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The Personal Space NZ Ltd

Privacy Policy & Disclosure Statement

Effective Date: 3 October 2026  |  Version 2.1

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 — IPP 12 & 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) and Information Privacy Principle 12 of the Privacy Act 2020 (NZ), we disclose that data may be transferred to and stored by the following sub-processors. Each is bound by contractual data processing terms requiring protections comparable to those under the Privacy Act 2020 (NZ) and the Privacy Act 1988 (Cth):

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.

Disclosure on a verified release event is limited to the content you designated for delivery, including the contents of each Legacy Briefcase, which is disclosed only to the single recipient named on that briefcase. This is a disclosure authorised by you in advance under Information Privacy Principle 11(d) of the Privacy Act 2020 (NZ) and Australian Privacy Principle 6.1(a).

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 the currency shown at sign-up — New Zealand dollars for New Zealand members, Australian dollars for Australian members, and United States dollars elsewhere. The price displayed is the total amount payable. Where we are registered for GST in New Zealand or Australia, any GST on the supply is included within that price and is borne by us — nothing is added at checkout. Pricing is displayed at the time of sign-up and on your account dashboard, and the currency and amount are confirmed before any payment is taken. 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. Data Breach Notification

We maintain a privacy breach response plan. Where a breach affects your personal information and it is reasonable to believe it has caused or is likely to cause serious harm, we will notify you and the relevant regulator as required by law.

• New Zealand members. We will notify the Office of the Privacy Commissioner and affected individuals as soon as practicable after becoming aware of a notifiable privacy breach, in accordance with Part 6 of the Privacy Act 2020.
• Australian members. We will assess any suspected eligible data breach within 30 days and, where the assessment confirms it, notify the Office of the Australian Information Commissioner and affected individuals under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth).

A notification will describe the nature of the breach, the information involved, the steps we have taken, and what we recommend you do. Because vault contents are held under encryption, a breach of our storage layer will not necessarily expose readable content; our notification will say plainly what was and was not at risk.

11. Contact & Complaints

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

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner (New Zealand) at privacy.org.nz, or the Office of the Australian Information Commissioner at oaic.gov.au. You do not need to complain to us first, although it usually resolves matters faster.

This policy was last updated on 3 October 2026. We will notify active members of material changes via email.

The Personal Space NZ Ltd

Terms of Service

Effective Date: 3 October 2026  |  Version 2.1

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.

2.1 The two briefcases

The service provides two distinct and separately governed storage areas. The difference between them determines whether their contents are ever disclosed to another person, and you should understand it before placing material in either.

Material you wish to pass to another person must be placed in a Legacy Briefcase or elsewhere in your vault. Material placed only in a Personal Briefcase will not reach anyone, and we are not obliged to notify you of that consequence at the time of upload.

3. Subscriptions & Billing

Subscriptions are charged annually in the currency shown to you at sign-up: New Zealand dollars for New Zealand members, Australian dollars for Australian members, and United States dollars for members elsewhere. The price shown to you is the total amount payable for the subscription term. Where we are registered for GST in New Zealand or Australia, any GST on the supply is included within that price and borne by us; we do not add GST, tax or any processing fee at checkout, and the amount you are shown is the amount charged. A GST tax invoice is available on request where we are registered. If you are resident outside New Zealand and Australia, any sales tax, VAT, import duty, bank or card issuer fee that your own jurisdiction or provider imposes is outside our control and remains your responsibility. The currency is determined by the country you are in when you subscribe, and you may change it before checkout. We do not convert between currencies after a subscription starts; a change of currency takes effect at your next renewal. A 7-day free trial is available on first sign-up. You provide a valid payment method when you create your account; no charge is made during the trial period. If you do not cancel before the trial ends, your nominated payment method will be charged automatically for the first annual term. You may cancel at any time; your vault remains accessible for 90 days after cancellation, after which it is permanently deleted.

Plan allowances. Each plan includes a stated amount of encrypted storage and a stated number of scheduled letters per profile. Individual Basic and Joint Basic include 3 scheduled letters per profile; Individual Advanced and Joint Advanced include 5 per profile. Joint plans include 2 member profiles, each with its own customer ID. Allowances are set out on the Plans page and in your member dashboard, and may be varied on renewal with notice under clause 10.

