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The Personal Space NZ Ltd

Privacy Policy & Disclosure Statement

Effective Date: 1 September 2026  |  Version 2.0

1. Introduction

The Personal Space NZ Ltd ("we", "us", "our") is committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital legacy vault service.

We operate under the New Zealand Privacy Act 2020 and its Information Privacy Principles (IPPs), and we ensure compliance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) for our Australian subscribers.

2. Definition of Sensitive Data & Purpose

All vault content is stored under AES-256 encryption at rest. Access is strictly zero-knowledge in normal operations — our staff cannot read your vault contents. Data is only decrypted when you authenticate and access your own vault, or when a verified legacy release event occurs (see Section 7).

3. Information We Collect

We collect: account registration details (name, email, date of birth, phone, address); vault contents you upload; payment identifiers passed from our payment processor; usage and access logs for security purposes; and device/browser metadata for fraud prevention.

4. How We Use Your Information

We use your personal information to: provide and maintain your vault service; process subscriptions and billing; send transactional communications (confirmations, renewal reminders, security alerts); verify identity for legacy release events; and comply with our legal obligations under NZ and Australian law.

5. Cookies & Tracking

We use only strictly necessary session cookies for authentication. We do not use advertising cookies, third-party tracking pixels, or behavioural analytics. Our infrastructure provider (Cloudflare) may process connection-level data subject to their own privacy policy.

6. Cross-Border Data Transfers — APP 8 Disclosure

The Personal Space NZ Ltd is a New Zealand-registered business. Our services are also available to Australian subscribers. Member data is stored on Cloudflare R2 infrastructure hosted in Australian data centre regions, managed and controlled by The Personal Space NZ Ltd.

In accordance with Australian Privacy Principle 8 (APP 8), we disclose that data may be transferred to and stored by the following sub-processors, each bound by appropriate data processing terms:

By using our service, Australian subscribers acknowledge that their personal information may be transferred to New Zealand and held by a NZ-based entity. We take reasonable steps to ensure all overseas recipients handle data consistently with the APPs.

7. Legacy Access, Beneficiary Verification & Disclosure

The following documents must be provided before any legacy release is triggered:

• New Zealand members: An official New Zealand Death Certificate issued by Births, Deaths and Marriages (BDM), plus a copy of the deceased's Will or a statutory declaration confirming executor status.
• Australian members: A certified copy of the death certificate issued by the relevant state or territory Registry of Births, Deaths and Marriages, plus either a Grant of Probate issued by an Australian court or Letters of Administration.
• Identity of the beneficiary/executor: A current government-issued photo ID of the person claiming access.

Upon receipt of verified documentation, vault contents are released according to the member's configured delivery instructions. Automated delivery to nominated recipients may follow the verified release event. All documentation is held securely and destroyed after the verification process is complete.

8. Subscription, Billing & Payment Gateway

Subscription billing is handled by Stripe, a PCI-DSS Level 1 certified payment processor. We do not store, process, or transmit raw credit card numbers, CVV codes, or full card details on our systems at any time.

Subscription fees are charged annually in NZD (inclusive of GST). Pricing is displayed at the time of sign-up and on your account dashboard. You will receive renewal reminder emails 7 days before each renewal date.

9. Your Rights

Under the NZ Privacy Act 2020 and Australian Privacy Act 1988, you have the right to: access the personal information we hold about you; request correction of inaccurate data; request deletion of your account and data; withdraw consent for non-essential processing; and lodge a complaint with the NZ Privacy Commissioner or the Australian Information Commissioner.

10. Contact & Complaints

Privacy enquiries and complaints may be directed to: [email protected]
The Personal Space NZ Ltd, New Zealand.

This policy was last updated on 1 September 2026. We will notify active members of material changes via email.

The Personal Space NZ Ltd

Terms of Service

Effective Date: 1 September 2026  |  Version 2.0

1. Acceptance of Terms

By creating an account with The Personal Space NZ Ltd ("we", "us", "our") you agree to be bound by these Terms of Service. If you do not agree, do not create an account or use our service.

2. The Service

The Personal Space provides a secure, encrypted digital vault for storing personal documents, letters, videos, and messages intended for delivery to nominated recipients upon your passing. The service is a personal storage and delivery platform — it is not a legal, medical, or financial service, and does not constitute legal advice or estate planning guidance.

