1. Introduction

This Privacy Policy explains how EdConsult LLC d/b/a Homegoing360 (“Homegoing360,” “we,” “us”) collects, uses, discloses, and protects personal information when you use homegoing360.com, app.homegoing360.com, co-branded/white-label instances, and related services (the “Platform”). By using the Platform, you agree to this Policy. If you do not agree, do not use the Platform.

We recognize that our Platform is used during profoundly sensitive times, and that it involves information about both living users and deceased individuals. We treat this information with corresponding care.

2. Information we collect

2.1 Information you provide

• Account information: name, email, password, phone number, role (family member, executor, concierge, provider, designer, partner).
• Estate and family information: decedent name, dates, relationships, state, invited family members, task and status data.
• Documents and content: files you upload to your vault, obituaries, memorial and tribute content, photos, videos, ledger entries, notes, and messages.
• Financial/transaction information: billing details processed by our payment processor (we do not store full card numbers), plan selections, and purchase history.
• Bank account information, only if you choose it. If you use the bank-import feature, our provider connects to your financial institution and returns account names and balances. We do not receive your banking credentials. See Section 4.
• Provider/partner information: business details, licensing, insurance, tax information (for example, W-9), service categories, and payout details.
• Communications: messages to us and to third parties through the Platform, and support requests.

2.2 Information you provide about other people

This is unusual enough to say separately, because two parts of the Platform collect information about people who are not our users and who never interacted with us:

• The guest registry. If a family enables a registry for a service, attendees enter their own name and may add an email address, a postal address, and a message. That information belongs to the family, is visible only to the estate’s members, and is never used to market anything to the attendee.
• The obituary’s “survived by” list. Naming living relatives in an obituary is ordinary practice, and the Platform treats it as sensitive anyway. The working draft is never published by anything. Publishing an obituary that names living people requires a separate, explicit acknowledgement that reads the list back to the family first, and it is only possible on a memorial page the family has deliberately enabled.

If you are named in either and want the entry removed, contact care@homegoing360.com and we will work with the family that holds it.

2.3 Information collected automatically

• Usage and device data: IP address, browser and device type, pages viewed, actions taken, timestamps, and referring URLs.
• Cookies and similar technologies: as described in our Cookie Policy. We do not use analytics, advertising, or tracking cookies.

2.4 Information from third parties

Payment processors, identity/background verification services (for providers and concierges), and co-brand partners who refer you.

2.5 Sensitive information

Some information may be sensitive (for example, health-related details a family records, or information about a deceased person). We collect it only as needed to provide the services you request and handle it accordingly. Homegoing360 is not a HIPAA covered entity or business associate in the ordinary course; however, where a concierge or provider relationship implicates health information, additional obligations may apply.

Encryption you control. Account numbers, and — at your option — every field in a life plan, can be encrypted on your own device with a passphrase we never receive. We cannot read those fields, and we cannot recover the passphrase. The Platform tells you plainly what that lock covers and what it does not before you rely on it.

3. How we use information

We use personal information to:

• Provide, operate, maintain, and secure the Platform and the services you request;
• Create and manage accounts, estates, and family collaboration;
• Process payments, subscriptions, and payouts;
• Generate AI-assisted guidance, documents, memorial pages, and print products;
• Facilitate connections and transactions with third-party providers you choose;
• Communicate with you (service messages, and text reminders if you opt in);
• Provide customer support and respond to requests;
• Detect, prevent, and address fraud, abuse, and security incidents;
• Comply with legal obligations and enforce our agreements;
• Analyze and improve the Platform.

We do not send marketing email. Everything we send is a service message about something you are doing, and the weekly family digest carries an unsubscribe link that works without signing in.

AI processing. Inputs to AI features may be transmitted to third-party AI providers to generate output. See our AI Usage Disclosure, which names every one of them. We do not permit our AI providers to use your inputs to train their general models.

4. How we share information — our subprocessors

We share personal information as follows.

Service providers and subprocessors. Vendors that host, process, or support the Platform, under contract and only as needed. As of this version, they are:

Vendor	What it does	What it receives
Cloudflare	Hosting, edge network, error reporting	Requests, IP addresses, error traces
Supabase	Database, file storage, authentication	Everything you store on the Platform
Stripe	Payments and payouts	Card data (directly from you), billing details
SendGrid	Transactional email	Recipient address, message content
Twilio	Text reminders, if you opt in	Mobile number, message content
Anthropic	The Guide, drafting, document reading	The text and documents you send to an AI feature
ElevenLabs	Read-aloud (text to speech)	The text being read aloud
HeyGen	The face-to-face video Guide	Your side of the conversation
Plaid	Bank import, if you use it	Institution credentials entered directly with Plaid, returned account names and balances
Authorize.Net	Flower orders	Card data, tokenized in your browser
Prodigi	Keepsake and print manufacturing	Names, shipping address, artwork
FedEx Office	Program printing, if you choose it	The file you send to print
LearnWorlds	Academy course delivery	Student name and email
Sentry	Error monitoring	Error traces, without message bodies or credentials

Several of these are only involved if you use the feature they power. If you never use bank import, Plaid receives nothing; if you never order flowers, Authorize.Net receives nothing.

