Global privacy policy

Effective date: 11 July 2026

At Gaia Digital Pty Ltd (ACN: 688 003 161) (together with our related brands, “Gaia,” “Gaia Digital,” “Company,” “us,” or “we”), we respect and protect the privacy of visitors to our website, www.gaiaapp.net, and the other websites under the gaiaapp.net domain (collectively, the “Sites”), and our customers who use our online wills, digital vault, funeral CRM, eulogy writing, memorial and tribute tools, and related services (together with the Sites, the “Platform”).

This Global Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect visitors’ and users’ information as part of the Platform. Any discussion of your use of the Platform in this Policy is meant to include your visits and other interactions with the Sites and Platform, whether or not you are a customer of Gaia’s product suite.

This Policy covers Gaia Digital Pty Ltd and the wider family of Gaia brands, including Funerals Live and Moments by Gaia (together, the “Gaia Group”). The Gaia Group is headquartered and operated from Australia, with users and visitors around the world. Gaia Digital Pty Ltd and Funerals Live are Australian entities and operate in accordance with Australian law. Moments by Gaia is operated from New Delhi, India, and where it collects personal information from users, it does so in accordance with applicable Indian data protection law, in addition to this Policy — see “Overseas disclosure” below for more detail. Where we provide services to New Zealand residents, we also have regard to the Privacy Act 2020 (NZ).

We are an Australian proprietary limited company and operate in accordance with Australian law, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles. From time to time, we may review and update this Policy, including to take account of new or amended laws, new technology, and/or changes to our operations. We will post changes to this Policy on our websites along with the effective date of the changed policy. We recommend that you review this Policy periodically. Your use of our services and the websites, and any dispute over privacy, is subject to this Policy and our Terms of Use, including applicable limitations on damages and the resolution of disputes.

By accessing and using our Platform, you signify your acceptance of the terms of this Policy. This includes the disclosures to service providers, partners, and overseas recipients described in this Policy — in particular, the countries identified under “Overseas disclosure” below. If you do not agree with, or you are not comfortable with, any aspect of this Policy, you should immediately discontinue access to or use of our Platform.

  1. Quality policy
  2. Gaia is dedicated to providing a high quality of service across online wills, digital estate planning, funeral and memorial technology, grief support content, digital consulting, and related products. We strive to exceed customer expectations by delivering safe, effective, and reliable solutions that align with the highest standards of customer experience and information security.

    We are committed to customer satisfaction, continuous improvement, compliance with Australian regulations (and, for Moments by Gaia, applicable Indian regulations), employee engagement, the safety and reliability of our products and services, and sustainability. Our Quality Policy is regularly reviewed to ensure it remains aligned with our business objectives, regulatory obligations, and the communities we serve.

    The entire Gaia team, across Gaia Digital, Funerals Live, and Moments by Gaia, is responsible for implementing this Quality Policy and contributing to its success. We are committed to making a difference for the families and funeral providers we work with through our dedication to quality, compassion, and customer satisfaction. To learn more about our commitment to quality, please get in touch with us.

  3. What “Personal Information” means
  4. In this Policy, “Personal Information” means any information relating to an identifiable natural person, or an opinion that can reasonably identify you, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Except as described in this Policy, Gaia will not give, sell, rent, or loan any Personal Information to any third party.

    Personal Information does not include data or information collected, derived, or otherwise generated from the use of the Platform, provided that such data has been anonymised, de-identified, and/or aggregated so as not to identify or permit the identification of any individual (“De-identified Data”). De-identified Data helps us understand trends in usage of the Platform so that we can better consider new features or otherwise tailor the Platform. In addition to collecting and using De-identified Data ourselves, we may share De-identified Data with third parties, including our customers, partners, and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Platform, as well as for advertising and marketing purposes.

  5. What information we collect
  6. When you visit our websites or use our products, we may collect personal information that you voluntarily provide to us. Depending on which product you use, this may include your name, date of birth, contact details, residential address, occupation, and in some circumstances financial information (for example, to process payments). For our will-writing, vault, and estate planning tools specifically, we may also collect details about your family, beneficiaries, executors, and assets, because this information is necessary for the documents and services you ask us to prepare.

