Privacy Policy

Lionet (“Lionet”, “we”, “us”, “our”) is operated by [your legal entity name] in Australia. This policy explains how we collect, use, store and protect your personal information, in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. What we collect

Lionet is a private vault where you record information about yourself, your family and your estate. The personal information you may enter includes:

• Identity details — name, date of birth, residency, marital status
• Family members and designated beneficiaries — names, relationships, contact details
• Key contacts — such as your solicitor, accountant or financial adviser
• Financial information — assets, liabilities, superannuation, insurance, trusts and companies, and account references
• Digital inventory — devices and online accounts, including logins and recovery details (not the passwords themselves)
• Uploaded documents
• Will and estate details, powers of attorney, end-of-life wishes, and personal property and bequests

We do not collect health or medical information, Tax File Numbers, or Medicare numbers.

2. Sensitive information

Some of what you store (such as financial details) is “sensitive information” under the Privacy Act. We collect it only with your consent and only where it is reasonably necessary to provide the vault service to you.

3. How we collect it

We collect personal information directly from you when you create an account and enter it into Lionet. We do not buy your information or collect it from third parties.

4. Why we collect and use it

We use your information solely to provide Lionet to you — to store your records securely, show them back to you, and make them available to the people you have authorised, in the circumstances you have set (such as a steward you appoint, or a beneficiary you nominate to receive access after your death). We do not use your information for advertising.

5. Who we share it with

We do not sell your personal information. We disclose it only:

• to trusted service providers who host and run Lionet on our behalf (see “Storage and security” below);
• to people you authorise — a steward, or a beneficiary you nominate for access after your death, subject to the rules and verification you set;
• where we are required or authorised to do so by law.

6. Storage and security

Your data is stored in Australia, using Supabase’s Sydney (ap-southeast-2) region. It is protected by encryption in transit (HTTPS/TLS) and at rest, and by row-level security so that each account can only ever access its own records. Access requires your email and password. [Describe two-factor authentication once enabled.]

7. Overseas disclosure

Your vault data is stored in Australia. We do not currently disclose your personal information overseas. If that changes (for example, if we introduce optional AI features that process data outside Australia), we will update this policy and obtain your consent where required under APP 8.

8. Access on death, and stewardship

Lionet lets you nominate beneficiaries who may be granted access to your vault after your death, and stewards who may help manage a vault. Access is governed by the settings and verification steps described in the app. [The exact verification and activation process needs legal review.]

9. Accessing and correcting your information

You can view, edit and delete your information at any time from within Lionet, and you can delete your account. If you need help accessing or correcting your information, contact us using the details below.

10. Data retention

We keep your information for as long as your account is active. When you delete your account, your vault data is removed [describe the deletion process and any grace period].

11. Data breaches

If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.

12. Cookies and local storage

Lionet uses your browser’s local storage to keep you signed in and to make the app work. We do not use third-party advertising cookies. [Describe any analytics used, if applicable.]

13. Complaints and contact

If you have a question or complaint about your privacy, contact us at [contact email]. If you are not satisfied with our response, you can contact the 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 here with a new “last updated” date, and where changes are material we will let you know.