Redstone Wills – Privacy Notice

1. Who we are

This Privacy Notice applies to the use and processing of personal information collected by Redstone Wills Ltd, Just Wills Holding Ltd, Just Wills Group Ltd and Just Wills Ltd which forms part of the Connells Group Limited. The ICO Registration number for Redstone Wills Ltd is Z2949180. Our registered address is Windmill Road, St Leonards on Sea, East Sussex, TN38 9BY

The phrases “us”, “we” or “our” will mean those businesses which are part of Redstone Wills Ltd on behalf of and in respect of whom this Privacy Notice is made.

For information concerning the collection, use and processing of personal information by any of our third party business partners or suppliers, please contact our representative with whom you usually deal.

2. Information covered by this Privacy Notice

1. Personal data. This is information, or any combination of separate pieces of information, that could be used to identify you
2. Special categories of personal data. This is information which is classified as sensitive (for example details of your health)

Please read this Privacy Notice carefully. If you have any questions about this notice or our use of your personal data, please contact the Connells Group Data Protection Officer by email to dataprotection@cdpll.co.uk or in writing to Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN.

Redstone Wills Ltd is part of the Connells Group, and all data protection matters are managed at Group level. Information concerning the make-up of the Connells Group can be found by visitinghttp://www.connellsgroup.co.uk/our-group  

3. Where we get personal information from  

When you enquire or register for products and services provided by Redstone Wills Ltd we may collect personal information from a variety of sources.

The majority of the personal information which we collect will have been provided by you during the course of your relationship with us either through face to face contact, by telephone, email or electronic communications such as messaging or through the internet.

However we may also obtain your personal data from other sources including:

• information we collect when you visit our websites
• other Connells Group companies
• information provided to us by other third parties

4. What information we collect

4.1 Information we collect directly from you

Depending on the type of service or product we are discussing, the following are examples of information we may collect directly from you:

• Your name, postal address, phone number, email address and details of your requirements. To provide you one of our services as detailed on our website.
• Your marital status, date of birth, nationality and tax status. To perform verification of identity, ‘Know Your Client’ to protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims and other liabilities as required by law.
• Your date of birth, nationality and details from identity documents you provide. To perform verification of identity, ‘Know Your Client’ to protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims and other liabilities as required by law.
• Financial Information such as Assets and Liabilities. To support the drafting of you Will or to provide another service.
• Your bank account or payment card details. Where we take payment for the services we provide to you
• Your name, gender, previous name, mother’s maiden name, date of birth, contact telephone numbers, current address and previous addresses, details of your health, your relationship status, your nationality, bank account details, savings and investments, existing financial commitments, your credit history, your mortgage requirements and existing protection arrangements. To perform verification of identity, ‘Know Your Client’ and to protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims and other liabilities as required by law.
• Family history including information about any dependants. To provide you one of our services as detailed on our website – E.g beneficial of a Will.
• Health information, including information regarding mental capacity and power of attorney. To provide you one of our services as detailed on our website.
• Your communication and marketing preferences. To ensure we only send you details of products and services you are interested in through your preferred communication channel

Any telephone calls either to or from our customer service teams may be recorded for training, monitoring, compliance and security.

4.2 Information we collect when you visit our websites

We use cookies and other technologies to collect information when you visit our web sites, including when you make use of our on line chat.

We may collect personal information in connection with your use of our website, such as:  

• your name, email address and telephone number when you use an online form to submit an enquiry
• details included on any enquiry form you submit in relation to our services
• data sent from your browser to our server which may include:

• the time, date and duration of your visit
• the site from which you have come (the referral URL)
• the pages you have visited  and
• your IP address

Details of how we use cookies are provided in Section 13 ‘Our Use of Cookies’ and in our Cookies Policy.

4.3 Information we obtain from other Connells Group companies

For activities related to providing advice with regards to any of our services, Redstone Wills Ltd are an appointed representative of Connells Limited, and may share your information within the Group.

Connells Ltd is authorised and regulated by the Financial Conduct Authority; the Financial Services Register number is 302221.

4.4 – Information we obtain from third parties

Where we are required by law, or for business purposes to provide you with the appropriate service, we will obtain information about you from third parties but only after we have your agreement to do so. This will include information received from Independent Financial Advisors upon a referral being made to ourselves.

5. How we use your information

We will process the information you provide or we obtain from other sources to provide you with products and services and answer any questions you may have.  

