This Privacy Policy was last updated on 12 May 2025.

1 Definitions
1.1 In this Privacy Policy (Policy):

(a) Customer means an individual, company or other legal entity that engages WIDI to provide its services to it.

(b) You means, where the context requires, in the case of an individual using a WIDI Website or purchasing a subscription through a WIDI Website, that individual, or in the case of an individual, using a WIDI Website or purchasing a subscription through a WIDI Website on behalf of a company or other legal entity, that company or other legal entity.

(c) Personal Information means information about an identifiable natural person.

(d) Privacy Officer means the Privacy Officer, with contact details provided at clause 19.1.

(e) Products and Services means all products and services offered by WIDI including the WIDI Software, being the [posthumous organisation and affairs tool] listed and described on the WIDI Website.

(f) WIDI, us, we, our means a business owned by The Trustee for Veritas Trust, ABN 67 304 207 478, and all legal entities owned or controlled by us (across any jurisdiction).

(g) WIDI Website means the online services accessible via the WIDI website.

2 Introduction

2.1 This Policy sets out how we collect, handle and use information that identifies you, for

example, your name, email and address.

2.2 We care about your privacy and have put measures in place to protect you and the

information you have entrusted to us.

2.3 We may update this Policy from time to time. Although we will not provide notice of the

changes to you, you can view the latest version of this Policy on our website at any time.

2.4 In this Policy we set out:

(a) the types of information that we may collect; and

(b) how that information will be used, handled, stored, and disclosed.

3. Application

3.1 This Policy applies to Personal Information that we may collect about you in the manner outlined in this Policy. To the extend permitted by law, this Policy does not apply to any information that may be collected by a third party (including a Customer) and how that third party may use, handle, store or disclose your Personal Information.

4. Information we collect about you

4.1 We may collect, use, store and transfer Personal Information about you, which information is generally grouped into one of the following types of data:

(a) Products and Services Data being any data you input into the Software for use and distribution in accordance with for the purpose of the Products and Services offering.

(b) Website User Identity Data being your first name, last name, title, address, email address and username collected through the Website;

(c) Customer Identity Data being your first name, last name, title, address, email address and username that is collected and input directly by a Customer;

(d) Contact Data being your billing address, shipping address, email address and telephone numbers;

(e) Financial Data, to the extent required by law or by any payment processor that we may use, being your bank account details, credit card details or other payment information;

(f) Transaction Data being details about payments to and from you and other details of Products or Services you have purchased from us;

(g) Technical Data being information regarding the IP addresses used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system and platform, type of device;

(h) Profile Data being your username or password from each WIDI Website, details regarding purchases or orders made by you, your interests, preferences, feedback and reviews;

(i) Usage Data being information about how you use the WIDI Website, and Products and Services;

(j) Marketing and Communications Data being information regarding your preferencing in receiving marketing from us and your communication preferences;

(k) Third-Party Data subject to clause 4.2, being information we may receive from third-parties such as business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers and search information providers, third party applications that plug into the Products and Services and

payment providers or merchants;

(l) WIDI Products and Services Data being information, communication, or opinions about any of our Products and Services, transactions, payment history and business activities;

(m) Proof of Identity Data being identifiers (such as tax file number and business number), citizenship and residency details, details regarding and information provided by your referees, details regarding and information provided by your guarantor(s) and business partner(s), financials/credit/criminal history checks, results of any pre-employment or profile tests, employment history, education history, identity documents, health information and next of kin details; and

(n) Digital Media Data being digital media and content such as video, footage and audio. In some situations, you may have the option to deal with us anonymously or by using a pseudonym, however, where you are requesting Products or Services from us or a Customer where such contact is via us or one of our Services, it may become impracticable for us to provide those Products or Services to you without verifying your identity. Where you do not give us information or the information that you do give us is not complete or accurate it may affect our or a Customer’s ability to provide you with our Products and Services.

