Privacy Policy

Noble Wills Limited (賢囑有限公司), a company registered in Hong Kong under company registration number 3025211 located at 2F, Ying Lee Mansion, 323 Hennessy Road, Wanchai, Hong Kong, is committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance") in relation to the collection, use, transfer, retention and storage of personal data. By providing your personal data to us, you are consenting to this Privacy Policy.

The term "personal data" shall have the meaning ascribed to it by the Ordinance.

This policy (together with our terms of service sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Basis for processing personal data

The paragraphs in this section explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.

To enter into and perform contracts with you: Where you ask us to provide services to you, we will process your personal data to provide these services to you. We need certain personal information about you to perform the services for you. If you do not wish to provide us with your personal data in this way, you will be unable to use our services.

To provide services to you: We use several third-party service providers to help us provide services. To do this, we may have to provide some of your information to them and we will only ever do this to the extent necessary to provide services to you and only when we have contractual provisions in place to ensure your information is securely held and not used for any other purpose.

To improve how we provide our services: We analyse personal data to identify areas so that we can improve our services and we sometimes engage third parties to assist us with this analysis. For example, analysing feedback you provide on external review platforms, on our website chat function or in emails and how you interact with our services.

To make our website better: We will also process your personal data to provide you with a more tailored experience when you visit our website. For example, we may use your personal data to tailor our website and make sure it is displayed most effectively for the device you are using. We also use various third-party cookies to help us improve our website (more details are set out in the sections below) but we will not share your personal data with the third-party analytics and search engine providers that assist us in the improvement and optimisation of our website.

We will also process your personal data to make our website more secure, administering our website and internal operations, including troubleshooting, data analysis, testing, research and statistical and survey purposes.

The legal basis on which we process your personal data in these circumstances is our legitimate interest to provide you with the best possible website we can and to ensure that our website is kept secure.

For user research: We have a legitimate interest to contact you in relation to your experience of using our products and services. We will use any feedback provided to tailor and improve our services. We may also conduct research to develop new products and services where input from users' experience would inform our approach.

For NobleWills marketing purposes: We may contact you if your recent activity suggests you might want to hear from us (for example, you entered one of our promotions, you have used our services or you have an annual subscription with us) unless you have already indicated that you do not wish to receive marking communications from us.

We process your personal data to form a view of what services, promotions or offers we think you may be interested in.

Our communications always include a link so you can unsubscribe. You can also remove yourself from our marketing list on the Account page of your Registered Account.

To create anonymised data sets: Anonymised data is information which cannot be used to identify a living person. It is useful for statistical analysis and identifying general trends. We will convert your personal data into an anonymised format so it can be used for press publication (for instance to show the age range of our customers or geographical areas where we provide a high volume of service). Anonymised data is not personal data.

For customised marketing content, insight and analysis: We may use your personal information to generate aggregated, anonymised data for the purposes of internal reporting, customised marketing content, insight and analysis. This will enable us to improve and personalise our Website, the products we offer and search results for our Site. As part of this, we use Google Analytics. For further information, see Google’s Privacy and Terms (https://policies.google.com/technologies/partner-sites).

If our business is sold, we will transfer your personal data to a third party: in the event that we buy or sell any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or if NobleWills or substantially all of its assets are acquired by a third party, in which case personal data held by NobleWills about its customers will be one of the assets transferred to the purchaser.

In each case, the legal basis on which we process your personal data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

Information we collect from you

We will collect and process the following data about you:

Information you give us. This is information about you that you give us by filling in forms on our site https://www.noblewills.com/ and https://wills.noblewills.com/ (collectively and individually our "Website") or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Website, place an order for a product, services and/or memberships on our Website and when you report a problem with our Website. The information you give us may include your name, address, e-mail address and phone number, financial information and other information related to your assets. We do not store credit card details nor do we share financial details with any third parties, unless with your consent to do so.

Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse the Website, you are agreeing to our use of cookies.

"A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. 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 use the following cookies:

Strictly necessary cookies

Purpose: these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

Cookies we use: NobleWills

Analytical/performance cookies

Purpose: they allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it and before they call us. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Cookies we use: Google

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

Do Not Track

We use your 'Do Not Track' status to decide whether to turn on tracking scripts such as affliates, and Google Analytics.

Most browsers let you turn on 'Do Not Track'. Learn how to turn on 'Do Not Track' in your browser.

Uses made of the information

We will combine the information you provide to us with the information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Where we store personal data

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You must not share your password with anyone.

Should you use our Storage Service and choose us to store the physical Products on your behalf, we will store your Products in a safe location, in a fireproof safe with secured lock systems in place.

Period of storage

Where you register on our Website and enter personal data but do not complete the process and create your Products, we will retain your data to for as long as necessary for us to provide the relevant services and for our own legal and administrative purposes.

Due to the nature of the services and pursuant to Article 17(3) GDPR, if you complete a will using our service we will securely store your data indefinitely. This is in order to protect against legal claims, as well as to provide supporting information if your will is ever contested.

Your rights under data protection laws

Right to object

You have the right to object to us processing your personal data where we are processing your personal data: based on our legitimate interests (as set out above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws. If you ask us to stop processing your personal data on this basis, we will stop.

Right of access

You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing.

Right to rectification

You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.

Right to restriction

You have the right to restrict our processing of your personal data where: the accuracy of the personal data is being contested by you; the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased; we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or we are processing your data on the basis of our legitimate interest(as set out above) and you:

• object to our processing on this basis; and

• want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.

Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.

Right to data portability

You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.

Right to erasure

You have the right to request that we erase your personal data which we are processing where at least one of the following grounds applies: the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed; our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data; you object to the processing as set out in the "right to object" section of this policy and we have no overriding legitimate interest for our processing; the personal data have been unlawfully processed; and the erasure is required for compliance with a law to which we are subject.

If you have any concerns or queries relating to the use of your personal data, please let us know in the first instance by contacting [email protected] and we hope to resolve any issue informally.

However, if an issue cannot be resolved, you also have the right to lodge a complaint with the Privacy Commissioner for Personal Data in Hong Kong.

Exercising your rights

You can exercise such rights by contacting us at [email protected]. We may require confirmation of your identity before acting on a request.

Links on our website

Our website may, from time to time, contain links to and from other websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that you have left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy. We will inform you of any significant changes to this policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Co-Founder Brian Michael MacPherson at [email protected].