Kwil will be what is known as the ‘Data Controller’ of the personal data you provide to us. This data includes all basic information you have provided, including name (current and previous), home address, date of birth, contact information, etc. Additionally, we will require evidence of your identity in the form of Photo ID, in order to verify you and help prevent against fraudulent activity. The information also includes the details of your estate and assets, your executor(s) and beneficiary(s), and your wishes in accordance with the Will itself.
Upon completion of your Will, we will also take and store the Personal Data of the parties witnessing your signature.
Special Personal Data
The information you have provided could potentially be linked to particularly sensitive personal data, including, but not limited to; medical information, sexual orientation, political opinion, political party, group or Trade Union membership or religious or philosophical beliefs. To this end, we are requesting specific consent from you to process any and all information that is essential in completing your Will. Due to the sensitive nature, we have requested that you provide us with specific consent to process this data for the purposes of carrying out our service.
Why we need it
Kwil requires this data, firstly to verify your identity, and confirm that you are the party named on the application and subsequent Will. Secondly, it is a contractual and legal requirement to have the details of your beneficiaries and executor(s). Finally, it is your consent for Kwil to securely hold the details of your Will until it is redeemed, as part of our service.
This consent, ‘contractual obligation’ and ‘legitimate business interest’ form Kwil’s legal basis for processing your personal data.
What we do with it
All the data we hold about you will be processed by our staff in the United Kingdom and no third parties will have access to either your own or your beneficiary or executor’s personal data unless there is a clear contractual, legal or commercial obligation for us to provide this. Your personal details, Will and contact information will only be accessible with your login, or redeemable by your Executor(s).
Your information will be stored on a Microsoft Azure cloud-based system whose servers are located within the European Union.
Your information will not be used for any other purposes, other than those directly required for carrying out our Service. We will contact both you and your Executor(s) periodically, as a reminder of our service, the location of your Will and steps that can be taken to redeem this. Your data will not be used for any direct marketing by Kwil (unless you have consented to receive this) and shall not be shared with any other third parties. We take all reasonable steps to ensure that your personal data is processed securely and more information on this can be found on our website.
You have an onus to inform your Executor(s) as to the completion of this Will, and the usage of their Personal Data to name them as such. Their consent must be obtained before they are named as Executor.
However, you may not wish for the Beneficiary(s) to be aware that they have been named within your Will. To that end, Kwil will not contact or provide any information to the named parties. Their data will remain secure and will only be accessible by you or your Executor(s).
How long we keep it
If you do not complete your Will, Kwil shall only retain your personal data for a period of twelve months from the point of your last access to our site.
Where a Will has been completed, Kwil shall retain full copies of this, along with your account information until this has been redeemed, either by you or your Executor(s) upon your death.
After the Will is redeemed, Kwil can offer to retain this document on our servers indefinitely. However, should you or your Executor(s) not opt for this service; the Will shall be erased from our systems after ninety days.
What are your rights?
If at any point you believe the information we process on you is incorrect, you can request to see this information and have the information corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO) by contacting them on 0303 123 1113 or visiting https://ico.org.uk/.
Our Data Protection Officer is Edward Beesley and you can contact him at < firstname.lastname@example.org
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