Privacy Policy

Willful UK Ltd (“Willful”, “we”, “us”) is a company registered in England and Wales. We operate willful.uk, an online platform for preparing wills, Lasting Powers of Attorney and codicils that are reviewed and approved by independent solicitors.

We are the data controller for the personal data collected through the platform. Willful is a technology company, not a law firm, and is not regulated by the Solicitors Regulation Authority; the solicitor who reviews your document is individually SRA-regulated and, for the professional records they must keep, acts as a separate data controller. Willful has applied to the SRA for authorisation as an Alternative Business Structure.

We collect the following categories of personal data:

• Identity data: full legal name, date of birth, address, nationality
• Contact data: email address, phone number
• Will and estate data: the people you name (executors, beneficiaries, guardians, attorneys and family members, including their names, relationships and addresses), your assets and liabilities, gifts, business interests, funeral wishes, ethical will, digital accounts you catalogue, and your capacity statements and any capacity video
• Identity verification data (special category): when you verify your identity we use Stripe Identity to process images of your identity document (UK passport or photocard driving licence) and a live selfie. This is biometric data and is special category personal data under UK GDPR Article 9. See section 6.
• Documents you upload: files you store in your vault, order-of-service photos, and death certificates submitted by an executor
• Messages: your correspondence with the reviewing solicitor and in the family dialogue room
• Technical data: IP address, browser type, device identifiers and access logs, including a tamper-evident audit log of actions taken on your account
• Payment and order data: card payments are processed by Stripe and we do not store card numbers. We keep a record of each order: what you bought, the amount, any discount code and Stripe’s payment reference.
• Marketing data (only if you accept analytics cookies): the website that sent you to us (its name only, not the page), the campaign tags on the link you followed, for example from an advert or a search result, the first page you visited, and a Google Analytics identifier. When you create an account or buy something we link these to your account, so we can see which adverts, searches and websites bring us customers.

Because a will necessarily describes other people, you will give us personal data about your family, beneficiaries and executors. Please only share what is needed, and let them know that their details are held by Willful for this purpose.

We process personal data on the following legal bases:

• Contract performance: to provide the service you have asked for, including preparing your draft, arranging solicitor review, storing your documents and giving access to the people you invite
• Legal obligation: to verify your identity and keep records under anti-money-laundering rules, to keep order and payment records for tax and accounting, and to support the regulatory obligations of the reviewing solicitor
• Legitimate interests: to keep the platform secure, prevent fraud and abuse (including rate limiting and bot protection), keep an audit trail, and understand how the service is used so we can improve it
• Consent: for marketing emails, for analytics cookies, and for recording which advert, search or website brought you to us (you can withdraw any of these at any time)
• Explicit consent (special category data): for the biometric processing carried out during identity verification, given at the point of verification. You may withdraw it by emailing privacy@willful.uk, although we will then be unable to submit your document for review.

The text of your will, LPA or codicil is assembled from your interview answers by Willful’s own clause library: every sentence comes from solicitor-approved wording, chosen and completed according to your answers, and no artificial intelligence writes or alters the document itself. We do use a large language model provided by Anthropic for two things only: to explain your document in plain English, and to check an estate for common problems. The preferences and instructions you write in an LPA reach the solicitor exactly as you wrote them. The model processes only the facts needed for each task, under a data processing agreement, and Anthropic does not use the data to train its models. No decision with legal or similarly significant effect is made about you by automated means alone: every document is read and approved by a named human solicitor before it reaches you, and you can ask that solicitor about any part of it.

We share data with the following third parties, each bound by a data processing agreement or acting as an independent controller as noted:

• The reviewing solicitor: an independent SRA-regulated solicitor, who acts as a data controller for their own professional records
• Supabase: database, authentication and file storage (hosted in the EU)
• Vercel: hosting and content delivery (London region)
• Anthropic: plain-English summaries and estate checks; it never writes or changes your document (see section 4)
• Stripe: payment processing, and Stripe Identity for identity verification (see section 6)
• Resend: transactional email
• Ideal Postcodes: UK address lookup when you type an address
• Upstash: rate limiting, which processes a hashed form of your IP address
• Cloudflare Turnstile: bot protection on sign-in and sign-up, where enabled
• Google Analytics: usage statistics on our marketing pages and, when you buy, the order number, product and amount linked to your Google Analytics identifier, so we can see which visits lead to orders. Only after you accept analytics cookies; your name, email and documents are never sent.
• Certainty, the National Will Register: registration of the existence of your signed will, where that service is available and you have opted in
• CFH Docmail / Royal Mail: printing and posting your documents where included
• People you invite: anyone you grant family access to sees the documents that access covers, and your name

We do not sell personal data, and we do not share it with advertisers. If we advertise on Google, Google Analytics may tell our own Google Ads account which adverts led to orders; that is measurement of our adverts, not sharing your details.

