Privacy Policy (Project Sunset)

Effective Date: October, 4 2025

Legal Entity: #TheElaboratePlan, LLC, legal@projectsunset.app

  1. What this policy covers

    Project Sunset ("we," "us," "our") operates a platform that helps users connect with non-medical end-of-life companions ("Companions"). This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use our websites, apps, and services (the "Services").

    Not HIPAA-regulated: We are not a healthcare provider or a covered entity under HIPAA. Do not upload protected health information intended for treatment, payment, or operations. If you do, it is handled under this Privacy Policy — not HIPAA.

  2. Information we collect
    • Account and Profile: name, email, phone, password (hashed), city/region, timezone, pronouns, language preferences, availability, profile photos.
    • Sensitive or Optional Attributes (with explicit consent): preferences or attributes such as religion or spirituality, cultural background or ethnicity, language proficiency, and end-of-life rituals for the purpose of better matching. Providing this is optional and you can remove it at any time.
    • Usage Data: app interactions, device info, IP address, cookies, approximate location, referral or UTM.
    • Communications and Content: messages, reviews, ratings, support requests, uploaded files.
    • Verification and Safety: ID checks, background screening status (pass/fail and date), sanctions or sex-offender registry checks where permitted by law, trust and safety notes.
    • Payment Data: billing address, last4 and tokenized payment method via our processor; we do not store full card numbers.
    • Third-Party Sources: identity verification vendors, payment processors, background check providers (where legal and with your authorization).
  3. How we use information (legal bases)
    • Provide and improve the Services (contract; legitimate interests).
    • Matching and discovery based on preferences and availability (consent where sensitive data is used).
    • Trust and Safety: prevent harm, detect fraud, enforce policies, and facilitate dispute handling (legitimate interests; legal obligations).
    • Payments and accounting (contract; legal obligations).
    • Communications: service updates, booking alerts, policy changes (contract or legitimate interests); marketing with opt-out (consent where required).
    • Research and analytics in aggregate or de-identified form.
  4. When we share information
    • Counterparties: information you choose to share in messages, profiles, and bookings is visible to the other party.
    • Service Providers: hosting, analytics, messaging, KYC or ID verification, background checks, payment processors, customer support. Bound by contract to use data only for us.
    • Legal and Safety: to comply with law, respond to lawful requests, protect rights, safety, and property, or investigate abuse.
    • Business Transfers: in a merger, acquisition, financing, or sale of assets, your data may be transferred under equivalent protections.
  5. Your choices and rights
    • Access, correct, delete, or export your data via account settings or by contacting us.
    • Marketing opt-out via unsubscribe links or settings.
    • Sensitive attributes can be added or removed at any time; removing may affect match quality.
    • Jurisdictional rights (for example CCPA/CPRA, GDPR) include access, deletion, correction, portability, and restriction or objection. Exercise at privacy@projectsunset.app. We will not discriminate for exercising rights.
  6. Data retention

    We retain personal data while your account is active and as needed for legitimate business purposes (for example fraud prevention, accounting, dispute resolution), then delete or de-identify it. Messaging related to bookings may be retained for compliance.

  7. Children and minors

    The Services are not for individuals under 18. We delete accounts that we learn belong to minors.

  8. Security

    We use administrative, technical, and physical safeguards (encryption in transit, least-privilege access, monitoring). No method is 100% secure; please use strong, unique passwords and enable available protections.

  9. International transfers

    We may transfer, store, and process information in the United States and other countries. Where required, we use appropriate safeguards (for example Standard Contractual Clauses).

  10. Data about deceased users and memorialization

    Upon verified notice of death, we may (a) memorialize an account, (b) allow a legally authorized representative limited access consistent with applicable law and our security processes, or (c) delete upon valid request.

  11. Do Not Track / Automated decision-making

    We do not respond to DNT signals. We use limited automated ranking to support matching; you may contact us to request human review of a match-impacting decision.

  12. Contact

    Privacy questions or rights requests: privacy@projectsunset.app
    General inquiries: support@projectsunset.app

  13. Changes to this policy

    We will post updates here and update the "Effective Date." Material changes will be notified in-app or via email.