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Privacy Policy

Test version. Last updated: May 2026.

Who we are

everly is a digital platform supporting people before, during, and after the loss of someone they love. Our service is being developed in the Netherlands.

Controller: everly B.V. (in formation), c/o Alexandra Sverdlovskaya, the Netherlands. For privacy questions: privacy@everly.partners.

This is a test version

The version you're using is for product validation with a small number of test users. The full data-protection framework — vendor agreements, formal Data Processing Impact Assessment, and the public production setup — is still under preparation. For this reason we ask you not to enter sensitive real data: BSN, bank account numbers, passport details, or full medical history. General information is fine.

What we collect

  • Account & identity: name, email, date of birth, address, GP (Huisarts), phone
  • Onboarding answers: your situation group, who's involved, what you've done, what worries you, emotional state
  • Module content: wishes, ceremony preferences, personal messages, life-story fragments, diary entries
  • Trusted persons: names and contacts you add
  • Documents status: which legal documents you have — never the document files themselves
  • Anonymous usage events: screens visited, steps finished — only after you accept analytics consent
  • Health context: only if you explicitly opt in via the Profile

We do not collect BSN. We do not store bank account numbers, payment card details, or full medical records.

Why we use your data (legal basis under AVG)

  • Contract (art. 6(1)(b)): to provide the service you signed up for
  • Consent (art. 6(1)(a)): for analytics, health context, and any marketing communications — you can withdraw at any time
  • Legitimate interest (art. 6(1)(f)): security, fraud prevention, basic product improvement

Who we share data with

  • Clerk — authentication (email, password, session). Clerk is our login provider; they process your sign-in details on their servers (EU region).
  • Railway — application hosting and managed Postgres database (EU region). Your saved content lives here.
  • PostHog (EU region) — anonymous product analytics. Only fires after you accept consent. The text of what you write is masked and never sent.
  • Anthropic — used by Compass when it's switched on. Compass is currently off during the closed beta, so no chat messages are sent.
  • We do not sell your data to advertisers or data brokers.

How long we keep your data

As long as your account is active, plus up to 30 days after deletion (for backup rotation). You can delete your content or your account immediately from Profile → Privacy & data — "Delete my data" keeps your account and wipes the content, "Delete my account" removes both.

Your rights

Under AVG you have the right to:

  • Access (art. 15) — see what we store. Available in Profile.
  • Rectification (art. 16) — correct any inaccurate data. All fields are editable.
  • Erasure (art. 17) — “right to be forgotten”. Available in Profile.
  • Portability (art. 20) — download your data as JSON. Available in Profile.
  • Object (art. 21) — to specific processing.
  • Withdraw consent (art. 7) — for analytics or other consent-based processing.

You can also file a complaint with the Dutch DPA (Autoriteit Persoonsgegevens).

Security

Data is stored in the EU. Access is restricted to the founding team during the test phase. For the public release we will publish full security details, including encryption at rest and a responsible disclosure programme.

Changes to this policy

We will notify you in the app and via email at least 14 days before any material change.

Contact

Privacy questions: privacy@everly.partners
General: hello@everly.partners