Third-party providers you select. When you engage a concierge, provider, designer, or partner, we share the information necessary to fulfill your request.

Co-brand/white-label partners. Limited information necessary to provide a partner-branded experience. Families’ payment details are processed by Homegoing360 and are not shared with the partner.

Other users you authorize. Family members and collaborators you invite, and viewers of memorial pages you make public.

Legal and safety. To comply with law, respond to lawful requests, enforce agreements, and protect rights, safety, and property.

Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

We do not sell your personal information, and we do not run advertising. We do not use advertising or analytics cookies, so there is no “sale” or “sharing” of the kind the CCPA/CPRA contemplates for those purposes. The opt-out in Section 8 remains available regardless.

5. Cookies and tracking

We use only the cookies required to keep you signed in and to keep the Platform secure. We do not use analytics, advertising, or cross-site tracking cookies of any kind. Because there are no non-essential cookies, there is nothing to consent to and no consent banner. See our Cookie Policy for the specifics, including what would change if that ever stopped being true.

6. Data retention

We retain personal information for as long as your account is active and as needed to provide the services, and thereafter as required for legal, tax, accounting, dispute-resolution, fraud-prevention, and backup purposes. Our Data Retention Policy sets out the periods and the two categories that are kept by design:

• Documents in a locked vault are not deleted for non-payment. If a plan or subscription lapses, the vault locks — nothing new can be added, and everything already there stays downloadable.
• A sealed recording cannot be deleted by anyone, including us. That is the point of sealing it, and you are told so before you seal.

7. Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls enforced in the database itself rather than only in the interface, and the customer-controlled encryption described in Section 2.5. No system is perfectly secure, and we cannot guarantee absolute security. In the event of a data breach affecting your information, we will notify you and the authorities as required by applicable law.

8. Your privacy rights

Depending on your state of residence, you may have rights to:

• Know / access the personal information we hold about you;
• Correct inaccurate information;
• Delete your information, subject to Section 6 and to Section 7.6 of the Terms;
• Portability — receive a copy in a portable format;
• Opt out of “sale,” “sharing,” or targeted advertising, and of certain profiling;
• Limit use of sensitive personal information, where applicable;
• Non-discrimination for exercising your rights.

How to exercise. Email privacy@homegoing360.com. We will verify your identity before fulfilling a request, and we will respond within the timeframes required by law. You may use an authorized agent where permitted. If we deny a request, you may appeal by replying to our response.

What we cannot delete, and we will tell you plainly rather than quietly failing. A sealed recording cannot be deleted by anyone, by design. Content you contributed to an estate that other family members still rely on may be retained for them. Records we are legally required to keep — payment records, consent records, fraud-prevention records — are retained for their required period. Everything else is deleted or de-identified.

Opt-out preference signals. We honor recognized preference signals, including Global Privacy Control. Since we do not use advertising or analytics cookies, there is in practice nothing for such a signal to switch off.

9. Children’s privacy

The Platform is not directed to children under 18, and we do not knowingly collect personal information from children under 13 (or as defined by applicable law). If we learn we have collected such information, we will delete it. Note that families may record information about deceased minors; such information is treated as estate content.

10. Deceased individuals

Information about a deceased person entered by a user is treated as content provided by that user. Rights regarding a decedent’s information are limited under most privacy laws; requests concerning a decedent should be directed to care@homegoing360.com and may require proof of authority.

11. Third-party links and services

The Platform may link to or integrate third-party sites and services with their own privacy practices. We are not responsible for those practices; review their policies.

12. International users

The Platform is intended for U.S. users and data is processed in the United States. If you access it from outside the U.S., you consent to processing in the U.S.

13. Changes to this Policy

We may update this Policy. Material changes will be posted with a new version number and “Last updated” date and, where required, additional notice. Continued use after the effective date constitutes acceptance.

14. Text message (SMS) program

Homegoing360 offers an optional SMS reminder program for people settling an estate. Participation is voluntary and requires your express opt-in.

How you opt in. You enter your mobile number in the app and check a consent box agreeing to receive text-message reminders about the estate’s tasks and deadlines. We record the exact sentence you agreed to, its version, and the date and time. You receive a one-time confirmation message when you subscribe.

Message frequency. Frequency varies with the estate’s tasks and approaching deadlines — occasional reminders, not a fixed number.

Rates. Message and data rates may apply, according to your mobile carrier plan.

We do not share or sell your mobile number. We do not sell, rent, or share mobile phone numbers or SMS opt-in information with third parties or affiliates for their own marketing or promotional purposes. Mobile information is used only to operate this reminder program, and is shared only with Twilio, the service provider that delivers the messages.

How to opt out. Reply STOP to any message, or turn off text reminders in the app. Reply HELP for assistance, or contact care@homegoing360.com. Message delivery is subject to your carrier; carriers are not liable for delayed or undelivered messages.

15. Contact

Privacy questions or requests: privacy@homegoing360.com General: care@homegoing360.com EdConsult LLC d/b/a Homegoing360 — 1098 Ann Arbor Rd W, #479, Plymouth, MI 48170