If you have any questions or need further clarifications, please do not hesitate to contact us.
1. General information
1.2 Data controller. The Website is owned and operated, and the Services are provided by Lifetime Trustees Ltd., a limited liability company having a registered place of business at 71 Heathlands, Westfield, Hastings TN35 4QZ, the United Kingdom (“we”, “us”, and “our”). We act as a data controller regarding your personal data and, unless stated otherwise in the applicable law, we are accountable for the processing of your personal data.
1.3 About the Services and the Website. We provide the Services in the field of estate planning. The Website features information about the Services, our contact details, news and reviews of the Services.
1.4 Applicable laws. We process your personal data in accordance with the applicable privacy laws, including the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR).
- If we are required by law to do so;
1.7 Age restrictions. The Website and the Services are not marketed and should not be used by anyone younger than 18 years old. Thus, we do not knowingly collect personal data from persons under the age of 18. If you learn that anyone younger than 18 has unlawfully provided us with personal data and you are a parent or legal guardian of that person, please contact us and we will take immediate steps to delete such personal data.
1.8 Cookies. We do not use any cookies on the Website.
- “Consent” means a freely given, specific, informed and unambiguous agreement to the processing of personal data;
- “Data controller” means the entity that determines the purposes and means of the processing of personal data;
- “Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of a data controller;
- “Personal data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information (e.g., name, address, email, phone number, and IP address); and
- “Processing” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data.
2. What personal data do we collect?
2.1 Types of personal data. We comply with data minimization principles and collect only a minimal amount of personal data that is strictly necessary to ensure your use of the Website and the Services:
- When you contact us through the contact form available on the Website, we collect your (i) name, (ii) email address, (iii) phone number, and (iv) any information you decide to provide us in your message.
- When you decide to create a review on the Website, we collect your (i) name, (ii) email address, (iii) website address, and (iv) any other information that you decide to provide in your review.
- When you contact us by email, WhatsApp, or similar electronic means, we collect your (i) name, (ii) email address, (iii) phone number, and (iv) any information you decide to provide us in your message.
- When you ask us to provide any Services (e.g., send correspondence, provide a consultation, or prepare documents), we may request you to submit certain personal data that is necessary for ensuring the performance of the contract between you and us. The types of such personal data depend on the Services requested by you.
2.2 Additional information. We may receive certain additional data if you participate in a contest, activity or event, request support, interact with our social media accounts, or otherwise communicate with us. Please note that the provision of such data is optional, and you may choose what personal data you would like to share with us.
2.3 Sensitive Data. We DO NOT collect, under any circumstances, any special categories of personal data (“sensitive data”) through the Website, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation. If such sensitive data is required for provision of the Services, we will make sure that you consent to the provision of such data.
2.4 Failure to provide personal data. If you fail to provide us with your personal data when requested, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Website, get our response or use the Services.
2.5 Non-personal data. We do not collect any technical non-personal data about your use of the Website.
2.6 Aggregated data. In case we start collecting non-personal data (e.g., technical data on how you use the Website) and your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.
3. For what purposes do we use your personal data?
|Personal data||Purpose||Legal basis|
|When you contact us by using the contact form:
|When you create a review on the Website:
|When you contact us by email, WhatsApp, or similar electronic means:
|When you ask us to provide you with the Services:
4. Disclosure of your personal data
4.1 Do we disclose your personal data? In some circumstances, where strictly necessary for legitimate purposes, we may share your personal data with third-party service providers (data processors) that are mentioned in this Section 4. Such data processors can be entities that provide certain technical support or other professional services to us, such as email distribution and developing services. Please note that we will disclose your personal data only if it is strictly necessary for ensuring your proper use of the Website or the provision of the Services. We do not transfer your personal data to third parties that are not our service providers and we do not sell your personal data to third parties.
4.2 When do we share personal data? The disclosure of your personal data is limited to the situations when such data is required for the following purposes:
• Ensuring the operation of the Website;
• Ensuring the delivery of the Services requested by you;
• Providing you with the requested information;
• Pursuing our legitimate business interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Performing our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior consent to such a disclosure.
· Our hosting service provider Host Europe GmbH;
· Our independent developing service providers; and
· The third parties that we need to collaborate with to perform a contract with you, such as:
i. Will drafting companies;
ii. Trust drafting companies;
iii. Probate managing companies; and
iv. Funeral planning providers.
4.4 Legal requests. If officially requested, we will respond to lawful requests from public authorities to disclose information about the users of the Website or our clients to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
5. Retention of your personal data
5.2 Retention as required by law. In some cases, we may be obliged by law to store your personal data for certain period. In such cases, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
6.1 Our security measures. To protect your personal data, we employ appropriate organizational and technical information security measures, such as secured networks, limited access by our staff to your data, and other industry-standard technologies. To ensure the security of your personal data, we kindly ask you to use the Website through a secure network only.
6.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a data breach occurs, we will inform our local data protection authority, namely, the UK Information Commissioner’s Office (ICO), without undue delay and immediately take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breaches will be limited to the highest extent permitted by the applicable law.
7. Third-party links
7.1 The Website may contain links to other websites (e.g., social media providers). We are not responsible for the privacy practices or the content of those websites. You will need to check the relevant privacy policies to understand how they process your personal data. If you access a third-party website, you may be requested to disclose your personal data. It is your responsibility to keep such data private and confidential.
8. Transfer outside the European Union
Therefore, you can be sure that your personal data is safe when transferred to the UK. In case it is necessary to make a transfer to other jurisdictions outside the EEA, we will make sure that such jurisdictions guarantee an adequate level of protection for your personal data (e.g., the country in which the recipient is located is white-listed by the European Commission or the recipient is a Privacy-Shield certified entity), we conclude an agreement with the respective third party that ensures such protection, or we take other appropriate safeguards.
9. Your rights
9.1 What rights do you have? Subject to any exemptions provided by law, you may ask us to:
· Get a copy of your personal data that we store;
· Get a list of purposes for which your personal data is processed;
· Rectify inaccurate personal data;
· Move your personal data to another processor;
· Delete your personal data from our systems;
· Object and restrict processing of your personal data;
· Withdraw your consent; or
· Process your complaint regarding your personal data.
9.2 How to exercise your rights? If you would like to exercise your rights listed above, please contact us by email at firstname.lastname@example.org and explain in detail your request. In order verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks.
9.3 How to launch a complaint? If you are not satisfied with the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
By email: email@example.com By phone: 0798 8830691
11.2 In order for us to take appropriate actions, please describe in reasonable detail the nature of your request or inquiry.
Effective date: 15 April 2019