Privacy Policy

1Legacy Privacy Policy

1Legacy Limited, a company registered in England and Wales under company registration number 13560551 and with registered office is 85 Great Portland Road, London, W1W 7LT, UK, is committed to protecting and respecting your privacy.

This policy (together with our terms and conditions 1legacy.co.uk/terms-and-conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection laws in the UK, the data controller is 1Legacy Limited. We are registered as a data controller with the Information Commissioners Office under number ZB645373.

You can contact 1Legacy at any time for more information about this policy so please get in touch with us at support@1legacy.co.uk.

This Privacy Policy primarily applies to our account-information services, our payment initiation services, and to your use of our platform and software applications hosted or made available by us, wherever and however you access them (“the Service”) and as provided by our Third Party Service Providers. To a lesser extent this Privacy Policy applies to any visitor to our websites (where the level of interaction with your data and the amount of data processing will be much less).

1Legacy’s Cookie Statement – our deployment of cookies across our website and our products (which will be different in each case)

The website and Services use cookies to identify you, remember information based on your previous interaction, provide personalized content and improve our Services. It can only store information that you voluntarily share. You may disable the use of cookies in your browser.
1Legacy uses (i) Strictly necessary (essential) (ii) Functional (iii) Analytical (measuring performance) and (iv) Tracking/advertising types of cookies.
Cookies may be delivered by us directly to you (first-party cookies) or delivered by one of our partners (such as Intercom for users of AISP or PISP services) (and/or our Third Party Service Providers). Cookies can be either session cookies or persistent cookies. Session cookies enable sites to recognise and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognise you and these are stored on your system or device until they expire, although you can delete them before the expiry date.

1Legacy uses cookies for the following reasons:

For our products/platform:

  • To help us improve End Users’ experience
  • To fulfil API calls and integration requests to connect to various accounts
  • To help with data protection and spot fraudulent activity

For our websites:

  • To remember preferences and settings
  • To identify errors on the site and assess performance
  • To help us understand traffic data relating to our site, e.g. time and date of visit

What other similar technologies does 1Legacy use?

1Legacy uses certain tools for basic font usage and to understand email-opening statistics by recipients of our emails). These help us to gauge the effectiveness of certain communications, promotions and marketing campaigns.

How you can take control of cookies and similar technologies

You have rights to manage and turn off/on certain cookies as you wish from your browser settings but you may not be able to use our applications or features of our sites if cookies are disabled.
In light of recent changes to cookies practices in 2021 (with respect to the disablement of third party cookies on some browsers) we include below an updated list of the more popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:

  • Google Chrome
  • Microsoft Edge
  • Mozilla Firefox
  • Opera
  • Apple Safari

Where & how 1Legacy uses cookies:

We use cookies in several places, and some examples from third parties are included below:
For our Product (platform):

  • Adjust
  • Braze
  • Heap
  • Intercom
  • Zendesk

For our websites:

  • Squarespace
  • Google Ads
  • Google Analytics
  • Vimeo
  • Cloudflare
  • Pardot

For more information on the main cookies currently used, their purpose and their duration please get in touch with us at support@1legacy.co.uk

Basis for processing personal data

Personal data is any information which can (or could be used to) identify a living person.

The paragraphs in this section explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.

To enter into and perform contracts with you: 

Where you ask us to provide services to you, we will process your personal data to provide these services to you. We need certain personal information about you to provide the services to you. We may also share your information in future with other 1Legacy companies in order to provide services to you. If you do not wish to provide us with your personal data in this way, you will be unable to use our services.

To provide services to you: 

We use a number of third party service providers to help us provide our services. In order to do this, we may have to provide some of your information to them and we will only ever do this to the extent necessary to provide services to you and only when we have contractual provisions in place to ensure your information is securely held and not used for any other purpose.

Where you ask us to provide personal finance technology and open-banking  services we will share your personal data with Moneyhub Financial Technology Limited who will act as an independent data controller. For more information how they will use your information, please see https://www.moneyhub.com/privacy-policy-and-cookies

Where you ask us to provide will/document storage services we will share your personal data with Cleardata UK Ltd who will act as an independent data controller. For more information how they will use your information, please see https://www.cleardatagroup.co.uk/cookie-policy/

Where you ask us to provide will drafting/compiling services we will share your personal data with LegalWills.co.uk (owned by PartingWishes Inc) who will act as an independent data controller. For more information how they will use your information, please see https://www.legalwills.co.uk/Privacy

Where you ask us to provide electronic data storage services we will share your personal data with Legado Technologies Limited who will act as an independent data controller. For more information how they will use your information, please see https://www.joinlegado.com/policies/privacy-policy/

Where you ask us to provide funeral or cremation services we will share your personal data with Dignity plc who will act as an independent data controller. For more information how they will use your information, please see Dignity’s privacy policy.

Where you ask us to provide insurance quotation services we will share your personal data with Moneysupermarket.com Limited who will act as an independent data controller. For more information how they will use your information, please see https://www.moneysupermarket.com/legal/privacy-policy/

To improve how we provide our services: 

We analyse personal data to identify areas so that we can improve our services and we sometimes engage third parties to assist us with this analysis.

Some examples are:

  • Recording calls to analyse and improve how we provide our services over the phone.
  • Analysing feedback you provide on external review platforms, on our website chat function or in emails and the way you interact with our services.
To make our website better: 

We will also process your personal data in order to provide you with a more tailored experience when you visit our website. For example, we may use your personal data to tailor our website, make sure it is displayed in the most effective way for the device you are using. We also use various third party cookies to help us improve our website (more details are set out in the sections below) but we will not share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will also process your personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research and statistical and survey purposes.

