MyIntent Privacy Policy

1.1 This is the privacy policy of Bequeathed Limited (company number 10960116) trading as MyIntent whose registered office is at Acre House, 11/15 William Road, London NW1 3ER.

1.2 In this policy we refer to ourselves as “we” and to users of this website as “you” (and related expressions must be interpreted accordingly).

1.3 Our business consists of two parts.

1.3.1 The first part consists of providing online tools and guidance to consumers via www.myintent.life (“Website”) to help them plan for their own death and deal with the death of someone else and services relating to will-writing, lasting powers of attorney or “LPAs”, recording of funeral wishes and other preferences for end-of-life arrangements, and probate and estate administration after a death.

1.3.2 The second part comprises a commercial scheme (our “Scheme”) for the benefit of our partners for which they may pay a fee. Our partners may from time to time include charities for legacy giving and in memory donations, funeral companies for funeral plans and funerals, celebrants for planning and conducting funerals, law firms for Wills, LPAs, advance directives, probate and estate administration and companies, employers and member organisations for assisting their customers and/or staff and/or members deal with issues around life and cope with a death. The arrangements between ourselves and partners do not involve the marketing of our respective services. Our partners do not as part of our Scheme exchange personal data between themselves.

1.4 Many of our services to consumers are free of charge. To enable us to provide those services, our partners may pay us subscription fees to participate in our Scheme and/or promote MyIntent to their customers and contacts or prospective customers.

1.5 We set out below important information about our processing of personal data by reference to the purposes for which we do so in the context of our business.

1.6 We have published this policy with the view of engendering your trust in our processes, so that you understand what we do and why, and in order that, if you wish to challenge them, you have information about your rights and how you can contact us.

1.7 The purposes are as follows:

1.7.1 Conduct of our Scheme and maintaining a database of our users’ intentions for the administration of their end of life, death and estate after their death;

1.7.2 Keeping records and accounts;

1.7.3 Recording of in-coming and out-going telephone and video calls;

1.7.4 Operating our business; and

1.7.5 Our website and use of cookies and tracking technologies.

1.8 We have included sections dedicated to describing your rights, our contact information generally, and how you can make a complaint.

1.9 Except where stated, this policy does not relate to our storage of personal data relating to your circumstances and wishes that you upload to the Website while using our online Will interview, keeping a copy of the draft Will the system creates from your answers, or keeping a record of your questions and answers. We perform those tasks on your behalf as a processor under our Terms of Service.

2.1 We believe that helping people to make a Will, plan for their own death, and deal with the death of someone else are good things to do. The systems required to do so are complex and to make some of them available to you free of charge we rely on fees from our partners. Therefore, we have a legitimate interest in processing personal data in accordance with our Scheme, which we undertake on our own behalf and for which we are responsible under data protection laws.

2.2 We also have a legitimate interest to keep all records relating to our business for our internal purposes and to deal with queries or complaints which may arise.

2.3 The legal basis on which we deal with people other than you depends on the circumstances. In all cases we make sure that we have a legitimate reason to do so in connection with our business.

3.1 From you

We will obtain personal information about you when you register on our Website to use our services, before you register if you request help with us through our Intercom chat and messaging service, and during your use of our Website. See our cookie policy in relation to cookies and tracking technologies.

3.2 During the operation of our Scheme

As part of our collaboration with charities, with funeral companies, with law firms, and with companies, employers and member organisations they may refer their actual or potential customers or clients to our Website. If you are such a person and visit our Website, we will obtain personal information about you in the same way we do with other visitors to the Website.

3.3 Other third parties

We communicate and deal with all manner of people in the ordinary course of our business, whether suppliers, competent authorities and others incidentally in connection with our business. While doing so, having regard to the nature and purpose of those dealings, we will obtain and process personal data.

4.1 The information about you that we use and disclose is collected through your use of this Website and information we learn from your use of the Website, or through your use of our other services.

4.2 The information we collect (excluding the information you upload to MyIntent while using our Online Will Interview which is addressed in the Terms of Service) is:

4.2.1 how you arrived at our Website;

4.2.2 your name, email address, postcode;

4.2.3 the pages you have visited on our Website;

4.2.4 any information you choose to provide us with in online chat and the tickets, emails, SMS, WhatsApp, telephone or video calls initiated through that online chat, or otherwise.

