Privacy

Privacy Collection Notice

Safe Will Pty Ltd (ACN 631 790 273), Safewill Estates Pty Ltd (ACN 648 912 163) and Safewill Legal Pty Ltd (ACN 648 090 297) (referred to collectively as we, us or our) collect your personal information when you access our services, you use our online platform directly or through one of our partners, such as our superannuation fund partners and charity partners.

We collect your personal information for example, when you create an account, contact us, prepare a Will or Power of Attorney, or use our Vault technology - and in other interactions with us.

We collect this personal information from you, and when you use our platform through one of our partners, including via your superannuation fund, bank, insurer or other financial institution provider (Safewill partner). We collect it so that we can:

• provide and manage our Will-writing and estate planning services;

• provide you with legal advice via our legal practice (Safewill Legal Pty Ltd);

• communicate with you about your account and estate planning documents;

• provide general financial advice through our platform;

• share information with a safewill partner our to enable them to track member engagement, provide follow-up support and advice, fulfil reporting obligations, and better service your financial planning needs; and

• comply with our legal obligations and improve our services.

When you use our services via a safewill partner we share your contact details, demographic information (age, marital status, family members, executor type, financial dependents), assets and liabilities, purchase and status of Safewill products as well as your engagement with products and services offers made on our platform.

In addition, we also share with a safewill partner when you express interest in Binding Death Benefit Nominations, life insurance, financial advice, banking product or superannuation consolidation.

When you use our services to support or bequest to a charity, and if you've given consent, we share your contact details (first name, last name, middle name, email, phone) and some demographic info (age, address), along with the amount/percentage of assets or possessions you've bequeathed to the charity, plus the status of your purchased Will product.

We may disclose personal information to our employees and contractors, platform service providers, related entities, safewill partner, and (if you consent) your nominated charity. We store personal information in Australia, but some of our service providers may store or access it in other countries.

If you do not provide your personal information, we may be unable to provide our services to you, and your superannuation fund or other safewill partner, supported charity or any of our other partners you may be engaging with may be unable to provide appropriate follow-up support or advice.

For more information about how we collect, store, use and disclose your information, including how to access or correct it, make a complaint, and how we handle complaints, please see our Privacy Policy at safewill.com/privacy.

If you have questions, contact us at support@safewill.com.

By providing your personal information, you consent to our collection, use, storage and disclosure of that information as described in this Privacy Collection Notice and our Privacy Policy.

Privacy Policy

Safe Will Pty Ltd (ACN 631 790 273), Safewill Estates Pty Ltd (ACN 648 912 163) and Safewill Legal Pty Ltd (ACN 648 090 297) (referred to collectively as Safewill Group, we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you. Each member of the Safewill Group collects and handles your personal information in accordance with its legal obligations, including those under the Privacy Act 1988 (Cth)and the Australian Privacy Principles, as well as the New Zealand Privacy Act 2020 and the Information Privacy Principles (in relation to New Zealand residents).

Who we are

Safe Will Pty Ltd, trading as "Safewill", is a smart digital solution for estate planning services. Safewill Legal, a wholly owned subsidiary of Safewill, is an incorporated Legal Practice for the purposes of the Legal Professional Uniform Law (NSW). As such, Safewill Legal is a law firm entitled to provide legal services. Safewill Estates Pty Ltd, a wholly owned subsidiary of Safewill, is an Estate Administration specialist company.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• basic identifying and contact information, such as your name, signature, date of birth, address, email and phone number;

• demographic information, such as your age, marital status, details about family members, executor type and financial dependents;

• information about your assets and liabilities;

• details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you;

• your interest in or use of financial products and services, including Binding Death Benefit Nominations, life insurance, financial advice, banking products and superannuation consolidation;

• information about your partner, beneficiaries, Estate Executor, next of Kin and other close relationships you may include in your Will or other services you receive from us;

• information you provide to us when you participate in any interactive features, including surveys, feedback forms, contests, promotions, activities or events;

• your preferences in receiving marketing from us and our third parties and your communication preferences

• if we need to verify your identity (for example, because we have a legal obligation to do so), your government-issued identification and proof of address documents;

• if you access any software or websites we make available to you, details about your use of such platforms, which may include username and password details, your internet protocol (IP) address, your search queries or browsing behaviour (including through the use of cookies, tracking pixels, and other analytics tools); or

• where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience, or whether you hold required authorisations or licences (if applicable).

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. The types of sensitive information we may collect includes:

• Health and medical information, including information in relation to future medical treatment preferences and organ donation.

Where you apply for a role with us, either as employee or contractor:

• results of criminal records checks; and

• your professional registrations and associations (where applicable);

How we collect personal information

We collect personal information in a variety of ways, including:

• when you provide it directly to us, including face-to-face, over the phone, over email, or online (including when you complete a will or use any of our other services available online);

• When you call us or when we call you, we normally record our phone calls. We will tell you when our phone calls may be recorded. You can request for the phone call not to be recorded.

• When you visit our office, for the safety of our staff and customers, we may use camera surveillance, such as CCTV, to monitor our premises.

