes for transparency and compliance purposes.

This policy is designed to be clear and honest about how we handle your precious memories and personal information, including how sharing with other users works. If anything isn’t clear, please ask us.