Privacy Policy

Overview

This Privacy Policy explains how Willed collects, stores, uses and discloses your Personal Information when you use the Willed Platform and our Services, and the choices you have over that information. It is written for customers and visitors to www.willed.com.au, and reflects our obligations under the Australian Privacy Principles in the Privacy Act 1988 (Cth).

1. Introduction

(a) This website (www.willed.com.au) (the Willed Platform) and the products or services sold on, or via, the Willed Platform are created, operated and controlled by Willed Pty Ltd (ACN 638 925 032) (we, us or our).

(b) We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act).

(c) By accessing, using and continuing to use, the Willed Platform and the products or services made available on the Willed Platform, you acknowledge that your Personal Information will be handled in accordance with this Privacy Policy.

(d) This Privacy Policy outlines how we collect, store, use, process and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

(e) Other privacy notices, collection notices, consents, terms and conditions may also apply to you. We may provide these when you create or update an account, use a Will, Power of Attorney, advance-care or medical-directive workflow, contact us for support, purchase or redeem a product or Subscription, upload User Data, or subscribe to marketing communications, surveys or other promotional activities.

1.1. Definitions

For the purpose of this Privacy Policy:

(a) Authorised Affiliates has the meaning given in clause 4.3(a)(v);

(b) Executor Services means professional executor services provided by Willed (or an Authorised Affiliate) in relation to administering the deceased estate of a user;

(c) Personal Information has the same meaning that it has under the Privacy Act, namely, information or an opinion about a natural person which identifies a natural person, or which is reasonably capable of identifying a natural person, whether or not the information is true or recorded in a material form;

(d) Power of Attorney means an enduring power of attorney and/or appointment of medical decision-maker;

(e) Sensitive Information has the same meaning that it has under the Privacy Act, namely, information or opinions about your health, political affiliations, sexual preferences, religious beliefs, racial or ethnic origin or other such private information;

(f) User Data means all data, information (including Personal Information), meta-data, materials, documents, photographs and videos uploaded to or stored on the Willed Platform by a user (including data, information, Wills and Powers of Attorney generated on, or via, the Willed Platform and Services);

(g) Services means the estate planning solutions made available through the Willed Platform, which may include all or any of the following:

(i) access to, and use of, the Willed Platform to create and download a Will and/or Power of Attorney (either on a one-off or Subscription basis);

(ii) a licence and right to upload and store User Data on the Willed Platform;

(iii) support services (if any);

(iv) Executor Services (if any); and/or

(v) any other products or services made available on, or via, the Willed Platform from time to time;

(h) Subscription means a licence granted to a user to access and use the Willed Platform and Services on an unlimited basis for the subscription term; and

(i) Will means a document which sets out, amongst other things, your wishes regarding the administration of your estate and the care of any minor children (if any).

2. The information we collect about you

2.1. Personal Information

(a) We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver the Willed Platform and Services to you, or as otherwise permitted by law.

(b) The type of Personal Information that we may collect and use depends on the type of dealings that you have with us and includes the following:

(i) user contact details (for example, full name, address, date of birth, email address, details relating to your age, gender and marital status);

(ii) user registration information (such as username and password);

(iii) marketing data and information from visitors to our website and users relating to your dealings, or enquiries you have made, with us, including information about the Services you have ordered on, or via the Willed Platform and your Subscription;

(iv) payment and billing information;

(v) information regarding your access to, and use of, the Willed Platform and Services (whether as a user or visitor), including location information, IP address, products you viewed or searched for, length of visits to certain pages, page interaction information, methods used to browse away from the page and any third-party websites you access;

(vi) information relating to your estate planning requirements and financial circumstances, including, but not limited to, your User Data, the assets and liabilities comprising your estate, your Wills and Powers of Attorney;

(vii) details of the executors, beneficiaries, guardians, attorneys and/or medical decision-makers appointed by a user under a Will and/or Power of Attorney generated or created using the Willed Platform and Services (including full name, address, date of birth and email address);

(viii) identity-verification information and government-related identifiers where required to deliver or support a Service, verify identity, satisfy legal or regulatory obligations, or support professional executor, probate, conveyancing or other affiliated services; and

(ix) other information that you provide to us or that we may collect in the course of our relationship with you.