    We may also collect information from you regarding other individuals related to your account, such as beneficiaries, executors, next of kin, or dependents. By disclosing information about these individuals, you warrant that you have their consent to such collection, use, and disclosure of their information as described in this Policy.

    Sensitive information. Some of our products may involve information that Australian law treats as “sensitive information”. For example, an advance care directive or health instruction stored in Gaia Vault contains health information, and a memorial, tribute, or funeral service page may reveal a person’s religious beliefs or cultural background. We only collect sensitive information that you choose to provide to us for the service you have asked us to deliver, and we treat your provision of that information as your consent to collect and handle it for that purpose. We do not use sensitive information for marketing.

    We may also automatically collect technical information about your device and how you use our website. This may include your IP address, browser type, device type, referring URL, pages visited, and similar usage information.

  7. How we collect information
  8. We are bound by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs), and any registered privacy codes that apply to us in Australia. For users of Moments by Gaia, we also collect and handle personal information in accordance with applicable Indian data protection law. This Policy sets out how we collect personal information:

    • directly from you when you use one of our products, such as our online will builder, Gaia Vault, CRM, or the Funerals Live and Moments by Gaia tribute and memorial tools;
    • directly from you when you submit an enquiry, contact form, or partner enquiry through our website;
    • from individuals who submit enquiries on behalf of a family member or client they represent;
    • from word of mouth referrals or links from social media or web campaigns;
    • through cookies and analytics tools when you browse our websites; and
    • through direct email and telephone communications.

    If you provide us with personal information about someone other than yourself (for example, a beneficiary named in your will, or a loved one you are creating a memorial for), you should ensure that individual is aware of and consents to the collection and use of their personal information as described in this Policy, where practical to do so.

  9. How we use your information
  10. We may use your personal information to respond to your enquiries, provide the products and services you have requested, communicate with you about your account or engagement with us, improve our websites and services, and meet our legal and regulatory obligations.

    We may also use your personal information for the direct marketing of products and services offered by Gaia Digital, Funerals Live, Moments by Gaia, or an organisation we are affiliated with. If you do not wish to receive direct marketing information, please contact us at any time to opt out. We will not charge you for giving effect to your request.

    We do not sell, trade, or rent your personal information to third parties for marketing purposes.

  11. Disclosure of your information
  12. We may disclose your information between Gaia Digital Pty Ltd, Funerals Live, and Moments by Gaia as part of our group operations, and to trusted service providers who assist us in operating our websites, conducting our business, or servicing you, provided those parties agree to keep this information confidential. We may also disclose information where required by law, regulation, or legal process in the country where the relevant Gaia Group entity operates.

    Payments. Payments across the Platform are processed by Stripe. Gaia does not see or store your full card details. If a family enables “gifts to the family” on an online memorial, the recipient’s identity and bank details are collected and verified by Stripe (not by Gaia) under Stripe’s own terms and privacy policy. If you send a gift or a virtual flower tribute, your name and any message you write appear publicly on the memorial’s tribute wall; gift amounts are never shown publicly. See our Gift terms for more detail.

    Charity links. Where a memorial or funeral page invites donations to a charity “in lieu of flowers”, the link takes you directly to the charity’s own donation page. Gaia does not collect, process, or receive any part of charity donations, and does not receive your personal information from the charity.

    Partners. We work with partner organisations — such as funeral homes and funeral directors, celebrants, and providers of complementary end-of-life services — to deliver and improve our services. Where a service you request involves a partner (for example, a funeral director who engaged Funerals Live for your family’s service, or a provider using Gaia CRM), we may share with that partner the personal information reasonably necessary to deliver that service. We do not share your personal information with partners for their own marketing purposes without your consent, and you may opt out of any partner-related marketing at any time by contacting us.