4.2 If we receive identifiable information about you from a third party, we will take reasonable steps to ensure that you have authorised the collection of that information and that the information is accurate. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified. We will only collect Personal Information from a third party where it is reasonably necessary for, or directly related to, WIDI’s functions or activities.

5. Collection of ‘sensitive information’
WIDI will not request any sensitive information from you as defined under section 6(1) of The Privacy Act 1988(Cth) unless:

(a) the individual is adequately informed before giving consent;

(b) the individual gives consent voluntarily;

(c) the consent is current and specific;

(d) the individual has the capacity to understand and communicate their consent; or

(e) as required or authorised by or under an Australian court/tribunal order.

6. How do we collect information from you

6.1 We use different methods to collect data from you and about you, including:

(a) (direct interactions) – you may give us your identity, contact, financial, profile and proof of identity data by creating an account with us, completing online forms or corresponding with us. You do not have to provide us with the personal data we request, but this may mean that you cannot use some parts of our Websites, Products and Services;

(b) (interactions you have with other sources) – we may receive identity, contact, financial, transaction, usage and marketing and communications data from business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers and search information providers, third party applications that plug into the Products and Services and payment providers or merchants;

(c) (automated technologies or interactions) – we may collect information automatically when you visit our websites and services, for example your IP address and device type or details of what pages you looked at and what links you clicked on. This information is useful for us to improve the value of our Products and Services to you. We may use the following technologies to collect technical and Third-Party Data:

(i) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, please see: https://allaboutcookies.org;

(ii) “Log files” track actions occurring on the WIDI Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and

(iii) “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the WIDI Website and Products and Services.

7. How do we use your personal information?

7.1 Where we collect personal data, we will process it for the following purposes:

(a) to perform a contract with you and provide you with the Products and Services;

(b) where we have legitimate interests to process the personal data and they are not

overridden by your rights;

(c) in accordance with a legal obligation; and

(d) where we have your consent.

7.2 In performing the purposes at clause 7.1, we may use your personal data to:

(a) communicate with you;

(b) manage our relationship with you;

(c) to provide technical or other support to you;

(d) to enhance our websites and services and develop new ones;

(e) to protect you;

(f) to market to you;

(g) to analyse, aggregate and report; and

(h) perform the activities in the below table at clause 8.1.
We will only collect Personal Information if it is for a lawful purpose connected with the functions or activities of WIDI, and the information is necessary for that purpose.

8. Whether giving it is compulsory or voluntary

WIDI will ensure that, where possible any Personal Information that we request for you provide can be provided voluntarily, and in circumstances when it cannot be provided voluntarily, as the information is required in order for WIDI to provide its Products and Services to you, we will inform you of this requirement.

8.1 Website users

8.2 Customers / Subscribers

9 Data Retention

9.1 The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

9.2 We will retain your personal data for as long as is necessary for a lawful purpose connected to our relationship with you or our business purposes or activities, for example where we need to retain it in accordance with our data retention practices and/or any terms and conditions entered into with you. Following that period, we will make sure it is deleted or anonymised.

10 Do Not Track Settings

10.1 Please note that we do not alter our WIDI Website data collection and use practices when we see a ‘Do Not Track’ signal from your browser.

11 Storing your Information

11.1 We are a growing business. To offer a consistent service to you we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third-party cloud service provider that may store your information or a backup of your information in:

(a) Australian data centres; and

(b) such other locations that the third-party cloud service provider determines from time to time.

11.2 The data that we collect from you may be transferred to and be stored to these servers or processed by staff operating in other jurisdictions or who work for WIDI.

11.3 We will take all steps reasonably necessary to ensure that your information is secured from misuse, interference, loss, unauthorised access, unauthorised modification, or unauthorised disclosure. Any information will be handled in accordance with this Policy and applicable privacy laws. Despite using all steps reasonably necessary, the transmission of information through the internet is not completely secure.

