Privacy Policy

WILLS TRANSFER LIMITED INTERNET PRIVACY POLICY

I. GENERAL

Wills Transfer Limited (“Wills Transfer”) is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable legislation. This internet privacy policy of Wills Transfer(this “Policy”) is a statement of principles and guidelines concerning the protection of the personal information of users (“Users”) of the www.willstransfer.com website (the “Website”). This Policy outlines the types of information that Wills Transfer collects and receives, the circumstances in which it is collected or received, and explains the procedures established by Wills Transfer for its storage, use and in some cases, disclosure.

The User’s access and use of the Websiteare subject to Wills Transfer’s Terms of Use (the “Terms”), also available on the Website.

II. INFORMATION COLLECTED

Wills Transfer collects information, some of which may constitute personal information, through a variety of means, including:

• directly from Users, including without limitation, when a User uses or visits the Website, contacts Wills Transfer, or requests information
• from data that is input by a User or otherwise posted to the Website;
• automatically from devices through which Users access the Website.

Given the customer base and business of Wills Transfer, Wills Transfer doesnot generally collect personal information from Users. Notwithstanding the foregoing, it is possible that the following information will be collected should the User provide it:

• name, telephone number, email address and similar identifying information; and
• “cookies” which enables Wills Transfer to remember and process a User’s requests on the Website (see Wills Transfer’s Cookies Policy, available on the Website).

III. USE OF INFORMATION COLLECTED

As stated above, Wills does not generally collect, use and disclose Users’ personal information.  Where it does, it is for the following purposes:

• to manage and track leads provided by customers
• to verify and authenticate information;
• to provide services and operate its business;
• to respond to customer requests, concerns and complaints, including customer service requests;
• to establish and manage customer relationships and provide notifications to customers and the User.
• to bill its customers;
• to disclose to third-party business partners for the purpose of providing third-party services that are integrated with Wills Transfer’s own services;
• to manage and track leads provided by customers;
• to detect and protect Wills Transfer and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with Wills Transfer’s policies and contractual obligations; and
• to respond to customer requests, concerns and complaints, including customer service requests.

IV. CONSENT

BY SUBMITTING PERSONAL INFORMATION ON OR THROUGH THE WEBSITE, THE USER AGREES THAT WILLS TRANSFER MAY COLLECT, USE, AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS INTERNET PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, the User may refuse or withdraw his or her consent to certain of the identified purposes at any time by contacting Wills Transfer’s privacy officer using the contact information provided below. If the User refuses or withdrawshis or her consent, Wills Transfer may not be able to provide the User’s organization or continue to provide the User’s organization with certain services or information which may be of value to the organization. If the User providesWills Transfer or its service providers or agents with personal information of another individual, the User represents that he or she has all necessary authority and/or has obtained all necessary consents from such person to enable Wills Transfer to collect, use and disclose such personal information for the purposes set forth in this Policy.

V. DISCLOSURE OF INFORMATION

Should a User have provided personal information, Wills Transfer may disclose it in the following circumstances:

• internally, within the enterprise;
• to a person who, in the reasonable judgment of Wills Transfer, is providing or seeking the information as the agent of one or more of its customers;
• to any third party or parties, where the right to make such disclosure has been obtained from the User or where such disclosure is required or permitted by law; and
• for any legitimate business purpose, provided that the personal information is aggregated and anonymized.

Wills Transferdoes not sell or license to third partiesany information collected from Users. In the event thatWills Transfer is acquired by or amalgamated with another company such information may form part of the transaction, in which case Wills Transfer will transfer such information to the acquiring or amalgamating entity with the other business assets being transferred.  Users are deemed to have consented to such transfer.

VI. STORAGE AND SECURITY

All personal information collected by Wills Transfer is stored in secure locations and on servers located at the facilities of its service providers.

To help protect the confidentiality of Users’ information, Wills Transfer employs industry standard administrative and technological safeguards to protect such information, including operating secure data networks protected by industry standard firewall and password protection systems.

A User may access, correct, amend, or delete any personal information that Wills Transfer has about the User by contacting Wills Transfer’s privacy officer at the following email address [] or by mail at cmearns@willstransfer.com. Please note that Wills Transfer may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backed up copies as required pursuant to records retention obligations, or as otherwise required by law.

VII. CHANGES TO THIS POLICY

Wills Transfer reserves the right to modify or supplement this Policy at any time. If changes are made to this Policy, Wills Transfer will post such changes to the Website and make such revised Policy and changes available upon request made to Wills Transfer’s privacy officer. Should Wills Transfer seek to collect, use or disclose the personal information of any User for purposes other than those for which consent has been obtained (unless otherwise required or permitted by law), Wills Transfer will obtain the necessary consents required under applicable privacy laws.

VIII. FURTHER INFORMATION

Wills Transfer has appointed Craig Mearns as its privacy officer to oversee compliance with this Policy and applicable privacy laws. For additional information on this Policy or other privacy policies of Wills Transfer please contact cmearns@willstransfer.com ‍‍