Data Protection & Privacy Policy

Twin Pine Wills Ltd is committed to protecting your privacy and this Privacy Policy sets out how we handle data which identifies you.

At Twin Pine Wills and all of its affiliates (hereinafter referred to as “Twin Pine Wills”, “Firm”, “we”, "our" or “us”) we aim to protect the privacy of every current, former and prospective client as far as possible. This Privacy Policy (the “Policy”) describes the type of personal information we may collect, the purposes for which we use the information, the circumstances in which we may share the information and the steps we take to safeguard the information to protect your privacy.

Twin Pine Wills Ltd trading as Twin Pine Wills works in association with Countrywide Tax & Trust Corporation to provide our Will software, Storage and review our advice. (Our Provider)

 

 

Data request and removal

 

You have the right to access, rectify, erase, restrict, challenge, object and migrate the data we hold on you. For more detailed information please read our Privacy Policy below. To find out what data we hold on you and to request to update or remove partially or wholly the data we hold on you (as long as it’s not data that we legally have to hold onto – as outlined in our Privacy Policy). If you want to get in contact with us about your data please:

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We aim to respond to data enquiries promptly but at busy times may take up to 28 days to get back to you.

 

 

Data Protection Information

We are registered under the Data Protection Act 1998 and any information you supply will be treated in accordance with that Act.  You can obtain further information about data protection laws by visiting the Information Commissioner’s website at www.ico.gov.uk.

 

Why are we asking you to read this document?

 

During the course of dealing with us we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, the personal information of your chosen Executors, Guardians and Trustees, and in some circumstances, your physical and mental health (Your Information). We would like to explain to you what we will need to do with Your Information, and the various rights you have in relation to Your Information.

 

 

What do we mean by “Your Information”?

 

Your Information means any information describing or relating to you.   Your Information may identify you directly, for example your name, address, date of birth, National Insurance number and the like. Your Information may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

 

In the context of providing you with assistance in relation to your Will and/or Estate Planning requirements Your Information may include:

•        Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity

•        Title, names, date of birth, contact details and addresses of your chosen Executors, Guardians and Trustees. This is required to make a valid Will/Trust and you should make sure you have consent to provide us with this information.

•        Bank account details, tax information, loans and credit commitments, levels of debt, personal and business assets, family circumstances and details of dependents

•        Health and Mental status, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)

•        Any pre-existing mortgage and/or insurance products and the terms and conditions relating to these

 

 

The personal information we collect and how we use it

We may collect information about you and use it in the following ways:

· We may collect personal information about you from applications or forms you may complete, agreements you enter into with us or in the course of your establishing or maintaining a client relationship with us regarding Will & Estate Planning including your name, telephone number, postal and email address, payment details, ongoing statements and other related information. This is to allow us to contact you regarding our services, we will not send any marketing by email, phone, text or post without consent.

· We also use cookies (see separate Cookie Policy).

· When you browse the website we will store information as to how you use the website in order to improve the quality of service provided to you. For example, it will allow us to decide the most appropriate site layout and navigation.

· We also use the information we collect in order to inform you about changes to the website and, subject to any applicable local laws, other information that we think may be of interest and/or useful to you including our products and services.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in us not being able to provide services offered by us to you.

 

Information gathered and its use

We receive and store any information you enter on our website, or give us in any other way, for example during a meeting. We use your contact details to communicate with you, we may also use your information to send you news about our products and services or those of other carefully selected companies which we think may be of interest to you.

As your advisers, we reserve the right to discuss your personal circumstances with Our Provider who provide us with advice on complex issues and review existing Wills for suitability. Our Provider provide us with the system to produce your Will and/or Trust and review our documentation for ensure our compliance with laws and regulation.

We may contact you by post, email, telephone or fax for these purposes. If you do not want to receive such communication you can opt-out during registration, by emailing us at data@twinpinewills.co.uk, or by following the unsubscribe instructions on the email. Please note that there may be instances where it may be necessary for us to communicate with you, in any event, for administrative or operational reasons relating to our service.

