How we look after your memories.

01

Who we are

This Privacy Policy explains how Rapt Ventures Pty Ltd (ABN 15 700 192 561) ("Heirloom", "we", "us", "our") handles personal information when you use the Heirloom mobile application, website and related services ("Heirloom").

Heirloom is based in Queensland, Australia. Where the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs) apply to us, we comply with them. We also use the APPs as a privacy framework for Heirloom. We are monitoring the development of Australia's Children's Online Privacy Code and will update our practices and this policy as applicable requirements are finalised.

Privacy and support contact: [email protected]

02

A quick summary

Heirloom is a private space for families and close groups to preserve memories. We do not sell personal information, show third-party advertising or use memories for targeted advertising. Timeline content is shared with the people who are members of that timeline. You can delete content, export account data and request account deletion, subject to the shared-content, operational, safety and legal exceptions explained below.

03

Personal information we collect

Information you give us:

• Account information: your display name, email address, date of birth and

an identifier from your chosen sign-in method.

• Memories: at least one photo or video, together with any title, written or

voice-generated caption, optional voice keepsake, date, optional location, contributions and names you choose to tag.

• Information about other people: a memory may include or name another

person, including a child. The person posting is responsible for the rights and consents described in section 8.

• Communications and safety reports: information you send in a support,

privacy, copyright or safety request.

Information collected when you use Heirloom:

• Service events: limited events and counts needed to operate and improve the

service, such as whether a timeline was created, an invitation was accepted or a memory was posted. These events do not contain the content of a memory.

• Technical information: device and operating-system details, app version,

build identifier, network/service errors and security information needed to operate the service.

Information from other services:

• Sign-in providers: Apple or Google may provide a verified email address,

private relay address, name and account identifier, depending on your choices.

• App stores and subscription services: Apple, Google and RevenueCat process

purchases and provide product, transaction and entitlement status. We do not receive or store your full payment-card number.

What we do not do:

• We do not use face recognition or create facial biometric templates.
• We do not create a voiceprint or use a recording to identify or verify you.
• We do not use third-party advertising pixels or cross-app advertising

tracking.

04

Voice-to-caption and AI processing

Heirloom memories always include a photo or video. An account holder aged 18 or over may optionally record the story behind that media. The recording is used to create an editable caption. If the person chooses to keep it, a separate voice keepsake can remain attached to that memory.

Before recording, Heirloom asks separately for agreement to overseas voice processing. The recording is sent securely through our service to:

• Google Cloud Speech-to-Text, which converts speech to text; and
• Anthropic's commercial API, which tidies the transcript into a readable

caption while aiming to preserve the speaker's meaning and tone.

Heirloom does not use customer content to train its own AI models and does not opt voice recordings, transcripts, captions, photos or videos into provider model-training programmes. Google Cloud Speech-to-Text does not log customer audio or transcripts for data logging by default, and Anthropic states that commercial API inputs and outputs are not used for model training unless the customer opts into a development programme. We do not make that opt-in. Providers may still process or retain limited information for security, abuse prevention, legal and service-operation purposes under their applicable commercial terms.

The source recording is scheduled for deletion from Heirloom's voice-audio storage within 7 days after processing. A selected voice keepsake remains with the memory until it is removed, the memory is deleted or another retention rule in section 10 applies.

05

Why we handle personal information

We handle personal information to:

• create, authenticate and secure accounts;
• create, store and show memories to authorised timeline members;
• generate editable captions and optional voice keepsakes;
• create invitation links that a member shares using their own device and apps;
• operate subscriptions and enforce the plan shown to the user;
• provide support, export and deletion functions;
• receive and investigate reports, enforce our Terms and protect users;
• maintain, diagnose and improve the service; and
• comply with legal obligations.

Where consent is the appropriate basis for a collection or use, it can be withdrawn as described in section 12. Withdrawal does not undo processing that was lawful before withdrawal and may mean the relevant optional feature cannot be provided.

06

Sensitive information

A memory may reveal information treated as sensitive under Australian law, including health information, racial or ethnic origin, religious beliefs or sexual orientation. By deliberately including that information, the person posting consents to Heirloom collecting it for the limited purpose of providing the memory to the selected timeline members. Do not post another person's sensitive information without an appropriate basis and permission.

Voice recordings are not used for biometric identification. We nevertheless protect them as highly personal content.

07

Who receives information

Information is disclosed only as reasonably needed to provide or protect Heirloom:

• Timeline members receive the content shared to timelines they have joined.
• Supabase provides authentication, database and file storage in an

Australian (Sydney) region.

• Google Cloud and Anthropic process optional voice-to-caption content,

as described in sections 4 and 9.

• RevenueCat, Apple and Google may process account, sign-in,

transaction or subscription information when their relevant feature is used.

• Postmark may process an email address and message details when a

Heirloom-operated transactional email or digest feature is enabled and used. Ordinary family invitations use the sender's operating-system share sheet; Heirloom does not collect the recipient's phone number or email address for that sharing flow.

• Professional advisers, regulators, law-enforcement bodies or other recipients

may receive information where reasonably necessary to obtain advice, comply with law, respond to lawful process, report unlawful material, enforce our rights or protect a person from harm.

