Privacy Policy

1. Who we are

Simple Wills is a self-serve document preparation tool operated by Vistera (“we,” “us,” “our”), based in Vancouver, British Columbia. Vistera is not a law firm and does not provide legal advice. Our Privacy Officer can be reached at:

Privacy Officer
Vistera — Vancouver, BC
info@spraggsgroup.com · 778-800-8866

2. What personal information we collect

We collect only the information necessary to generate and deliver your Will. The categories of personal information we collect include:

• Identity information: full legal name, date of birth, address, city, postal code, email address, phone number, province of residence, and Canadian residency status.
• Family and relationship details: marital status, spouse’s name (if applicable), separation or divorce dates (if applicable), children’s names and dates of birth, and whether any dependents have a disability.
• Estate planning details: executor and guardian names, contact information, and relationships; beneficiary names, relationships, and locations; asset distribution instructions; specific gift descriptions and recipients; and funeral wishes.
• Technical data: IP address, browser type and version (user-agent), collected automatically for security and consent audit purposes.
• Account data: email address used for sign-in, session tokens.

We do not collect or store credit card numbers. Payment is processed entirely by Stripe.

3. How we use your information

We use your personal information for the following purposes:

• Will generation and delivery: to create your Will document, store it securely, and deliver it to you by email.
• Payment processing: to process your purchase through Stripe (we send only your email address and order reference to Stripe).
• Account and authentication: to create and manage your account, send sign-in links, and save your form progress.
• Executor notification: if you opt in, to send a notification email to the executor(s) you have named, informing them of their appointment. These emails are sent on your behalf.
• Escalation referral: if our tool identifies that your estate may require a lawyer’s review (for example, due to a separation, disabled dependent, or other complex circumstance), we share your contact information and the reason for referral with Vistera lawyers so they can follow up with you.
• Customer support and records: to maintain records necessary for customer support, compliance, and legal obligations.
• Consent audit trail: to record the date, time, IP address, and device information associated with your acknowledgment of each disclosure, as required for legal compliance.

4. Third-party service providers

We share personal information only with services necessary to operate Simple Wills. We do not sell your personal information.

• Stripe (payments) — receives your email address and order reference to process payment. Stripe’s privacy policy governs their handling of payment data.
• Resend (email delivery) — receives email addresses and message content to deliver sign-in links, will delivery emails, and executor notification emails.
• Cloudflare (document storage) — stores your completed Will PDF and intake data in encrypted cloud storage (Cloudflare R2).
• Zoho (CRM and scheduling) — receives your name, email, phone number, city, and province to manage customer records and, where applicable, escalation referrals.
• Neon (database) — stores your account, will records, consent records, and draft progress in a secure PostgreSQL database.

5. Cross-border data transfers

Some of the service providers listed above store and process data on servers located in the United States, including Neon (AWS US-East-1), Stripe, Resend, Zoho, and Cloudflare. By using Simple Wills, you consent to your personal information being transferred to, stored in, and processed in the United States by these providers. Each provider is contractually required to protect your information in accordance with their published privacy policies and applicable law.

6. Cookies and browser storage

We use essential cookies for sign-in sessions only. We also use your browser’s local storage and session storage to save your form progress so you can return to where you left off. We do not use advertising, analytics, or tracking cookies.

7. Data retention

We retain your personal information only as long as necessary for the purposes described above:

• Completed wills and consent records: retained for 7 years from the date of purchase, after which they are securely deleted. This period reflects standard record-keeping practices for legal documents.
• Draft (in-progress) data: retained for 90 days from last activity, then automatically deleted.
• Account data: retained for as long as your account is active. You may request account deletion at any time (see “Your rights” below).
• Escalation referral records: retained in our CRM for as long as needed to complete the referral, then archived according to the firm’s standard retention schedule.

8. Security

We protect your information using industry-standard security measures, including encrypted connections (TLS), secure cloud storage, access controls, and signed temporary download links that expire automatically. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your rights

Under the Personal Information Protection Act (BC) and the Personal Information Protection and Electronic Documents Act (Canada), you have the right to:

• Request access to the personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of your personal information, subject to legal retention requirements.
• Withdraw consent for future collection or use (note: this may prevent us from providing the service).

To exercise any of these rights, contact our Privacy Officer at info@spraggsgroup.com. We will respond within 30 days.

10. Breach notification

In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm, we will notify you and the Office of the Privacy Commissioner of Canada as required by PIPEDA. Where applicable, we will also notify the BC Information and Privacy Commissioner under PIPA.

11. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last updated” date at the top of this page. Continued use of Simple Wills after changes are posted constitutes acceptance of the updated policy.

12. Contact

If you have questions or complaints about our privacy practices, please contact:
Privacy Officer
Vistera — Vancouver, BC
info@spraggsgroup.com · 778-800-8866

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the BC Office of the Information and Privacy Commissioner.