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Privacy Policy

Last updated: 8 October 2026

This Privacy Policy applies to all personal information collected by LIONET Pty Ltd (we, us or our) via the website located at lionet.app (Website).

1. What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the website. The Personal Information which we collect and hold about you may include: name, email address, password, and profile details (date of birth, residency, marital status); contact details; user-entered vault content including financial, estate, legal, end-of-life and health-adjacent information, a digital inventory and uploaded documents; details of nominated people and contacts; subscription and payment information (card details handled by our payment provider); technical and device data (IP address, device and browser information, server logs); and cookies and local storage data.

2. Types of information

The Privacy Act 1988 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

We collect Sensitive Information (including health-adjacent and end-of-life information) only when you use specific features of our service, such as the digital vault. We obtain your express consent to collect this information separately during the relevant workflow. If you accidentally provide us with Sensitive Information that we did not request, please contact us immediately so we can ensure it is handled correctly.

Sensitive Information will be used by us only:

  1. for the primary purpose for which it was obtained;
  2. for a secondary purpose that is directly related to the primary purpose; and
  3. with your consent or where required or authorised by law.

3. How we collect your Personal Information

  1. We may collect Personal Information from you whenever you input such information into the Website, related app or provide it to Us in any other way.
  2. We may also collect cookies from your computer which enable us to tell when you use the Website and also to help customise your Website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
  3. We generally don’t collect Sensitive Information, but when we do, we will comply with the preceding paragraph.
  4. Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party, in cases like this we will take steps to make you aware of the information that was provided by a third party.

4. Purpose of collection

  1. We collect Personal Information to provide you with the best service experience possible on the Website and keep in touch with you about developments in our business.
  2. We customarily only disclose Personal Information to our service providers who assist us in operating the Website. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
  3. By using our Website, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from use. We do not use sensitive Personal Information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe button link.

5. Security, Access and correction

  1. We take reasonable steps in the circumstances to keep your Personal Information safe. These include technical, administrative, and physical controls appropriate to the nature of the information, and we require our staff and contractors to be bound by confidentiality obligations. Your Personal Information is encrypted both in transit and at rest. We require multi-factor authentication for account access and use role-based access controls to limit staff access to your data. When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy, delete or anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept as long as your account is active and we need it to provide the service. You can delete your information or close your account at any time. After your account is closed we permanently delete your vault data following a short grace period (around 30–90 days, during which you can reactivate or export it), except for limited records we are legally required to keep — such as billing and tax records, which we retain for up to 7 years, to fulfil our record-keeping obligations.
  2. The transmission of information via the internet is not completely secure. While we take reasonable steps to protect your Personal Information, we cannot guarantee the security of information sent through our platform.
  3. If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).
  4. The Australian Privacy Principles:
    1. permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
    2. allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
  5. Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.

6. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by our Privacy Officer and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

7. Access after death and third-party access

Our service is designed to provide access to your vault data to nominated people (such as executors or deputies) after your death. We will provide access to such persons upon receipt of satisfactory evidence of your death and their identity/authority (such as a death certificate and grant of probate or letters of administration).

Information about a deceased person is not 'Personal Information' under the Privacy Act 1988 (Cth). However, we continue to treat such information with care, particularly where it contains Personal Information about living individuals (such as beneficiaries or nominated contacts).

Nominated people and contacts provided by you may be contacted by us to facilitate the delivery of your digital legacy. We collect their information indirectly from you for this purpose.

8. Overseas transfer

Your Personal Information may be transferred to or stored in countries outside of Australia (including the United States). We use third-party service providers (such as cloud hosting and payment processors) to operate our services. To ensure your information remains protected, we take reasonable steps to secure the handling of your data, including:

  1. entering into contractual safeguards with recipients;
  2. performing vendor due-diligence checks;
  3. verifying that recipients hold relevant security certifications; and
  4. configuring services in an Australian region where available.

We accept responsibility under the Australian Privacy Principles for any mishandling of your Personal Information by an overseas recipient.

9. GDPR

In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not specifically target customers located in the European Union and we do not monitor the behaviour of individuals in the European Union, and accordingly the GDPR does not apply.

10. How to contact us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through: admin@lionet.app.