3. Subscriptions & Billing

Subscriptions are charged annually in NZD inclusive of GST. A 7-day free trial is available on first sign-up. After the trial, your nominated payment method will be charged automatically. You may cancel at any time; your vault remains accessible for 90 days after cancellation, after which it is permanently deleted.

4. Legacy Release & Beneficiary Access

Upon receipt and verification of these documents, legacy content is released according to the member's configured delivery instructions. Automated delivery to nominated recipients may follow the verified release event. The Personal Space NZ Ltd reserves the right to request additional verification at its discretion.

5. Member Responsibilities

You are responsible for keeping your account credentials secure; ensuring your designated recipients and legacy contact details remain current; complying with all applicable laws in your jurisdiction when uploading content; and not uploading content that is unlawful, harmful, or infringes third-party rights.

6. Data & Vault Retention

Your vault data is retained for the duration of your active subscription plus 90 days following cancellation or non-renewal. After this period, data is permanently and irreversibly deleted from our storage systems. We will send deletion warning notices at 30 days and 7 days before permanent deletion.

7. Limitation of Liability

To the maximum extent permitted by law, The Personal Space NZ Ltd is not liable for any indirect, incidental, or consequential loss arising from use of the service, failure of automated delivery, or force majeure events. Our total liability to you shall not exceed the subscription fees paid by you in the preceding 12 months.

8. Governing Law

These Terms are governed by the laws of New Zealand. Any disputes shall be subject to the exclusive jurisdiction of the New Zealand courts. Australian Consumer Law rights are not excluded by these Terms to the extent they apply to you.

9. Changes to Terms

We may update these Terms from time to time. Material changes will be communicated to active members via email with at least 14 days' notice. Continued use of the service after the effective date constitutes acceptance of the revised Terms.

10. Contact

Questions about these Terms may be directed to: [email protected]
The Personal Space NZ Ltd, New Zealand.

These Terms were last updated on 1 September 2026.

The Personal Space NZ Ltd

Copyright & Intellectual Property Statement

Effective Date: 28 September 2026

1. Ownership of This Website and Platform

Unless otherwise indicated, this website, the digital legacy vault platform, and all associated software, source code, databases, functionality, website designs, audio, video, text, photographs, and graphics on the platform (collectively, our "Proprietary Content") are owned or licensed by us. They are protected by copyright, trademark, and other intellectual property rights under:

• The Copyright Act 1994 (New Zealand)
• The Copyright Act 1968 (Australia)
• International copyright treaties and conventions.

Our trademarks, logos, and service marks may not be used in connection with any product or service without our prior written consent.

2. Limited Licence to Subscribers

Subject to your active subscription and compliance with our Terms of Service, we grant you a non-exclusive, non-transferable, revocable licence to access and use our platform solely for your personal or designated estate planning purposes. You must not copy, reproduce, aggregate, republish, download, post, publicly display, encode, translate, transmit, distribute, sell, licence, or otherwise exploit any part of our platform or Proprietary Content for commercial purposes without our express prior written permission.

3. Ownership of Your Uploaded Vault Data

We claim zero ownership or copyright over any text, files, images, photos, videos, or other materials you upload to your digital legacy vault (collectively, "User Content"). By using our platform, you represent and warrant that:

• You own the copyright to the User Content, or you have the necessary licences, rights, and permissions to store it.
• The storage of your User Content does not infringe the intellectual property rights of any third party.

4. Zero-Knowledge and Monitoring Disclaimer

Because our platform operates on a zero-knowledge encryption architecture, all User Content is encrypted client-side before it reaches our infrastructure or Cloudflare networks.

• We cannot view, read, monitor, or access your uploaded files.
• Consequently, we do not screen, audit, or review User Content for copyright compliance.
• You assume full legal responsibility for ensuring that your uploaded files do not violate New Zealand, Australian, or international copyright laws.

5. Rights of Beneficiaries and Legacy Contacts

Upon the successful activation of your legacy vault (following our verification of a trigger event), the licence to access your decrypted User Content will transfer to your designated beneficiaries or executors according to your account settings. We act solely as a secure custodian of the cryptographic data and do not adjudicate copyright disputes between beneficiaries or third parties.

6. Copyright Infringement Notifications (Takedown Policy)

We respect the intellectual property rights of others. If you believe that any material available on or through our website infringes upon any copyright you own or control, please notify us immediately at [email protected].

Please note that due to our zero-knowledge encryption, we are physically unable to view or remove specific files stored inside a user's private encrypted vault. However, we will act swiftly to address infringing material on our public-facing website, marketing channels, or unencrypted metadata layers in compliance with the New Zealand Copyright Act 1994 and the Australian Copyright Regulations 1969.

