Privacy Policy

4.1 Account, identity, and contact information

We may collect a name, nickname, profile photograph, email address, telephone number, mailing address, username, authentication information, account settings, communication preferences, and Hub role. Passwords are maintained in protected form; Leaves does not have access to a user’s readable password.

4.2 Family and relationship information

We may collect family-tree and relationship information, invitations, Hub membership information, and information about parents, siblings, children, grandchildren, ancestors, and other relatives. This may include names, dates and places of birth or death, relationships, and other details supplied by users.

4.3 Heritage Content

Heritage Content may include life stories, family histories, photographs, video, audio, voice recordings, documents, letters, cards, genealogical records, timelines, maps, annotations, comments, captions, prompts, transcripts, AI-generated outputs, and related metadata. It may concern the submitting user or other living or deceased people.

4.4 Sensitive Personal Data

Because family stories reflect real lives, Heritage Content may reveal Sensitive Personal Data. Users control whether to submit such information, subject to the rights of other people described in the content. Leaves processes Sensitive Personal Data only to provide user-directed Services, meet legal and security obligations, or for another purpose disclosed at collection and supported by a valid legal basis.

Where the GDPR or UK GDPR applies and Leaves is the controller of processing involving special-category data, Leaves will identify and document an applicable condition under Article 9. When processing is based on explicit consent, Leaves will request that consent separately and allow it to be withdrawn.

4.5 AI, voice, and derived information

We may collect prompts, instructions, transcripts, voice recordings, media, user feedback, and other inputs used to provide AI-assisted features. We may also generate outputs, summaries, captions, tags, embeddings, indexes, relationship suggestions, or other information derived from user-provided content to provide the requested feature.

Voice recordings and voice characteristics are Personal Data and may be treated as biometric or sensitive data under applicable law when used for identification, authentication, or creation of a voice model.

4.6 Transaction information

We collect records of Lifetime Memberships, Credits, gifts, purchases, refunds, transaction dates, amounts, and billing status. Payment-card details are collected and processed by our payment processor. Leaves does not store full payment-card numbers or card security codes on its servers.

4.7 Communications, support, and feedback

We collect messages sent to support, survey responses, contest or promotion submissions, reports of suspected violations, feedback, and other communications with Leaves.

4.8 Device, usage, and technical data

When a user visits or uses the Services, we may collect IP address, browser type and version, device type, operating system, application version, referring and exit pages, access dates and times, session information, pages or features used, error logs, security events, approximate location derived from IP address, and cookie or similar identifiers.

This information may be Personal Data even if it does not directly identify a person by name.

6.1 Provide and administer the Services

We use information to create and authenticate accounts; establish and administer Hubs; manage roles and invitations; store, organize, retrieve, display, share, export, and preserve Heritage Content; provide requested applications and features; deliver purchases; and maintain user settings. Where the GDPR or UK GDPR applies, this processing is generally necessary to perform our contract with the user or to take requested steps before entering a contract.

6.2 Provide AI-assisted and voice features

We use user-provided inputs to generate requested stories, transcripts, summaries, captions, timelines, maps, voice outputs, search results, organizational suggestions, or other requested outputs. Depending on the feature, this processing is based on performance of a contract, the user’s direction, and, where required for sensitive or biometric processing, separate consent.

6.3 Process transactions

We use transaction information to process purchases, issue receipts, administer Credits, prevent payment fraud, provide customer service, maintain financial records, and comply with tax and accounting obligations. This processing is based on performance of a contract, legal obligations, and legitimate interests in preventing fraud and maintaining accurate business records.

6.4 Communicate with users

We use contact information to send account confirmations, security alerts, service messages, support responses, billing notices, policy notices, and other communications necessary to operate the Services. We may send optional marketing communications about Leaves products and services where permitted by law. Users may opt out of marketing messages without losing required service communications.