5.1 Customer Surveys

From time to time we may request customer to complete a short survey so that we can monitor and improve the services we provide. We may occasionally contact you including by post or email to ask you for your feedback and comments on our services.

5.2 Information about our products and services

We may also use your personal data to contact you by post, e mail, telephone or other electronic means to provide you with information about products and services from the Connells Group and carefully selected third parties which we feel may be of interest or relevant to your needs.

Please see Section 12 for information about how you can exercise your rights.      

6. Who we share your information with

We may share your information both within the Connells Group of companies and also relevant third party business partners, both for the purposes set out in this Privacy Notice, or for other purposes approved by you.

6.1 Connells Group

We may share information within the Connells Group of companies for the following purposes:

• where services are provided by one Connells Group Company to another pursuant to an intra-company
• for the purpose of administering our business
• to provide you with information about products and services
• for any other purpose agreed by you

6.2 Third Party service providers

Where we engage third party service providers to perform a variety of business services and operations we provide them with only the personal information they need to perform the service we request. We contractually require them to securely protect information, and not to use it for any other purpose.

Indicatively – but not limited to – we may disclose your information to the third parties listed below for the purpose listed:

• Approved partners The business partner that referred you to Redstone Wills to assist in progressing your case. Your Attorneys who you appoint under your Lasting Power of Attorney To provide documents and support when required.
• Callcredit – the Callcredit privacy notice is available at here. In order to conduct identification checks to help prevent fraud and money laundering.TransUnion: For fraud prevention and identity verification. Details regarding TransUnion can be found here. Credas: For fraud prevention and identity verification.
• Referencing Companies - For fraud prevention, anti-money laundering checks and identity verification
• Scottish Legal Provider. To progress Wills and other documents required under Scottish Law.
• The Office of Public Guardian. To register your Lasting Power of Attorney.
• Probate and Estate Administration Companies. To provide you with these services.
• HM Land Registry. To submit changes in title required to support your Will.
• Legal Document Storage. Storage of Wills, Lasting Power of Attorney and related documents.
• Will Review Companies. To provide support and review your documents in the future to ensure your Will and other documents are current and advise you of any changes in law which may impact your Will.
• Certainty, National Will Register. Registration of your Will.

7. Lawful basis of processing

Redstone Wills Ltd processes your information under any of the following lawful conditions:  

1. Performance of a contract -  this is where the collection and processing of your data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract
2. Legal obligation - this is where the collection and processing of your data is necessary for compliance with a legal obligation, for example, verification of identity and fraud prevention
3. Consent  - where we process information under consent we will seek your clear and unambiguous consent before processing your data, for example to send and/or receive marketing information from other Connells Group companies
4. Legitimate interests - some information is processed by Redstone Wills Ltd as part of its legitimate interests which include network and information security, direct marketing, web analytics, updating customer details, lettings, sales, and other core services provided

8. Other situations

We may transfer or otherwise process your personal information:

• As part of the sale of a Connells Group business to another company, or in relation to the purchase of another business
• When we have received your instruction to pass the sale of your property to another agent
• To enforce our terms and conditions  
• When required by law and/or government authorities
• When requested by the Property Ombudsman Service or any other consumer ombudsman or trade association

9. How long we keep your information for

We will keep your information for as long as is reasonably necessary for the purposes set out in this privacy notice, and to fulfil our legal and regulatory obligations.

For further information about how long we will keep your information, please contact the Connells Group Data Protection Officer by email at dataprotection@cdpll.co.uk

10. When we communicate with you

10.1 Service related

We will send you service related communications and respond to any questions which you may ask.  

10.2 Marketing our services to you

We will contact you in order to provide you with information about our products and services which we believe may be of interest to you, and which relate to your needs. This may include but is not limited to a Will review at no additional cost.

Where you have given us your permission, we will contact you to provide information about products or services which are not similar to those that we currently provide, but which we believe may be of interest to you.

11. How we communicate with you

For service related communications, we will contact you either by e mail, through the post or via telephone.

We give you choices about how we communicate promotions and offers to you.

