1. Important Information and Who We Are
This website is not intended for children. By providing us with your data, you warrant to us that you are over 18 years of age.
1.2. Data Controller
Worth.Legal is the Data Controller and is responsible for your Personal Data.
Registered Address: Marland House, 13 Huddersfield Road, Barnsley, S70 2LW
Telephone: 0113 841 3113
Registered Address: Worth.Legal Limited, Arena, Holyrood Close, Poole, England BH17 7FJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (‘ICO’), the UK regulator 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. Our Complaints Procedure is available upon request.
1.3. Your Duty to Inform Us of Changes
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.
1.4.Third Party Links
2. The Data We Collect About You, Use and Legal Bases
2.1. Types of Data
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 including your first name, maiden name, last name, username or similar identifies, marital status, title, date of birth and gender. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
Contact Data including your billing address, delivery address, e-mail address and telephone numbers. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
Correspondence Data including information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Enquiry Data including information contained in any enquiry you submit to us regarding goods and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely our interest in the proper administration
Notification Data including your preferences in receiving marketing from us and our third parties and your communication preferences. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Transaction Data including details about payments from you and other details of products and services you have purchased from us. The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
Usage / Technical Data including your internet protocol (IP) address, login data, browser type and version, time zone setting and geographical location, browser plug-in types and versions, operating system and platform, referral source, length of visit, page views and website navigation paths as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We do not collect any Special Categories of Personal Data about you, which includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. NB: Self-Will Writing Aspect and additional information.
We also do not collect any information about criminal convictions or offences.
2.2. General Consent
Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.
2.3. Failure 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
2.4. Change of Purpose
We will only use your Personal Data for the purpose 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.
3. How Your Personal Data is Collected
We use different methods to collect data from and about you including through:
3.1. Direct Interactions
You may give us your data by filling in forms on this website (or otherwise) or by communicating with us by post, phone, e-mail or otherwise. This includes Personal Data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
3.2. Automated Technologies or Interactions
3.3. Third Parties or Publicly Available Sources
We will receive Personal Data about you from various third parties [and public sources] as set out below [delete or add to list as appropriate]:
- Usage / Technical Data from the following parties:
- Analytics providers such as Google based outside the UK;
- Advertising networks based outside the UK; and
- Search information providers based outside the UK.
- Contact and Transaction Data from providers of technical, payment and delivery services based outside the UK.
- Identity and Contact Data from data brokers or aggregators based outside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- Information provided by you if you use our Online Wills Service.
- Usage / Technical Data from the following parties:
4. Disclosure of Your Personal Data
4.1. Third Parties
We may share your Personal Data with the parties set out below for the purposes set out above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- 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 private 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.
We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.3. Agents and Trusted Partners
We may disclose your Personal Data to our suppliers or subcontractors insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.4. Financial Transactions Partners
Financial transactions relating to our website and services may be handled by our payment services providers, Stripe Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.stripe.com/gb/privacy.
4.5. Legal Obligations
In addition to the specific disclosures of Personal Data set out, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your Personal Data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International Transfers
5.1. Countries Inside the European Economic Area (‘the EEA’)
We do not directly transfer your Personal Data outside of the EEA. However, [many] [some] of our third parties service providers are based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside of the EEA. Further information is set out below.
5.2. Countries Outside the EEA
Countries outside of the EEA do not always offer the same levels of protection to your Personal Data, so European law has prohibited transfers of Personal Data outside of the EEA unless the transfer meets certain criteria.
If we ever have a need to directly transfer your Personal Data out of the EEA, we do our best to ensure a similar degree of security of data 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; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give Personal Data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
5.3. Our Website
The hosting facilities for our website are situated in Europ] including the UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection_en.
You acknowledge that Personal Data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
6. Data Security
6.1. Security Measures
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.
7. Data Retention
7.1. How Long We Will Use and Hold Your Personal Data
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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, regulatory, tax, accounting or reporting requirements.
Details of retention periods for different aspects of your Personal Data are available in our Data Retention Policy which you can request by contacting us.
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.
In some circumstances, set out below, you can ask us to delete your Personal Data.
8. Your Legal Rights
8.1. Your Legal Rights
Under certain circumstances you have the rights under data protection laws in relation to your Personal Data. These include the right to:
- request access to your Personal Data;
- request correction of your Personal Data;
- request erasure of your Personal Data;
- restrict the processing of your Personal Data;
- object to the processing of your Personal Data;
- request transfer of your Personal Data;
- complaint to a supervisory authority; and
- withdraw consent.
Further information about these rights can be found on the ICO website: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of these rights, please contact us, in writing.
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 could refuse to comply with your request in these circumstances.
8.3. 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 legal 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.
8.4. Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.