Privacy Policy

Last updated: 16 December 2021

BACKGROUND:

The Will Associates Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients, staff and contacts and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Notice carefully and ensure that you understand it.

1. Information About Us

The Honey Group which is a trading style representing the following companies:

• The Will Associates Limited, a company registered in England under Company Number 07118208, whose registered office is at The Old Magistrates Court, Cheshire Street, Market Drayton, Shropshire TF9 1PH.  VAT number is 987 525 955.
• The Will Associates Asset Management Limited, a company registered in England under Company Number 07136902 and whose registered office is at The Old Magistrates Court, Cheshire Street, Market Drayton, Shropshire TF9 1PH. The Will Associates Asset Management Limited is regulated by The Council for Licensed Conveyancers.
• TWA Finance Ltd, a company registered in England under Company Number 09616295 whose registered address is The Old Magistrates Court, Cheshire Street, Market Drayton, Shropshire TF9 1PH.
• Data Protection Officer:  Steve Barker.

Email address: [email protected]

Telephone number: 01630 723105.

Postal address: The Old Magistrates Court, Cheshire Street, Market Drayton, Shropshire TF9 1PH

2. Definitions and Interpretation

In this Notice, the following terms shall have the following meanings:

• “personal data” Personal data is defined by the Data Protection Legislation (Data Protection Act 2018 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)); as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.The personal data that we use is set out in Clause 5, below.

3. What Does This Notice Cover?

This Privacy Notice applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our or collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in
Clause 13.

b) The right to access the personal data we hold about you. Clause 12 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Clause 13 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Clause 13 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Clause 13.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Clause 13.

5. What Data Do We Collect?

Depending upon your use of our website or your reason for supplying or consenting to us receiving your data, we may collect some or all of the following personal and non-personal data. In addition we may be provided with your data from data supply companies or partners who will have obtained your consent prior to providing us with this information or provide your data where they have a legitimate interest to do so.  We ensure that all companies and partners that we deal with are held to the same level of GDPR compliance that we adhere to and that wherever possible we have verified that they have obtained and processed your data lawfully.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Act 2018 and GDPR and any subsequent legislation at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, We may use your data for the following purposes:

• We will use your personal contact information to contact you by telephone or email and liaise with you regarding our services and products that may be of interest to you;
• Supplying our products and/or services to you (please note that we require your personal data in order to enter into a contract with you);

• Personalising and tailoring our products and/or services for you;
• Replying to emails from you;
• Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in the footer of emails)
• Market research;
• Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience;

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Act 2018 or GDPR and subsequent legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 Third parties (including but not limited to BBC Corporation, YouTube, Google, Microsoft, Yahoo, HotJar, Tawk.to) whose content appears on our Site may use third party Cookies, please refer to our Cookie Policy for further information. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected or to comply with any legal regulatory or reporting obligations or to assert or defend against legal claims.

Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

• Pre-Sale Information: Any information we hold that does not lead to a sale will generally be kept for a period of 12 months. If you have asked us not to contact you it will be necessary for us to keep your basic contact information within our suppression files for the purposes of recording and complying with your request.
• Post Sale Information: Due to the nature of the business of Estate Planning we will keep any information indefinitely due to the importance of providing on-going customer service.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

7.1.1 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our Site and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Act 2018, GDPR and subsequent legislation including:

7.1.1.1 Encryption at rest and encryption in transit.

7.1.1.2 Secure backups.

7.1.1.3 Strict access controls.

7.2 Data security is very important to Us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.

7.3 Steps we take to secure and protect your data include:

7.3.1 Encryption at rest and encryption in transit.

7.3.2 Secure backups.

7.3.3 Strict access controls.

7.3.4 Regular security audits.

8. Do We Share Your Data?

8.1 Subject to section 8.2, we will not share any of your data with any third parties for any purposes without your consent unless we are legally obligated to do so.

8.2 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.

8.3 We may share your data with other companies in our group details of which are listed in Schedule Two for those purposes stated within that Schedule Two.

8.4 If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

8.5 We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

8.6 We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.7 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Legislation as set out in Schedule Two.

8.8 In certain circumstances, We may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will, however, have the choice to have your data deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details.

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict our use of Cookies. For more information, see our Cookie Policy.

12. How Can You Access Your Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Clause 13.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress. Please contact us for more details at [email protected], or using the contact details below in Clause 13.

13. Contacting Us

If you have any questions about Our Site or this Privacy Notice, please contact us by email at [email protected], by telephone on 01630 723105, or by post at The Old Magistrates Court, Cheshire Street, Market Drayton, Shropshire TF9 1PH. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

14. Changes to Our Privacy Notice

We may change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our site following the alterations.  You can access our Privacy Notice by requesting a copy at any time using any of the methods listed in Clause 13 above. We recommend that you check this Notice regularly to keep up-to-date.