Privacy Policy

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Table of Contents

**PRIVACY POLICY **

**Introduction **

  1. At WillCraft, your privacy is of our utmost concern. This privacy policy sets out the basis which WillCraft (“we”, “us” or “our”) will collect, use, disclose or otherwise process your personal data (as defined below) when you use our products, services, technologies or functionalities offered by us on our website https://willcraftnow.com (“Website”) and any site hosted at any related subdomain of the same (including but not limited to the site/application hosted at willcraft.netlify.com) or engage us in other ways (collectively called “Services”).
  2. The purpose of this policy is to detail our approach in ensuring the protection of your personal data and the continued handling of your personal data in compliance with the Singapore Personal Data Protection Act 2012 (“PDPA”).
  3. This privacy policy applies to personal data in our possession or under our control including personal data which we have obtained from third party organisations which we have engaged to collect, use, disclose or process personal data for the purpose of providing Services .
  4. By continuing your interaction with us, such as using our website, submitting information to us or using our Services, you confirm that you understand and consent to the collection, use, disclosure and processing of your personal information (or the personal information of any individual you are authorised to provide).

What is Personal Data?

  1. Personal Data is defined as data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access to (“Personal Data”).
  2. Depending on your interaction with us, some examples of Personal Data we may collect from you include: -
    • Full names;
    • Identification documents, such as NRICs, passports, birth certificates, work permits or foreign identification card;
    • Gender;
    • Marital status;
    • Religion;
    • Residential addresses; and
    • Contact information such as telephone numbers and email addresses.
  3. We may also be required to collect information relating to:
    • your spouse and/or children;
    • your assets and liabilities such as bank statements;
    • your insurance policies;
    • your properties; or
    • such other information which may be necessary for us to provide you with Services.
  4. In circumstances where you have provided Personal Data relating to other individuals (including but limited to your family members, friends and companies), you represent and warrant that you are authorised to provide their Personal Data to WillCraft and you have obtained their consent for their Personal Data to be processed and used in the manner as set forth in this Privacy Agreement.
  5. We receive and store such Personal Data.

How Personal Data may be provided to us?

  1. Personal Data may be provided when you: -
    • visit our premises in person and engage our Services;
    • communicate with us via email, telephone or any other form of communication;
    • use our Services - this includes details provided by you when you sign up for an account, information entered by you into our Drafting Interface and any other information which you provide us in order to generate a Draft Will when using our Will Drafting Service, or information relating to the Personal Data you provide (such as the date of entry of Personal Data).
    • access our Services through your system/device - we may obtain information about the devices that are used by you, such as your device type, operating system, browser type and IP address. We may also obtain information or data that is uploaded, synced or imported from your device (for example, your personal contacts).
    • make payment for our services - your payment information including bank account numbers, credit card or debit card information will be provided to us.
  2. All Personal Data provided by you must be true, complete and accurate. You must immediately notify us of any changes to any Personal Data.
  3. You may decline to provide us with your Personal Data. However, if you choose to not provide us with such Personal Data as we require, we will not be able to provide our Services to you.

How we collect, use or disclose your Personal Data

  1. Depending on your interactions with us, we may collect and use your Personal Data for any or all of the following purposes: -
    • Verifying your identity pursuant to our KYC/AML requirements;
    • Performing obligations in the course of or in connection with our Services as requested by you, including processing the information provided by you on the WillCraft platform and the generation of your draft Will;
    • Provide, activate and manage your access and use of our Service;
    • Provide technical, product and other support and to help keep our Services working, safe and secure
    • Responding to, handling and processing queries, requests, applications, complaints and feedback from you;
    • Managing your relationship with us;
    • Processing payment or credit transactions;
    • Complying with applicable laws, regulations, codes of practice, guidelines, rules or to assist law enforcement and investigations conducted by any government and/or any regulatory authority;
    • Sending emails, newsletters and other communications to keep you informed with developments, insights and other services;
    • Identifying usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, comprising of but not limited to determining the effectiveness of our promotional campaigns and evaluating our business performance;
    • Transmitting to any unaffiliated third parties including third party service providers and agents, and relevant governmental and/or regulatory authorities;
    • Any other purpose for which you have provided the Personal Data; and
    • Any other incidental business purpose related to or in connection with the above.
  2. We may disclose your Personal Data:
    • where we believe in good faith that such disclosure is necessary;
    • to facilitate payment processing, support technology or infrastructure, cloud storage, and perform audits;
    • where such disclosure is necessary for performing obligations in the course or in connection with our Services as requested by you;
    • to meet any obligations pursuant to any applicable law, regulation, legal process or other legal obligation;
    • to detect, investigate and help prevent security, fraud or technical issues;
    • to protect the rights, property and safety of WillCraft, our users, employees or others; and/or
    • as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.

**Links to Third Party Websites **

  1. We may provide links to websites that are owned or operated by other third parties (“third-party websites”). When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarise yourself with the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.

**Managing your information **

  1. We retain your Personal Data for as long as necessary to provide our Services and fulfil the transactions you have requested, or for essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting fraud and abuse and enforcing our agreements.
  2. We will take all reasonable steps to ensure that your Personal Data will be destroyed, permanently deleted or anonymised if it is no longer required for the above purposes.

Access and updating of Personal Data

  1. You may request access to any Personal Data we hold about you at any time. Please contact us directly. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it. We may charge you a fee to cover our administrative and other reasonable costs in providing such information to you.
  2. In some instances, we cannot grant you access to Personal Data that we hold. For example, we may refuse access if granting such access would interfere with the privacy of others or it would result in a breach of confidentiality. In such instances, we will give you written reasons for such refusal.
  3. You may request to correct or update your Personal Data. Please contact us directly.

**Withdrawal of consent **

  1. You may withdraw your consent previously given. Please contact us directly.
  2. All requests to have personal information removed from our databases or physical storage facilities will be entertained and performed within our reasonable abilities.
  3. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.

Tracking technologies

  1. The site uses tracking technologies on our Website. These enable us to understand how you use our Website which, in turn, helps us to provide and improve them. However, the tracking technologies do not access, receive or collect information which can be used to identify you.
  2. The site uses “cookies”. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Website, estimate and report our Website’s total audience size and traffic, and conduct research to improve our Website. You can configure your device’s settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Website.

**Data security **

  1. We keep your Personal Data for as long as necessary to provide our Services unless otherwise required by law. We maintain control of your Personal Data and protect your Personal Data using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.
  2. We have procedures in place to manage any suspected breach of your Personal Data and will notify you and any applicable governmental authority of any actual or suspected breaches of your Personal Data where we are required by contract or law to do so.
  3. While no method of transmission over the Internet or method of electronic storage is completely secure, we endeavour to ensure the protection of your Personal Data. We are constantly reviewing and enhancing our data security measures.

**Changes to our Privacy Policy **

  1. We reserve the right to update this Privacy Policy without any prior notice. You may determine if any such revision has taken place by referring to the date on which this policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.

Data Protection Officer

  1. Any complaints, enquiries or feedback regarding your personal data or this Privacy Policy should be addressed to our Data Protection Officer at [email].

**Disclaimer **

  1. To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your Personal Data.

Governing Law

  1. This Privacy Policy is governed by the laws of Singapore. In the event of any dispute arising from this Privacy Policy, you must first contact our Data Protection Officer regarding your concern and use your best endeavours to amicably resolve any dispute in good faith. If no amicable resolution is reached within thirty (30) days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

Last updated: [date]

2024-02-28T12:35:31+08:00