Legal

Privacy policy

Effective November 6, 2026. Under review by counsel; a revised version will carry a new date.

LUPASA, LLC ("LUPASA", "we") owns and operates Truman Planner and trumanplanner.com. This policy explains what personal information we collect, why, who sees it, and the choices you have. It covers the public website and the service.

Two roles

For visitors to the website and for the people who hold accounts, LUPASA decides what is collected and why: it is the controller (in US state-law terms, the business). For the records an organization enters into the service about trusts, beneficiaries, owners and transactions ("customer data"), the organization decides; LUPASA processes that data only on its instructions, as a service provider or processor. If you are a beneficiary, owner or other person whose information appears in customer data, the organization that administers the entity is the right place to direct questions and requests; we will help it respond.

What we collect

Account information. Your name, email address, a hash of your password (never the password), your role in each organization, and sign-in times and IP addresses.
Customer data. What your organization enters or uploads: entities, people, assets, documents, transactions, decisions and their audit history. It may include financial and personal information about third parties such as beneficiaries. It is processed only to provide the service.
Billing information. A Stripe customer and subscription identifier, the subscription status, the entity count billed, and invoice history. Card numbers are entered on Stripe's pages and never reach LUPASA.
Support and correspondence. What you send us by email, and our replies.
Website and service logs. IP address, browser type, pages or endpoints requested, timestamps and error reports, collected by our servers and by Cloudflare, which protects our network. We do not use advertising trackers or third-party analytics on the website.

Why we use it

To provide the service, including keeping the fiduciary record your organization relies on and its audit history.
To bill and collect fees, through Stripe.
To secure the service: detecting abuse, rate-limiting sign-in attempts, investigating incidents.
To support you and tell you about changes to the service, your subscription or these terms. We do not send marketing email without your consent, and every such message will have an unsubscribe link.
To comply with law and enforce our terms.

We do not sell personal information, share it for cross-context behavioural advertising, or use customer data to train models.

Model-assisted features

Where an organization enables suggested classifications or instrument reading, the data needed for the task is sent to a model provider listed on the subprocessors page under terms that prohibit the provider from training on it. Proposals are stored with the model's name and reasoning. Nothing is posted or decided without a person accepting it.

Who sees it

Your organization. Its members, according to the roles its administrators grant. No other customer can see your records; the boundary is enforced by the database, not by policy.
LUPASA staff, only to operate, secure and support the service or at your request. Access is logged.
Service providers that process data on our behalf, listed with their purpose and location on the subprocessors page. We update that page when the list changes.
Legal requirements. We disclose information when the law requires it, to protect rights, safety or property, or in connection with a merger or sale of the business, under confidentiality.

Cookies and browser storage

The website sets no cookies of its own. The service keeps your sign-in session and your last-selected organization and entity in your browser's local storage, which is essential to the service and is cleared when you sign out. Cloudflare may set a cookie needed to distinguish legitimate traffic from automated abuse. We use no advertising or analytics cookies. Because we set no tracking cookies, browser "Do Not Track" and Global Privacy Control signals change nothing about how the site behaves, and we honour the choice they express.

Retention

Account information is kept while the account exists and for up to 12 months after closure, then deleted or anonymised, except where the law or a dispute requires longer. Customer data is kept for as long as your organization exists and is available for export for at least 60 days after closure before deletion. Billing records are kept for 7 years, as tax law requires. Audit history inside customer data is retained as part of the fiduciary record because the record requires it.

Security

Connections are encrypted with TLS. Passwords are hashed with bcrypt. Documents are stored in versioned object storage. The ledger is append-only and hash-chained. Access is by role, and administrative access is logged. See Security. No system is perfectly secure; if we learn of a breach affecting your information we will notify your organization's owner without undue delay and as the law requires.

Your choices and rights

You can see and change your account information in the service and export your organization's data at any time. Depending on where you live, you may have rights under state privacy law, including California, Colorado, Connecticut, Texas, Virginia and others, to access, correct, delete or obtain a copy of your personal information, and to not be discriminated against for exercising those rights. To exercise them, email [email protected] with "Privacy request" in the subject. We will verify your identity, respond within the time the law allows (generally 45 days), and tell you if we cannot act on a request and why. You may appeal a refusal by replying to our response. Requests about information held in customer data are routed to the organization that administers the relevant entity, as the law provides for service providers.

We do not sell personal information and have not done so in the preceding 12 months, so there is nothing to opt out of.

Children

The website and service are not directed to anyone under 18 and we do not knowingly collect personal information from children. Information about minor beneficiaries may appear in customer data, entered by the organization administering the trust, which is responsible for it.

Where data is kept

The service is operated in the United States and is intended for US organizations. If you use it from elsewhere, your information is transferred to and processed in the United States.

Financial privacy

Where a customer is a financial institution subject to the Gramm-Leach-Bliley Act, LUPASA acts as its service provider, uses nonpublic personal information only to provide the service, and keeps it confidential as that Act and the customer's own policy require.

Changes

We may update this policy. For material changes we will notify your organization's owner by email or by notice in the service before they take effect. The current version is always at trumanplanner.com/privacy.

Contact

LUPASA, LLC, [registered address]. Email [email protected].