(c) We may also collect and hold information that is not Personal Information, including:

(i) aggregated or de-identified data;

(ii) business information about contractors, suppliers or partners that does not identify, or reasonably identify, an individual; and

(iii) information about a deceased person.

(d) Information about a deceased person is not Personal Information under the Privacy Act and is not covered by this Privacy Policy. We still treat information about deceased people carefully, particularly where a record also includes Personal Information about living people (such Personal Information about living people is handled in accordance with this Privacy Policy).

2.2. Sensitive Information

(a) Health information and related sensitive matters in advance care planning. Some of our Services involve the collection of health information about you, which is Sensitive Information under the Privacy Act. Specifically, when you use our medical directive, advance care planning or enduring power of guardianship features, we collect information about your health preferences and instructions. Depending on the features you use, you may also choose to record related sensitive matters — such as religious, spiritual or ethical beliefs that bear on your treatment, end-of-life or care preferences. We collect this Sensitive Information with your consent, which we obtain separately during the relevant workflow. We use this information for the purpose of creating, storing and (where relevant) delivering your medical directive, Power of Attorney or guardianship document, or as otherwise permitted or required by law.

(b) Aside from the categories described in clause 2.2(a), we generally do not intend to collect Sensitive Information from you. Some of our Services are automated and we may not recognise that you have accidentally provided us with Sensitive Information unrelated to those workflows. If you have accidentally sent us Sensitive Information of this kind, please contact us using the details below.

2.3. Children

The Services are intended for individuals aged 18 years or older. We do not knowingly collect Personal Information directly from minors. If you become aware that a minor has provided Personal Information to us, please contact us using the details below and we will delete that information.

We may, however, collect Personal Information about minors from users where it is relevant to the Services. For example, a user may name a minor child as a beneficiary, appoint a guardian for a minor child, or provide information about minor children when preparing a Will, Power of Attorney or related document. Please see clause 3.2 below for further information on this indirect collection.

3. How we collect Personal Information

3.1. Direct collection from you

(a) We collect your Personal Information (directly or automatically) from you in a variety of ways, including if you:

(i) set up or update an account or other registration on the Willed Platform;

(ii) visit, access and use the Willed Platform;

(iii) purchase, access and use our Services (including when you purchase a Subscription) made available to you on, or via the Willed Platform including when you use any support services that are provided by us or our Authorised Affiliates;

(iv) submit an enquiry to us via the Willed Platform or Help/Support Chat Box;

(v) participate in our surveys, competitions, promotions, questionnaires or other promotional activities or complete any forms or documents for our products or services or subscribe to our publications, alerts and newsletters; or

(vi) interact or communicate with us, such as by telephone, email or in person or make a comment on our social media sites.

(b) When we collect Personal Information directly from you, we generally take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.

(c) As a collection notice is specific to a particular collection of Personal Information, it will provide more specific information about our information-handling practices than this policy.

(d) This policy is subject to any specific provisions contained in our collection notices and the terms and conditions of any offers, products and services. We therefore encourage you to read those provisions carefully.

(e) By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

3.2. Indirect collection from Will maker or donor

We may collect Personal Information about third parties (such as executors, beneficiaries, guardians, attorneys or medical decision-makers, including children where relevant) indirectly from users of the Willed Platform who provide this information when creating a Will, Power of Attorney or related document, including in the following circumstances:

(a) If you have been appointed as an executor, beneficiary or guardian, we may collect Personal Information about you from a user of the Willed Platform and Services (in their capacity as a Will maker or testator) who accesses and uses the Willed Platform and Services to create or generate a Will.

(b) If you have been appointed as an attorney, guardian or medical decision-maker, we may collect Personal Information about you from a user of the Willed Platform and Services (in their capacity as a donor) who accesses and uses the Willed Platform and Services to create or generate a Power of Attorney.

3.3. Indirect collection from third parties

(a) We may also collect Personal Information from publicly available sources and third parties, including:

(i) from third parties (including our related bodies corporate, business partners, service providers and government agencies);

(ii) from your executors, beneficiaries, attorneys, guardians or medical decision-makers, with whom we may deal from time to time;

(iii) click identifiers and referrer data passed to us when you arrive at the Willed Platform via an advertising or social platform link (for example, fbclid, msclkid, or gclid parameters);

(iv) our third-party payment processor (Stripe) — for example, your Stripe customer identifier and the transaction reference, amount and item details associated with payments you make to us.

