Kinwise Ltd · kinwise.co.uk
Last updated: 5 April 2025 — Version 1.0
1. Who We Are
Kinwise Ltd (“Kinwise”, “we”, “us”, “our”) operates the estate planning platform available at kinwise.co.uk. We provide online will-writing, Lasting Power of Attorney (LPA) preparation, and related estate planning services.
For the purposes of UK data protection law, Kinwise Ltd is the data controller responsible for your personal data.
Contact details:
2. What Personal Data We Collect
2.1 Data you provide directly
- Full name, date of birth, address, and contact details
- Details of your beneficiaries, executors, attorneys, and other named individuals (including third-party personal data you supply on their behalf)
- Financial and property information relevant to your will or LPA
- Payment information — processed securely by our payment provider; we do not store full card details
- Identity verification documents where required
- Communications with us (email, support chat)
2.2 Data collected automatically
- IP address, browser type, device type, operating system
- Pages visited, time on site, referral source (via cookies and analytics)
- Session and authentication data
2.3 Data from third parties
- Identity verification providers (e.g. address lookup services)
- Payment processors confirming transaction status
3. Legal Basis for Processing
We process your personal data under the following legal bases (UK GDPR Article 6):
- Contract: To fulfil your order and deliver our services.
- Legal obligation: To comply with our regulatory and legal duties.
- Legitimate interests: To operate and improve our platform, prevent fraud, and communicate with you — where these interests are not overridden by your rights.
- Consent: For non-essential cookies and marketing communications (you may withdraw consent at any time).
Where we process special category data (such as health information relevant to an LPA), we rely on your explicit consent (Article 9(2)(a)) or, where applicable, the substantial public interest condition.
4. How We Use Your Data
- To create and deliver your will, LPA, or other estate planning documents
- To manage your account and customer portal
- To process payments and send receipts
- To communicate with you about your order, including status updates
- To comply with anti-money laundering and identity verification requirements
- To improve and develop our services through aggregated, anonymised analytics
- To send you service-related communications and, with your consent, marketing emails
- To detect and prevent fraud and abuse of our platform
5. Who We Share Your Data With
We do not sell your personal data. We share it only as necessary with:
- Service providers: hosting, email delivery, payment processing, identity verification, and document generation — all operating under data processing agreements
- Professional advisers: solicitors or will-writing professionals involved in reviewing or certifying your documents
- Regulatory and legal authorities: where required by law or court order
- Business successors: in the event of a merger, acquisition, or sale of assets, with appropriate safeguards
All third parties are required to handle your data securely and only for the purposes we specify.
6. International Data Transfers
Some of our service providers may process data outside the UK or EEA. Where this occurs, we ensure appropriate safeguards are in place — such as UK adequacy regulations, Standard Contractual Clauses, or equivalent protections — in accordance with UK GDPR requirements.
7. How Long We Keep Your Data
- Account and document data: retained for the duration of your account plus 7 years
- Completed will and LPA documents: retained for a minimum of 7 years after execution
- Marketing preferences: until you withdraw consent or request deletion
- Anonymous analytics data: retained indefinitely in aggregated form
When data is no longer required, it is securely deleted or anonymised.
8. Cookies
We use cookies and similar technologies to operate our platform and understand how it is used. These include:
- Essential cookies: required for the platform to function (e.g. authentication, session management)
- Analytics cookies: to understand traffic and usage patterns
- Marketing cookies: only with your explicit consent
You can manage your cookie preferences at any time via our cookie banner or browser settings. Withdrawing consent for non-essential cookies will not affect your ability to use the platform.
9. Your Rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access: to receive a copy of the data we hold about you
- Right to rectification: to have inaccurate data corrected
- Right to erasure: to request deletion of your data (subject to legal retention obligations)
- Right to restriction: to limit how we process your data in certain circumstances
- Right to data portability: to receive your data in a structured, machine-readable format
- Right to object: to processing based on legitimate interests or for direct marketing
- Rights related to automated decision-making: we do not make solely automated decisions with significant legal effects
To exercise any of these rights, please contact us at privacy@kinwise.co.uk. We will respond within one calendar month. You will not be charged for making a request.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.
10. Security
We take the security of your data seriously. We implement appropriate technical and organisational measures including:
- Encryption of data in transit (TLS) and at rest
- Access controls limiting data access to authorised personnel only
- Regular security reviews of our systems and third-party providers
In the event of a data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform affected individuals without undue delay.
11. Third-Party Personal Data
When you use Kinwise, you may provide us with personal data about other individuals — for example, your beneficiaries, executors, or attorneys. You are responsible for ensuring those individuals are aware their data is being shared with us and that you have a lawful basis to do so. Our privacy notice is available at kinwise.co.uk/privacy.
12. Children
Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from children under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.
13. Changes to This Policy
We may update this privacy policy from time to time. The current version will always be available at kinwise.co.uk/privacy, with the effective date shown at the top. Where changes are material, we will notify you by email or via a notice on the platform.
14. Contact Us
If you have any questions about this policy or how we handle your data:
If you are unhappy with our response, you have the right to complain to the ICO at ico.org.uk.