4.3 The pages you visit may indicate to us information about your circumstances or questions that may be of interest to you. This depends on your use of the Website and we may communicate with you later about those matters (see the relevant sections below for more information). However, we will never collect information about you concerning your religion, beliefs, criminal record, health, or sexuality without your explicit consent.

5.1 Generally

5.1.1 Unless you have told us not to do so, we will use and disclose your information for the purposes outlined in this section. If you tell us not to do so, we may not be able to provide you with all or any of our services.

(a) To communicate with you during the instruction-taking process for making your Will.

(b) To contact you about maintaining the currency of your Will and estate planning including to identify when your Will may be affected by a change in the law.

(c) If you opt in, to keep you up to date with our other products and services and the products and services of our partners related to planning for your own death and coping with the death of someone else.

(d) Where you have arrived at our Website via a link on the website of one of our partners, to mark you as a contact of that partner so that we may tailor our communications to you accordingly.

(e) To administer your user account.

(f) To provide contextual online support to you during your use of the system or tools.

(g) To process any request for advice or information.

(h) To customise the Website.

(i) To ensure that any content you post complies with the terms and conditions of use of the Website.

(j) To ensure that content from our Website is presented in the most effective manner for you and for your computer.

(k) To allow you to participate in interactive features of our service, when you choose to do so.

(l) To notify you about changes to our service.

(m) To analyse how our Website is used and share anonymous information relating to that use with third parties.

5.1.2 We do not use or disclose data we obtain from anyone else for any purpose in the course of our business other than for which it was given to us.

5.1.3 If we sell or buy any business or assets, we may disclose your information to the buyer or seller of the business or the assets. If we or substantially all our business or assets are acquired by a third party, your information is likely to be included in the transfer.

5.2 Charities

5.2.1 We disclose information about our user-base and legacy-giving in anonymised form to charities.

5.2.2 Subject to your express permission in the Online Will Interview, we will inform the relevant charity if you have included a legacy gift in your Will and provide the charity with your contact details for the purpose of it getting in touch with you to say thank you and to request permission to keep in touch with you as set out in the opt-in provided to you in the Online Will Interview.

5.3 Law firms

5.3.1 The services we provide to law firms includes the preparation of a draft Will and associated draft advice according to the answers you provide in the Online Will Interview. We determine what questions to ask and the content of the draft Will and draft advice. The purpose of doing so is to assist the law firm to productively render its independent legal advice (as your lawyer), including the final version of your Will. As set out also in our Terms of Service, the draft Will and associated advice prepared by us for the law firm must not be relied on by you (even if you obtain a copy of it).

5.3.2 During the Online Will Interview, in addition to specific questions about your Will, we will also ask you about other aspects of your wishes in respect of probate and administration, LPAs, advance directives, and funeral planning. We may contact you separately about those wishes via the communication channels, including email (to which you consent), and contact details you provide.

5.3.3 Unless you tell us not to do so, we will introduce you to a law firm on our panel with which you agree and sign a Client Care Letter and any terms of business) in accordance with the law firm’s procedures, so that it may draft your Will, advise you on its contents, or about other matters (as you request). Where you have been referred to our Website by a law firm, we will not introduce you to another law firm, unless it transpires the referring firm is unable or unwilling to act for you (see below).

5.3.4 This introduction includes arranging an appointment for you with a member of staff at the law firm via our Calendly account. You will be able to book an appointment by entering your details. We can do so even where you have been referred to us by the firm itself. The personal data you provide via Calendly will be sent by Calendly to the law firm. We may also send you a Calendly link on behalf of the firm from its Calendly account, in which case, none of the personal data (or any other data) you provide in the process is retained or processed by us on our own behalf.

5.3.5 Where you have a Client Care Letter with the firm, with your consent, we transfer the personal data you have entered in our system to the law firm relevant to the writing of your Will or other advice you require from the law firm (as appropriate). In relation to the writing of a Will, the data comprises a copy of your interview with us, our initial advice, and a copy of the draft Will.

5.3.6 If a law firm is unable or unwilling to act for you, we may be able to introduce you to an alternative firm on our panel. In that case, the above processes and disclosure of your personal data to the alternative firm are repeated.

5.3.7 Subject to the Terms of Service, we will retain your information for the purpose of our Scheme for as long as the information is relevant for our Scheme, and afterwards for the purposes of Keeping Records and Accounts (see below).

5.4 Funeral Companies

5.4.1 We work with Funeral Partners Bidco Limited (company number 09622240) (“FPBL”) to meet needs of consumers who are coping with a death to whom we each provide our respective services.

