Effective date: 27 February 2026

1. Our privacy commitment

My Will My Way (“we”, “us”, “our”) is committed to protecting your personal information.

Our privacy framework is built on two foundations:

1. 1. the EU General Data Protection Regulation (GDPR) as our global benchmark standard; and
   2. the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) as our primary domestic legal framework.

This means that, regardless of where you are located, we design our data practices to be consistent with the core protections of the GDPR, while also complying with the APPs in Australia.

Where there is any inconsistency between the GDPR and the APPs, we will apply the standard that provides the higher level of protection to your personal information.

2. Who we are and what we do

My Will My Way is operated by My Law Firm (ABN 60 128 788 938), with registered postal address PO Box 1208 Fremantle WA 6959.

My Will My Way provides an online Platform that:

2. 1. uses an AI-powered Avatar to conduct a Will interview;
   2. collects and processes your information;
   3. generates a draft Will based on your responses; and
   4. provides execution guidance specific to your selected Australian State or Territory.

We are not a law firm for the purposes of your Will unless your matter is escalated and you separately engage a lawyer under a distinct costs agreement.

Use of the Platform is governed by our Terms and Conditions and this Privacy Policy. The Platform provides document preparation services only and does not provide legal advice unless your matter is escalated and you separately engage a lawyer.

3. Who this policy applies to

This Privacy Policy applies to all users of the Platform, whether located in Australia or overseas.

The Platform is primarily designed for users who reside in Australia and will execute their Will in Australia, as stated in the Terms and Conditions. Users outside Australia may still access the Platform but acknowledge that additional local legal requirements may apply in their jurisdiction.

3. 1. Children and persons lacking capacity

1. The Platform is not intended for use by persons under 18 or persons who lack legal capacity to make a Will.
2. We do not knowingly collect personal information from such persons. If we become aware that we have collected information from a person who should not be using the Platform, we will take steps to delete that information or suspend the Account.

4. What personal information we collect

4. 1. General collection

Because the Services involve preparing a Will, we collect personal and sensitive information that is reasonably necessary to generate your document.

1. 2. Identity and contact information

This may include:

1. full name;
2. date of birth;
3. residential address;
4. email address;
5. phone number; and/or
6. country of residence.

1. 3. Family and estate information

This may include:

1. marital status;
2. children and dependants;
3. beneficiaries;
4. executors and substitute executors;
5. guardians for minor children;
6. details of assets (for example: property, bank accounts, superannuation, investments, personal possessions); and/or
7. liabilities where relevant to your estate plan.

1. 4. Sensitive personal information

Consistent with your Terms, the Platform may collect sensitive personal information, including:

1. details about your family members and relationships;
2. information about your assets and financial affairs;
3. details about beneficiaries, executors and guardians; and
4. potentially, information about health, disability, or special circumstances of beneficiaries.

1. 5. Consent and collection limits

You expressly consent to the collection and use of this information for the purposes of generating your Will and providing the Services.

We will not collect sensitive information for any unrelated purpose.

We collect only information that is reasonably necessary to provide the Services.

5. How we collect your information

5. 1. Collection methods

We collect your personal information when you:

1. complete the Avatar Will interview;
2. input information into the Platform;
3. upload documents to your Account;
4. communicate with us via email, chat or support channels;
5. create an Account; or
6. interact with our website (including via cookies).

1. 2. Anonymous use

You may explore the Platform with limited identifiers, but generating a complete draft Will typically requires identifiable information at the final drafting stage.

6. How we use your information

6. 1. Permitted uses

We use your personal information to:

1. conduct the Will interview through the Avatar;
2. generate your draft Will;
3. determine whether your matter should be escalated;
4. provide execution guidance for your selected State or Territory;
5. deliver your draft Will in digital format;
6. maintain your Account if you choose to store drafts;
7. operate, secure and improve the Platform; and
8. comply with legal obligations.

1. 2. What we do not do

We do not:

1. verify the accuracy of your information; or
2. use your personal information for marketing or sale to third parties.

