This Privacy Policy explains how UnclaimedX Private Limited, the company behind Pass Down ("Pass Down", "we", "us", "our"), collects, uses, stores, and protects your personal data when you use the Pass Down mobile application and related services (together, the "Service").
Pass Down is a digital inheritance application. It allows you to securely store passwords, credentials, financial account details, and other important information in an encrypted vault, and ensures this information is passed on to your chosen nominee after your death through our proprietary SAFE Protocol, a multi-stage welfare and verification system designed to prevent fraud and premature access.
This policy applies to three types of people who interact with the Service:
- Owners: individuals who create a Pass Down account to store and protect their information.
- Nominees: individuals designated by an owner to receive access to the owner's vault after verified death. A nominee may be a primary or a backup nominee.
- Beneficiaries: individuals assigned by an owner to specific assets within their vault, for context and identification purposes.
By using Pass Down, you confirm that you have read and understood this Privacy Policy and agree to the collection and use of your personal data as described here.
We collect only the data that is necessary to provide the Service to you. We do not collect data for advertising, profiling, or any purpose beyond what is described in this policy.
When you create a Pass Down account, we collect:
- Name: your full name, used to identify your account and referenced in nominee communications.
- Mobile number: your 10-digit Indian mobile number. This is your primary account identifier and is used for OTP-based login. All logins require a one-time password sent to your registered mobile number.
- Email address: used for account communications, notifications, and policy updates.
All of the above account data is encrypted at rest. Pass Down staff cannot read it in normal operations.
When you add a nominee to your account, you provide the following information about them:
- Full name: used to verify the nominee's identity at the time of vault handover.
- Email address: used to send the nominee their invitation and relevant notifications.
- Mobile number: used for nominee OTP authentication and to reach the nominee during welfare calls if you are unresponsive.
- Supporting identity document (optional): you may choose to upload a copy of any government-issued identity document to assist with nominee verification at the time of vault handover. This is entirely at your discretion. Pass Down does not require or mandate any specific document.
- Relationship to you: used for internal context during communications. This helps our team communicate appropriately during welfare calls.
When you add a beneficiary to a specific asset in your vault, you may provide their name, email address, mobile number, and relationship to you. Email and mobile are optional for beneficiaries.
Nominee and beneficiary data is encrypted. Pass Down staff cannot access it in normal operations. A nominee who wishes to have their data removed should request the account owner to remove them. If the owner is unreachable and the nominee has a legitimate need, they may write to us at hello@unclaimedx.com.
Your vault can store passwords, login credentials, financial account details, notes, instructions, and supporting documents (up to 10 MB per file). You may store whatever information you choose.
All vault contents are encrypted on your device before being transmitted to our servers. Pass Down receives and stores only encrypted ciphertext. We cannot read, access, or decrypt the contents of your vault at any time. This is not a policy choice. It is an architectural choice: Pass Down holds no key that could unlock your vault contents independently.
To deliver core app functionality, maintain service reliability, and improve your experience, we collect the following technical data:
- Push notification token (FCM for Android, APNs for iOS): used to deliver SAFE Protocol check-in reminders and system alerts to your device. Not used for advertising or tracking.
- Device and app information: operating system, app version, and device model, used for compatibility and technical support purposes.
- IP address: recorded in access logs for security monitoring and fraud prevention.
- Basic usage data: we collect non-personal, aggregated data about how users interact with the app, such as which screens are completed, where users drop off during onboarding, and whether key tasks are completed successfully. This helps us identify usability issues, fix bugs, and improve the product experience. It does not include your vault contents, your personal details, or any sensitive information.
Pass Down does not use third-party advertising networks, behavioural tracking SDKs, or analytics tools that share data outside our systems.
We use your personal data for the following purposes only:
- Creating and maintaining your account.
- Encrypting and securely storing your vault contents.
- Managing nominee and beneficiary assignments and the secure handover process associated with them.
- Running the SAFE Protocol: scheduling and processing your daily or weekly check-ins, detecting inactivity, and triggering the welfare escalation sequence when you do not respond.