11.1 By e mail

We only send you promotional emails if you explicitly select to receive these (you opt in). If you would prefer not to receive information from the Redstone Wills Ltd or carefully selected third parties you can opt out by contacting Redstone Wills Ltd, by emailing enquiries@redstonewills.co.uk

11.2 By post

We only send you promotional postal mail if you explicitly select to receive these (you opt in). If you would prefer not to receive information from the Redstone Wills Ltd or carefully selected third parties you can opt out by contacting Redstone Wills Ltd, by emailing enquiries@redstonewills.co.uk

11.3 Telephone

We will only contact you by phone for promotional reasons if you explicitly select to receive these (you opt in). If you would prefer not to receive information from the Redstone Wills Ltd or carefully selected third parties you can opt out by contacting Redstone Wills Ltd, by emailing enquiries@redstonewills.co.uk

12. Your statutory rights

You have a number of rights concerning the personal information we use. These include the right to:

• ask us for access to a copy of your personal information we hold about you  

• ask us to correct your personal information

• ask us to delete your personal information

You can delete your online account at any time. This will delete any personal information in your account that we have about you, and it will mean any data about how you’ve used the online account will be made anonymous.  

However, deleting your online account will not delete any data you’ve shared with us for reasons that are not connected with your online account. If you wish us to delete your data which is unconnected with your online account, please contact us as described below

• withdraw your consent to use your personal information

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time. If you withdraw your consent, your previous consent will remain valid in respect of our use of your data in relation to good or service we are still contracted to provide. If you would prefer not to receive information from the Redstone Wills Ltd or carefully selected third parties you can opt out by contacting Redstone Wills Ltd, by emailing enquiries@redstonewills.co.uk

We will act to respond to your request to stop receiving promotional email, phone, text or postal messages from Connells Group as quickly as is practicable (around 10 working days, as systems take time to replicate). We will keep information for record keeping purposes, to ensure we fulfil your request not to send particular types of messages.

• ask us to restrict the use of your personal data, including direct marketing

• object to our use of your personal data

• object to an automated decision, including profiling (for example, in terms of credit risk)

• lodge a complaint with the Information Commissioner’s Office, if you object to the way we use your personal information. For more information please go to www.ico.org.uk  

If you wish to make a request for access to a copy of your personal data, please write to the Connells Group at Group Legal Services, Bridgegate House, 5 Bridge Place, Lower Bridge Street, Chester CH1 1SA or email dataprotection@cdpll.co.uk

If you wish to exercise any of your other rights, please write to the Connells Group Data Protection Officer at Connells Group, Cumbria House, 16-20 Hockliffe Street, Leighton Buzzard, Bedfordshire, LU7 1GN or email dataprotection@cdpll.co.uk

We will acknowledge your request and let you know what we will need from you to carry out your request. Every effort will be made to respond to or comply with your request as quickly as possible, and we will ensure our systems are updated as soon as is practicable in response to your request.

13. Our use of cookies

A cookie is a small file placed on your device when you visit a website that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and to store your preferences when using a particular site. It may contain a unique identifier to ensure that you are not shown the same information and/or are only shown information you have stated that you are interested in.

Our security software may use your IP address and browser version to help protect our systems and provide diagnostic information in the case of an issue.

Further information about our use of cookies is provided in our Cookies Policy

14. How we protect your information  

We store your personal information on our computer systems and in our paper records.

We have implemented strict security procedures to ensure that personal information is not damaged, destroyed or misused, and to prevent unauthorised access to your information.

The information that we collect is stored in a secure facility with restricted physical access.

We also use a number of security measures to prevent electronic access.

Where - in line with this Privacy Notice - information is shared with third parties, similar security measures are used to protect your information.

15. Data Transfers

If we need to transfer data outside the European Economic Area (EEA) and the country it’s transferred to is not on an approved list for having adequate security controls in place, we will limit when we do this and the amount of personal data we send. We will also ensure that there is adequate protection in place before sending anything to other countries outside the EEA by imposing contractual obligations on the recipients to ensure the security and confidentiality of your data.

16. Children’s privacy

We do not offer any products or services to children. In certain circumstances (for example to indicate the beneficiary of a Will) we may need to collect the name and date of birth of children. This may then be shared with third parties as listed in section 6.2.

17. Our Promise to you

When you provide us with this information, you agree to the collection, use and sharing of your information in accordance with this data privacy notice. Our promise to you is that

• We’ll work with other businesses to put together offers we think you might like
• You are in control of your data
• You can change your privacy settings at any time
• If you don’t think the data is correct tell us and well put it right
• We will keep your data secure
• We also promise to collect, process store and share your data safely and securely and to make sure the businesses we work with do the same

18. Updates to our Privacy Notice

We will occasionally update our Privacy Notice, so we suggest that you review this Notice from time to time. If we make substantial changes to our Privacy Notice, we will endeavour to inform you directly about these changes.