Privacy Policy
Personal Data
In the EU’s General Data Protection Regulation (GDPR), Personal Data is defined as “…any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.”
How we use your information
The following privacy policy will outline how Smart Later Life Ltd will collect and use your data.
What information is being collected?
We are collecting information that is provided through the contact form on our websites, www.smartlatrerlife.co.uk, as well as data collected from cookies on our website. This data comprises of your name, email address, phone number, property value and date of birth.
We will collect information in order to produce the documents you are paying for. This information includes, but is not limited to, your name, date of birth, address, executor’s names, beneficiary names, an overview of your assets and liabilities, trustee names and attorney personal details. We may collect this information over the phone, via video call, or in person.
We will request to see original documents to prove your identity and address.
How will we use the information about you?
We process personal information for certain legitimate business purposes, which include some or all of the following.
· By providing us with your contact details, you have registered interest in us contacting you to discuss the products and services listed on our website.
· To update and maintain our internal records.
· To respond to your queries and information requests.
· Respond to service requests.
· Respond to complaints and refer you to Society of Will Writers if necessary, see complaints procedure for more information.
· To track website usage to make improvements to the website.
· We may periodically send promotional emails or leaflets to you containing information which we feel may be of interest to you using the email address which you have provided, or the postal address provided. All promotional emails will include an unsubscribe link should you wish to opt out of receiving email marketing. All marketing leaflets will include our address for you to contact if you wish not to receive any further information by post. If you have any concerns regarding the opt out process, please contact the data controller using the contact details available at the bottom of this privacy policy. It should be noted that you have no legal or contractual obligation to provide your personal data for the purposes listed above, and there are no consequences to you for this data not being provided outside of the purposes of the processing listed above not being fulfilled. This data will not be used for any automated decision making or profiling purposes.
· By supplying your contact details to Smart Later Life Ltd and/or doing business with us, you have registered interest in us contacting you from our sister company, Smart Independent Financial Advice Ltd, 5 Tudor Grange, Wirral, CH49 1TD, and its trading styles. You are also agreeing to Smart Independent Financial Advice Ltd privacy policy, which you can find on their website, www.smart-IFA.co.uk. From time to time, Smart Later Life Ltd and Smart Independent Financial Advice Ltd reserves the right to change this privacy policy and will post any revisions on their web site. In relation to the products and services offered though Smart independent Financial Advice Ltd, we may periodically send promotional emails or leaflets to you containing information which we feel may be of interest to you using the email address which you have provided, or the postal address provided. Please let us know at any time if you do not wish to receive this information, by emailing, Richard.jones@smartlaterlife.co.uk, or writing to 164 Banks Road, West Kirby, Wirral, CH48 0RH, or phoning 07944648080.
If you decide to store your documents with Smart Later Life Ltd, we will also use your information in the following ways:
· Store Wills, LPAs and other legal documents in our storage facility.
· Perform document validity checks on entry to storage.
· Search our database for stored documents.
· Provide location data to Certainty National Will Register and/or ‘WillFindA’.
· You have agreed to share your name, address and bank details with the third party, GoCardless, in order for a direct debit mandate to be set up for collection of the annual storage fee.
Why do we need to collect and store personal data?
In order for us to do any of the above, we must collect and store your data firstly for correspondence purposes. We will ensure that the information collected will only be used for its intended purpose and does not constitute an invasion of your privacy.
Smart Later Life Ltd and Smart Independent Financial Advice Ltd may wish to contact you for marketing purposes.
Will we share your personal data with anyone else?
We may need to pass your details onto third parties who are either contracted to, or part of the Smart Later Life Ltd, Smart Equity Release Ltd group of companies. We may need to pass your personal data over to SWW Trust Corporation (Unit 3 Checkpoint Court, Sadler Road, Lincoln, LN6 3PW) if you are applying for a lifetime trust, or for any queries that are relevant in relation to what you are trying to achieve. We may also share your information with The Society of Will Writers (Chancery House, Whisby Way, Lincoln, LN6 3LQ) if we request an accuracy check or in the event of a complaint/membership enquiry. If a direct debit is set up to pay for document storage, we use the third party, GoCardless. Any third parties who we do pass your details onto are obliged to store your details securely and only process them if responding to obligations or requests on yours or our behalf. When the time comes that they no longer require your personal data, they will dispose of this accordingly and in line with our company policy. If we wish to pass your personal data to a third party not already mentioned, we will only do so with your explicit consent, unless we are legally obliged to do so otherwise.
