Family Wise Ltd is committed to protecting your data and respecting your privacy.
Family Wise Ltd are a probate and genealogy research company; therefore, we collect personal data to be able to provide our services in terms of tracing heirs in estates, locating and reuniting people, and researching your family history when you have asked us to.
We collect information about you, such as your contact details, certificates of life events, identity data, customer data, family history, financial data, marketing data and data about how you use our website. We don’t process any special category data about you. We don’t proactively collect data about anyone under the age of 18.
We collect personal information that you provide to us, that is publicly available, automatically through our website, or from other organisations; when you have given them your consent to share your information.
Family Wise Ltd process personal information to provide, improve and administer our services, to communicate with you, for security and fraud prevention, and to comply with the law. We rely on our contractual obligations, legitimate interests, your consent, and our legal obligations to process personal information.
Family Wise Ltd have put measures in place to protect the security of your personal information.
- Our responsibilities.
- Your responsibilities.
- Contact details.
- The information we collect.
- Special category data.
- Children’s data.
- How do we gather your information?
- How we use your information.
- Here is what each Lawful Basis means.
- Do we share your personal information?
- International transfers.
- Links from other websites.
- Social media.
- How do we store your data and keep it secure?
- Your rights.
- Data retention.
- Questions and complaints.
When we are processing personal data, Family Wise Ltd acts as the ‘data controller’ and is responsible for your personal data. This means we determine how and why your data is processed. We are registered as a data controller with the Information Commissioner’s Office (ICO) under number ZA069854.
There isn’t much that you have to do, we ask that you:
- If you are our client, please also check the contracts between us: they may contain further details on how we collect and process your data.
There are many ways in which you can contact us, including by phone, email, and post. Our full contact details are:
Full name of legal entity: Family Wise Ltd
Data Protection Manager: Kirsty Gray
Email address: email@example.com
Telephone number: 01249 476777
Postal Address: 19 High Street, Calne, England, SN11 0BS
We may collect the following categories of information about you:
- Contact Details – including your name, email address, telephone number, billing address, delivery address;
- Publicly available certificates of life events;
- Financial Information – including your bank account number and sort code;
- Customer Data – including information about any goods and/or services you have purchased from us and your payment history;
- Marketing Data – including your preferences in receiving marketing from us and our third parties and your communication preferences;
- Data to confirm your identity – if you become our client, we will also need data to confirm your identity, this will be explained to you and detailed in our letter of engagements.
- Data about how you use Family Wise – your URL clickstreams (the path you take through our site), products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, the number of times you visit our pages and other actions; and
- Data that identifies you – including your IP address, browser type and version, time zone setting and location. The source of this data is from our analytics tracking system.
You do not have to provide us with this information, however, without certain information, we may not be able to provide you with our services, for example, we will be unable to respond to any queries that you have if we do not have your contact information.
We do not collect any special category data from users of our website or clients, except when we have your explicit consent, or when we must collect it to comply with the law. Special category data is also known as “sensitive data” (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sex life or sexual orientations, and offences or alleged offences).
Family Wise do not provide services to, or proactively collect any personal information from, any person under the age of 18. In certain circumstances, with the person with parental responsibilities consent, we may, at their request, add children’s details to their family tree binder.
We your collect personal information in the following ways:
Directly, when you:
- provide your information when interacting with us by phone, email, or post;
- have made an enquiry to us;
- subscribe to our newsletter or to receive marketing communications; or
- fill out the contact form on our website;
- when you give permission to other organisations to share it;
- where the information is publicly available, such as registers of birth, marriages, or civil partnerships;
- through third parties, such as analytics providers like Google and Facebook.
Data protection law means that we can only use your data for certain reasons and where we have a lawful basis to do so. Here are the reasons for which we process your data:
- To deliver our service – When you enter into a contract with us for goods or services, we need to process your personal information so that we can provide this to you. Our lawful basis is for the performance of a contract.