The basis upon which our Firm will deal with Your Information

 

When we speak with you about your Will and/or Estate Planning requirements we do so on the basis that a contract for the supply of services is in place between us.  In order to perform that contract, and to arrange the products you require, we have the right to use Your Information for the purposes we set out below.

 

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Information provided it is in our legitimate business interest to do so and your rights are not affected.  For example, we may need to respond to requests from solicitors, document storage or Our Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

 

On occasion, we will use Your Information to enable us to meet any contractual responsibilities we may owe our Provider, or for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance or other regulatory obligation to which we are subject.

 

 

The basis upon which we will process certain parts of Your Information

 

Where you ask us to assist you with your Will and/or Trust, in particular, executing the Will, we will ask you the information about your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries in relation to ensuring you have the capacity to make a Will and to provide you with advice regarding the suitability of any product that may be available to you.   

 

If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently our Provider) will record information on our systems that relates to those children and potentially, to their Special Data.

 

Your Special Data and any Criminal Disclosures will be used by us in the same way as Your Information generally, as set out in this Customer Privacy Notice.

 

 

How do we collect Your Information?

 

We will collect and record Your Information from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Will and/or Estate Planning.  You will provide information to us verbally and in writing, including email.

 

We may also obtain some information from third parties, for example, searches of information in the public domain such as the voters roll.  If we use technology solutions to assist in the collection of Your Information, such as software that is able to verify your identity online or to access your credit status and/or bank account entries, then you will be required to provide your consent for us or our nominated processor to access your information in this manner, and details of how such software operates will be provided to you prior to the activation of the service.

 

 

What happens to Your Information when it is disclosed to us?

 

In the course of handling Your Information we will:

•        record and store Your Information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by our Firm as necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service

•        input Your Information, along with full details of the Will and/or Estate Planning, discussed with you or which you have taken out, to the computer systems of our Provider

•        use Your Information for the purposes of responding to any queries you may have in relation to any Will product or Trust product you may take out, or to inform you of any developments in relation to those products of which we might become aware

 

 

Sharing and transferring Your Information

 

From time to time Your Information will be shared with or transferred to:

•        our Provider

•        third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified, such third parties will include but may not be limited to, Legal professionals, Mental Capacity experts, providers of legal services such as conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

in each case for the purposes set out in this customer privacy notice, i.e. to progress your mortgage and/or insurance enquiry and to provide you with our professional services. 

 

Please note that this sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

 

We do not envisage that the performance by us of our service will involve Your Information being transferred outside of the European Economic Area.

 

 

The basis upon which our Provider will deal with Your Information, Your Special Data and Criminal Disclosures

 

In the course of handling Your Information and Your Special Data/Criminal Disclosures our Provider will:

•        record and store Your Information and Your Special Data/Criminal Disclosures on Provider systems run on secure servers. Your Information and Your Special Data/Criminal Disclosures will be accessed by authorised employees and consultants within, or engaged, by the Provider as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation the Provider may have

•        use, and where appropriate transmit, Your Information and Your Special Data/Criminal Disclosures to respond to any request from the Financial Ombudsman Service, HMRC, the Office of the Information Commissioner or any other regulatory, law enforcement or governmental body

 

Your Information and Your Special Data/Criminal Disclosures will be retained by our Provider either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable the Provider to fulfil its legal and regulatory obligations.

 

Please note that the above information is a summary of the Provider Privacy Policy for customers.  If, you wish to understand in more detail what the Provider will do with Your Information and Special Data/Criminal Disclosures then please visit the Provider Privacy Policy for customers located at https://www.countrywidegroup.co.uk/home

 

 

Site monitoring

When you use the site we anonymously record the details of the pages you look at but this data is not personally identifiable. We use this data to monitor site traffic and analyse paths customers take through our site which enable us to improve the service we provide. This information is only used by us and is not passed to any other party.

