IMPORTANT:
This Privacy Policy explains how IDY Pty Ltd ABN 22 688 561 042 ("IDY", "we", "us", "our") collects, uses, stores, and protects personal information in connection with the Afterlife AI™ platform. Afterlife AI™ is a digital legacy platform that enables you to build a governed AI representation of yourself — a persona that captures your memories, personality, and voice, and that can continue to interact with your designated loved ones after your death, governed by the Executor Lock™ mechanism. We handle some of the most personal information a person can share. We take that responsibility seriously.
1. Who We Are
IDY Pty Ltd operates Afterlife AI™ from New South Wales, Australia. We comply with the Australian Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs), the EU General Data Protection Regulation (GDPR) for EEA users, the UK Data Protection Act 2018 for UK users, and the California Consumer Privacy Act (CCPA) for California residents. Our Privacy Officer can be contacted at privacy@idy.ai.
2. Lawful Basis for Processing
We process personal data only where we have a lawful basis to do so under GDPR Articles 6 and 9 and equivalent frameworks. The following bases apply:
Consent (Article 6(1)(a) and Article 9(2)(a))
All personal data and special-category data (including voice recordings, facial images, and emotional metadata) is processed on the basis of your explicit, informed, and revocable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Contractual Necessity (Article 6(1)(b))
Processing necessary to deliver the Platform services you have requested, including persona creation, Executor Lock™ governance, and account management.
Legitimate Interest (Article 6(1)(f))
Processing necessary to maintain Platform security, prevent fraud and misuse, and ensure service integrity, where these interests are not overridden by your data protection rights.
Legal Obligation (Article 6(1)(c))
Processing required to comply with applicable law, including data protection, financial, and regulatory obligations.
3. What We Collect and Why
Persona Data
Text, voice, video, and image inputs you provide to build your digital persona. Processed under your explicit consent and for the purpose of delivering the contracted service.
Emotional and Behavioural Metadata
With your explicit consent, we analyse audio and video inputs for emotional signals — tone, cadence, and expressive characteristics — to enrich persona authenticity. Classified as sensitive personal information with additional safeguards. Withdrawable at any time.
Executor and Trusted Contact Data
Names, email addresses, and access permissions for your designated Executor and Trusted Contacts. Shared only with the individuals you designate.
Account and Subscription Data
Email address, subscription tier, billing history, and transaction confirmations. Payment card details are processed by Stripe and not stored by IDY.
Technical Data
Device type, operating system, pseudonymised IP address, session identifiers, and usage logs. Used for security, fraud prevention, and service reliability only. Not used for advertising or profiling.
Support Communications
Messages sent to support@idy.ai or privacy@idy.ai. Retained for up to 2 years for quality assurance and legal compliance.
4. How We Use Your Information
We use your personal information solely to: build and maintain your Afterlife AI™ persona; operate the Executor Lock™ governance mechanism; enable secure access for your Executor and Trusted Contacts; process your subscription and manage your account; send service notifications and security alerts; comply with legal obligations; and maintain Platform safety and integrity. We do not use your personal information to train AI models unless expressly permitted under a separate agreement. We do not sell, rent, or licence your personal data. We do not use your data for advertising or profiling.
5. Sensitive Information
Afterlife AI™ processes sensitive personal information including voice recordings, facial images, emotional metadata, and health or wellbeing information you choose to share in your persona. We collect sensitive information only with your explicit consent and with additional safeguards. You may withdraw consent at any time; relevant data will be deleted within 30 days.
6. Posthumous Data
Afterlife AI™ is specifically designed for posthumous persona management. When your Executor activates the Executor Lock™ mechanism following your death, your persona data is frozen and transitions to read-only governance under your pre-configured permissions. IDY does not modify, supplement, or alter your persona after the Executor Lock™ Event. Posthumous data processing is conducted under your pre-death consent and IDY's legitimate interest in honouring the service contract you entered into. The Post-Lock Persona is retained until the Executor requests deletion or 25 years from the Executor Lock™ Event date, whichever is earlier.
7. Who We Share Data With
Subprocessors
Third-party service providers bound by data processing agreements requiring protection of your data to at least the standard in this Policy. Current subprocessor list: afterlife.ai/subprocessors.
Your Executor and Trusted Contacts
After the Executor Lock™ Event, your Executor and Trusted Contacts access your persona within the permissions you configured. IDY facilitates but does not initiate or modify these interactions except for safety purposes.
International Data Transfers
IDY Pty Ltd is incorporated in Australia. Where personal data is transferred outside Australia or the EEA to subprocessors or infrastructure providers located in other countries, IDY uses Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent transfer mechanisms, to ensure that your data receives a level of protection consistent with GDPR requirements. A list of countries to which data may be transferred is included in the subprocessor list at the relevant platform URL. You may request a copy of the applicable transfer safeguards by contacting privacy@idy.ai.
Legal Requirements
We may disclose personal data where required by law or to protect the rights, property, or safety of IDY, our users, or others.
Business Transfers
In the event of a merger, acquisition, asset sale, restructure, or other business transfer, your personal data may be transferred to the successor or acquiring entity as part of that transaction. Any successor entity will be bound by this Privacy Policy with respect to your personal data. Your continued use of the Platform following such a transaction constitutes acceptance of the transfer.
8. Security
We protect your data with AES-256 encryption at rest, TLS 1.3 in transit, role-based access controls, multi-factor authentication for administrative access, append-only audit logging, and short-lived pre-signed URLs for media access. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you directly without undue delay in accordance with GDPR Article 34, and will notify the relevant supervisory authority within 72 hours in accordance with GDPR Article 33. Notification will include the nature of the breach, likely consequences, and measures taken to address it.
9. Retention
Data retained for as long as your account is active. On deletion: all personal data removed within 30 days including backups. For posthumous personas: retained until Executor requests deletion or 25 years from the Executor Lock™ Event date. Anonymised analytics retained indefinitely.
10. Your Rights
Subject to applicable law, you have the right to: access your personal data; correct inaccuracies; request deletion; receive your data in portable format; restrict or object to processing; and withdraw consent at any time. Contact: privacy@idy.ai. We respond within 30 days.
11. Cookies and Analytics
We use privacy-preserving, anonymised analytics to measure Platform reliability. No advertising cookies, cross-site tracking, or third-party analytics are used. Opt-out available in account settings.
12. Children
Afterlife AI™ is intended for users aged 18 and over. We do not knowingly collect personal data from children under 18.
13. Changes to This Policy
Material changes will be notified by email or in-app notice at least 30 days before taking effect. Current Policy always available at afterlife.ai/privacy-policy.
14. Contact and Complaints
Privacy Officer, IDY Pty Ltd | ABN 22 688 561 042 | Email: privacy@idy.ai
Complaints may be referred to the Office of the Australian Information Commissioner at www.oaic.gov.au.