PRIVACY POLICY
We understand how important your privacy is, and that you have certain rights in relation to your data. At any time, you can exercise your rights or contact us with queries at help@betterwill.uk.
For further details about our processing of your data and your rights, please see below.
CONTENTS
1. ABOUT US
Betterwill is a trading name of Betterwill Limited (“we”, “us”, “our”), a company registered in England and Wales (Company Number: 11947701), whose registered office address is at Henleaze Business Centre, 13 Harbury Road, Bristol, England BS9 4PN.
For the purposes of the General Data Protection Regulation (the “GDPR”), Betterwill Limited is the controller in relation to your data. We are registered as a controller with the Information Commissioner’s Office (“ICO”) under registration number ZA523715.
2. HOW OUR SITE WORKS
Our site enables you to provide your personal data to us via our webforms. The data collected may include (but is not limited to) information about your identity, assets, family members and how you want your estate to be distributed on your death. We will run the information you provide through our proprietary software in order to generate a will document. We need to be able to process your personal data in this way in order to provide documents and services to you. If you do not consent to providing your personal data to us, we will be unable to enter into a contract to provide documents and services to you.
3. WHAT DATA WE COLLECT AND HOW
We collect personal data about you when you give this to us by completing our webforms with a view to purchasing documents and services. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which has been anonymised.
When you visit our Site or correspond with us in person or by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so. We explain below the kinds of data we may process:-
Our webforms will ask you for your contact details, such as your name, date of birth, email address, telephone number, and post code. We may also ask you for information about your financial assets, payment/credit card details and information about the identity of your family, beneficiaries, guardians and executors including their names, addresses, email addresses or other identifying information which may be required to generate the documents and provide services.
We may also store and use your data for marketing and communications purposes; for example we will keep a record of your preferences with regards to receiving marketing communications from us or third parties.
Occasionally we update our webforms, so you may be asked for other information. The webform will always be clear about what information is requested, and we will only request information that is relevant to your request and the product and/or service that we are providing.
When you connect to our website we store and share Internet Protocol (IP) addresses. Every device has a unique IP address that enables it to communicate with other devices over the Internet. We may also collect information about your browser type and version, time zone, operating system and login information.
We will also collect and analyse data about how you use our website, such as the length of your visit, how you interact with certain pages and forms and any errors, page response times and download data.
We may collect data about you if you contact us, or we contact you, by email or post, or if you post comments, material or other content on our site.
We also obtain information about you through our use of cookies. Please refer to our separate Cookie Policy, which can be found here.
4. HOW WE USE YOUR DATA & WHO WE SHARE IT WITH
At times there may be a requirement to share your data with third parties, in order to fulfil our obligations under our contract with you and to provide products and/ or services to you. We require all third parties to treat your data securely and in accordance with the law and not to process your data for their own purposes.
We may use your data in the following ways:
4.1. To enter into a contract with you to provide documents and/or services to you
In order to provide you with a will document, we need to process your personal data which we will ask you to provide through our webforms. Your data will be processed using our proprietary software in order to generate a will document.
We may need to share your personal data with legal professionals, other professional advisers, estate administration providers, charities, executors and beneficiaries of a will, funeral directors or funeral plan providers.
4.2. Working with suppliers
We work with suppliers who process data on our behalf. These include cloud storage providers and web-based platforms. We have appropriate contracts in place with each supplier to ensure the protection and confidentiality of data.
Some of our suppliers may be based outside of the European Economic Area – please see section 5 for more information regarding this.
4.3. To personalise our services to you
We may store your data to personalise our services to you by pre-populating fields to make it easier for you to provide information when you return to our site.
4.4. For compliance purposes or if required to do so by law
For example, we may be required to share your data as part of legal proceedings, or with the ICO and/or other regulatory/governing bodies for the purposes of compliance monitoring.
4.5. For research
We may compile statistics about the use of our site, including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers.
We will not share your data with any third parties for the purposes of direct marketing.
5. TRANSFERRING YOUR DATA
We may transfer your data outside the European Economic Area (the “EEA”).
This may be because:
Some of the countries outside of the EEA (e.g. Canada, USA) have a European Commission adequacy decision, which means that they are considered to offer an adequate level of data protection.
Other countries without an adequacy decision do not have the same level of legal protection as countries within the EEA. If we do transfer your data to one of these countries, we will take steps to ensure that your data is given the same protection as required within the EEA. For example, we may use the EU’s model contract clauses, or ensure that the organisation is registered with the EU-US Privacy Shield.
6. STORING YOUR DATA
Because of the nature of the products and services we provide, if you enter into a contract to purchase a will document using our service we will securely store your data indefinitely. Pursuant to Article 17(3) of the General Data Protection Regulations (“GDPR”), we are able to retain your data in order to protect against future legal claims or to provide an information trail in case your will is subject to legal challenge.
If you register with us and provide personal data but do not complete the webforms and create your will, or do not go through with the purchase, we will retain your data for a period of six years to ensure that we are able to assist you efficiently in future.
7. LEGAL GROUNDS
In accordance with Article 6 of the GDPR, data controllers must provide details about the lawful bases for all processing activities, which are set out below. At least one of these must apply in order for us to be able to lawfully process your personal data:
7.1. Consent
We rely on this ground to provide marketing information to you.
7.2. In order to perform a contract with you
If you have registered with our website and wish us to provide you with products and services, we will need to process your personal data in order to fulfil our contractual obligations to you (for example providing you with a will document).
7.3. Legitimate Interests
This means that we are using your data when it is necessary for our legitimate interests, except when your interests and fundamental rights override our legitimate interests.
We rely on this ground:
You have the right to object to processing based on legitimate interests. For more information, please see section 8 below.
7.4. Legal or regulatory obligations
It may be necessary for us to use your data to comply with our legal or regulatory obligations.
8. YOUR RIGHTS
Under the GDPR, you have a number of rights in relation to the processing of your data.
Your right of access - You have the right to ask us for copies of your personal data. This right always applies. There are some exemptions, which means you may not always receive all the data we process.
Your right to rectification - You have the right to ask us to rectify data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete. This right always applies.
Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.
Your right to object or to restrict processing - You have the right to object to or ask us to restrict the processing of your data in certain circumstances. For example, if we are relying on the basis of legitimate interests to process your data, and there are no compelling grounds which override your rights and interests.
Your right to data portability - This only applies in certain circumstances, and relates only to data you have given us. You have the right to ask that we transfer the data you gave us from one organisation to another, or to give it to you.
Your right to withdraw consent - You can withdraw your consent to the collection, processing and transfer of your data at any time.
Your right not to be subject to automated-decision making - As explained at section 4.1. above, some of our decisions are made automatically by inputting your data into a system where the decision is calculated using certain automatic processes. You have the right to request human intervention or challenge a decision based on automated decision-making. We may not be able to offer you any products or services if you opt out of automated decision-making, as some automated decisions are necessary to comply with our legal obligations when providing products or services to you.
Your right to lodge a complaint - If you are unhappy about the way in which we have handled your personal data, you have the right to lodge a complaint with the lead supervisory authority, the ICO - https://ico.org.uk/.
If you have any queries or wish to exercise any of your rights under the GDPR, please get in touch (see below). You are not required to pay any charge for exercising your rights.
CONTACTING US
If you have any questions regarding this notice or in relation to data protection or our website, you can contact us by:
Email: help@betterwill.uk
Post: Henleaze Business Centre, 13 Harbury Road, Bristol, England BS9 4PN
9. CHANGES TO THIS NOTICE
We may change this privacy policy from time to time (for example, if the law changes).
Last reviewed: June 2019