Farewill Ltd, a company registered in England and Wales under company registration number 09701947 our registered office is 7 Ability Plaza, Arbutus St, London, E8 4DT, UK. is committed to protecting and respecting your privacy.
This policy (together with our terms and conditions https://farewill.com/terms sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection laws in the UK, the data controller is Farewill Ltd. We are registered as a data controller with the Information Commissioner’s Office under number ZA258663.
Basis for processing personal data
The paragraphs in this section explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.
To enter into and perform contracts with you: Where you ask us to provide will writing services to you, we will process your personal data to provide these services to you. Our use of your personal data in this way includes, in particular, passing your personal data through our in-house technology which generates your will. We need to process your personal data in this way to enter into and perform the will writing contract with you. If you do not wish to provide us with your personal data in this way, you will be unable to use our services.
To make our website better: We will also process your personal data in order to provide you with a more tailored experience when you visit our website. For example, we may use your personal data to tailor our website, make sure it is displayed in the most effective way for the device you are using. We also use various third party cookies to help us improve our website (more details are set out in the sections below) but we will not share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also process your personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research and statistical and survey purposes.
The legal basis on which we process your personal data in these circumstances is our legitimate interest to provide you with the best possible website we can, and to ensure that our website is kept secure.
For marketing purposes: Where you have opted in to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided.
Where you have opted in to receive marketing communications from third parties we select, we will transfer your personal data to them in order for them to send you such communications.
The legal basis on which we process your personal data for marketing purposes is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at [email protected] or, where relevant, by following the unsubscribe link in any marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.
To allow charities to communicate with you if you leave them a gift in your will and consent to be communicated with: Where you have opted in to share your name, email, postcode and date of birth with a charity or charities, they will have the right to provide you with marketing communications in line with the preferences provided. This consent must be given separately to the consent obtained when you register for the services.
To create anonymised data sets: We will also process your data into an anonymised format where it can be used for press publication (for instance to show the age range of our customer, or geographical areas where we provide a high volume of service) and to help charity partners raise money through gifts in wills by helping them to evaluate the efficacy of their marketing campaigns.
If our business is sold: We will transfer your personal data to a third party: in the event that we buy or sell any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or if Farewill Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by Farewill about its customers will be one of the assets transferred to the purchaser.
In each case, the legal basis on which we process your personal data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.
Basis for processing anonymised data
We process data and share it with select charity partners anonymously in order to help then raise money through gifts in wills. We share the number and size of gifts left to particular charities, as well as generalised demographic information, in order to help charity partners understand the efficacy of their legacy marketing efforts while maintaining your privacy.
Information we collect from you
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site www.farewill.com (our "Website") or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Website, place an order for a document and/or services on our Website and when you report a problem with our Website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information and other information related to your assets.
- Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
"A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site."
We use the following cookies:
Strictly necessary cookies
Purpose: these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
Cookies we use: Farewill
Purpose: they allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
Cookies we use: Facebook and Google
Purpose: these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Cookies we use: Intercom
Purpose: these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Cookies we use: Optimise, Conectia, Afill, Facebook and Google
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.
Do Not Track
We use your 'Do Not Track' status to decide whether to turn on tracking scripts such as affliates, Facebook, Google Analytics and Hotjar.
This doesn't opt you of using Intercom as we require this as part of our service to send you key information about your will.
Most browsers let you turn on 'Do Not Track'. Learn how to turn on 'Do Not Track' in your browser.
Uses made of the information
We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Where we store personal data
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share your password with anyone.
Period of storage
Where you register on our website and enter personal data but do not complete the process and create your will, we will retain your data for a period of 6 years after to ensure that we are able to assist you should you have any questions or feedback in relation to our services.
Due to the nature of the services and pursuant to Article 17(3) GDPR, if you complete a will using our service we will securely store your data indefinitely. This is in order to protect against legal claims, as well as to provide supporting information if your will is ever contested.
Where we have processed your personal data to provide you with marketing communications with your consent, we may contact you at least every 12 months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our list.
Your rights under data protection laws
Right to object
You have the right to object to us processing your personal data where we are processing your personal data: based on our legitimate interests (as set out above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
Right of access
You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing.
Right to rectification
You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
Right to restriction
You have the right to restrict our processing of your personal data where: the accuracy of the personal data is being contested by you; the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased; we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or we are processing your data on the basis of our legitimate interest(as set out above) and you:
- object to our processing on this basis; and
- want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.
Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
Right to data portability
You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.
Right to erasure
You have the right to require we erase your personal data which we are processing where at least one of the following grounds applies: the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed; our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data; you object to the processing as set out in the “right to object” section of this policy and we have no overriding legitimate interest for our processing; the personal data have been unlawfully processed; and the erasure is required for compliance with a law to which we are subject.
"You also have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales."
Exercising your rights
You can exercise such rights by contacting us at [email protected].
Links on our website
Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects you to different websites. If you follow a link to any of these websites or use our service, please note that you have left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before you submit any personal data to these websites.