    Business customers (CRM). Where a funeral provider or other business customer uses Gaia CRM to manage information about their own clients, that information is collected by the provider, and we hold and process it on the provider’s behalf to deliver the CRM service. If you are a client of one of our business customers and have questions about how your information is handled, please contact that provider in the first instance — we will assist them in responding.

  13. Overseas disclosure
  14. We may disclose your personal information to overseas entities that provide support functions to us, including entities within the Gaia Group. The countries in which recipients of your personal information are likely to be located are:

    • the United States — our core cloud infrastructure and several of our service providers are US-based, including Google (Firebase cloud hosting, databases, and analytics), Stripe (payment processing), Anthropic (AI assistant processing — see “Artificial intelligence” below), and our website, scheduling, and email delivery providers; and
    • India — where Moments by Gaia and members of our team operate (see the callout below).

    Before we disclose any of your personal information to another entity, we take all reasonable steps to satisfy ourselves that the entity has a commitment to protecting your personal information at least equal to our commitment, or that you have consented to us making the disclosure.

    The personal information we hold about you may be held by us in electronic form on secure servers and may also be held in paper form. We use reputable cloud providers to store personal information, and those cloud servers may be located outside Australia, including in the United States as described above.

    Moments by Gaia is operating from India

    Moments by Gaia is operated out of New Delhi, Delhi NCR, India. Where Moments by Gaia collects, holds, or processes your personal information, it does so in accordance with the Digital Personal Data Protection Act, 2023 (India) and other applicable Indian law, in addition to the protections set out in this Policy. Any dispute relating to Moments by Gaia’s handling of personal information is subject to the jurisdiction of the courts of Delhi NCR.

    Gaia Digital Pty Ltd and Funerals Live remain Australian entities, incorporated and operated in Australia, and are governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

  15. Storage and security
  16. We take reasonable technical and organisational measures to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

    Personal information collected by Gaia Digital Pty Ltd and Funerals Live is stored with reputable cloud providers, principally Google cloud infrastructure located in the United States, and is handled in accordance with the Australian Privacy Principles wherever it is stored. Personal information collected by Moments by Gaia is stored and secured in accordance with applicable Indian law. Where information is transferred between Gaia Group entities or stored overseas, we take reasonable steps to ensure recipients apply protections consistent with this Policy.

    Data breaches. We maintain a data breach response process consistent with the Notifiable Data Breaches scheme under the Privacy Act. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

  17. How long we keep your information
  18. We keep personal information for as long as it is needed for the purposes described in this Policy, and then take reasonable steps to destroy or de-identify it. As a guide:

    • account content (including Gaia Vault documents) is permanently deleted within 30 days of you closing your account, as described in our Terms of Use;
    • published memorial and tribute content remains available for as long as the memorial is published, and may be removed by the memorial’s owner at any time;
    • enquiry, booking, and support correspondence is kept only as long as needed to respond and maintain our records; and
    • transaction records are retained as required by Australian tax, accounting, and other laws.
  19. Artificial intelligence
  20. Some features of the Platform use artificial intelligence:

    • Theia, our website chat assistant, uses a third-party AI provider (Anthropic, located in the United States) to answer questions about our plans, products, and services. Messages you type into the chat are processed by that provider to generate a response. Please don’t enter personal information into the chat beyond what is needed for your question.
    • Our Eulogy Writer and similar writing tools use AI to help draft eulogies and tributes from the details and memories you choose to provide. This content is often deeply personal — we only use it to generate your document.

    We do not use your personal information, your documents, or your memorial content to train AI models. AI-generated content is a starting point that you should always review — it may contain errors, and it is not legal, financial, or professional advice. We do not currently use personal information in automated decisions that produce legal effects or similarly significant effects on you; if that changes, we will update this Policy to describe those decisions.

    The Platform contains links to websites and applications other than the Platform, including websites and applications operated by affiliates and other third parties. This Policy applies only to information collected by the Platform.

