Privacy Policy

Introduction

This privacy policy aims to give you information on how we collect and processes your personal data including when you access this website, any data you provide when you complete one of our online forms, and when you choose to become our customer. It sets out your privacy rights and how the law protects you. We keep our privacy policy under regular review. This version was last updated 20th September 2022.

Our privacy policy is provided in a layered format so you can easily click through to the information you need. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. About Us

Data Controller

We are Trust Family Associates, an Estate Planning company (collectively referred to as “TFA”, “we”, “us” or “our” in this privacy policy).

We are the controller responsible for the personal data that we collect from you. We are a registered data processor on the Information Commissioners Office (ICO) Register: ZA814411

We are a limited company registered in England & Wales. Our companies registered number is: 11749141 and our registered address is Suite 1&3, Metropolitan House, Cheadle Hulme, Cheshire SK8 7AZ.

Contact details

If you have any questions about this privacy policy or how we treat your data, you can contact us in the following ways:

By email: hello@trustfamilyassociates.co.uk 

By post: Trust Family Associates, Metropolitan House, Station Road, Cheadle Hulme, SK8 7AZ

By phone: 08000 662563

You have the right to make a complaint about the handling of your data to the Information Commissioners Office (ICO), the UK’s independent authority for data protection and privacy rights: https://ico.org.uk/ We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, means any information that relates to an individual from which that person can be identified, or is identifiable.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Type of personal information:	Data we collect
Identification	Name, Date of Birth, Proof(s) of Residential address, previous (maiden) name, title, marital status
Contact	Name, Address, Telephone/Mobile number, email address
Transaction	Includes details about your interactions with us, such as payment methods, how you contacted us, what product you purchased and on what terms
Financial	Payment details where you purchase one of our products, such as debit/credit card, bank account number and sort code
Usage	Data collected throughout your use of our website, services and products
Technical	Data collected automatically when you visit our website, such as your internet protocol (‘IP’) address, web browser type and version, operating system and platform, and other technology on the devices you use to access this website
Profile	Purchases and payment type, your demands and needs, marketing preferences, reviews, survey responses and feedback

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly identity you. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used only in accordance with this privacy policy.

When discussing our Estate Planning products with you, we may ask questions about your health. These are classed as Special Categories of Personal Data under the UK GDPR and we will always ask for your explicit consent to record this information within our transaction data. Obtaining this information from you will help us to assess whether our products meet your needs and in turn provide you with fair value.

We do not collect any information about criminal convictions and offences.

This website is not intended for children, and we do not knowingly collect data relating to children.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with or administer your Estate Planning Product). In this case, we may have to cancel or withdraw our contract, but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

Direct Interactions – Where you provide us with your personal data	When you fill in one of our online forms to request further information about our Estate Planning Products When you contact us to receive a quote When you purchase one of our products Throughout our relationship with you in managing and administering your product Where you request our marketing or sign up to a service or publication, enter a competition or survey Where you provide a testimonial or review, provide feedback or submit a complaint
Automated Technologies or Interactions – Where data is collected automatically	As you interact with our website we will automatically collect technical data by using Cookies, server logs and similar technologies. Please see our Cookies section for more details
Third Parties – Where we request or collect your data from other sources	Technical data from analytics providers such as Google Contact, financial and transaction data from providers of technical, payment and delivery services Identity and contact data from data aggregators based inside or outside the EU Where there is a Power of Attorney or nominated representative authorised by a plan beneficiary, they may provide the beneficiaries personal data to us

4. How we use your personal data

We will only process your personal data where we have a lawful basis to do so.

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose / Activity	Type of data processed	Lawful basis
To call you and discuss your enquiry or quote	Identity Contact	Consent
Arrange a home visit with a Estate Planning Manager	Identity Contact Transaction	Consent
Negotiation of a sale	Identity Contact Transaction	Contract
Conclusion of a sale (Processing and/or arranging payments)	Identity Transaction Financial	Contract
Managing/Administering your product	Identity Contact Financial Transaction Profile	Contract
Notifying your nominated representative	Identity Contact Transaction Profile	Consent
Asking you to provide a review or testimonial	Identity Contact Transaction Profile	Necessary for our legitimate interests (to assess how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Technical Usage Contact	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Profile Technical Usage Contact	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Profile Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Profile Usage	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We will always seek your consent to marketing. We will never cold call and only contact you if you have completed one of our online submission forms requesting further information about our products.

When you become our customer, we may contact you from time to time by email to offer you other similar products and services that we think might be of interest to you. Each communication will include an option to opt-out of receiving our emails.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased an Estate Planning Product from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will never share your personal data with any third party for marketing purposes without your explicit consent. This shall include the name of the third party, the purpose and type of marketing, and an express statement from you that you agree to TFA sharing your data for this purpose.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us to fulfil an Estate Planning contract. You can opt out of receiving marketing communications without affecting the performance of our contract with you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table How we use your personal data at Section 4, above.

• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

6. International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

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

8. Data retention

How long will you use my personal data for?

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be related with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• The Great British Probate Trust
• Rowanmoor Group Limited
• Fulfilment companies

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.