Privacy Policy

1.About this policy

This Privacy Policy explains how Big Screen Entertainment Pty Ltd (ABN 71 006 931 675) of Melbourne, Victoria, Australia ("Willby", "we", "us", "our") handles personal information in connection with the Willby app (the "App") and our website at willby.com.au.

We handle personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). By using the App you agree to this policy. It should be read together with our Terms of Service.

Our website. The website collects only what's needed to run it. We use privacy-friendly, cookieless analytics (Cloudflare Web Analytics) that set no cookies and build no advertising profile, and, if you choose to use our contact form, the details you send us, delivered through Netlify Forms. The website sets no advertising or cross-site tracking cookies.

2.Our core privacy promise

The one exception is your own device backups: if you back up your device (for example to iCloud or a computer), that backup can include your Willby data. Those backups are controlled by you and Apple, not by us, see section 8.

Only the limited, non-document information described in section 3 ever leaves your device to reach us or our providers, and only for the purposes described.

3.What information we collect and how it is handled

3.1 Information stored only on your device (we never receive it)

• Your document content and personal details, as described in section 2. This includes health-related information if you create an Advance Care Directive, it is created and stored on your device and is never sent to us.
• Your acceptance of our Terms, we store a record that you accepted (the version, the date, and your confirmation that you are 18 or older). This record contains no name, email, or identifier and is kept in your device's secure keychain.

This information stays on your device. If you delete the App or reset your will within it, this information is permanently removed and cannot be recovered by us.

3.2 De-identified usage analytics

We collect de-identified product-analytics events to understand how the App is used (for example, that an onboarding step or a purchase screen was reached) so we can improve it. These events contain no document content and no directly identifying information, only event names and coarse, non-identifying labels.

This is provided by TelemetryDeck, a privacy-focused analytics service that does not fingerprint devices or build advertising profiles, and uses on-device salted, hashed identifiers. We do not use analytics to track you across other apps or websites, and we do not attempt to re-identify you from this data. Our website uses a separate cookieless analytics service (see section 1).

3.3 Purchases and subscriptions

When you buy a product or the WillbyOne subscription, the purchase is processed by Apple through the App Store. We never receive your payment card details. We use RevenueCat to manage and verify purchases and to restore your entitlements across your devices; for this purpose RevenueCat processes purchase and transaction identifiers associated with your Apple account.

3.4 If you contact us

If you contact us, through the contact form on our website, or an optional in-app support option, the message you write is sent to us over an encrypted (HTTPS) connection, together with any reply email address you choose to provide and basic technical details (such as app or browser version, and device model) that help us respond. Website contact-form messages are delivered through Netlify Forms. Please do not include your will content in a support message, we don't need it. Providing a reply email is optional but helps us get back to you.

3.5 Device features you can enable

• Face ID / Touch ID (optional app lock): if you turn on the app lock, authentication is handled entirely by iOS. We never receive or store your biometric data.
• Notifications (optional): if you allow them, we schedule local reminders on your device (for example, to sign your will or review it annually). These are generated on your device.

4.What we do not do

• We do not require an account, login, name or email to use the App.
• We do not sell or rent your personal information.
• We do not use third-party advertising or cross-app tracking, and we do not serve ads.

5.How we use information

We use the limited information above to: operate and improve the App and website; process and restore your purchases; respond to your support requests; and meet our legal obligations. We do not use it for any other purpose without your consent.

6.Automated decisions

The App turns your answers into a formatted document. It does not use automated processes to make decisions that could significantly affect your rights or interests, for example, we do not assess your eligibility for anything, score you, or make legal determinations about you or your documents. If this ever changes, we will update this policy to explain it, consistent with the automated decision-making transparency requirements under the Privacy Act 1988 (Cth).

7.Disclosure to third parties and overseas recipients

We disclose limited information only to the service providers needed to run the App and website:

Because some of these providers are located overseas, your information may be disclosed outside Australia to the countries listed above. We take reasonable steps to ensure that overseas recipients handle your information in a way consistent with the Australian Privacy Principles, including by choosing reputable providers that publish their own privacy commitments. Where we remain accountable for an overseas recipient under APP 8, we stand behind that obligation.

We may also disclose information if required or authorised by law.

8.Backups

Because your document data is stored on your device, it is included in any backup you make of your device (for example, an iCloud or computer backup) if you have backups enabled. Those backups are controlled by you and by Apple under Apple's terms, we have no access to them.

9.Data security

We take reasonable steps to protect your information through both technical and organisational measures: your document content is kept on your device and protected by your device's security features (including your device passcode and, if you enable it, the App's Face ID / Touch ID lock); the limited information that leaves your device is sent over encrypted (HTTPS) connections; your Terms-acceptance record is stored in your device's secure keychain; and we limit access to the small amount of information we do hold (such as support messages) to those who need it. No method of storage or transmission is completely secure, and you are responsible for securing your device and any copies (such as exported PDFs) you make.

10.Data breaches

If a data breach involving personal information we hold occurs, we will assess it promptly. Where a breach is likely to result in serious harm to affected individuals, we will notify those individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth), and take reasonable steps to contain and remediate it. Because your document content stays on your device and never reaches us, the information we could be responsible for in a breach is limited to the items in section 3 (such as support messages and purchase identifiers).

11.Data retention and deletion

• On-device data is kept until you delete it, you can reset your will within the App, or delete the App, to remove it. Once removed from your device it cannot be recovered by us.
• Analytics events are de-identified and retained by our analytics providers in aggregate.
• Support messages are retained by us for as long as needed to handle your request and keep reasonable records, then deleted or de-identified.

12.Children

The App is intended for people 18 years or older and is not directed at children.

13.Your privacy rights and complaints

Under the APPs you may ask to access or correct the personal information we hold about you. Because we deliberately hold very little (we don't receive your document content, and analytics are de-identified), most of your information is already under your control on your device. To make a request, contact us using the details below; we don't charge to make an access request, and we'll respond within a reasonable time.

If you wish to make a privacy complaint, contact us first using the details in section 15. We will acknowledge your complaint promptly (within 5 business days) and aim to respond substantively within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

14.Changes to this policy

We may update this policy from time to time. We will post the updated version at this URL and update the version number and effective date above. Material changes may require you to re-accept in the App.

15.Contact us

Privacy questions, requests or complaints:
Big Screen Entertainment Pty Ltd, Melbourne, Victoria, Australia
Email: support@willby.com.au
Or use our contact form.