Farewill LTD, a company registered in England and Wales under company registration number 09701947 our registered office is 27 Downham Road, N1 5AA, 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
Personal data is any information which can (or could be used to) identify a living person.
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 services to you, we will process your personal data to provide these services to you. We need certain personal information about you to provide the services to you. We may also share your information with other Farewill companies in order to provide services to 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 provide services to you: We use a number of third party service providers to help us provide our services. In order to do this, we may have to provide some of your information to them and we will only ever do this to the extent necessary to provide services to you and only when we have contractual provisions in place to ensure your information is securely held and not used for any other purpose.
To improve how we provide our services: We analyse personal data to identify areas so that we can improve our services and we sometimes engage third parties to assist us with this analysis.
Some examples are:
- Recording calls to analyse and improve how we provide our services over the phone.
- Analysing feedback you provide on external review platforms, on our website chat function or in emails and the way you interact with 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 optimise website visitor engagement, inform future content and to ensure that our website is kept secure.
For user research: We have a legitimate interest to contact you in relation to your experience of using our products and services. We will use any feedback provided to tailor and improve our services. We may also conduct research to develop new products and services where input from users' experience would inform our approach.
For Farewill marketing purposes: We may contact you if your recent activity suggests you might want to hear from us (for example, you entered one of our promotions, you have used our services or you have an annual subscription with us), unless you have already indicated that you do not wish to receive marketing commmunications from us.
We process your personal data to form a view on what services, promotions or offers we think you may be interested in.
Our communications always include a link so you can unsubscribe. You can also let us know you would prefer not to be contacted by emailing [email protected] and clearly stating that you wish to be removed from our marketing list.
To allow charities to communicate with you: We sometimes ask you if you are happy to receive marketing communications from the charities we work with (for example, they have referred you to our services or you have left the charity a gift in your will). If you agree and provide your consent, we send the charity your personal data so they can contact you directly. Where you change your mind and decide you would prefer not to be contacted by the charity, you should let them know (their communication should also contain an unsubscribe link).
Where you do not receive a prompt to ask you for your consent to share your personal data with the charity for their marketing communications, this means that Farewill have an agreement with the charity whereby we provide your personal data to them so they can contact you directly (unless you have indicated to us you do not want us to share your personal data for this reason).
To allow our charity partners to analyse and optimise their legacy campaigns and to update their supporter databases: We will share some basic information relating to you (name, address, email address, date of birth, phone number) and gift type (if any), to allow our charity partners to assess and improve their legacy campaigns and update their supporter databases.
To enable tracking and attribution of referrals and campaigns from our commercial partners: Where you have been referred by one of our commercial partners we will share some basic information relating to you (name, address, email address, date of birth, phone number) to allow our commercial partners to attribute referrals. This will be in addition to your communication preferences and this information will not be used for marketing purposes if you have not given consent for that purpose.
To create anonymised data sets: Anonymised data is information which cannot be used to identify a living person. It is useful for statisical analysis and identifying general trends. We will convert your personal data into an anonymised format so it can be used for press publication (for instance to show the age range of our customers, 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. Anonymised data is not personal data.
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 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 farewill.com and wills.farewill.com (collectively and individually 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 or relating to your involvement in the estate of someone who has died. We do not store credit card details nor do we share financial details with any third parties.
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 and before they call us. 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, Google and CallRail
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: Zendesk, Trustpilot
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 (such as the charities we work with) in order to make advertising displayed on other websites (such as Facebook) more relevant to your interests.
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.
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).
Who we share your personal data with
- Our staff: Our staff have access to your personal data.
- Charities and businesses we work with: For example the charities we work with through our wills service.
- External parties: That are performing tasks on our behalf (including subcontractors and professional advisors).
- Regulatory authorities: Where we have a legitimate legal reason for doing so.
- Any actual or potential buyer of our business.
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.
If you have any concerns or queries relating to the use of your personal data, please let us know in the first instance by contacting [email protected] and we would hope to resolve any issue informally.
However, if an issue cannot be resolved, 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. For further information, please see https://ico.org.uk/make-a-complaint/.
Exercising your rights
You can exercise such rights by contacting us at [email protected]. We may require confirmation of your identity before acting on a request.
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.
Modern Slavery Statement
Farewill Limited is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015. It sets out our approach for dealing with the potential risk of slavery and human trafficking in our business or within our supply chains.
We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.
1. About us
Farewill is a private limited company incorporated under the laws of England and Wales. We provide funeral, will writing and probate services to people in the United Kingdom.
Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.
2. Our Supply Chain
We are committed to ensuring that slavery or human trafficking do not take place in any part of our business or within our supply chains. We will not knowingly support or do business with any organisation that is involved in such practices and we would seek to terminate any relationship immediately where evidence of the same occurred.
Our key suppliers are based in the United Kingdom and include funeral and legal service providers. Prior to any engagement with our suppliers, we ensure that they are a suitable organisation with which to do business.
3. Our Commitment To Ethical Trading
We are committed to acting ethically, working to the highest professional standards and complying with all applicable laws and regulations. We do not, and shall never, tolerate slavery and human trafficking and any other illegal or unethical conduct.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
5. Further Steps
We will monitor the effectiveness of the measures that we are taking to ensure that there is no slavery or human trafficking in our business or our supply chain, including building upon and improving the policies that we have put in place.
This statement was approved by the board of directors on the 9th of June 2021, signed by Dan Garrett, director, on 10th of June 2021, and it is reviewed annually.
These policies were last updated on 7 September 2022.