7. AI processing and data governance

7. 1. How AI is used

The Platform uses automated systems (including AI) to assist in generating your Will based on your responses. The system structures and formats your information according to pre-set drafting logic; it does not make binding legal decisions about your rights.

1. 2. AI model and data use

The AI Avatar operates on a fixed model within a controlled technical environment. It does not learn from your responses, and your data is not shared externally or used for AI training.

1. 3. Internal records

We maintain internal records of our data processing activities as required under applicable privacy laws, including the purposes of processing, categories of data, and security measures implemented.

1. 4. Your right to query automated processing

You have the right to ask us how the automated system works in general terms and to request human assistance if you have concerns about the output.

1. 5. Escalation criteria

Escalation decisions are based on pre-defined criteria designed to identify matters that require legal review.

8. Lawful basis for processing (GDPR alignment)

8. 1. Basis for processing

Where the GDPR applies to your personal information, we rely on:

1. your explicit consent (for sensitive personal information and Will instructions);
2. performance of a contract (to provide the Services you requested).

1. 2. Withdrawing consent

You may withdraw consent at any time by contacting us, subject to legal or contractual limitations. If you withdraw consent to the processing of information necessary to generate your Will, we will be unable to complete the Services. Refund eligibility is governed by the Terms and Conditions.

If you withdraw consent before your Will is generated, we will stop processing your personal information for that purpose, subject to any legal retention obligations.

9. Cross-border data handling

9. 1. Overseas storage and processing

Because the Platform operates online, your personal information is stored and processed on secure cloud infrastructure that may be located outside your country of residence.

1. 2. Safeguards

We implement technical and organisational safeguards consistent with GDPR standards and the APPs to protect your information during these overseas transfers.

1. 3. Your consent to transfer

By using the Platform, you consent to overseas data transfers. If you do not consent to overseas storage or processing, you should not use the Platform.

1. 4. Comparable protections

Where your information is transferred overseas, we take reasonable steps to ensure comparable privacy protections are in place.

10. Security of your information

10. 1. Our security measures

We implement reasonable technical and organisational measures to protect your personal information, including encrypted data storage, restricted system access, and secure cloud infrastructure.

1. 2. No absolute guarantee

However, no online system is completely secure. You use the Platform at your own risk.

1. 3. Your security obligations

Your personal security obligations (passwords, devices, and notification of suspected breaches) are set out in clause 12 of the Terms and Conditions.

11. Cookies and analytics

11. 1. Types of cookies we use

We may use the following types of cookies:

1. Essential cookies: Required for the Platform to function (e.g., maintaining your session, security features).
2. Functional cookies: Remember your preferences and settings.
3. Analytical cookies: Help us understand how users interact with the Platform to improve performance and user experience.

1. 2. No advertising cookies

We do not use third-party advertising cookies.

1. 3. Managing cookies

You may disable non-essential cookies via your browser settings, though some Platform features may not function properly. Essential cookies cannot be disabled without affecting Platform functionality.

12. Disclosure of your information

12. 1. When we may disclose

We may disclose your personal information only in the following circumstances:

1. To third-party service providers that support the Platform, including:
   1. cloud hosting and storage providers (provider name);
   2. payment processors (provider name);
   3. email delivery services (provider name);
   4. identity verification services (provider name); and
   5. remote witnessing platforms (provider name) (if applicable).

   These providers are bound by confidentiality obligations and process your information only as instructed by us.

2. To authorised witnesses or third parties if you request remote or special witnessing assistance.
3. Where required by law, court order, or regulatory authority.
4. With your express consent.
5. If your matter is escalated to a lawyer for review or completion, your information will be disclosed to that lawyer. The lawyer’s handling of your information will be governed by their own professional and privacy obligations. Once your matter has been escalated and transferred to a lawyer, we may delete your information from the Platform in accordance with our retention practices.

1. 2. Third-party responsibility

Your use of third-party services is subject to their own privacy policies and terms. We are not responsible for privacy breaches caused by third-party providers.