6.5 Protect the Services, users, and the public

We use information to authenticate users; detect, prevent, and investigate fraud, abuse, unauthorized access, security incidents, and suspected violations; maintain backups and service integrity; enforce the Terms of Use; and protect rights, property, and safety. Where the GDPR or UK GDPR applies, this processing is based on legal obligations or Leaves’ legitimate interests, balanced against the rights of affected individuals.

6.6 Maintain and improve the Services

We use technical data, usage information, feedback, and De-identified Data to diagnose errors, measure performance, understand feature use, improve accessibility, and develop the Services. Leaves does not use Heritage Content to train or fine-tune generalized AI or machine-learning models except through the separate opt-in described in Section 7.

6.7 Comply with law and establish legal rights

We use and preserve information when reasonably necessary to comply with law, respond to valid legal process, exercise or defend legal claims, cooperate with regulators, and satisfy audit, accounting, and recordkeeping requirements.

6.8 No legally significant automated decisions

Leaves does not use Personal Data to make decisions based solely on automated processing that produce legal or similarly significant effects concerning a person. If that changes, Leaves will provide the disclosures and choices required by applicable law before beginning that processing.

7.1 User-requested processing is not generalized model training

Processing Heritage Content solely to produce a user-requested output, organize or retrieve that user’s content, create embeddings or indexes for that user or Hub, or operate a user-directed personalized feature is not generalized model training. Leaves and its service providers may perform that processing only to provide, secure, and support the requested feature and subject to contractual and technical restrictions.

7.2 Separate opt-in for generalized training

Leaves will not use Heritage Content to train or fine-tune a foundation, shared, or generalized AI or machine-learning model unless the affected user first receives a clear explanation of the proposed use and provides a separate, specific, informed, affirmative opt-in. The opt-in will not be bundled into general acceptance of the Terms of Use or this Privacy Policy. Refusing will not prevent access to unrelated core features.

Where withdrawal is technically and legally possible, a user may withdraw that consent prospectively. Leaves will explain any limits on removing information already incorporated into a trained model before obtaining consent.

7.3 Voice features

Before creating a synthetic or personalized voice, Leaves will provide a feature-specific notice describing what voice data is collected, how it is used, whether a voice model or voiceprint is created, who may activate or hear the resulting voice, how long the voice data and model are retained, and how deletion may be requested. Leaves will obtain any consent required by applicable biometric, publicity, voice, or data-protection law.

8.1 Hub members and user-directed sharing

Heritage Content is shared with Account Owners, Family Administrators, Family Members, Guest Members, or other people according to the permissions, roles, and sharing choices selected within the Services. A user may also choose to export content, send it to another person, connect an integration, or enable a separately identified public-sharing feature.

Users should review the audience shown before sharing. People who receive exported or publicly shared content may copy or redistribute it outside Leaves, and Leaves cannot control their later use.

8.2 Service providers acting for Leaves

We disclose only the information reasonably necessary to contracted providers that help us operate the Services, such as cloud hosting and storage providers, security and fraud-prevention providers, AI and API providers, email and notification providers, customer-support platforms, analytics providers, professional advisers, and vendors supporting data export or content production.

Providers acting as our agents or processors must process Personal Data only on our documented instructions, apply appropriate security measures, keep it confidential, assist with applicable privacy obligations, and delete or return it as required by contract. Where the Data Privacy Framework applies, onward transfers are also governed by Section 15.

Some providers, such as payment processors, may act as independent controllers for limited processing they determine under their own privacy policies. We identify those providers at or before the relevant transaction or integration where required.

8.3 User-selected integrations

If a user connects or directs Leaves to interact with a third-party service, Leaves may send or receive the information necessary to complete that request. Before activation, Leaves will describe the categories of information involved when required. The third party’s subsequent processing may be governed by its own privacy policy.