- Keeping Family Wise Ltd running – As a probate and genealogy company, we need to process personal information to be able to find and contact potential beneficiaries. Sometimes this involves tracing an individual named on a Will, or where a person has died and not left a Will, we will research their family history to enable us to find their next-of-kin. We also need to audit and administer our accounts. Our lawful basis is for our legitimate interests.
- Improving Family Wise Ltd – We want to ensure that content from our site is presented in the most effective manner for you and your computer/device. We also need your personal information to deal with enquires and complaints made by or about you regarding our business. Our lawful basis is for our legitimate interests.
- Marketing Purposes – We like to keep you updated on any services we feel may be of interest to you. Our lawful basis is consent and legitimate interests.
- To comply with the law – Sometimes we need to process data to comply with the law. Our lawful basis is a legal obligation.
Contract – Processing your data is necessary for a contract that you have with us, or because we have asked you to take specific steps before entering into that contract.
Consent – You have given us your consent to process your data for a specific purpose. Remember you can change your mind and withdraw your consent at any time. You can do this by emailing us at firstname.lastname@example.org. Note: under the Privacy and Electronic Communications Regulation (PECR), if you have engaged with us previously (i.e., purchased services, or expressed interest in purchasing services) then we may send you relevant marketing information, unless you opted out of receiving it. All communication will contain an opt-out option. This regulation is not superseded by GDPR but works in tandem with it. For more information, please see What are PECR? | ICO
Legitimate Interest – The main purpose of Family Wise Ltd is to undertake genealogical and probate research. Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities. Our legitimate interests are:
- Tracing individuals named on a Will, that have not been found;
- Researching the family history of an individual who has died intestate;
- Locating individuals subject to formal evidential instruction;
- Contacting you about services we feel may interest you, relevant news stories or blogs;
- Responding to enquiries;
- Delivering products, services or information that have been requested;
- Maintaining a database of clients and enquirers;
- Gaining insights from your behaviour on our website;
- Processing financial transactions and maintaining financial controls;
- Enforcement of legal claims; and
- Reporting criminal acts and compliance with law enforcement agencies.
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
For the purposes of fulfilling our services detailed in the Family Wise Ltd Letter of Agreement, we may sometimes need to share your personal information with other organisations involved in the dealing with the estate. This will vary depending on the circumstances of the case, but each one will have been deemed necessary, and can include the Government Legal Department, asset holders and custodians, councils, banks and building societies, solicitors, and the organisations administrating the estate.
Family Wise Ltd, like most companies, sometimes need to use third parties to help their business run. We have detailed other circumstances in which we may share your personal information below:
- Accountants – we share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts; and
- Third party service providers – we share information for our legitimate business purposes. For example, we share email addresses and marketing preferences with our email marketing provider, and we use a cloud-based CRM solution to manage customer records.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We do not routinely transfer your data outside of the EU. However, with your consent, we do use Google Analytics. Google uses the information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis.
To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: How Google uses information from sites or apps that use our services – Privacy & Terms – Google
We operate on the following social media platforms:
- Facebook (Meta Platforms Ireland Ltd). You can see their privacy information here.
- Twitter (Twitter, Inc). You can see their privacy information here.
- Instagram (Meta Platforms Ireland Ltd. You can see their privacy information here.
When you visit our social media pages, data is also processed by the social media platform, so we suggest that you also familiarise yourself with the privacy information of that platform.
What are ‘Cookies’?
Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
We are required to obtain your consent for all non-essential cookies used on our website.
What type of Cookies do we use?
The cookies we use are either:
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any personal data from your computer; or
- Persistent cookies: a persistent cookie is stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
We use both first and third party cookies. First party cookies are cookies set by our website. Third party cookies are cookies on our website that are set by a website other than our website, such as where we have adverts on our website or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the social media sites including Facebook, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
We also use Google Analytics to collect data about website usage. These cookies are collected in a way that does not directly identify anyone. Further information about googles privacy and safeguards can be found here: Safeguarding your data – Analytics Help (google.com).