• from your superannuation fund or other safewill partner, where you access our services through them;

• from your financial advisor, when you are seeking advice from them and they need access to some of our services to assist them in giving you that advice;

• when you complete a form, such as registering for any events or newsletters, or responding to surveys;

• when you use any software or website we operate and make available to you (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);

• when you add reviews, forum or chat room messages or comments in any elements of one of our website that permit user-generated content;

• when you register for access to premium content or request certain premium features; or

• when you send us an email or other communication.

How do we collect information about you when you are not a customer of Safewill?

As part of our services, for example Will writing and executor administration, our customers may provide us with personal information about their beneficiaries, partners, key contact person, estate executors, next of kin or other important people in their lives (non-customers). When you have this type of relationship with one of our customers and they provide us personal information about you, we collect, hold, use and disclose your personal information in accordance with this privacy policy.

Where practicable, we will take reasonable steps to notify you of this collection when we first make contact with you, or as soon as practicable afterwards, including by providing you with a copy of, or a link to, this Privacy Policy.

Why we collect, hold, use and disclose personal information

Personal information: We collect, hold, use and disclose your personal information for the following purposes:

• to work with you as a customer or supplier of our business, including where you are a customer for the purposes of drafting your will, facilitating charity bequests, estate administration and other legal or compliance activities related to the services we will provide to you;

• to work with you as a customer, including where you are a beneficiary, nominated contact person, executor, next of kin or family member of a deceased person, who we are managing their estate or providing assistance to their estate executor;

• where you access our services through a superannuation fund or other safewill partner, to share information with your superannuation fund or other safewill partner to enable them to track member engagement with estate planning services, provide follow-up support and advice, fulfil reporting and compliance obligations, and better service your financial planning or other financial services needs;

• to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;

• to contact and communicate with you about any enquiries you make with us via any website we operate;

• To contact and communicate with you about our business, including in response to a request by your partner or another customer who asked us to send you an invitation to use one of our services, such as will preparation.

•to contact and communicate with you about our services or in the process of delivering services to our customer(s), including if you are a non-customers and our customer has provided us with your contact details.

• to refer you to one of our partners, such as life insurance companies and funeral homes service providers, featured on our platform when you request us to do so and provide your consent;

• provide general financial advice through our platform;

• for internal record keeping, administrative, invoicing and billing purposes;

• to conduct identity and other checks that we may be required to do under the Anti-Money Laundering and Counter Terrorism laws

• To conduct appropriate checks for credit-worthiness and for fraud and to prevent and detect any misuse of our services, or fraudulent activities;

• to provide, anonymised and/or aggregated whenever reasonably possible, data analytics and research to our partners, such as superannuation funds and charities, to help them better understand and service their members and bequestors, based on their use of our platform.

• for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms;

• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;

•We may use your personal information to contact you with new information or offers for products or services from us and our business partners which we think might be of interest to you. We may send this information to you by post, email, phone or SMS. Your personal information will never be added to a general marketing database. If you don’t wish to receive marketing material, please opt-out by adjusting your account settings using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us.

• to run promotions, competitions and/or offer additional benefits to you;

• if you have applied for employment with us, to consider your employment application; and

• to comply with our legal obligations or if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

• any purposes you consent to, including facilitating charity bequest notifications and you storing your information in the digital vault;

• the primary purpose for which it is collected;

• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to work with you as a customer or supplier of our business;

• to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and

• if otherwise required or authorised by law.

Our disclosures of personal information to third parties

Personal information: We will only disclose personal information (excluding sensitive information) to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information (excluding sensitive information) to:

• our employees, contractors and/or related entities;

• your authorised representatives or legal advisers (when requested by you to do so)

•When you use our services via a superannuation fund or other partners we share your contact details, demographic information (age, marital status, family members, executor type, financial dependents), assets and liabilities, purchase and status of Safewill products as well as you engagement with products and services offers made on our platform.

• A charity that you have chosen to support and if you've given consent, we share your contact details (first name, last name, middle name, email, phone) and some demographic info (age, address), along with the amount/percentage of assets or possession you've bequeathed to the charity, plus the status of your purchased Will product

•A charity or other partner, we share your contact details (first name, last name, middle name, email, phone) when you register for an event, such as webinar, in response to a marketing campaign

•Your financial advisor, in response to a request from them that you have consented to, for our products and services

• IT service providers, data storage, web-hosting, cloud-hosting and server providers;

• marketing or advertising providers, including mailing systems;

• The police or other appropriate persons where your communication or use of our services suggests possible illegal activity or harm to others;

• professional advisors, bankers, auditors, our insurers and insurance brokers, including any of your authorised representatives or legal advisors (when requested by you to do so);

• credit-reporting bodies, fraud-checking agencies and/or credit-providers;

• payment systems operators or processors;

• our existing or potential agents or business partners, including any charities or not-for-profit organisations;

• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

• third parties to collect and process data, such as analytics providers and cookies; and

• any other third parties as required or permitted by law, such as where we receive a subpoena.

