Privacy policy

1. Who is responsible

1.1 The controller of the personal data processed through https://www.testaweb.com is WEB EDITIONS II, .

1.2 Any question about this policy, and any request to exercise a right, may be sent to [email protected]. Billing questions go to [email protected] and all other requests to [email protected].

2. Highly personal data

2.1 A will reveals your family situation, the make-up of your estate, the people you wish to benefit and, at times, your funeral wishes or your beliefs. Testaweb processes this data for one purpose only: to enable you to prepare, keep, prove and pass on your wishes to the people you have chosen. It is not sold, rented, or used for advertising or profiling purposes.

2.2 This policy applies under Regulation (EU) 2016/679 (GDPR) and the applicable national data protection laws, including those of the data subject's country of residence where it provides additional protection.

2.3 The service is reserved for adults. No account may be opened for a minor.

3. Data we process

Account data

Email address, first name, last name, language, and a hashed password or the identifier of the social account used to sign in.

Questionnaire answers

Civil status (name, date and place of birth, nationality, address, marital status), family situation (children, dependants, free-text details), beneficiaries and shares, nature and description of assets, assets abroad, funeral wishes, specific bequests, personal message, and designated executor. These are saved as you type.

Will

The formatted text and PDF file of each version, its SHA-256 fingerprint, its version number and status, as well as earlier versions.

Trusted contacts

Name, email, phone number where applicable, chosen access level and date the invitation was accepted.

Attached documents

Files you upload to your space (10 MB maximum each), with their name, type and size.

File log

The date and nature of each action on the file: creation, modification, validation, saving, viewing, download, sharing, revision. It contains neither the text of the will nor the identity of the beneficiaries.

Timestamp data

The document fingerprint, the OpenTimestamps proof, the Bitcoin block, and the anchoring and confirmation dates.

Billing data

Chosen plan, amounts, dates and status of payments and of the subscription, billing address and phone number, invoices. Card details are entered directly with the payment provider and are never received by Testaweb.

Support data

The content of exchanges with support and, where applicable, the death certificate and supporting documents provided by a trusted contact.

Technical data

IP address, browser and device, sign-in and security logs, and visit origin data (source, campaign).

3.2 A questionnaire started without an account is saved under a random identifier stored in a cookie in your browser, with no link to your identity until the account is created, which then attaches it to your file.

4. People you name

4.1 Your will and your space contain data about other people: beneficiaries, executor, family members, trusted contacts. This data is processed only to carry out your wishes as you have set them out in the service.

4.2 A trusted contact may be contacted by Testaweb to inform them of their role, obtain their acceptance and, when the time comes, open the access you have planned for them. A beneficiary who has not been designated as a trusted contact is never contacted by Testaweb.

4.3 Any person named in a file may exercise their rights with [email protected]. A third party's right of access does not extend to the content of a will that has not been opened to them by its author: informing them of it would infringe the author's rights.

5. Why data is processed, and on what basis

5.2 You may withdraw your consent at any time, by deleting the relevant information from your will or by deleting your account, without affecting the lawfulness of prior processing.

5.3 No decision producing legal effects concerning you is taken solely on the basis of automated processing. The questionnaire alerts (for example on forced heirship, the reserved share) are simple information.

6. Who can access your will, and when

6.2 Every access to the file is verified on the server against your account. A trusted contact is identified by a personal invitation link, not by a simple identifier. Documents are never accessible through a public address.

6.3 The public tool for verifying a fingerprint only answers "anchored" or "unknown", together with the date: it reveals neither the document, nor its author, nor its beneficiaries.

6.4 Every designation, withdrawal and access is dated in the file log, which you can view in your space.

7. Processors that handle data

7.1 Data is shared only with the processors below, each bound by a data processing agreement and acting only on instructions, as well as with an authority where the law requires it.

7.2 The content of your will, your questionnaire answers and your attached documents are not transmitted to any of these processors other than the host.

8. Blockchain and transfers outside the European Union

8.1 Your will, your answers and your attached documents are hosted within the European Union and do not leave it.

8.2 The timestamp recorded on the public Bitcoin blockchain covers the SHA-256 fingerprint of the document, and only that fingerprint. This fingerprint contains no readable data and does not allow the document to be reconstructed. As a public blockchain is replicated worldwide and cannot be modified, the fingerprint cannot be removed from it, including after your account is deleted.

8.3 Some of the processors listed in Article 7 (payment, email, audience measurement, security) may process account, billing or technical data outside the European Economic Area (EEA). These transfers are governed by the European Commission's standard contractual clauses or, where the provider is certified, by the EU-US Data Privacy Framework.

9. How long data is kept

9.2 A death certificate submitted to open an access is kept with the file, so that the chronology of the opening can be established.

10. Deleting your data

10.1 From your space, you may at any time delete an attached document, a beneficiary or a trusted contact: deletion is immediate, and removing a trusted contact revokes their access without delay.

10.2 To delete your entire account, use the data erasure request page of the website or write to [email protected]. The request is confirmed by a link sent to the email address of the account. It results in:

• immediate anonymization of your account and closure of your sessions;
• erasure of your will and all its versions, the PDF files, attached documents, beneficiaries, trusted contacts, the log and the timestamp data held by Testaweb;
• retention of only those records that the law requires us to keep (invoices, accounting) for the period stated in Article 9.

10.3 Where a payment has taken place within the last one hundred and twenty (120) days, erasure of the file is deferred until that period expires, during which a bank dispute remains possible; it is then carried out without a further request. Trusted contacts receive no further access from the date of your request.

10.4 Deletion is final. Download your will and its timestamp certificates beforehand if you wish to keep them, and keep the original handwritten copy, which Testaweb does not hold.

11. Security

11.1 Exchanges with the website are encrypted in transit. Passwords are stored hashed, never in plain text. Files are kept in private storage and are released only after verifying that the request comes from the account holder.

11.2 Access to production systems is limited to staff who need it, and actions on a file are logged.

11.3 In the event of a personal data breach likely to result in a high risk to your rights, you and the supervisory authority will be notified within the time limits set by the GDPR.

12. Cookies

12.1 The website uses:

• strictly necessary cookies — session, language, security and anti-bot protection, and the cookie that lets you resume a questionnaire started without an account;
• audience measurement cookies, set only with your consent;
• an attribution cookie that records where a visit came from, to measure campaign performance.

12.2 You may change your choice at any time from the cookie management module or your browser settings. Refusing non-essential cookies does not prevent you from using the Service.

13. Your rights

13.1 You have the right of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw any consent given at any time.

13.2 Most of these rights can be exercised directly from your space: you can view and edit your information, revise your will, download its PDF and your attached documents, and delete the items of your choice. Any other request may be sent to [email protected] and will receive a response within one month, extendable by two months where the request is complex. Proof of identity may be requested where there is reasonable doubt.

13.3 You may lodge a complaint with the data protection authority of your country of residence — in France, the CNIL (www.cnil.fr) — or with that of the country where WEB EDITIONS II is headquartered.

14. After your death

14.1 The choice of trusted contacts and their access level constitutes your instructions regarding the fate of your will after your death. Testaweb complies with them, under the conditions set out in Article 6.

14.2 You may also send [email protected] specific directives on the retention, erasure and disclosure of your data after your death, and amend or revoke them at any time.

14.3 Failing any contrary directive, your heirs may request the closure of your account and the end of the subscription upon presentation of a death certificate. Access to the content of the will remains reserved to the persons you have designated.

15. Changes to this policy

15.1 This policy may be updated. The applicable version is the one published on the website at the time of consultation; any substantial change will be notified by email or in your space.