5.4.2 If we consider that the services available from FPBL or its subsidiaries (other than a subsidiary offering funeral plans) may assist you, with your consent, we will introduce you to FPBL. You may also do so by contacting them on the telephone at the number published on our Website.

5.4.3 This introduction includes arranging an appointment for you with a representative of FPBL via Calendly. You will be able to book an appointment by entering your details. We can do so even where you have been referred to us by FPBL itself. The personal data you provide via Calendly will be sent by Calendly to FPBL. We may also send you a Calendly link on behalf of FPBL, in which case, none of the personal data (or any other data) you provide in the process is retained or processed by us on our own behalf.

5.4.4 Where you arrive on the Website via a unique URL or QR code promoted by FPBL, and register as a user of the Website, we will mark you as being initiated by FPBL.

5.4.5 To meet our contractual obligations to FPBL, including to assist each other to comply with data protection laws, we may need to disclose personal data about you to them. The nature of the personal data that may be disclosed will depend on the circumstances but will be minimised to the extent necessary and will be in accordance with data protection laws.

6.1 Our Website sets cookies on your device, and may read cookies already on your device, regarding your use of our Website and services. Please see our cookies policy for further details regarding the collection and use of this information.

6.2 We also place Facebook Pixels from some of our charity customers on our site so they may track the actions of users who visit our site having responded to the charity's advertising.

6.3 We have implemented the Google Analytics Demographics and Interest Reporting feature which provides us with aggregated information about the age and gender of our users, along with the interests they express through their online activities. Details of how we use Google Analytics cookies are contained in our Cookies Policy.

6.4 You can opt out of the Google Analytics Demographics and Interest Reporting feature by changing your Google Ads settings on the Google website via this link. Alternatively, Google Analytics provides an opt-out add-on for certain internet browsers which you can get by visiting this link.

7.1 We keep personal data (including data subject to our Terms of Service) only where and for so long as it is necessary to provide our products and services and afterwards for so long as necessary to meet our legal or regulatory obligations or, if longer, in relation to claims which could be made against us.

7.2 Our normal practice is to keep information for at least 6 years.

8.1 General

8.1.1 This section is concerned with the systems we use to process personal data and our processing of personal data for internal purposes (including, in respect of Amazon Web Services only, the personal data you upload in your use of our online Will interview which is addressed in the Processor Terms).

8.1.2 It is not concerned with the nature of the data, the classes of individual on whom we process data, the classes of the data, the sources and disclosures of the data, nor the period of time which we hold data. For information on those topics, please consult the other sections of this policy.

8.1.3 We process personal data using the following principal systems: Amazon Web Services, Intercom, GetAccept, Calendly, Zoom, Xero, PayPal and GoCardless, some of which we make work together using Zapier.

8.2 AWS

8.2.1 Our web application and data (i.e. data from the Online Will Interview) are hosted within AWS, in UK datacentres.

8.2.2 So, AWS policies and processes are our policies and processes for our physical and network security standards.

8.3 Intercom

8.3.1 We use a third-party application called Intercom to communicate with you and provide you with support via email, telephone and online chat and, should you request it, SMS and WhatsApp.

8.3.2 The information we transfer to Intercom is stored in EU datacentres in Ireland.

8.4 Calendly

8.4.1 We use Calendly to enable you to book appointments directly with us and with our partners, including through an integration with Intercom.

8.4.2 Where you book with us, we integrate Calendly with Zoom.

8.4.3 Calendly stores the data you choose to input with Amazon Web Services and Google in the U.S.

8.4.4 A Data Processing Addendum is included in the standard Calendly terms and conditions.

8.4.5 To read more about the measures Calendly takes in relation to privacy, visit the Calendly site at https://calendly.com/legal/privacy-notice.

8.5 Zoom

8.5.1 We use Zoom to conduct video calls with you.

8.5.2 See also our Call Recording Policy.

8.5.3 We have opted to store our recordings in the Cloud with Zoom in the EU in Germany.

8.5.4 To read more about the measures Zoom takes in relation to privacy, visit the Zoom site at https://www.zoom.com/en/trust/privacy/privacy-statement.