11.4 Submission of any information to us is an acknowledgement that you agree to such use, storage, and disclosure.

12 How we disclose your Information

12.1 There may be times when we need to share your personal data with third parties.

12.2 We may share your information with:

(a) any and all of our affiliates;

(b) third parties including business partners, suppliers and subcontractors;

(c) where we are required to disclose your information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with organisations for the purposes of fraud protection and credit risk reduction;

(d) an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and

(e) other people where we have your consent, including your implied consent given where disclosure is required for the performance of a contract with you.

13 When will we disclose personal information

Personal Information will only be used or disclosed for purposes related to the purpose for which it was collected and is relevant to you. WIDI will obtain consent from you where appropriate and necessary. Exceptions to this include where:

(a) the use or disclosure is required to lessen or prevent a serious and imminent threat to an individual’s life, health or safety, or to public health and safety;

(b) WIDI suspects fraud or unlawful activity;

(c) the use or disclosure is necessary to assist a law enforcement agency in its law enforcement functions; or

(d) the use or disclosure is required or authorised by or under law.

14 International Data Transfers

14.1 We may collect and store Personal Information globally from each jurisdiction we operate in and from each legal entity that is owned or operated by us in different international jurisdictions and may transfer, process and store your Personal Information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Products.

15 Accessing and Correcting your Information

15.1 You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this Policy. We will respond to any such request for access to Personal Information within a reasonable time and will provide you access to the Personal Information that we hold relating to you unless we are authorised not to do so by law.

15.2 Where permitted by law, we may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so. For example, if the information doesn’t exist, cannot be located, the information may involve an unwarranted breach of someone else’s privacy, or releasing it may pose a serious threat to someone’s safety.

15.3 If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant, or misleading, please notify our Privacy Officer using the details set out in this Policy. WIDI will take reasonable steps in the circumstances to ensure (having regard to the lawful purpose that it was collected) to ensure that the information is accurate, up to date, complete and not misleading.

15.4 If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. If we decline the request to correct Personal Information, you may request to associate a statement with the information.

16 Complaints

16.1 If you believe we have not fulfilled our obligations under any relevant law or have not complied with the terms of this Policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the contact details set out in this Policy.

16.2 We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

16.3 If you are not satisfied with the handling of your complaint by WIDI, you have the right to escalate the matter. You may refer your complaint to the Office of the Australian Information Commissioner (OAIC). For further information or to lodge a complaint, you can visit their website at https://www.oaic.gov.au or contact them directly on 1300 363 992. We encourage you to engage with us directly in the first instance, as we are committed to resolving your concerns swiftly and fairly.

17 Our external provider’s privacy policies

17.1 We hold your Personal Information on behalf of the Customer in which you are dealing with or employed by.

17.2 Accordingly, where you are dealing with a Customer and you are concerned that there may have been a breach of this Policy by an independent third party associated with us and/or a Customer, please contact the Privacy Officer at the details set out in this Policy.

17.3 We hold your Personal Information on behalf of the Customer for the following purposes:
(a) to facilitate various services on behalf of a Customer to you;

(b) for the Customer to maintain its data and records about you in a centralised customer relationship management system;

(c) for the Customer to communicate with you in a secure manner;

(d) for you to make payments to a Customer;

(e) for a Customer to market to you;

(f) for a Customer to organise and store your Personal Information in a consistent manner for the Customer to better provide its services to you;

(g) to provide analytics services, of any kind, to Customers;

(h) to provide any entity in our group of companies; 

(i) where disclosure is required or authorised by or under an Australian law, a law in any jurisdiction in which we operate or a court/tribunal order; and 

(j) where we reasonably believe that the use or disclosure of your Personal Information is necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

18 Unsubscribe

18.1 When it comes to marketing communications, you can ask us not to send you these at any time by following the unsubscribe instructions contained in our communication, or make your request from to the Privacy Officer, details as outlined in clause 19.

19 Contact

19.1 If you have any comments, concerns or questions regarding this Policy or PersonalInformation that we hold about you, please contact our Privacy Officer by email to [email protected] or by post at:

Privacy Officer
WIDI
[email protected]
https://widiapp.com.au