7. Limitation of Liability and Guarantees

7.1 Statutory Guarantees and Consumer Rights

Nothing in this statement excludes, restricts, or modifies any consumer guarantees, rights, or remedies implied by law that cannot be excluded under:

• The Consumer Guarantees Act 1993 (New Zealand)
• The Competition and Consumer Act 2010 (Australia) / Australian Consumer Law (ACL)

Where our services fail to meet a statutory guarantee that cannot be legally excluded, our liability is strictly limited, at our sole option, to resupplying the subscription services or refunding the cost of the affected subscription period.

7.2 Zero-Knowledge & Cryptographic Key Responsibility

You explicitly acknowledge and agree that our platform operates on a zero-knowledge encryption architecture.

• Lost Keys: We do not hold, store, or have access to your master passwords, private encryption keys, or recovery phrases. If you or your designated beneficiaries lose, misplace, or forget these keys, we cannot recover them, reset them, or decrypt your data.
• Total Data Loss: We accept zero liability for any permanent loss of data, files, or digital assets resulting from your failure to securely store your cryptographic access credentials.

7.3 Third-Party Network Infrastructure (Cloudflare)

Our platform relies on Cloudflare and other third-party cloud infrastructure providers to host, route, and distribute encrypted data packets. We do not warrant that the platform will be entirely uninterrupted, secure, or free from server downtimes, network latency, cyberattacks, or routing errors outside of our direct, reasonable control. To the maximum extent permitted by law, we exclude all liability for disruptions caused by these third-party integrations.

7.4 Maximum Liability Cap

To the maximum extent permitted by law, our total aggregate liability to you, your estate, your executors, or your designated beneficiaries for any claims arising out of or in connection with this platform — whether in contract, tort (including negligence), breach of statutory duty, or otherwise — is strictly limited to the total amount of subscription fees paid by you to us in the twelve (12) months immediately preceding the event giving rise to the claim.

7.5 Exclusion of Consequential Loss

In no event will we, our directors, employees, or agents be liable to you or any third party (including beneficiaries) for any indirect, consequential, exemplary, incidental, special, or punitive damages. This includes, without limitation, claims for loss of profit, loss of revenue, loss of sentimental or financial data, emotional distress, or estate administration delays arising from your use of, or inability to use, the platform.

8. Deceased Verification and Legacy Handover Policy

8.1 The Handover Framework

We take the security of your digital vault seriously. Access to a subscriber's account lifecycle metadata or the initiation of the cryptographic data release workflow will only be granted to a designated Legacy Contact or Legal Personal Representative (LPR) once a formal trigger event has been legally verified by our team.

8.2 Required Documentation for Verification

To initiate a legacy handover request, the claimant must provide official, high-resolution documentation via our secure verification portal.

8.3 Verification Assessment and Fraud Mitigation

Upon receipt of a claim, we reserve the right to cross-reference the submitted documents with official death registries, contact the issuing authority, or require statutory declarations under the Oaths and Declarations Act 1957 (NZ) or the Statutory Declarations Act 1959 (Cth, Australia).

• We allow a standard assessment window of up to 10 business days to process and verify the validity of the documentation.
• We reserve the right to reject any claim or freeze access to the account indefinitely if we suspect document forgery, identity fraud, or an active dispute between beneficiaries or executors.

8.4 Execution of the Zero-Knowledge Handover

Once documentation is fully verified, we will execute the automated handover protocol as configured by the original subscriber:

• No Access to Vault Content: We will never have the capacity to decrypt, view, or extract the contents of the vault for the claimant, nor can we override a lost master password or key.
• Key Delivery Shield: We act solely as a delivery vehicle. We will provide the claimant with access to the encrypted data blobs and any user-stored, encrypted hints. If the original subscriber did not securely share the private cryptographic key or passkey with the Legacy Contact prior to their passing, the data will remain permanently encrypted and inaccessible.
• Dispute Indemnification: If multiple claimants emerge (e.g., competing executors or family members disputing a Will), we will immediately lock the platform's metadata transfer until an agreement is reached or a court order is issued by a competent court in New Zealand or Australia. We accept no liability for execution delays caused by family or estate disputes.

This Copyright & Intellectual Property Statement is effective from 28 September 2026. © 2026 The Personal Space NZ Ltd. All rights reserved.