8.6 Payment processors - Xero, GoCardless and PayPal

We use these applications to invoice you where you order paid-for services and to enable you to make payments. You can read about the GDPR polices and processes of each at:

8.6.1 https://www.xero.com/uk/data/xero-and-gdpr/

8.6.2 https://gocardless.com/legal/gdpr/

8.6.3 https://www.paypal.com/uk/webapps/mpp/paypal-and-your-data

8.7 GetAccept

8.7.1 We use GetAccept to send you the Client Care Letter under which legal services are to be provided, gather your ID, and enable you to sign the Client Care Letter.

8.7.2 The Client Care Letter is sent first to the law firm for approval and then to you. You need to sign the Client Care Letter to become a client of a law firm. GetAccept sends signed copies to both you, the law firm, and to us, which we keep as a record that you have become a client of the law firm through our service and so that we may see your authorisation to transfer your data to the law firm.

8.7.3 Data you enter into our system that is shared with GetAccept to enable this e-contracting process is stored in a datacentre in the EU, in Ireland.

8.7.4 We have timetabled auto-delete rules in place to delete your data 120 days after you have completed the Client Care Letter or if you choose not to sign the Client Care Letter after 120 days.

8.8 Zapier

8.8.1 We use Zapier to help make the other third-party systems work together.

8.8.2 We have a direct agreement with Zapier on EU Standard Contractual Clause as amended by the UK Addendum regarding the collection, use and retention of personal data.

9. Computers and mobile devices

9.1 Our staff and representatives use computer and communications equipment to access these systems to perform their duties, and in particular workstations, laptop computers, other mobile computing devices and mobile phones. Personal data is stored on these devices appropriate to the use for the time being.

9.2 We use personal data for the following internal purposes:

9.2.1 Training

9.2.2 Corporate governance and management

9.2.3 External service providers

9.3 In addition to the third-party applications listed above, we have engaged external service providers to provide the following services:

9.3.1 Tier 2 Consulting Limited, for developing and maintaining our Website , technology platform;

9.3.2 The SaaSy People Limited, for supporting us in our use of Intercom.

10.1 All information you provide to us is stored on secure servers or encrypted devices.

10.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10.3 The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

10.4 Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

Please see our Call Recording Policy.

Information processed via the third-party services listed in this policy may be processed outside of the EEA. Data held directly on behalf of Bequeathed is at AWS in the UK and at Intercom in Ireland. Please refer to section 8 (Operating Our Business) for more details.

13.1 Individuals have several rights under data protection law in relation to how we process personal data. These are identified below. To read more please visit the Information Commissioner’s website at https://ico.org.uk/.

13.2 We cannot charge for providing information where individuals exercise their rights, except that we may charge a reasonable fee based on our administrative costs to provide additional copies where requested in connection with a request to access data, or where we can demonstrate that requests are manifestly unfounded or excessive. In the latter case we may alternatively refuse to act on a request.

13.3 If someone wishes to exercise any of their rights, please contact us at [email protected]

13.4 Right to be given clear and easy to understand information on what personal information we have, why and who we share it with.

13.5 Right to access information that we hold as personal data, subject to protecting the interests of others as appropriate.

13.6 Where any information we hold is inaccurate or incomplete, we can be required to rectify it.

13.7 Right for information to be deleted or removed if there is not a compelling reason for us to retain it.

13.8 Right to restrict processing of personal data for certain reasons.

13.9 Right for a copy of personal data to be provided for personal purposes to use across different services, including to transfer the personal information we hold to another company.

13.10 Where we are subject to a breach of security which is likely to result in a high risk to individuals about whom we hold data we must communicate the breach to the individuals concerned without undue delay. In some cases, this may be done by public communications. This right is subject to certain exceptions where measures have been taken to protect the information.

13.11 Right to object to processing of personal data.

13.12 You can object to us processing your personal data where it is based on our legitimate interests, in which case we can no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

13.13 You can object at any time to our use of personal data relating to you in connection with our direct marketing. Where you do so, the personal data shall not afterwards be processed for such purposes.

13.14 Where personal data is processed for direct marketing purposes, you have the right to object at any time to processing.

13.15 Where we are processing personal data about you with your consent you can withdraw it at any time.

14.1 If you have any questions about this Privacy Policy or the personal data we will obtain and process about you, please contact us at [email protected]

14.2 If someone has a complaint about our handling of personal data, we ask that they contact us at [email protected].

14.3 If we are unable to resolve a complaint, the matter can be referred to the Information Commissioner's Office. You can make that complaint from the ICO website at https://ico.org.uk/make-a-complaint/. A claim may also lie in the courts.