PRIVACY & COOKIE POLICY

This is the Privacy Policy of Your Will Matters which is a trading name of Tele Prospects Ltd, a company registered in England and Wales (Registered Number 05091787) whose registered address is Swinford House, Albion Street, Brierley Hill, West Midlands, DY5 3EE.

Tele Prospects Ltd (t/a Your Will Matters) is committed to acting in compliance with the UK General Data Protection Regulation and Data Protection Act 2018. Our ICO Registration number is Z9386334.

Your Will Matters are committed to protecting your privacy and maintaining the security of any personal information received from you. We follow strict security procedures in the storage and disclosure of information, which you may have given us, to prevent unauthorised access in accordance with stringent requirements of the UK General Data Protection Regulation and Data Protection Act 2018.

The purpose of this statement is to explain to you how Your Will Matters collects, stores and processes your personal information, it also details the cookies we use on our Site. You will find below details on your rights in relation to your personal data and how you can get in touch with us.

This privacy policy relates only to data collected under the brand name of Your Will Matters.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Tele Prospects Ltd (t/a Your Will Matters) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Lynn Stevens

compliance@yourwillmatters.co.uk

Contract:

When we are providing our will writing services to you we process data necessary for the performance of the contract.

Consent:

Generally, we do not rely on consent as a legal basis for processing your personal data although we will ask for your consent to send you marketing communications in the future about our other products and services. You have the right to withdraw consent to marketing at any time by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Legitimate Interest:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

We have a legitimate interest to respond to enquiries you make with us and to provide you with access to our website services. We also have a legitimate interest to send marketing communications to our customers unless you ask us not to.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect, store and use the following kinds of data:

• Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, number of page views, statistical or demographic data for any purpose) (Aggregated Data). Aggregated Data could be derived from your personal data but is not considered personal.

• data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

• Information relating to any transactions carried out between you and us on or in relation to this website, including information relating to the supply of our services

• Information that you provide to us for the purpose of registering with us (including name, address, telephone numbers, email addresses, date of birth, previous addresses and any financial information including payment details)

• Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters

• Information required to complete your services that we will request directly from you, including your personal circumstances, family details, beneficiaries and executors, information about your home and finances etc. This may include special categories of data but only if required for the purpose of creating your will

• Any other information that you choose to send to us

• If you call us we may record the call and store a copy of the call recording. If we do this we will obtain your permission at the start of the call.

• If you visit our offices we have CCTV installed, we may record footage of you on our CCTV system

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you do not provide the personal information we have requested, it may affect our ability to provide the services that we offer and we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We will use your data to make contact with you (by post, telephone or email) in relation to the service we are providing to you, or to provide information requested via our website or to send you marketing communications.

We control the use of your data as you have expressed.

To allow us to provide our services to you, the following third parties provide critical functions to our business and will process your personal information as directed by us and in accordance with strict data security arrangements:

• Our Services: during our services we will provide your data, under your specific instruction, to our partner law firm, My Law Matters. If you use our Premium Advised Will Service or if you need a Lasting Power of Attorney we will obtain your consent to transfer your information and request to My Law Matters. My Law Matters is a trading stye of Fentiman Legal Ltd, a company registered in England and Wales under registration number 12661534, registered office Greville Court Business Centre, 1665 High Street, Knowle, Solihull, B93 0LL, ICO number ZA786713;

• Our Systems and IT: we use third party firms who provide and support our CRM infrastructure.

• We use a third party firm, Arken.legal (UK) Ltd who provide the cloud based technology on our website which is used to enable us to provide you with our online wills service. Arke.legal (UK) Ltd is a company registered in England and Wales under registration number 2690082, registered office General Wolfe House, 83 High Street, Westerham, Kent, TN16 1PG;

• Post and Printing: we use an outsourced print-house who manages our printing. They receive a copy of postal communications and print and send this on our behalf;

• Email broadcast platforms;

• Payment services providers;

• Our Regulators: we may be required to provide your data to our Regulators, who include the Financial Conduct Authority and the Information Commissioner’s Office;

• Our Professional Services: we use professional legal, consultancy and accountancy services to help us fulfil our legal obligations.

We do not sell your data to third parties in any circumstances. We have carefully selected our third parties based on their ability to keep your data safe and secure. If you have any concerns about the above third parties please let us know and we can provide advice and support to help you manage your data preferences. You can find our contact details at the end of this privacy policy.

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy.

In addition, we may disclose information about you:

• To the extent that we are required to do so by law;

• In connection with any legal proceedings or prospective legal proceedings; and

• In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of debt collection, fraud prevention and reducing credit risk.

Your personal information may also be processed by other organisations on our behalf for the purpose of providing information or services to you. The use of your personal information for these purposes will remain under our control at all times. We may disclose your information to other members of our informal group of companies, and to our partners, associates, agents or subcontractors and to possible successors to our business.

We will retain your data for as long as reasonably necessary to fulfil the purpose we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will keep your contact details following an enquiry to our website or other marketing channels for a period of three years. If we create a will on your behalf we will retain the information indefinitely. Financial records and details of our transactions are retained for up to 7 years.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Your Will Matters have a procedure in place if a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

We will assess the scope and impact of the breach. If, due to the nature of the breach that Tele Prospects Ltd (t/a Your Will Matters) is required to inform the ICO, we will do so within 72 hours of becoming aware of the essential facts of the breach.

Based on the assessment of the likely risks to individuals, we will notify the individuals and/or their connected organisations that a data breach has occurred where this may result in a significant risk to the rights and freedoms of individuals, or where we may be in breach of a contractual obligation. Any such notification to individuals will be carried out as soon as reasonably possible and will include information on the nature of the breach, the name and contact details of our Data Protection representative, the likely consequences of the breach, measures taken or proposed by Tele Prospects Ltd (t/a Your Will Matters) to address it, and recommendations for affected individuals to mitigate any potential adverse effects. Such individuals will also be provided advice on how to make a complaint to the ICO.

Our website may contain linksto other third party websites plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page periodically to ensure you are happy with any changes. We shall communicate with you if we make any changes that directly affect you.