Sensitive information: We will only disclose sensitive information with your consent or where permitted by law. This means that we may disclose sensitive information to:

• our employees, contractors and/or related entities;

• IT service providers, data storage, web-hosting and server providers;

• professional advisors;

• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

• third parties to collect and process data, such as analytics providers and cookies; and

• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

Australian Residents

We store your personal information in Australia. Where we disclose your personal information to third parties, including our technology and other service providers, those third parties may store, transfer or access personal information outside of Australia. We will not disclose your personal information to providers that store data overseas unless and until we have taken reasonable steps to ensure that the overseas recipient will handle your personal information in a manner consistent with the APPs, or you have consented to the transfer of the information.

New Zealand Residents

We store your personal information in Australia. Where we disclose your personal information to third parties, including our technology and other service providers, those third parties may store, transfer or access personal information outside of New Zealand and Australia. We will not disclose your personal information to providers that store data outside New Zealand and Australia unless and until we have taken reasonable steps to ensure we comply with Information Privacy Principle 12 and only disclose the information if:

• you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020;

• we believe the overseas recipient is subject to the Privacy Act 2020;

• we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020;

• we believe that the overseas recipient is a participant in a prescribed binding scheme;

• we believe that the overseas recipient is subject to privacy laws in a prescribed country; or

• We otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to work with you as a customer or supplier of our business.

Anonymity and pseudonymity

If you’re requesting general information via our website, phone or email, you may do so anonymously or by using a pseudonym. However, for specific account enquiries it is generally impracticable and illegal for us to deal with you on an anonymous basis. We must be certain of your identity before we can discuss your account with you. If you contact us to discuss your account, you must be able to prove your identity. This ensures that we can protect your personal information by only giving it to you or someone who can prove that they are lawfully authorised to act on your behalf.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (if you are an Australian resident) or the Office of the New Zealand Privacy Commissioner (if you are a New Zealand resident).

Data Breach: In Australia, if we suspect that a data breach has occurred, we will undertake an assessment into the circumstances of the suspected breach within 30 days after becoming aware of

the occurrence of the suspected breach. Where it is ascertained that a breach has actually occurred and where required by law, we will notify the Privacy Commissioner and affected individuals in accordance with our legal requirements.

Duration of retention of your data: We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning). In some circumstances you can ask us to delete your data. We are under no obligation to retain your data where you have opted out of our subscription services.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

User-Generated Content

We may enable you to post reviews, comments, photos and other user-generated content. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.

Cookies and Analytics

We may use cookies, tracking pixels and similar technologies on our website and in our emails from time to time. Cookies are text files placed in your computer's browser to store your preferences. Tracking pixels are tiny, invisible images (typically the size of one pixel) embedded in web pages or emails. Cookies and tracking pixels, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie or collected by tracking pixels. Unlike cookies, tracking pixels do not store any information on your device, but instead send information to our servers when the pixel is loaded.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

You can block tracking pixels by using ad-blocking or privacy-focused browser extensions. Some email providers allow you to block images by default, which can prevent tracking pixels in emails from loading.

However, if you use your browser settings to block all cookies (including essential cookies) and tracking pixels you may not be able to access all or parts of our website and you may not receive personalised content.

Google Analytics: We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

To find out how Google uses data when you use third party websites or applications, please see here.

Facebook/Meta Analytics: We may use tools provided by Meta, such as the Meta Pixel, advanced matching, and Conversions API. These allow us to measure ad performance and deliver ads that may be relevant to you on Meta platforms based on your activity on our website/app. You can control whether we can join data from third party partners with your Meta account for ads by adjusting your preferences within Meta's settings. You can disconnect this data from your Meta account by changing your settings for Off-Facebook activity. For more information, please see Meta's Privacy Policy here.

Links to other websites

Our website may contain links to other parties' websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from single sign-on accounts

If you connect your account with us using a single sign-on account, we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or followers and any other personal information you choose to share.

We use the personal information we receive from the single sign-on provider to create a profile for you on our platform and to access our services.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which

personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Use of Artificial Intelligence (AI)

Overview: We may use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations and the provision of our Services. We will only use AI Technologies when legally permitted and reasonable for our business operations.

How we use AI Technologies: We may use AI Technologies for the following purposes: • to conduct analysis and processing;

• to generate and modify content and coding;

• to improve and optimise our services and operations;

• to automate certain processes and communications, such as routine tasks; • to personalise your experience with our services;

• for quality assurance purposes; and

• to assist with customer support and respond to customer queries.

Data Protection and Security: Where we use service providers who provide AI Technologies to us, we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.

We will not input your personal information into any platform provided by an AI Technology service provider which then trains its model based on that information.

Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this Privacy Policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:

• Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon; and

• Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability; and

• Risk mitigation: we regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Australian Information Commissioner’s website (https://www.oaic.gov.au/). If you require any further information about the Privacy laws in New Zealand, you can visit https://www.privacy.org.nz/.

For any questions or notices, please contact our Privacy Officer at:

Email: support@safewill.com

Updated: 1 September 2026