    Gaia does not endorse and is not responsible for the practices of third parties or their websites or applications. We do not determine and are not responsible for the privacy practices or the content of websites or applications operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies.

    We are not responsible for, and we do not control, any third parties that you authorise to access your website content. If you are using a third-party website or service and you allow such a third party access to your website content, you do so at your own risk.

  21. Access and correction
  22. You have the right to access the personal information we hold about you and to request that we correct any information that is inaccurate, out of date, incomplete, irrelevant, or misleading. To exercise these rights, please contact us using the details below.

    You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au if you believe we have breached the Australian Privacy Principles.

  23. Cookies
  24. We may collect your personal information through cookies and other tracking devices. When you access our websites, we may send your device a “cookie” (a small summary file containing a unique ID number). This enables us to recognise your device each time you visit our websites, without requesting you to register or log in. It also helps us keep track of products or services you view, so we can send you news about them.

    We use cookies to measure traffic patterns, determine which areas of our websites have been visited, and measure aggregate transaction patterns. We use this to research our users’ habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser so your device does not accept them. We may also log IP addresses to analyse trends, administer the website, track user movements, and gather broad demographic information.

    We may also collect anonymous data (not personal information) relating to your activity on our websites (including IP addresses) via cookies or collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems, and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply, and we may use this information for any purpose and by any means whatsoever.

    We may combine the information that we have collected about you. If you have registered for secure access to our websites, or accessed an email we have sent you that includes a web beacon or sets a cookie, we are able to combine the information we collect about your usage of our websites with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our websites, even if you do not log on, and determine whether you came to our websites by clicking on an email link. This enables us to link information about your website visits, as well as any ads you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our websites and the effectiveness of our email communications and online advertising, as well as to identify products and services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see “Website analytics and interest-based advertising” below.

  25. Website analytics and interest-based advertising
  26. We partner with third parties to collect the information discussed in this Policy to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other devices and may use web beacons to collect information about your activity on our websites. In particular, our websites use Google Analytics to help collect and analyse certain information for the purposes discussed in this Policy. The information generated about your use of the websites may be transmitted to and stored by Google Analytics on servers outside your country of residence, including in the United States.

    From time to time we may also partner with third parties to provide targeted advertising services through digital channels and social media that are customised based on your online activities over time and across unaffiliated websites (“Interest-Based Advertising”). If we do, those third parties may use cookies and web beacons (and other storage technologies) to collect or receive information about your activity on our websites, and they may combine it with information about your activity on other unaffiliated websites. This means that you may see our banners and ads when you are on other websites and apps, such as social media.

    For more information about Interest-Based Advertising and how to opt out, please visit the Australian Digital Advertising Alliance (ADAA) opt-out page, available at http://www.youronlinechoices.com.au/opt-out/.

    Although our websites do not respond to “do not track” browser headers, you can limit tracking by taking the above mentioned steps. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies and not this Policy.

  27. Liability and our Terms of Use
  28. The content of this Platform is provided for general informational purposes only and should not be construed as legal, financial, or any other type of professional advice. The information contained herein is not a substitute for obtaining professional advice from a qualified person or entity. Use of this website does not create a professional relationship of any kind between the user and Gaia.

    Limitations of liability, indemnities, and intellectual property terms for your use of the Platform are set out in our Terms of Use, which also preserve your rights under the Australian Consumer Law.

  29. Contacting Us, Complaints, and Feedback
  30. If you would like to seek access to the personal information we hold about you, or if you have any questions or complaints about how we collect, use, disclose, manage, or store your personal information, you can contact us via the below channels:

    • Postal Address:
      Gaia Digital Pty Ltd
      G02/7 Smith Street
      Epping, NSW 2121
      Australia
    • Phone: +61 449 990 737
    • Email: info@gaiaapp.net

    If you make a complaint, we will take reasonable steps to investigate the complaint and respond to you within a reasonable time. For more information about privacy in general, or if you are not happy with our response, you may complain directly to the Office of the Australian Information Commissioner at www.oaic.gov.au.