8.4 Legal obligations, security, and safety

We may preserve or disclose information when we reasonably and in good faith believe it is necessary to comply with applicable law, a court order, or other valid legal process; respond to lawful requests from public authorities; enforce our agreements; prevent or investigate fraud, abuse, or security incidents; protect users or the public; or establish, exercise, or defend legal claims.

Leaves will assess the validity and scope of a request, disclose only information reasonably necessary, and notify the affected user before disclosure when legally permitted and reasonably practicable.

8.5 Business transactions

Information may be disclosed in connection with due diligence for, or completion of, a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or transfer of all or part of the business. Any successor receiving Heritage Content must assume privacy and security obligations materially consistent with this Privacy Policy and the Terms of Use. Where reasonably possible, Leaves will provide advance notice and a meaningful opportunity to export Heritage Content before the transfer.

8.6 What Leaves does not do

Leaves does not sell or rent Personal Data or Heritage Content; share either for cross-context behavioral advertising or targeted advertising; disclose either to third parties for their own direct marketing; display third-party advertisements in the Services; or use Heritage Content for generalized AI or machine-learning training without the separate opt-in described in Section 7.

9.1 Private by design

A Family Heritage Hub is private by default. It is not searchable by the public and is not visible to Leaves users who have not been invited, except when an authorized user separately enables a clearly identified public-sharing feature for particular content.

Hub roles affect what users may see and manage. Account Owners and Family Administrators may administer membership and content according to the Terms of Use and the permissions displayed in the Service. Users should not assume that content shared with a Hub is visible only to one individual.

9.2 Information submitted about family members and others

Heritage Content frequently concerns people who did not upload it and may not have a Leaves account. Users must respect the privacy, publicity, intellectual-property, and other rights of living people and must not submit information they have no right to provide.

Where consent, authorization, or notice is required by applicable law, the submitting user must have a lawful basis to provide the information. This does not eliminate Leaves’ own obligations under applicable privacy law. A person whose Personal Data appears in the Services may contact Leaves using Section 17 to ask about applicable access, correction, restriction, objection, or deletion rights.

11.1 Accounts and profile information

Account and profile information is generally retained while the account remains active. Following a verified deletion request, Leaves will disable or close the account within ten business days and delete or de-identify account-level Personal Data from active systems within 90 days, unless a longer period is required or permitted for security, fraud prevention, dispute resolution, or legal compliance.

11.2 Heritage Content and shared Hubs

Heritage Content is retained while the relevant account or Hub remains active and according to user choices, Hub administration, succession, memorialization, and preservation provisions in the Terms of Use. Deleting an individual account does not necessarily delete content submitted or shared by other users, content another user lawfully controls, or an entire multi-member Hub.

Before deleting Heritage Content or a Hub, Leaves may provide an export and notice period as described in the Terms of Use. Users should export content they wish to retain before requesting irreversible deletion.

11.3 Backups

Residual copies may remain temporarily in encrypted backups and disaster-recovery systems until overwritten through the ordinary backup cycle. During that period, backup data is isolated from routine use and accessed only for restoration, security, or legal purposes. For maximum backup-retention periods and data restoration policies, see our Terms of Use.

11.4 Transactions and legal records

Transaction, tax, accounting, consent, security, and legal records may be retained for the period required by applicable law or reasonably necessary to demonstrate compliance, prevent fraud, resolve disputes, and establish or defend legal claims.

11.5 Marketing and suppression records

Marketing preference information is retained until a user changes the preference or the information is no longer needed. Leaves may retain a minimal suppression record after an opt-out so that the preference continues to be honored.

14.1 How to submit a request

Requests may be submitted by emailing [email protected]. The request should identify the right being exercised and the account or information involved.

Leaves may request information reasonably necessary to verify identity, authority, and the scope of the request. An authorized agent may submit a request where permitted by law, but Leaves may require proof of authorization and direct identity verification.