• If the business is restructured or transferred, information may be disclosed

under confidentiality and with notice where required.

We do not sell personal information and do not disclose it for third-party targeted advertising.

08

Children and young people

Heirloom is designed for family histories, so memories may include children. The following safeguards apply:

• A person must be at least 16 years old to create an account.
• Voice recording and voice keepsakes are available only to an account recorded

as 18 or over.

• Before a memory that includes or identifies a child under 16 is posted, the

person posting must declare that fact and confirm parent or guardian consent.

• Families should involve a child in the decision where the child can understand

it, and act in the child's best interests.

• A parent, guardian or affected person may ask us to review or remove a child's

personal information, including a voice keepsake in which the child appears. Valid removal rights continue to apply if a timeline is memorialised.

• We do not use children's information for advertising or profiling.

An age control is based on the account holder's recorded date of birth. Heirloom cannot determine the age of every person who appears incidentally in a photo, video or adult's recording, so the declaration and guardian-consent obligation on the person posting is important.

If you believe a child's information was added without appropriate consent, contact [email protected].

09

Overseas disclosure

Heirloom's primary database and media storage are in Sydney, Australia. Optional voice-to-caption processing by Google Cloud and Anthropic can involve disclosure to and processing in the United States. RevenueCat, Apple, Google and Postmark may also process relevant service information in the United States and other countries in which they and their subprocessors operate.

Before optional voice processing begins, the App describes the overseas processing and asks for separate agreement. Where APP 8 applies, we take reasonable steps appropriate to the circumstances before disclosing personal information overseas. Overseas recipients may also be subject to the laws of their location.

10

Retention

We retain information only for as long as reasonably needed for the purposes in this policy, subject to these practical rules:

• Account information remains while the account is active and through a pending

deletion process.

• Memories remain while they are retained in a timeline.
• Source voice audio is scheduled for deletion within 7 days after processing.
• A chosen voice keepsake remains until it or its memory is removed.
• Deleted content is removed from ordinary user access and queued for storage

deletion. Technical retries and backup rotation can mean residual copies take additional time to disappear.

• Limited audit, transaction, consent, security and deletion records may remain

where reasonably needed for fraud prevention, accounting, dispute resolution, legal compliance or demonstrating that a request was actioned.

• Content reasonably believed to be unlawful or necessary evidence may be

restricted and preserved where required or permitted by law instead of being returned to ordinary access.

11

Deleting content and accounts

Deleting a memory removes it from ordinary access and starts removal of its media, caption, contributions, tags, source audio and voice keepsake from Heirloom-controlled systems, subject to section 10.

Account deletion disables sign-in and starts removal or de-identification of the personal account profile, subject to the limited records described in section 10. The person is asked to choose:

• Keep my memories: content previously contributed to shared timelines

remains for the family and is attributed to a former member.

• Delete everything: memories and contributions authored by that account are

removed from the relevant timelines and queued for deletion.

A memorialised account is read-only and is intended to preserve what the person shared. Before memorialisation, the living account holder's deletion choice applies. After a death is reported, next of kin and affected people can contact us about specific content, and a valid request concerning a living child is not overridden by memorialisation.

We cannot delete copies that another person made outside Heirloom, such as a download, screenshot or forwarded file.

12

Access, correction, export and consent

You can edit your display name, delete your own memories and export account data from the App. You may also ask us to:

• provide access to or correct personal information we hold about you;
• help with an export or deletion request;
• withdraw an optional consent, including overseas voice processing or guardian

consent; or

• review content that includes you or a child in your care.

Email [email protected]. We may need to verify identity and may limit an export where disclosure would unreasonably affect another person's privacy. We respond within a reasonable period and as required by applicable law.

13

Security and data breaches

We use encrypted transport, provider-managed encryption at rest, authentication, database-enforced timeline membership rules, private media storage, short-lived signed media links, access controls, audit records and operational monitoring. No internet service can guarantee perfect security.

If a data breach occurs, we investigate and take appropriate containment and notification steps. Where the Notifiable Data Breaches scheme applies and the legal threshold is met, we notify affected individuals and the Office of the Australian Information Commissioner as required.

14

Communications

Service and security messages may be sent when needed to operate an account. An optional digest or marketing message is sent only where the feature is enabled and the required consent exists. Commercial electronic messages identify the sender, include contact details and provide an unsubscribe method. An unsubscribe request is actioned as required by law.

Family invitation links are normally shared by a member using another app on their device; Heirloom does not choose the recipient or send that message.

15

Anonymity and pseudonyms

An account and display name are needed so timeline members can understand who shared a memory. Where it is lawful and practicable, a general enquiry may be made anonymously or using a pseudonym.

16

Complaints

Send a privacy complaint to [email protected]. Include enough detail for us to investigate. We will acknowledge and investigate the complaint, communicate the outcome and explain available review options. If the Privacy Act applies and you are not satisfied, you may be able to complain to the Office of the Australian Information Commissioner at oaic.gov.au.

17

Changes to this policy

We may update this policy as Heirloom, its providers or the law changes. If a change is material, we will provide notice in the App or by email and request a new acknowledgement or agreement where appropriate.

18

Contact

Rapt Ventures Pty Ltd ABN 15 700 192 561 Queensland, Australia [email protected]