How will we use the personal data we collect about you?
Processing data constitutes as collecting, storing and using. We will process this data in accordance with the GDPR. We will do our utmost to keep your information accurate and up to date and not keep it longer than is necessary. Smart Later Life Ltd may issue occasional reminders to all customers to keep their contact details up to date and will update them accordingly.
Please be advised that there is information that we are required to keep in accordance with the law, such as information needed for tax and audit purposes. Personal data may be held for longer than these periods, however this will depend on the individual needs of the company.
Under what circumstances will we contact you?
We will only ever contact you when necessary, or when you have requested that we do so. We do not mean at any point to be intrusive or ask for unnecessary information. We will do our best to ensure that the information we hold is as secure as possible to minimise the risk of unauthorised access or disclosure.
Our storage facility is under strict lockdown and only accessible by staff. All documents in store are scanned for security purposes on entry to storage.
Can you find out about the personal data that we hold about you?
If you want to see what personal data we hold on you and how it is processed, you may contact us to request this. This is known as a Data Subject Access Request (DSAR) and you must request this in writing (either by post or email), providing the necessary identification before any information is released. If Smart Later Life stores any of your personal data, you may request information on the following:
· Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
· Contact details of the GDPR owner, where applicable.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of Smart Later Life Ltd or a third party, information about those interests.
· The categories of personal data collected, stored and processed.
· Recipient(s) or categories of recipients that the data is/will be disclosed to.
· If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
· How long the data will be stored.
· Details of your rights to correct, erase, restrict or object to such processing.
· Information about your right to withdraw consent at any time.
· How to lodge a complaint with the supervisory authority.
· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
· The source of personal data if it wasn’t collected directly from you.
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Data Access Request - What forms of ID will you need to provide to access this?
Smart Later Life Ltd will accept the following forms of ID when information on your personal data is requested:
Passport; Photo Driving Licence; Utility Bill (from the last three months); Notarised ID Document; bank statement (from the last 3 months), Council Tax bill (from the last 12 months). Letter from your GP confirming your personal details.
In the event of the testator’s death, we require a copy of the death certificate and identification of the executor(s) before any documents can be released.
Contact details of the GDPR Owner
If you wish to submit a DSAR, or have any questions regarding this privacy statement, you must do so in writing using the following information.
Address:
164 Banks Road
Werst Kirby
Wirral
CH48 0RH
Email:
Richard.Jones@smartlaterlife.co.uk
Telephone:
07944648080
Use of cookies on this site
To make this site simpler, small data files are placed on your computer. These are known as cookies. Most big websites do this too.
They improve things by:
· remembering settings, so you don’t have to keep re-entering them whenever you visit a new page;
· remembering information you’ve given (e.g. your postcode) so you don’t need to keep entering it;
· measuring how you use the website so we can make sure it meets your needs.
Our cookies aren’t used to identify you personally. They’re just here to make the site work better for you. Indeed, you can manage and/or delete these small files as you wish.
You can opt out of Google Analytics cookies for all sites.
You can find further information about Cookies on our website, www.smartlaterlife.com, or you can learn more about Cookies and how to manage them by visiting, AboutCookies.org.
i) First Party Cookies
These are cookies that are set by this website directly.
We use Google Analytics to collect information about how people use this site. We do this to make sure it’s meeting its users’ needs and to understand how we could do it better. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not use cookies to collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.
There are also cookies that store basic data on your interactions with SquareSpace, the CMS running this website.
ii) Third Party Cookies
These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by Twitter, Facebook, Nextdoor and Google+. If you want to prevent sites setting third party cookies, instructions to do so are here.
iii) Log Files
Log files allow us to record visitors’ use of the site. These logs are automatically generated from all our visitors, which we use to make improvements to the layout of the site and to the information in it, based on the way that visitors move around it. Log files do not contain any personal information about you.
Links to other websites
Our website contains links to our partners, as well as other external sites. You should note, that if you click through to any of these external sites, we do not have control over that site (unless it is a website which forms part of the Smart Later Life, Smart Independent Financial Advice Ltd Group of companies and trading styles.) We cannot be responsible for the protection of any information that you provide to these other websites as they are not governed by this privacy statement. You should always exercise caution and look at the privacy statement of whichever website it is that you are visiting.
Policy Changes
Smart Later Life Ltd reserves the right to change this privacy policy and will post any revisions on our web site, www.smartlaterlife.co.uk. Your continued use of this web site will be subject to the then-current privacy policy.