13. Your privacy rights (GDPR-aligned)

13. 1. Your rights

You have the right to:

1. access the personal information we hold about you;
2. request correction of inaccurate or incomplete information;
3. request deletion of your personal information where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements; and
4. withdraw consent where consent is our lawful basis for processing.

1. 2. Response timeframe

We will respond to your request within 30 days. If we require more time due to complexity or volume of requests, we will inform you and explain why.

1. 3. Additional GDPR rights

Where the GDPR applies, you also have the right to:

1. data portability (receive your information in a structured, commonly used format);
2. object to processing in certain circumstances; and
3. restrict processing where accuracy is contested or processing is unlawful.

14. Data retention

14. 1. General retention principle

We retain your personal information only for as long as necessary to provide the Services, maintain records you have chosen to store, or meet legal obligations.

1. 2. Draft Wills (not executed)

We may retain draft Wills for up to 90 days following Account inactivity, after which they may be deleted without further notice. You are responsible for downloading and saving any drafts you wish to keep and must not rely on the Platform as your sole storage location.

1. 3. Executed Wills and witnessing records

We may retain executed Wills and associated records while your Account remains active, or until you request deletion, subject to legal retention obligations. If your Account becomes inactive for an extended period, we may attempt to contact you before archiving or deleting records. You are responsible for keeping your contact details current and for informing your executor where to access your Will.

1. 4. Access while active

While your Account is active, you may access and download your stored information at any time through the Platform.

1. 5. After termination or closure

If your Account is terminated or closed:

1. we may retain your information as required by law or for legitimate business purposes;
2. we are not obliged to maintain or provide ongoing access to your data; and
3. you are responsible for downloading any Wills before requesting Account closure.

15. Data breach notification

15. 1. Eligible data breach response

If we experience an eligible data breach (as defined under the Privacy Act 1988), we will:

1. assess whether the breach is likely to result in serious harm to you;
2. notify affected individuals and the OAIC where required; and
3. provide information about the breach, the kind of information involved, and steps you should take.

1. 2. GDPR notification obligations

We will comply with equivalent notification obligations under the GDPR where applicable.

16. Complaints

16. 1. How to lodge a complaint

If you believe we have breached your privacy rights, you may lodge a complaint in writing to us.

1. 2. Our response process

We will acknowledge your complaint within 7 days and provide a substantive response within 30 days. If we require additional time, we will notify you and explain the reason for the delay.

1. 3. External escalation

If your complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) for Australian matters, or the relevant privacy regulator in your jurisdiction.

17. Contact details

Privacy Officer

My Will My Way

PO Box 1208 Fremantle WA 6959

Phone: 1300 529 888

Email: support@mywillmyway.com.au

Website: https://mywillmyway.com.au

18. Changes to this Privacy Policy

18. 1. Updates to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements.

1. 2. Notification of changes

We will notify you of material changes by email and by posting a notice on the Platform. We will update the effective date at the top of this document.

1. 3. Continued use constitutes acceptance

Your continued use of the Platform after changes take effect constitutes acceptance of the updated Privacy Policy. If you do not agree to the changes, you should discontinue use of the Platform.

19. Communications from us

19. 1. Service-related communications

We may send you service-related communications including:

1. Account notifications and security alerts;
2. Updates about your Will preparation status;
3. Reminders to update your contact details;
4. Important changes to our Terms or Privacy Policy; and
5. Responses to your support requests.

1. 2. Mandatory communications

These communications are necessary for the operation of the Services and cannot be opted out of while you maintain an Account.

1. 3. No marketing communications

We do not send marketing or promotional communications unless you have separately opted in to receive them.

20. Third-party links

20. 1. Links to external services

The Platform may contain links to third-party websites or services (including payment processors, witnessing services, or legal resources).

1. 2. No responsibility for third parties

We are not responsible for the privacy practices or content of these third parties. Your use of third-party services is governed by their own privacy policies and terms.

We recommend you review the privacy policy of any third-party service before providing them with personal information.