Leaves will respond within the period required by applicable law. GDPR and UK GDPR requests are generally answered within one month, subject to lawful extensions. Qualifying U.S. state requests are generally answered within 45 days, subject to lawful extensions. Leaves will explain a denial and any available appeal process.

14.2 Account and Hub deletion

An Account Owner may request deletion of an account or Hub as permitted by the Terms of Use. Other users may request deletion of their account and Personal Data, but they may not have authority to delete content controlled by another user or an entire multi-member Hub. Leaves will explain any limitation or exception applicable to the request.

14.3 Export and portability

Users may use available export tools or request an export. Export rights depend on Hub role, content ownership, the rights of other people, technical feasibility, and applicable law. Leaves will not use technical measures to prevent users from retaining content they are authorized to export.

14.4 Marketing choices

Users may unsubscribe through a marketing message or adjust available account settings. Opting out of marketing does not stop required account, security, billing, support, or policy communications.

14.5 Rights of people who are not users

A person described or depicted in Heritage Content may contact Leaves to exercise applicable rights. Leaves will consider the requester’s rights together with authenticity, freedom of expression, household use, historical and archival interests, the rights of the submitting user, and other applicable legal considerations.

15.1 Data Privacy Framework participation

Leaves LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF (UK Extension), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

Leaves LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to Personal Data received from the European Economic Area in reliance on the EU-U.S. DPF, that those commitments extend to Personal Data received from the United Kingdom and Gibraltar in reliance on the UK Extension, and that it adheres to the Swiss-U.S. DPF Principles with regard to Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF.

If this Privacy Policy conflicts with the applicable DPF Principles concerning Personal Data transferred in reliance on the DPF, the applicable DPF Principles govern.

To learn more and view Leaves LLC’s certification, visit the Data Privacy Framework participant list and search “Leaves.”

15.2 DPF notice and choice

The categories of Personal Data covered, purposes of processing, and categories of recipients are described in Sections 4 through 8. Leaves may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national-security or law-enforcement requirements.

Individuals whose Personal Data is covered by the DPF may request access to, and correction or deletion of, that data as described in Section 14. They may also choose to opt out before Leaves discloses Personal Data to a non-agent third party or uses it for a purpose materially different from the purposes for which it was originally collected or subsequently authorized. Leaves will obtain affirmative express consent before disclosing Sensitive Personal Data to a non-agent third party or using it for a materially different purpose when the DPF requires that consent.

15.3 Accountability for onward transfers

When Leaves transfers DPF-covered Personal Data to a third-party controller, it will comply with the Notice and Choice Principles and enter into a contract requiring the recipient to process the data only for limited and specified purposes consistent with the individual’s consent and to provide the same level of protection required by the DPF Principles.

When Leaves transfers DPF-covered Personal Data to an agent, it will transfer the data only for limited and specified purposes, require protections at least equivalent to the relevant DPF Principles, take reasonable and appropriate steps to ensure effective processing consistent with Leaves’ obligations, require notice if the agent can no longer meet those obligations, and take reasonable steps to stop and remediate unauthorized processing.

Leaves remains responsible under the DPF Principles if an agent processes DPF-covered Personal Data inconsistently with the Principles, unless Leaves proves it is not responsible for the event giving rise to the damage.

15.4 Questions and complaints

Individuals in the EEA, United Kingdom, Gibraltar, or Switzerland with a question or complaint concerning Personal Data received in reliance on the DPF should first contact Leaves LLC using Section 17. Leaves will investigate and attempt to resolve DPF-related complaints within 45 days.

If a complaint remains unresolved, Leaves LLC has committed, at no cost to the individual, to cooperate with the panel established by the EU data protection authorities, the UK Information Commissioner’s Office, and the Swiss Federal Data Protection and Information Commissioner, as applicable to the relevant transfer, and to comply with their advice.

Leaves LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Under specified conditions described in Annex I to the DPF Principles, an individual may invoke binding arbitration for certain residual claims after other recourse procedures have been exhausted.