- Executing the vault handover process after your death is verified through all required stages.
If you are inactive for 24 continuous hours (based on daily or weekly check-in decided by you), the SAFE Protocol places an automated welfare call to your primary nominee's registered mobile number. This call is a safety check to confirm you are well. It is not a debt-collection call, a marketing call, or an initiation of the inheritance process. The call script identifies itself as coming from Pass Down.
If you remain inactive beyond your configured inactivity period, a Pass Down team member places a human call to your nominee to check on your status. To make this call, the team member is provided your nominee's name and mobile number for that specific operational purpose. This access is logged and time-limited.
- Sending you OTPs for login and authentication.
- Sending nominees their invitation when you add them to your account.
- Annual re-verification prompts to confirm your nominee's contact details are still current.
- Service notifications: account alerts, policy updates, and security notices.
- Analysing aggregated, anonymised usage patterns to identify where users face difficulty, reduce drop-offs, and improve the product experience.
- Diagnosing technical issues and fixing bugs using crash and error logs.
- Conducting internal testing and quality assurance.
- Maintaining audit logs of sensitive operations (key fragment access, vault handover events) to support legal defence, regulatory inquiry, or user dispute resolution.
- Retaining death verification records as required by applicable law.
- Responding to lawful requests from courts, government authorities, or regulatory bodies to the extent required by Indian law. Pass Down cannot independently provide access to vault contents even in response to a valid legal order. The zero-knowledge architecture of the system means vault data can only be accessed with the participation of the account owner or, after verified death, the primary nominee. Without their involvement, vault contents remain technically inaccessible to Pass Down and to any third party.
We do not sell, rent, lease, or trade your personal data to any third party for any commercial purpose. Ever.
We share personal data with third-party service providers only where operationally necessary, only to the minimum extent required, and only under contractual obligations that restrict their use of the data. The categories of third parties we work with are:
- Cloud infrastructure provider: encrypted data, including account metadata and key fragments, is stored on servers physically located in India (AWS Mumbai and Hyderabad regions). All data resides within Indian territory.
- Communication service provider: MSG91 is used for SMS-based OTP delivery and Exotel is used for IVR welfare calls and human confirmation calls. These providers process mobile numbers only for the purpose of placing the specific message or call and are bound by contractual data protection obligations.
All personal data is stored and processed within India. We do not transfer personal data to servers outside India.
We may share certain account information with authorities if required by law. We will notify you of such requests where we are legally permitted to do so. However, vault contents cannot be disclosed by Pass Down in response to any legal order, regardless of its origin. The zero-knowledge architecture of the system means that vault data is encrypted on the owner's device and can only be accessed with the active participation of the account owner or, after verified death, the primary nominee. Pass Down does not hold the keys required to decrypt vault contents independently, and this is by design.
The key protections in place are:
- Zero-knowledge vault: your vault contents are encrypted on your device before they reach our servers. Pass Down cannot read, decrypt, or access your vault at any time. This is not a policy statement. It is a technical impossibility given how the system is built.
- Encrypted storage at rest: all personal data held on our servers, including account metadata, nominee details, and key fragments, is encrypted at rest. Pass Down staff cannot view this data in normal operations.
- Secure key management: encryption key fragments are stored in hardware security modules with non-exportable key storage. Fragment reconstruction occurs only inside a secure execution environment and only after multi-party authorisation.
- No single point of access: no single person, including any Pass Down employee or your nominee acting alone, can access your vault. The design requires separate authenticated parties to collaborate before access is possible.
- Data in transit: all communication between the app and our servers uses TLS encryption.
- Need-basis access controls: Pass Down staff access to personal data is event-triggered, purpose-specific, and logged in an immutable audit trail. Access for welfare calls and vault handover operations is the only scenario in which personal data becomes visible to any staff member, and only the minimum required data is surfaced.
Despite these measures, no system is completely immune to security risks. We continuously review and improve our security practices to address emerging threats. In the event of a security incident that affects personal data, Pass Down will notify affected users via their registered email address as soon as reasonably practicable.
