Valulife Ltd (“Valulife”, “we”, “us” or “our”) is committed to protecting your privacy.

This Privacy policy and our terms and conditions set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Valulife.

The policy equally applies to all correspondence with us including your visit to our website. We ask that you read this policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

1. Who we are

For the purpose of the General Data Protection Regulations, the Data Controller is Valulife Ltd, a company registered and operating under the laws of England and Wales.

63-66 Hatton Garden Fifth Floor, Suite 23 London
EC1N 8LE

Our company registration number is 12406683
Our registered VAT number is GB 341940314.

We are registered as a data controller with the Information Commissioner’s Office under number xxxxxxxx.

2. Information that we collect from you

We collect information about you when you access our website, register with us or correspond with us in person or by phone, e-mail or otherwise. This information may be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:

• Identity Verification Data covers information such as your first name, last name, username, or similar identifier, marital status, title, date of birth and gender. We may also collect, use, store and transfer details about your will, executors and beneficiaries. This will normally depend on the nature of the service you request from us;
• Correspondence Data which includes your billing address, delivery address, home address, email address, telephone numbers and social media account details;
• Payment Data such as your bank account or payment details;
• Estate and Property Data which covers details of any assets you have listed in your will;
• Transaction Data includes details about your financial interactions with us and other specifics of services you have purchased from us;
• Technical Data including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Profile Data includes your username and password for any accounts set up to access our services, purchases or orders and details of any feedback you give us by phone, email, post or via social media;
• Behavioural Data such as information about your purchase and order patterns, frequency of your visits to our website and your preferred products and services;
• Promotion and Communications Data covers your preferences in receiving marketing correspondence from us, our partners and third parties and includes your communication preferences.

3. How we collect your data

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

• Direct interactions. You may give us any of the categories of data identified above by filling in forms on our website or by corresponding with us. This includes personal data you provide when you:
• register to use our website;
• access our Electronic Drafting Service;
• request marketing communications to be sent to you;
• give us some feedback or request support services.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers.
• Correspondence, Fiscal and Transaction Data (if applicable) from providers of technical, payment and delivery services.

4. Why we process your data

The lawful bases for processing personal data are set out in Article 6 of the GDPR. We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact 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 below. At least one of these must apply whenever we process personal data:

• Consent: you have given clear consent for us to process your personal data for a specific purpose such as marketing communications;
• Contract: the processing is necessary for a contract we have with you (for example, to process and deliver our services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract;
• Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations);
• Vital interests: the processing is necessary to protect someone’s life; and
• Legitimate interests: the processing is necessary for our legitimate interests (for example to administer and maintain our website) or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. 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).

We rely on the following legitimate interests when processing your personal data:

• To manage our business and comply with our obligations to our staff, affiliates and suppliers;
• To protect our proprietary and commercially sensitive information;
• To administer and maintain our website.

5. How we keep your data secure

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, partners, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our authorisation in accordance with this policy and are subject to a duty of confidentiality.

6. When we can disclose your data

We will share your personal data with third parties in order to provide specific services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf 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 and in accordance with the law. 

The following is a list of third parties, but it is by no means exhaustive:

• Affiliates such as Valulife Trustees Limited as data processors where you request our Executor Service;
• Professionals including solicitors, bankers, auditors, insurers, consultants and valuers;
• Estate Agents;
• Service providers such as IT suppliers who provide IT and system administration services to us;
• Sub-contractors for the performance of any contracts we enter into with them or you;
• Other Estate Administration providers; and
• Executors or beneficiaries of a will in accordance with your wishes.

We will not share or transfer your personal data outside the European Economic Area (EEA).

7. Where we store your personal data

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You must not share your password with anyone.

8. How long we keep your personal data

Where you register on our website and enter personal data but do not complete the process and create your will, we may retain your data for a period of 6 years to ensure that we are able to assist you should you have any questions or feedback in relation to our services.

Due to the nature of the services and pursuant to Article 17(3) GDPR, if you complete a will using our service, we reserve the right to securely store your data indefinitely. This is in order to protect against legal claims, as well as to provide supporting information if your will is ever contested.

Where we have processed your personal data to provide you with marketing communications with your consent, we may contact you at least every 12 months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your correspondence data will be removed from our list.

9. Which are your rights under data protection laws

• Right to object. You have the right to object to us processing your personal data where we are processing your personal data: based on our legitimate interests (as set out above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and for direct marketing purposes. If you ask us to stop processing your personal data on this basis, we will stop.
• Right of access. You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing.
• Right to rectification. You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
• Right to restriction. You have the right to restrict our processing of your personal data where: the accuracy of the personal data is being contested by you; the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased; we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or we are processing your data on the basis of our legitimate interest(as set out above) and you:
  • object to our processing on this basis; and
  • want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

• Right to data portability. You have the right to receive your personal data in structured, standard machine-readable format and the right to transmit such personal data to another controller.

Right to erasure. You have the right to require we erase your personal data which we are processing where at least one of the following grounds applies: the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed; our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data; you object to the processing as set out in the “right to object” section of this policy and we have no overriding legitimate interest for our processing; the personal data have been unlawfully processed; and the erasure is required for compliance with a law to which we are subject.

You can exercise such rights by contacting us at [email protected]. If you are unhappy with how we are processing your personal data, you have the right to complain to the Information Commissioner’s Office. 

10. Why we use Cookies and how they benefit you

Our website uses cookies, as almost all websites do, to help provide you with a tailored experience when you browse our website. 

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you access our website.

The table below provides more information about the cookies we use and why:

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

11. Other links on our website

Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects you to different websites. If you follow a link to any of these websites or use our service, please note that you have left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before you submit any personal data to these websites.

12. Changes to our privacy policy 

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.