The legal basis on which we process your personal data in these circumstances is our legitimate interest to optimise website visitor engagement, inform future content and to ensure that our website is kept secure.

For user research: 

We have a legitimate interest to contact you in relation to your experience of using our products and services. We will use any feedback provided to tailor and improve our services. We may also conduct research to develop new products and services where input from users’ experience would inform our approach.

1Legacy marketing purposes:

We may contact you if your past or recent activity suggests you might want to hear from us (for example, you completed one of our reviews or questionnaires or entered one of our promotions, you have used our services or you have an annual subscription with us), unless you have already indicated that you do not wish to receive marketing communications from us.

We process your personal data to form a view on what services, offers or promotions we think you may be interested in.

Our communications always include a link so you can unsubscribe. You can also let us know you would prefer not to be contacted by emailing contact@1legacy.co.uk and clearly stating that you wish to be removed from our marketing list.

To allow charities to communicate with you: 

We sometimes ask you if you are happy to receive marketing communications from the charities we work with (for example, they have referred you to our services or you have left the charity a gift in your will). If you agree and provide your consent, we send the charity your personal data so they can contact you directly. Where you change your mind and decide you would prefer not to be contacted by the charity, you should let them know (their communication should also contain an unsubscribe link).

Where you do not receive a prompt to ask you for your consent to share your personal data with the charity for their marketing communications, this means that 1Legacy Limited have an agreement with the charity whereby we provide your personal data to them so they can contact you directly (unless you have indicated to us you do not want us to share your personal data for this reason).

To allow our charity partners to analyse and optimise their legacy campaigns and to update their supporter databases: 

We will share some basic information relating to you (name, address, email address, date of birth, phone number), gift type and gift amount bracket (if any), to allow our charity partners to assess and improve their legacy campaigns and update their supporter databases.

To enable tracking and attribution of referrals and campaigns from our commercial partners: 

Where you have been referred by one of our commercial partners (and/or our Third Party Service Providers) we will share some basic information relating to you (name, address, email address, date of birth, phone number) to allow our commercial partners to attribute referrals. This will be in addition to your communication preferences and this information will not be used for marketing purposes if you have not given consent for that purpose.

To create anonymised data sets: 

Anonymised data is information which cannot be used to identify a living person. It is useful for statistical analysis and identifying general trends. We will convert your personal data into an anonymised format so it can be used for press publication (for instance to show the age range of our customers, or geographical areas where we provide a high volume of service) and to help charity partners raise money through gifts in wills by helping them to evaluate the efficacy of their marketing campaigns. Anonymised data is not personal data.

For customised marketing content, insight and analysis:

We may use your personal information to generate aggregated, anonymised data for the purposes of internal reporting, customised marketing content, insight and analysis. This will enable us to improve and personalise our Site, the products we offer and search results for our Site. As part of this we use Google Analytics. For further information, see Google’s Privacy and Terms.

If our business is sold: We will transfer your personal data to a third party: 

In the event that we buy or sell any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or if 1Legacy Limited or substantially all of its assets are acquired by a third party, in which case personal data held by 1Legacy Limited about its customers will be one of the assets transferred to the purchaser.

In each case, the legal basis on which we process your personal data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

How long we store your personal data for (retention & duration)

Where we hold your personal data and are responsible for it, it will be stored for the life of your contract with us and/or our Third Party Service Providers (stored for the life of your contract plus 5 days as per the Moneyhub data retention policy). Your contract with us would typically expire when you delete your account with us or ask us to delete your account for you. Our databases are backed up but such back-ups are never held for more than 90 days at a time. It is crucial that we hold your personal data in this way because without it, we would not be able to fulfil our contract with you and show you copies of your account information or payment transaction information, when you request/select to see these

Data Security

Once we (and/or our Third Party Service Providers) have received your information, we (and/or our Third Party Service Providers) will use procedures and security features to try to prevent unauthorised and unlawful access and processing, as well as accidental loss, destruction or damage. We (and/or our Third Party Service Providers) use encryption technology to protect personal data that you submit to us (and/or our Third Party Service Providers) online in order to reduce the risk of your data being intercepted by unauthorised persons during transmission.

We (and/or our Third Party Service Providers) deploy a range of technical and organisationalmeasures including physical, electronic, and procedural safeguards to protect information we (and/or our Third Party Service Providers) process and maintain. 

Please be aware that the transmission of information via the internet or mobile networks is not completely secure; we (and/or our Third Party Service Providers) cannot guarantee the security of your data transmitted to or from us and any transmission is at your own risk. 1Legacy (and/or our Third Party Service Providers) 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. It will be clear to you when you click on a link that will take you to a Third Party Member we strongly encourage you to read their privacy policies in detail. We do not control these third-party websites and are not responsible for their content or their privacy statements. 

In the event there is an occasion in future where there is an unauthorised use or breach with respect to personal data, 1Legacy (and/or our Third Party Service Providers) shall comply with GDPR expectations and timelines (including a 72 hour investigation and reporting window) in order to mitigate the risk to any individuals affected.

Changes to this Privacy Policy

We reserve the right to add to or change the terms of this Privacy Policy in the same way that we need from time to time to vary our terms and conditions (1legacy.co.uk/terms-and-conditions) to keep up to date with evolving data protection laws or to take account of changes to our Service.You are therefore advised to keep abreast of this Privacy Policy through whatever medium, site or device you access it.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at contact@1legacy.co.uk if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at support@1legacy.co.uk .

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICOs address:            

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk 

Version: March 2024

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