(b) If you provide us with Personal Information about another individual (including, as their authorised representative), we rely on you to:

(i) inform them that you are providing their Personal Information to us;

(ii) advise them that they can contact us for further information;

(iii) take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy; and

(iv) upon our request, assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

3.4. Third-party payment processor

We use a third-party payment processor, Stripe, to process payments made to us. We do not collect or store your full card number, card verification code (CVC/CVV), or bank account number. That information is provided by you directly to Stripe and is governed by Stripe's privacy policy, which may be viewed at https://stripe.com/au/privacy.

We do, however, retain transaction records associated with payments you make to us — including your Stripe customer identifier, a transaction reference, the amount paid (including GST), the item or Subscription purchased, and the date of the transaction. We retain these records to deliver the Services to you, to provide receipts and refunds, and to satisfy our taxation, corporations-law and accounting record-keeping obligations.

3.5. Dealing with us without providing your Personal Information

You are under no obligation to provide us with your Personal Information. We may provide individuals with the option of not identifying themselves, or using a pseudonym, where it is lawful and practicable to do so. For example, you can access our website, make general phone enquiries or email us without identifying yourself, or by using a pseudonym.

However, without certain information from you, we may not be able to provide you with our full scope of Services or information that is tailored to your needs. For example, if you do not provide us with the information requested in a Will, Power of Attorney or advance-care workflow, we may not be able to prepare the relevant document or deliver the related Service.

4. How we use and disclose your Personal Information

4.1. Purposes of use and disclosure

(a) We use, process, share and disclose your Personal Information for the purposes for which it is collected.

(b) We may also use your Personal Information for purposes which are incidental to those purposes, within your reasonable expectation, or permitted or required by law.

(c) In particular, we use, process, share and disclose your Personal Information to:

(i) provide or deliver our Services to you, including, without limitation, to provide you with access to, and use of the Willed Platform (including Will and Power of Attorney templates and solutions);

(ii) assist with, or respond to, your queries (including support services requests);

(iii) improve, develop and manage our Services and the Willed Platform, including through the use of artificial intelligence tools, and to assist us in providing a better service to you;

(iv) operate, maintain, test, train and upgrade the Willed Platform, systems and tools (including artificial intelligence tools); and

(v) notify you of opportunities we think you might be interested in, including new product or service offerings (such as insurance products and services and legal, probate and conveyancing services), information about the Willed Platform, offers, competitions, promotions, events and surveys and general information relating to estate planning, probate and estate administration;

(vi) verify your identity;

(vii) conduct fraud and risk-reduction checks;

(viii) perform research and analysis about our Services and the Willed Platform, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is de-identified by removing data that can identify you;

(ix) comply with regulatory or other legal requirements;

(x) for any purpose to which you have consented; and

(xi) for any other purpose notified to you at the time of collection.

(d) In the event of a merger, acquisition or sale of the whole or part of our business or assets, we may transfer your Personal Information as part of the transaction to the extent permitted by the Privacy Act, and we will take reasonable steps to notify affected individuals where required.

4.2. Automated decision-making

We do not use your Personal Information to make decisions about you based solely on automated processing that produces legal or similarly significant effects. Some features of the Services use automation and your Personal Information (such as account, document-workflow, transaction, device, security and support information) to assist with administrative tasks (for example, document generation, fraud detection, security monitoring and the routing of support enquiries), but the outcomes that materially affect you (such as the contents of your Will or Power of Attorney) are determined by you.

