Privacy Policy
Last updated: February 2025
1. Data Controller
The data controller for your personal information is Probate Tech Ltd (Company No. 12571623), registered in England and Wales. The director responsible for data protection is James Cole.
2. What Data We Collect
We collect the following categories of personal data:
- Identity data: full name, date of birth, marital status, address
- Contact data: email address, phone number (if provided)
- Will data: details of assets, liabilities, beneficiaries, executors, guardians, and your wishes as expressed through the will-writing process
- Conversation data: the content of your conversations with our AI assistant, used to generate your will
- Account data: authentication information managed through our identity provider (Clerk)
- Technical data: IP address, browser type, and usage patterns for service improvement and security
3. Lawful Basis for Processing
We process your personal data primarily under the lawful basis of performance of a contract (Article 6(1)(b) UK GDPR). The processing is necessary to provide you with the will-writing service you have requested.
Where we process data for marketing communications, we do so on the basis of your consent (Article 6(1)(a) UK GDPR), which you may withdraw at any time.
We may also process data where we have a legitimate interest (Article 6(1)(f) UK GDPR) in improving our services and ensuring security, provided this does not override your fundamental rights and freedoms.
4. How We Use Your Data
We use your personal data to:
- Generate your will document based on the information you provide
- Manage your account and authenticate your identity
- Communicate with you about your will and our service
- Improve our AI-assisted will-writing service
- Comply with legal and regulatory obligations
- Send you marketing communications (only with your explicit consent)
5. Data Sharing
We share your data with the following categories of third parties, solely to provide and support the service:
- Clerk: for authentication and account management
- Anthropic: for AI-assisted conversation processing (conversation content is sent to generate responses; refer to Anthropic's data processing terms)
- Hosting providers: for secure infrastructure
We do not sell your personal data to any third parties.
6. Data Retention
We retain your will data and associated records for a minimum of 6 years from the date of creation or last modification. This retention period is in line with the Limitation Act 1980 and standard legal practice for testamentary documents. Conversation data used to generate your will is retained for the same period. You may request earlier deletion, subject to our legal obligations.
7. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including encryption at rest and in transit, access controls, and regular security reviews. Will data containing sensitive personal information is encrypted with per-user encryption keys.
8. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: request correction of inaccurate data
- Right to erasure: request deletion of your data (subject to legal retention requirements)
- Right to restrict processing: request that we limit how we use your data
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interests
- Right to withdraw consent: withdraw consent for marketing at any time
To exercise any of these rights, please contact us using the details below.
9. Cookies
We use essential cookies required for the operation of our service (authentication, session management). We do not use advertising or tracking cookies.
10. Contact
If you have any questions about this privacy policy or wish to exercise your data rights, please contact:
James Cole, Director
Probate Tech Ltd
Email: privacy@sailwills.co.uk
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.