You can delete your account by going to Settings > Account > Delete Account.
We retain your personal data only for as long as necessary to provide the Service, meet our legal obligations, or resolve disputes. The following retention periods apply:
| Data Type | Retention Period |
|---|---|
| Vault contents and account data (active account) | Retained for the life of the account. |
| Vault contents and fragments (deletion initiated) | A 30-day dormancy window begins when you initiate account deletion. You may reactivate at any time during this window by logging in. After 30 days with no login, all data and encryption key fragments are permanently and irreversibly deleted from all systems, including backups. Nominee details and key fragments are revoked immediately when dormancy begins. |
| Operational and security logs | Retained for a minimum of 1 year after account closure. |
| Death verification records (death certificate, nominee identity verification, all confirmation records) | Retained for 3 years after vault handover. These records may be required to respond to legal disputes or regulatory enquiries arising from the handover event. |
Under the Digital Personal Data Protection Act, 2023 (DPDPA 2023) and the Information Technology Act, 2000, you have the following rights with respect to your personal data. You can exercise any of these rights by writing to us at hello@unclaimedx.com. We will respond within 30 days.
- Right to access: you may request a summary of the personal data we hold about you. Because of our zero-knowledge architecture, this will cover your account metadata and operational records. We cannot provide vault contents because we cannot decrypt them.
- Right to correction: you may update your name, email address, and mobile number at any time through the Settings section of the app. If you believe any other data we hold is inaccurate, write to us and we will correct it.
- Right to erasure (right to be forgotten): you may delete your account at any time from Settings. A 30-day dormancy period applies before permanent deletion, as described in Section 6. You may reactivate within that window. After the window, deletion is permanent and irreversible.
- Right to withdraw consent: you may withdraw your consent to the processing of your personal data at any time by deleting your account. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
- Right to data portability: you have the right to receive a copy of your personal data in a structured, machine-readable format. An encrypted vault export feature will be available in a future phase of the product. In the interim, you may write to us at hello@unclaimedx.com to request your account data.
- Right to grievance redressal: if you have a complaint about how we handle your personal data, write to us at hello@unclaimedx.com. If you are not satisfied with our response, you may approach the Data Protection Board of India as provided under the DPDPA 2023.
- Right to nominate a representative: under the DPDPA 2023, you may nominate another person to exercise your data rights on your behalf in the event of your incapacity or death.
The Pass Down mobile application does not use cookies. However, our website at www.unclaimedx.com uses cookies and similar technologies to operate the site and understand how visitors use it.
- Essential cookies: necessary for the website to function. These cannot be switched off.
- Analytics cookies: help us understand how visitors interact with our website, such as which pages are visited. We use this data in aggregated, anonymised form only.
We do not use advertising cookies or behavioural tracking cookies on our website. We do not share website visitor data with advertising platforms.
Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or to alert you when cookies are being sent.
We periodically review cookies in use and will update this section accordingly.
If you have any concerns, complaints, or questions relating to this Privacy Policy or the handling of your personal data, please contact us:
Email: hello@unclaimedx.com
Address: UnclaimedX Private Limited, No 40, Abhee Prakruthi, Iggalur, Chandapura, Bangalore South, Bengaluru 560099, Karnataka, India
Website: www.unclaimedx.com
We will acknowledge your complaint within 7 days and aim to resolve it within 30 days. If we require additional time, we will inform you of the reason and the expected resolution timeline.
We may update this Privacy Policy from time to time to reflect changes in the product, our data practices, or applicable law. When we make material changes to this policy, we will:
- Send a notification to your registered email address explaining what has changed and when the changes take effect.
- Post the updated policy on www.passdownapp.com and www.unclaimedx.com with a revised effective date.
Your continued use of Pass Down after the effective date of a revised policy constitutes your acceptance of the changes. If you do not agree with the revised policy, you may delete your account before the effective date of the change. We will not make retroactive changes that reduce your privacy protections without your explicit consent.