Privacy policy

Last updated: 28 August 2026

1. Who we are

This policy explains how FCG Financial Services Pty Ltd (ACN 635 012 396, ABN 38 635 012 396) of Ground Floor, 345 Ann Street, Brisbane QLD 4000, Australia (we, us, our) handles personal information in connection with WillCloud, including app.willcloud.com.au and related applications (the Service).

We are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth). This policy applies to the Service. It does not cover third-party sites we link to.

2. What we collect

Depending on how you use the Service, we may collect:

• identity and contact details (name, email, phone, address, date of birth);
• account and security information (including authentication data);
• estate and will information you enter (family, gifts, executors, witnesses, funeral wishes, and similar answers);
• identity documents and biometric data for verification (typically collected by our provider Sumsub);
• payment and billing metadata (processed by Stripe; we do not store full card numbers);
• photos, videos, messages, and other files you upload (including vault items and last-words recordings);
• technical data such as IP address, device and browser type, and how you use the Service.

We collect information from you, from people you invite (for example a witness or solicitor), from service providers acting for us, and automatically when you use the Service.

3. Why we collect it

We collect and use personal information to:

• provide, secure, and improve the Service;
• create and manage accounts;
• verify identity where the Service requires it;
• process payments and keep records;
• share information with people you authorise (executors, witnesses, solicitors, beneficiaries, or support staff);
• send service messages (and marketing only where permitted);
• comply with law, prevent fraud, and handle disputes.

If you do not provide information we need for a feature, we may not be able to provide that feature.

4. Who we disclose it to

We may disclose personal information to:

• Sumsub — identity verification (documents and biometrics);
• Stripe — payments;
• Google — cloud hosting, authentication, and (if you use it) the in-app assistant;
• email delivery providers we use to send service mail;
• professional advisers, courts, or regulators where required or permitted by law;
• a buyer or successor if we transfer our business, on confidentiality terms.

We do not sell personal information. Service providers may only use information to perform their services for us, unless the law requires otherwise.

5. Overseas disclosure

Some providers (including Google, Stripe, and Sumsub) may process information on servers outside Australia, including in the United States and the European Union. Where we disclose personal information overseas, we take reasonable steps to ensure it is handled in a way that is consistent with the Australian Privacy Principles.

6. Security and retention

We use administrative, technical, and physical measures appropriate to the sensitivity of the information. No internet transmission is completely secure. We keep information for as long as we need it for the purposes above, including legal, accounting, and will-record obligations, and then delete or de-identify it where practicable.

7. Access, correction, and complaints

You may ask to access or correct personal information we hold about you, or complain about our handling of it, by emailing support@willcloud.com.au or writing to us at the address below. We will respond as soon as practicable, usually within 30 days.

If you are not satisfied, you may contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

8. Changes

We may update this policy by publishing a new version on this page. The “Last updated” date will change. Please check this page from time to time.

9. Contact

FCG Financial Services Pty Ltd
Ground Floor, 345 Ann Street, Brisbane QLD 4000, Australia
Email: support@willcloud.com.au