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WHAT IS THIS POLICY FOR?

Vale Wills Ltd takes issues relating to your personal data really seriously. This policy is to explain more to you about how we handle your personal data. We will always be clear about why we need the details we ask for and ensure your personal information, or that belonging to any third party you give to us, is kept as secure as possible.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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 Policy supplements the other notice and is not intended to override them.

Please also use the Glossary below to understand the meaning of some of the terms.

 

CONTROLLER

Vale Wills Ltd is the controller and responsible for your personal data (collectively referred to in this policy as “we”, “us” or “our”).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. You should not hesitate to contact our Jane Chesterman.

Email address: [email protected]

Postal address: Vale Wills Ltd, 25 Borough Close, Cowbridge, Vale of Glamorgan CF71 7BN

Telephone number: 01446 774 383

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 

This version was last updated on 25th May 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you provide us with an email address that you share with another person (such as a partner), you can expect them to see any emails that we send to you.

 

THIRD-PARTY LINKS

 Our website may include links to other websites. Clicking on those links 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 notice of every website you visit.

 

THE DATA WE COLLECT ABOUT YOU  

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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery addresses, email address and telephone numbers.
  • Financial Data includes bank account details and payment card details.
  • Advice Data includes all information about you which you have disclosed in order to obtain legal or practical advice from us.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, and details of the devices you use to access our website.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website article. 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.

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 FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). 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.

 

HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

– Direct interactions. You may give us your Identity, Contact, Transaction and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Use our services;
  • Subscribe to our service or publications;
  • Request marketing materials or other information to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.

– Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your activity. We collect this personal data by using cookies and other similar technologies. 

– Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  •    Another client who has referred you to us
  •    Another service provider who has referred you to us such an accountant, a financial advisor or mortgage broker

– Identity and Contact Data from publicly availably sources such as Companies House based inside the EU. For example, we will check Companies House to ascertain who the directors are of a client company.

 

HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. 

We only process data for the purposes we have agreed with you. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you – we need to consider the data when advising, in order to give the best and most appropriate advice

  • Where we need to comply with a legal or regulatory obligation.

  • Pursuing our legitimate interests (such as being able to communicate with you and update you regarding our services) and your interests and fundamental rights do not override those interests

  • Something necessary for the protection of a person’s vital interests (this is likely to be exceptional but may related to someone’s health in an emergency)

  • Something you have consented to 

  • Data that has been made public by you

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please tell us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data
To register you as a new customer (a) Identity

(b) Contact

To process and deliver your order including:(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity(b) Contact

(c) Profile

(d) Marketing and Communications

To enable you to partake in a prize draw, competition or complete a survey a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity(b) Contact

(c) Technical

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical(b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity(b) Contact

(c) Technical

(d) Usage

(e) Profile

To refer you to other third parties where that is important to you (a) Identity(b) Contact

 

 MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

PROMOTIONAL OFFERS FROM US  

 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.

 

OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

 

 COOKIES  

We don’t deliberately collect data about you using cookies, but our website is hosted using a content management system that may be collecting functional data in the form of cookies. If you sign up for our mailing list on the website that emails us directly and that data is not then retained on the website.

 

CHANGE OF PURPOSE  

 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

 

INTERNATIONAL TRANSFERS 

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.  For example we use Xero for accounting purposes, this is a cloud based software company based in New Zealand.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA SECURITY  

 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.

 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION  

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.  

By law we have to keep basic information about our clients (including Contact, Identity, Financial, Advice and Transaction Data) for six years after they cease being customers for tax, insurance and regulatory purposes.

In some circumstances you can ask us to delete your data: see request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you that you have given to us and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

GLOSSARY  

 

LAWFUL BASIS  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES  

INTERNAL THIRD PARTIES

Vale Wills Ltd is not part of any other group of companies.

EXTERNAL THIRD PARTIES  

  1. Service providers based in the UK who provide IT and system administration services: generally, they are accessing our systems for the legitimate interest of diagnosing and dealing with IT related problems rather than accessing personal data. We are satisfied that our contractual relationships with those providers contains provisions dealing with the security of all data and that Lawware take appropriate measures to prevent unlawful access to the data.
  2. We use Xero, a cloud-based accounting system, which is based outside of the United Kingdom.
  3. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, pension and accounting/book-keeping services.

Generally, they are not accessing personal data when providing us with advice and support but, if they are likely to have access to such data, we make sure we have in place with them contractual terms protecting your data.

  1. Debt-collectors, based in the UK acting as joint controllers who will have access to Financial Data and Identity Data in order to enforce the debts you owe us.
  2. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  3. In the case of individual clients: You may require us to share your Identity data with a third party such as a financial advisor or funeral plan provider. We will only do this with your express written consent.

 

May 2020