We use the following categories of cookies:
- Necessary: these cookies are essential for you to be able to use the website effectively.
- Preferences: these cookies allow the website to remember choices you have made in the past, like what language you prefer, and provide enhanced features.
- Performance: these cookies allow for the services to be optimised, to give you the best possible experience.
- Advertising/Marketing: these cookies help us provide our visitors with relevant advertisements and marketing campaigns.
- Analytics: these cookies collect information about how you use the website, like which pages you visited, and which links you clicked on. They allow us to monitor and improve the performance of the website.
How can I change my cookie settings?
Most web browsers allow you to control cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.allaboutcookies.org or www.aboutcookies.org.
You can opt out of being tracked by Google Analytics across all websites, by going to http://tools.google.com/dlpage/gaoptout
You can find more information about the individual cookies we use and the purposes for which we use them, by selecting “Manage Cookies” in the cookie consent mechanism. The information is regularly updated using our consent mechanism.
We use physical, electronic, and managerial procedures to safeguard and secure the information that we process. Most of the information that we hold about you will be stored electronically and is stored in the European Economic Area (EEA). Physical documents containing personal information are stored at our office in Calne. We have security measures in place to protect this data.
Examples of our security include:
- securely storing electronic information with appropriate encryption or security controls where required, both at rest and in transit;
- carrying out processing in accordance with our policies and risk assessments;
- regular testing of our technologies and ways of working including keeping up to date on the latest security updates; and
- controlling access to systems and networks so that only those people who need to and are allowed to see your personal information are able to access it.
Please remember that when you provide us your personal information, you do so at your own risk. Unfortunately, no data is guaranteed to be 100% secure.
Where we rely on your consent to use your personal information, you have the right to object and withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time.
You also have the following rights:
- the right to be informed – you have the right to be told how your personal information will be used. This statement and other policy statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used;
- the right of access – you can ask for any of the information we have about you. This is also called a ‘Subject Access Request’. Provided we are satisfied that you are entitled see the information requested and we have successfully confirmed your identity, we have one calendar month to comply;
- the right of erasure – also known as the right to be forgotten. Under certain circumstances you can ask us for your personal information to be deleted from our records;
- the right of rectification – if you believe our records of your personal information are inaccurate you have the right to ask for those records to be updated;
- the right to restrict processing – you have the right to ask for processing of your data to be restricted if there is disagreement about its accuracy or legitimate usage; and
- the right to data portability – where we are processing your personal information with your consent, because such processing is necessary for the performance of a contract (or enable us to take steps, at your request, prior to entering into a contract) AND that processing is taking place by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
To exercise these rights, please contact us using the contact details below. Where we consider that the information provided does not enable us to identify the personal information in question, we may ask for personal identification and/or further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance – Individual rights | ICO – or please contact us using the details below.
Personal data is held for only as long as is required for the purpose we collected it or for our legitimate interest purposes.
Genealogical research is of lasting historical value to our business and to the beneficiaries, so we retain our records of research cases, such as family trees and copies of certificates as a permanent archival record. We will always ‘weed out’ out non necessary information and securely delete or destroy this.
With regards to client files, following conclusion of the work we are retained to do, we will electronically scan paper documents, and retain electronic copies of documents relating to the file for up to 7 years, unless otherwise required by law. However, if before that date:
- your personal information is no longer required in connection with such purpose(s);
- we are no longer lawfully entitled to process it; or
- you validly exercise your right of erasure
then we will remove it from our records as soon as is practicable.
Should you ask us to stop sending your direct marketing or other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
This policy was last updated on 01/08/2023.
If you have any questions, you can contact our Data Protection Manager, Kirsty Gray:
Family Wise Ltd
19 High Street
If you feel that after contacting us, that we are not acting appropriately with respect to our data privacy, you have the right to contact the governing body. In the UK this is the ICO, the Information Commissioner’s Office, their web pages for handling issues are at:
Or you can contact them by post, telephone, or email:
Information Commissioner’s Office
Telephone: 0303 123 1113