PRIVACY POLICY

Last updated: May 6, 2016

This Privacy Policy, together with the Terms and the Additional Terms (collectively the Agreements) constitute all the terms and conditions agreed upon between you and us in connection with the Services. Capitalized terms are defined in this Privacy Policy or in the Terms or the Additional Terms.

Data collection and use

When you use the Services you provide us with or store on our servers certain data. Here is how we use the data you provide us with or store. By using the Services you consent to the use of your data as described below.

Access Data. These are your username, password, and other security codes that you use to log into the Site. We use Access Data to create and give you access to your account.

Your name, date of birth, email addresses, telephone numbers, mail addresses, and ID. We use these data to give you access to the Services, to communicate with you, and to provide some of the Services to you (e.g. the service called Pulse Check makes use of your email addresses and mobile phone numbers; the Create Your Will service makes use of your name, date of birth and ID). We may use your contact details to send you messages or notifications including informational, marketing and promotional communication about the Company’s Services. We will not let third-parties use your contact details for informational, marketing or promotional communication.

Your Beneficiaries’, Trustees’, Witnesses’, and Executor’s names, dates of birth, email addresses, telephone numbers, mail addresses, IDs, messages and notes. We use these data to communicate with your Trustees to confirm your status, and to send your User Content to your Beneficiaries and Executor, in accordance with your instructions. The Create Your Will service makes use of your Beneficiaries’, Witnesses’ and Executor’s names, dates of birth and IDs to help you create your legally binding will.

Assets and Will data. This is personal information you store on our servers by using the Assets and Your Will sections of the Site. It may include, without limitation, text, files, documents, contracts, photographs, images, graphics, illustrations, logos, patents, trademarks, copyrights, audio, videos, music, software. We give you access to your Assets and Will data when you securely log into the Site. We may also give your Beneficiaries and Executor access to your Assets and Will data in accordance with your instructions.

Your broad, non-specific location, which we derive from your IP address. We may use it to comply with legal restrictions that may limit the permissible use of our Services; and to improve our understanding of how users interact with our Services.

Actions you perform or do not perform, including your login time, your use of certain Services, your storage of particular content (e.g. PDF files) and your replies or lack of replies to Pulse Check messages we send. We use these to administer the Services and improve their features and usability.

Payment Data. To grant you access to Paid Services we or our providers of payment and billing processing services may ask you to provide personal information that allows us to process your payments including, without limitation, name, date of birth, credit or debit card details, postal code. We use third-party payment providers and therefore have only limited Payment Data pertaining to you, for instance only a limited number of digits of your card number. By using the Services you expressly authorise us to use and share with our payment and billing service providers, which may be located outside of the country of your residence, the Payment Data provided by you to us, even if such information is covered by local banking secrecy laws. To the extent permitted by applicable law you expressly waive your rights under such banking secrecy laws with regard to the Company and its service providers for the purpose of providing the Services.

Technical and sensor information necessary to operate the Services. This includes the type of browser and device you use, data from the touchscreen, and information from your device’s accelerometer and gyroscope sensors. This allows us to optimise the Site’s format to your specific device. We use cookies and similar technologies to assist with functions such as user authentication, remembering user preferences, understanding how users use the Services. A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. You can remove cookies from your browser and set your browser not to accept cookies. However, in some cases the Services may not function if you remove or do not allow cookies.

Sharing data

We are committed to maintaining all your User Content strictly confidential. To achieve this we make use of data security technologies to protect your data; you can find out more about security here. We have also set up certain internal policies to guarantee your User Content confidentiality. Here are the principles we abide to:

  • You remain the sole owner of your User Content. We do not own, sell or rent it;
  • We do not use your User Content for any purpose other than providing the Services. We use third-party providers of payment, billing, data storage, and other services. We do need to share your User Content with them, but we do so only for the purpose of providing the Services to you and only via secure communication channels. Where a third party (e.g. a hosting service provider) processes User Content on our behalf, it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law. We do not, without your express consent, provide your personal data to any third parties for the purpose of direct marketing;
  • Your Assets’ and Will’s data are encrypted. We do not read any User Content related to your Assets and your Will. Your Beneficiaries’, Trustees’, Witnesses’, and Executor’s data are encrypted. We do not read any User Content related to them, unless it becomes necessary to do so in order to send your User Content to them, in accordance with your instructions. For example if you provide email addresses for your Beneficiaries, when it becomes necessary to send your User Content to them we can do so in an automated way. However, if you do not provide email addresses, we will need to read your Beneficiaries’ postal addresses and phone numbers to contact them and send them your User Data, in accordance with your instructions;
  • We don’t keep a copy of data you delete;
  • If you decide to delete your account, we will permanently delete your User Content within 24 hours. If you stop replying to our Pulse Check messages we will send your details to your beneficiaries as per your instructions, and then permanently delete your User Content;
  • No part of your User Content is made public by us;
  • We may use and share with third parties information about our users and their behaviour on the Site, but in an aggregate and de-identified format;
  • We may access or disclose your User Content if we determine that the access or disclosure is required or permitted by law to protect the rights, property or personal safety of the Company and users of the Services, or is required to comply with applicable laws, regulations, court orders or governmental requests.
  • We will comply with the relevant data privacy laws within Singapore, including but not limited to the Personal Data Protection Act 2012 (PDPA). The individuals responsible for our compliance with the PDPA can be contacted via email here: contact us [link].

Sharing data triggered by your actions

The Services may feature the transmission of some or all of your User Content to people or organisations other than yourself, by post, electronic mail, or other media as specified in the Services from time to time. Such transmission may be triggered by certain actions or inactions of yours as specified by the Services. You agree that any such action or inaction is equivalent to your instructing us to transmit some or all of your User Content to the addresses specified by you on the Site. You understand and agree that electronic mail, post and any other transmission media that we may use from time to time to transmit your User Content are not necessarily secure and you authorise us to use them to transmit your User Content.

Transfer to other countries

We transfer, process and store User Content on servers located in Singapore and in other countries. Your personal information may therefore be subject to privacy laws that are different from those in your country of residence. We are committed to adequately protecting your personal information regardless of where the data reside.

Accessing and updating data

You can view, amend and delete your User Content by logging into the Site. If you have questions about your personal information or about this Privacy Policy, or if you would no longer like to receive e-mails from us you can contact us.

External links

The Agreements between you and us are limited to your access to the Site and the Services. If you visit a website that we mention or include links to, your access and any information that you may provide to any such website will not be governed by this Privacy Policy or the Agreements.