4.3. Disclosure to third parties

(a) We may provide your Personal Information (as well as, in relation to clause 4.3(a)(iv) below, your date of birth) to the following recipients:

(i) our employees, related entities, business partners, third-party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering our promotions, deals, competitions, products, services and the Willed Platform. For example, we may disclose your Personal Information to our affiliated law firm, Willed Law Pty Ltd;

(ii) third-party service providers who process or use your Personal Information for the purpose of performing functions on our behalf, but which may not process or use such information for any other purpose (which may be a disclosure in some cases). Examples of these third-party service providers include, but are not limited to, cloud hosting and storage providers, our payment processor, transactional and marketing email providers, analytics providers, customer support tools and accounting software;

(iii) to your executors:

A. for the purpose of advising them that you have appointed them as the executors of your Will and that a copy of your Will and messages expressing your last wishes may be stored on the Willed Platform; or

B. after you pass away to assist them with applying for probate and to otherwise administer your estate;

(iv) to a specific charity, in circumstances where you have chosen to bequeath assets from your estate to the specific charity, for the purpose of contacting you or your executors; and

(v) external business advisors, such as auditors, lawyers (including the lawyers of your estate to assist them to apply for probate), insurers and financiers, (collectively, Authorised Affiliates); and

(vi) third-party entities with which we have a referral arrangement, for the purposes of such third-party entities managing their relationship with you and managing the referral arrangement with us.

(b) When we disclose your Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.

(c) Authorised Affiliates may also provide us with Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliate, we rely on you to provide the Authorised Affiliate with consent for us to collect, store, use, process, alter and disclose your Personal Information.

(d) We may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.

4.4. Overseas disclosure, transfers and sharing of information

(a) Some of the Personal Information we collect is stored, accessed from, processed from, or disclosed outside Australia by our service providers. The countries to which information may be shared, and the categories of information shared, are summarised below.

(b) United States. Personal Information transferred to providers located in the United States includes:

(i) Firebase Authentication (Google LLC) — account identity and authentication records, including your email address, display name, authentication credentials and security settings, provider identifiers, account status, sign-in metadata, and account-recovery or verification records. All Willed user identity records are stored in United States Google infrastructure because Google does not currently offer Firebase Authentication in an Australian region;

(ii) Stripe — payment processing data;

(iii) Postmark (operated by AC PM, LLC, a subsidiary of ActiveCampaign) — transactional emails (such as password-reset, account-confirmation, email-change verification, receipts and other account or document notifications);

(iv) Mailchimp — marketing emails and audience records, used to deliver marketing communications you receive from us and to manage your communication preferences (including unsubscribe records);

(v) Anthropic — AI services used by our staff for research, code review and other operational support. Under our approved use, Anthropic is not used to generate or review your estate-planning documents;

(vi) HelpScout — customer support chat. Where you initiate a support conversation, your name, email and the content of your messages are processed by HelpScout to enable us to respond;

(vii) Other service providers including Slack, Netlify, GitHub, Sentry, UptimeRobot and Vanta receive operational metadata, telemetry, marketing-website content, or business-administration data.

(c) Australia. Personal Information processed in Australia by our service providers includes the following. In some cases, these services may also involve Personal Information being processed, transiting through or accessed from locations outside Australia for support, failover, telemetry, or sub-processor services.

(i) Firebase Cloud services (Google LLC) — your account data, the contents of your Wills, Powers of Attorney and other estate planning documents are stored in Google's Sydney region. (Note: while these services are pinned to Australia, the related Firebase Authentication service is United States only, as described in clause 4.4(b)(i) above.)

(ii) Supabase — the prepaid-funerals platform database, hosted in the AWS Sydney region;

(iii) Zoho CRM and Zoho People — customer-relationship management and human-resources data, hosted in Zoho's Australian region;

(iv) Smokeball — Australian legal practice management platform used for legal-services records where relevant.

(d) Other jurisdictions.Xero, our accounting and bookkeeping provider, is incorporated in New Zealand with primary infrastructure in the United States. Personal Information transferred to Xero includes Willed staff payroll and bookkeeping records, and customer/client invoicing and accounting records for our funeral, cremation, estate administration and legal services. These records may include billing contact details, relevant matter or service contact details, invoice descriptions, amounts and payment status. Xero is not used as a repository for substantive estate-planning or legal-service document content.

(e) Where we transfer your Personal Information overseas, we take reasonable steps to ensure that your Personal Information is treated securely and that the overseas recipient handles it in a manner consistent with the Australian Privacy Principles. These reasonable steps may include:

(i) contractual safeguards, vendor due-diligence checks, or accepted terms of service that address privacy and security obligations;

(ii) verification that the recipient holds relevant security certifications or attestations;

(iii) configuration of services in an Australian region where appropriate and available.