We reserve the right to change, modify, add or remove provisions of this Privacy Policy. Any changes to this Policy will be shown here, and we recommend that you check this Policy again from time to time.

 

Place of processing

The personal information held by us is held on and processed by computers situated in the United Kingdom.

 

Security and retention of Your Information

 

Your privacy is important to us and we will keep Your Information secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.

 

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.

 

Your Information will be retained by us either electronically or in paper format for a minimum of six years, or if longer than six years, the duration of this Firm’s relationship with you.

 

We have security measures in place to protect our customer database and access to this database is restricted internally. However, it remains your responsibility:

  • to protect against unauthorised access to your log in details;

  • if you open more than one browser of the same type whilst using the website, to remember to close down all browser windows when you finish.

  • if you share a computer with someone else or use public Internet access then we advise you to delete the browsing history and log off the computer. This will help ensure any personal information stored temporarily in the computer’s memory is lost.

 

Your rights in relation to Your Information

 

THE RIGHTS MARKED WITH A * ARE EFFECTIVE FROM 25 MAY 2018

You can:

•        request copies of Your Information that is under our control

•        ask us to further explain how we use Your Information

•        ask us to correct, delete* or require us to restrict or stop using Your Information (details as to the extent to which we can do this will be provided at the time of any such request)

•        ask us to send an electronic copy of Your Information to another organisation should you wish*

•        change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

 

 

Disclosure for legal and regulatory reasons

We reserve the right to communicate such personal information as we hold to third parties which seek the disclosure of it if we are requested to do so by law or by a regulatory authority.

 

Links to third party sites

Our site contains links to other sites. We are not responsible for the privacy practices, or the content of those websites. You should read the privacy policies of every website that collects data.

Legal Information and Your Agreement

Access by you to our website is confirmation that you have understood and agreed to be bound by all of these terms and conditions.

This website is prepared and issued in the United Kingdom and is intended for the information of United Kingdom residents only.

This website is for information purposes only and its content is subject to change without notice.

Nothing on this website shall be deemed to constitute financial advice and in the event that you wish to have any such advice, please contact us.

 

Disclaimer

Whilst we use all reasonable efforts to ensure that the information published on this website is accurate, current and complete at the date of publication, no representations or warranties are made (express or implied) as to the accuracy, currency or completeness of such information. We cannot accept responsibility (to the extent permitted by law) for any loss arising directly or indirectly from the use of, or any action taken in reliance on, any information appearing on this website or any other website to which it may be linked. We make no warranty that this website is free from errors, defects or viruses.

We reserve the right to change, modify, add or remove provisions of this Privacy Policy. Any changes to this Policy will be shown here, and we recommend that you check this Policy again from time to time.

 

Copyright Notice

The entire contents of this website is our property and is subject to copyright with all rights reserved.

You may download or print individual sections of the website for personal use and information only provided that these properly indicate our copyright and other proprietary notices.

You may not reproduce (in whole or in part), modify, decompile, disassemble or transmit or use for any commercial purpose whatsoever any information from this website without our prior written consent.

 

Email

 

There is no guarantee that any email you send will be received by us or that the confidentiality of that email will be maintained during internet transmission.

 

Applicable Law

 

Any disputes arising from the use of this website shall at all times be governed by the laws of England and Wales and the parties shall submit to the exclusive jurisdiction of the English Courts.

 

International Transfers of Personal Information

 

As the internet can be assessed worldwide, if you are visiting the site from outside the UK, your visit will necessarily result in the transfer of information across international borders. By visiting this site and communicating electronically with us you are consenting to these transfers.

 

How to make contact with our Firm in relation to the use of Your Information

 

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

 

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Information, so that we may investigate and fulfil our own regulatory obligations.

 

If you have any concerns or complaints as to how we have handled Your Information or Your Special Data/Criminal Disclosures you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.