To comply with our legal obligations and those of the reviewing solicitor, you must verify your identity before a document can be submitted for review. We use Stripe Identity (Stripe, Inc.) to do this. The process involves:

• Capturing an image of your identity document (UK passport or photocard driving licence)
• Capturing a live selfie to match against the document
• Automated comparison of the document details with the information you have given us

What we receive: a verification result (verified or not verified), the document type and a Stripe reference. We do not receive, process or store the document images or biometric data on our own systems.

What Stripe holds: Stripe retains the images and biometric data under its own privacy policy and applicable law, for a limited period by default. You can ask Stripe to delete this data at stripe.com/gb/privacy.

Legal basis: your explicit consent (UK GDPR Article 9(2)(a)) given at the point of verification, together with our legal obligations relating to identity checks under anti-money-laundering legislation.

Your data is stored in the UK and the EU. Some of our processors (Anthropic, Stripe, Vercel, Resend, Upstash and Google) are based in the United States or may process data there. Where data leaves the UK we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and where available on the UK Extension to the EU-US Data Privacy Framework.

• Your will, LPA and codicil documents and the record of their review: for as long as your account is open and for at least 7 years after your death is notified to us or your account is closed, whichever is later, because wills may be needed long after they are made and the reviewing solicitor must keep a record of their work
• Identity verification results and the Stripe reference: for the life of your account and 5 years after closure, in line with anti-money-laundering record-keeping rules
• The audit log of actions on your account: 7 years, as part of the tamper-evident record that protects you and the reviewing solicitor
• Vault documents, funeral wishes, ethical will and digital estate map: until you delete them or close your account, subject to the will retention above where they form part of your estate record
• Order and payment records: 6 years after the end of the financial year in which you paid, as tax law requires
• Marketing data linked to your account: for the life of your account, or until you ask us to remove it. The cookie in your browser expires after 90 days.
• Marketing preferences: until you withdraw consent

If you close your account we erase or anonymise personal data not covered by the periods above within 30 days.

You have the right to:

• Access a copy of your personal data (you can export it yourself from Settings)
• Have inaccurate data corrected
• Have data erased, where the law permits
• Restrict or object to processing based on our legitimate interests
• Receive your data in a portable format
• Withdraw consent, including for biometric verification and analytics cookies, at any time
• Not be subject to a decision based solely on automated processing that has legal effect on you (see section 4)

To exercise any right, email privacy@willful.uk. We respond within one month. You may also complain to the Information Commissioner’s Office at ico.org.uk.

Sensitive fields, including your will content, interview answers and the names of your documents, are encrypted at rest with AES-256 in addition to the encryption applied by our hosting providers. Data is encrypted in transit with TLS. Access is controlled by role, staff accounts require two-factor authentication, and a tamper-evident audit log records access to your data and is verified daily. Our infrastructure is reviewed regularly for security issues.

We use strictly necessary cookies to keep you signed in and to remember your preferences on the platform. Cloudflare Turnstile, where enabled on sign-in and sign-up, sets a short-lived cookie to tell people from bots.

Two kinds of cookie are set only if you choose “Accept all” in the cookie banner: Google Analytics cookies (_ga), which measure how our marketing pages are used, and our own willful_attr cookie, which remembers which advert, search or website brought you to us and lasts 90 days. If you choose “Essential only”, neither is set. You can change your choice at any time from “Cookie settings” at the foot of every page; withdrawing removes both cookies. We do not use advertising cookies.

Willful is for adults. We do not knowingly collect data from anyone under 18, other than the names and dates of birth of children you name in your will so that guardians and trusts can be set up correctly.

We will post any changes here with a new date and version number, and email you about changes that materially affect how we use your data.

Data Controller: Willful UK Ltd
Email: privacy@willful.uk