(f) If you have any questions in relation to the transfer of your Personal Information please contact us using the contact details set out below.

4.5. Disclaimer

(a) We may disclose your Personal Information to third parties (including our Authorised Affiliates) where:

(i) you have consented to such disclosure;

(ii) we are required or authorised by law, including the Privacy Act;

(iii) we are permitted to do so under this policy; or

(iv) such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure that the Willed Platform functions properly.

(b) This policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

5. Storage and security

5.1. Protecting your Personal Information

(a) We take reasonable steps in the circumstances to keep your Personal Information safe, including through technical, administrative, and physical controls appropriate to the nature of the information and the risk of harm if it is misused, interfered with, lost, accessed, modified or disclosed without authorisation.

(b) Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information.

(c) Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information take reasonable steps to:

(i) protect and maintain the security of your Personal Information; and

(ii) comply with the relevant APPs when accessing and using your Personal Information.

5.2. No guarantee

(a) The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information, we cannot guarantee the security of any Personal Information transmitted through the Willed Platform.

5.3. Retention and destruction of Personal Information

(a) We retain your Personal Information only for as long as we need it to provide our Services or as required by law, and then take reasonable steps to destroy or de-identify it.

(b) The following retention periods apply by default:

(c) You may request earlier deletion of your Personal Information by contacting us using the details below (see clause 10.2). Where we are required by law to retain certain records (such as payment records), we will inform you of the retention basis and the specific information we retain.

6. Notifiable Data Breaches Scheme

(a) If we suspect on reasonable grounds, or determine, that an eligible data breach has occurred, we will handle the breach in accordance with our legal obligations under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.

7. Direct marketing

7.1. Marketing communications

(a) We may use and disclose your Personal Information to send you information about our Services and the Willed Platform as well as other products, services and information that may be of interest to you (including, but not limited to, insurance products and services and legal services such as professional executor, conveyancing and probate services) offered by us or our Authorised Affiliates.

(b) We will only send these communications in accordance with the Privacy Act (including APP 7), the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth), and only where you have consented, we are otherwise permitted to do so, and you have not opted out from receiving such communications.

(c) We may send this information to you via the communication channels specified at the time you provide your consent.

(d) These communication channels may include mail, email, SMS, telephone, social media or by customising online content and displaying advertising on the Willed Platform.

(e) If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out below.

7.2. Opting-out

You can opt out of receiving these communications by:

(i) contacting us using the details below; or

(ii) using the unsubscribe function in the email or SMS.

You can also visit Your Online Choices to opt out from targeted advertising based on your browsing history for organisations that have signed up to Your Online Choices. When you opt out of receiving targeted ads via Your Online Choices, this information is usually saved on a cookie. This means that if you clear your cookies, you may have to opt out again.

Where targeted advertising or analytics are provided through a third-party platform, you may also need to manage your privacy, advertising or tracking preferences directly with that platform. The main platform-level controls relevant to Willed are:

Willed does not currently use Hotjar or TikTok tracking technologies. If that changes, we will update this Privacy Policy to describe the relevant controls.

Regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if required by law, or in relation to the products or Services we are providing to you.

8. Links to other sites from the Willed Platform

(a) The Willed Platform may contain hyperlinks or banner advertising to or from third-party websites.

(b) We do not endorse any of these third parties, their products or services, or the content on these websites.

(c) These websites are not subject to our privacy standards, policies and procedures. Therefore, we recommend that you make your own enquiries about their privacy practices.

(d) We are in no way responsible for the privacy practices or content of these third-party websites.

9. Cookies, pixels and online tracking technologies

(a) We may collect information when you access and use the Willed Platform by utilising features and technologies of your internet browser, including cookies, pixel tags, web beacons, embedded web links and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.

(b) The type of information we collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using.

