Terms and Conditions – Willfred

Your Rights in Relation to Privacy
We understand the importance of protecting the privacy of an individual’s personal information and adopt the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Act).

This Privacy Policy sets out how we collect, use and disclose information about you, how we aim to protect the privacy of your personal information and your rights in relation to your personal information.

Kinds of Personal Information

During the provision of our services or through your use of our Application and Website, we may collect your personal information. Personal information is information or an opinion about an identified, or reasonably identifiable, individual, whether or not the information or opinion is true and whether or not it is recorded in a material form.

The kinds of personal information we collect may include:

• contact details such as your full name, business or personal addresses, email addresses, phone and fax numbers;
• date of birth;
• details of your family members and spouse;
• information about your personal assets and financial position;
• information about other individuals such as beneficiaries, witnesses and executors, including names, addresses, contact details, preferences and dates of birth;
• financial information including credit card and debit card details.

“Personal Information”

You must notify us as soon as reasonably practicable of any changes to the Personal Information provided to us by you or if you are aware of any inaccurate, out of date, misleading or false information.

Sensitive Personal Information

We may also process sensitive Personal Information about you where we have your explicit consent and where it is necessary for us to perform our services.

The kinds of sensitive Personal Information we process may include, but is not limited to, information about your:

• medical and health information and history;
• history of serious illnesses;
• religious beliefs or affiliations;
• philosophical beliefs;
• political opinions;
• membership of a political association or trade union;
• racial or ethnic origin; and
• sexual orientation.

Sensitive Personal Information may be required in order to prepare a will which is tailored to your needs. For example, you may nominate a same-sex partner or political organisation as a beneficiary and/or include references to medical matters or religious preferences within your will.

Collection of Personal Information

Generally, we will collect your Personal Information through:

• direct contact with you, whether in person or over the phone, email or post;
• your use of our Application;
• information services providers, social media sites or publicly available information

When you use Willfred, the following information may be logged for statistical purposes and for the purposes of marketing and advertising to you:

• the date and time of your visit to Willfred;
• your IP address;
• pages that you accessed and documents downloaded; and
• the type of browser you were using.

Cookies may be used on our website. Cookies are pieces of information that a website transfers to a computer’s hard drive for record keeping purposes. Most web browsers are set to accept cookies and do not personally identify the user.

Purpose of Collection

We may require your personal information for the following reasons:

• to provide you with access to the Application;
• to prepare a will through use of the Application;
• to respond to your enquiries via our Website;
• for accounting, billing and other internal administrative purposes;
• to provide you with Prompts to make updates or changes to your will;
• to invite you to events, functions or training and provide you with updates and publications;
• to add you to our mailing list where you have subscribed to our newsletter;

We may also use and disclose your personal information in order to inform you of products and/or services that may be of interest to you. In the event you do not wish to receive such communications, you may, at any time, request not to receive direct marketing communications from us or use any opt-out mechanism provided and we will comply with that request.

Collection of Personal Information by Third-Parties

You may be redirected and asked to submit Personal Information to third-party entities in the course of using the Application.

We engage the services of billing agent ‘Stripe’ to assist us to process the Subscription Fee. When you subscribe, you will be redirected to the Stripe website and may need to create an account with Stripe before you are able to complete your purchase. You may need to submit Personal Information to Stripe to create an account.

We highly recommend that you read Stripe’s privacy policy prior to submitting any Personal Information. This may be found by clicking on the link below:

Stripe: www.stripe.com/au/privacy

Whilst you are not under any obligation to provide any third-party with your Personal Information, please be aware that we may be unable to provide you with our full range of services unless you do so.

Disclosure of Personal Information

We may disclose your Personal Information to third parties such as service providers, suppliers or marketing agencies. We limit the information provided to third party providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

We will otherwise not disclose your personal information to third parties without your consent or unless required by law.

Security of Your Personal Information

We take reasonable steps to ensure that the Personal Information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. Generally, we hold your Personal Information electronically, but may from time to time hold your information in paper form also.

In the event that your Personal Information is subject to a data breach, we will comply with all mandatory statutory notification requirements.

We will destroy your Personal Information in circumstances where it is no longer required, unless required by law to retain the information.

How You May Access Your Personal Information

Under the Privacy Act, you have a right to access and seek correction of your Personal Information that is collected and held by us.

If at any time you would like to access or correct the personal information that we hold about you, please contact our privacy officer:

Shehan De Silva
[email protected]

To obtain access to your Personal Information:

• you will have to provide proof of identity to ensure that Personal Information is provided only to the correct individuals and that the privacy of others is protected;
• you will need to be reasonably specific about the information you require; and
• We may charge you a reasonable administration fee, which reflects the cost to us for providing access in accordance with your request.

If we refuse your request to access or correct your Personal Information, we will provide you with written reasons for the refusal and details of complaint mechanisms.

Complaints

Please direct all privacy complaints to our privacy officer. At all times, privacy complaints will be treated seriously and dealt with in a prompt and confidential manner.

You will be informed of the outcome of your complaint following completion of the investigation, which will take no more than 30 days.

In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.