Additional profiles and storage. Joint Advanced members may purchase up to 4 additional member profiles at NZD $9.99 per profile per year, to a maximum of 6 profiles in total. Additional storage may be purchased on any plan. Add-ons are billed annually alongside your membership, renew with it, and are non-refundable in accordance with clause 4. Cancelling your membership cancels all associated add-ons.

4. Cancellation Process & Refunds

How to cancel. You may cancel your membership at any time — from your member dashboard under Account Settings, or by emailing [email protected]. Cancelling stops any future automatic renewal. Your membership and full access to your vault continue until the end of the billing period you have already paid for.

After cancellation. Once your paid period ends, your vault enters a 90-day retention window during which you may reinstate it. After 90 days, your vault and all its contents are permanently and irreversibly deleted, and any scheduled deliveries are cancelled. We send reminder notices before deletion.

No refunds. Subscription fees are non-refundable. We do not provide refunds or credits for partial subscription periods, unused storage, or time remaining after you cancel, except where a refund is required by law (including the Consumer Guarantees Act 1993 (NZ) and the Australian Consumer Law, where they apply). The 7-day free trial is provided so you can evaluate the service before any payment is taken.

5. 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.

5.1 What is released

On verification, we release the vault content you have designated for delivery. This includes your letters, videos, voice messages, documents, recipes, bucket list and Digital E-Will where you have marked them for release, and the contents of each Legacy Briefcase, delivered to the recipient named on that briefcase and to no one else. Each Legacy Briefcase is delivered intact and separately; a recipient receives only the briefcase addressed to them.

5.2 What is never released — the Personal Briefcase

6. 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.

7. 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.

8. Your Consumer Rights & Our Liability

8.1 Statutory guarantees are not excluded

8.2 Encryption and the limits of what we can do

Vault contents are held under encryption and we do not hold a means of reading them in ordinary operation. We therefore cannot recover content for you if you lose your credentials, cannot screen or moderate what you upload, and may be technically unable to produce readable content in response to a lawful demand. You accept this as a feature of the service rather than a defect in it. This clause does not limit any liability we have for our own negligence or for a failure to take reasonable care.

8.3 Limitation

Subject always to clause 8.1, and 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; and our total aggregate liability to you shall not exceed the subscription fees paid by you in the twelve months immediately preceding the event giving rise to the claim.

9. Governing Law & Disputes

These Terms are governed by the laws of New Zealand, and the New Zealand courts have jurisdiction over any dispute. If you are an Australian consumer, nothing in this clause prevents you from bringing proceedings in Australia where the law gives you that right, and your rights under the Australian Consumer Law are not excluded by these Terms.

We would rather resolve a complaint than litigate it. Please contact us first at [email protected]. New Zealand consumers may take an unresolved dispute to the Disputes Tribunal where it is within that Tribunal's jurisdiction; Australian consumers may contact the ACCC or their state or territory consumer affairs office.

Unfair contract terms. We intend these Terms to be fair and readable. If any term is found to be an unfair contract term under subpart 2 of Part 2 of the Fair Trading Act 1986 (NZ) or sections 23 to 24 of the Australian Consumer Law, that term is severed and the remainder of these Terms continues to apply.

10. 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.

11. Contact

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

These Terms were last updated on 3 October 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.

Where you have created a Legacy Briefcase, the licence to access its contents passes to the single recipient named on that briefcase, and to no other person. This transfer does not extend to the contents of your Personal Briefcase, which is excluded from legacy release in all circumstances and is never disclosed to a beneficiary, executor, or any other third party. See clause 5.2 of our Terms of Service.

Copyright in User Content is not transferred by a legacy release. A recipient receives a personal licence to access and retain the material delivered to them; ownership of copyright passes under your will or the intestacy rules of your jurisdiction, not under this statement. We do not adjudicate between a recipient's licence under this clause and the rights of your estate.

6. Templates and Formats We Provide

Templates and formats we make available within the platform — including the Digital E-Will format, letter prompts, and bucket list structures — remain our Proprietary Content. You may use, adapt, and reproduce them freely for your own personal estate and legacy purposes, and any completed document you create from them is your own User Content, owned by you. You may not redistribute, resell, or publish our blank templates as your own work or as part of a competing service. Our provision of a template is not legal advice and does not create a solicitor-client relationship.

7. 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.

8. Limitation of Liability and Guarantees

8.1 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.

8.2 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.

8.3 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.

8.4 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.

8.5 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.

9. Deceased Verification and Legacy Handover Policy

9.1 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.

9.2 Required Documentation for Verification

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

9.3 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.

9.4 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.