(c) We may use cookies and similar technologies to:

(i) enable us to identify you as a return user and personalise and enhance your experience and use of the Willed Platform;

(ii) help us improve our service to you when you access the Willed Platform and to ensure that the Willed Platform remains easy to use and navigate;

(iii) measure and report on the performance of our marketing activities (including via third-party analytics and tag-management tools such as Google Analytics and Google Tag Manager, and via click identifiers passed to us by advertising platforms);

(iv) provide customer support (for example, the HelpScout Beacon support chat may set cookies when you interact with it);

(v) detect and prevent abuse and protect the integrity of the Willed Platform (for example, reCAPTCHA Enterprise, used as part of Firebase App Check, collects device and browser signals); and

(vi) capture diagnostic and error information to help us identify and fix faults (for example, the Sentry error-monitoring service).

(d) The Willed Platform is intended for users in Australia. We do not target the European Economic Area, the United Kingdom or other jurisdictions with cookie-consent regimes that differ from Australian law. Visitors from those jurisdictions should be aware that cookies described in this clause may be set on first visit unless rejected via browser settings.

(e) Most browsers are initially set up to accept cookies. However, if you do not wish to receive any cookies (other than those that are strictly necessary), you can reset your browser to refuse all cookies or warn you before accepting cookies. To change your web browser preferences, please visit the relevant preferences or settings page on your browser and amend the privacy settings in relation to cookies and site data. It may be necessary for you to opt out separately from each device and browser that you use to access online content.

(f) If you reject our cookies or similar technologies, you may still use the Willed Platform but may only have limited functionality of the Willed Platform.

(g) We may also use your IP address to analyse trends, administer the Willed Platform and other websites we operate, track traffic patterns and gather demographic information.

10. Access, correction and deletion

10.1. Accessing and correcting your Personal Information

(a) We will take reasonable steps to keep your Personal Information accurate, up-to-date and complete.

(b) You have the right to access any Personal Information we hold about you, subject to some exceptions provided by the Privacy Act.

(c) You can access, or request that we correct, your Personal Information by writing to us using the details below. We may require proof of identity.

(d) If we do not allow you to access any part of your Personal Information, we will tell you why in writing.

(e) We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.

(f) We will endeavour to respond to your request for access or correction within 30 calendar days of your request.

10.2. Deleting your Personal Information

(a) You may request that we delete your Personal Information by contacting us using the details below. We may require proof of identity before actioning a deletion request.

(b) Where we action a deletion request, we will take reasonable steps to delete the relevant Personal Information we hold about you across our customer-facing Services, including account data, Wills, Powers of Attorney and relevant marketing-list or customer-relationship records.

(c) Where we are required by law to retain certain records (such as payment records for tax purposes), we will inform you of the retention basis and the specific information we retain. Records retained for legal obligations will be securely deleted at the end of the retention period.

(d) Deletion is permanent and cannot be reversed. If you delete your account and your Wills or Powers of Attorney are stored on the Willed Platform, you will lose access to those documents.

(e) We will endeavour to action deletion requests within 30 calendar days.

11. Changes to the policy

(a) We may amend this Privacy Policy from time to time at our sole discretion.

(b) Any revised Privacy Policy will be posted on the Willed Platform and effective from the time of posting. Where the changes are material, we will take reasonable steps to notify existing customers in advance (for example, by email or by in-app notification) before the changes take effect.

(c) If you continue to use our products, services or the Willed Platform after a revised Privacy Policy takes effect, your Personal Information will be handled in accordance with the revised Privacy Policy.

(d) You should regularly check and read the Privacy Policy.

12. Complaints

(a) If you have any issues about this Privacy Policy or the way we handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.

(b) At all times, privacy complaints:

(i) will be treated seriously;

(ii) will be dealt with promptly;

(iii) will be dealt with in a confidential manner; and

(iv) will not affect your existing obligations or your commercial arrangements with us.

(c) Our Privacy Officer will:

(i) acknowledge your complaint in writing within 5 business days of receipt; and

(ii) provide you with a substantive response within 30 calendar days. Where a substantive response cannot be issued within 30 calendar days for good reason, we will write to you before that date to explain why and to give you a revised date.

(d) If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner (OAIC):

(i) online at oaic.gov.au; or

(ii) by telephone on 1300 363 992.

13. Contact us

You can contact us by:

(a) email to privacy@willed.com.au for privacy enquiries, access requests, correction requests, deletion requests and privacy complaints;

(b) email to hello@willed.com.au for general enquiries;

(c) telephone on 1300 945 533.