Privacy & Cookie Policy

This privacy policy sets out how WeWill uses and protects any information that you give WeWill and when you use this website.

Last updated: 24th February 2023

  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
    2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
    3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
    4. In this policy, "we", "us" and "our" refer to WeWill. For more information about us, see Section 16.
  2. The personal data that we collect
    1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
    2. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address. The source of the contact data is you.
    3. We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website.
    4. We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, gender, date of birth, relationship status. The source of the profile data is you.
    5. We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you. The source of the customer relationship data is you.
    6. We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
    7. We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
    8. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems.
    9. Please do not supply any other person's personal data to us, unless we prompt you to do so.
  3. Purposes of processing and legal bases
    1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    2. Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
    3. Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
    4. Personalisation - We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
    5. Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
    6. Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
    7. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
    8. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
    9. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    10. Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    11. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
  4. Providing your personal data to others
    1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
    2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
    3. Your personal data held in our website database will be stored on the servers of our hosting services providers identified at Amazon Web Services aws.amazon.com and Heroku heroku.com.
    4. We may disclose your personal data to our partner identified at Macnabs Solicitors macnabs-law.co.uk insofar as reasonably necessary for obtaining expert legal advice via referral.
    5. Financial transactions relating to our website and services are handled by our payment services providers, Stripe stripe.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at stripe.com/en-gb/privacy-center/legal.
    6. We may disclose contact data along with any other personal data contained in enquiries made through our website or services to one or more of those selected third party suppliers of goods and/or services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the personal data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
    7. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  5. Retaining and deleting personal data
    1. This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain your personal data as follows:
      1. contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us, and for a maximum period of 3 years following that date;
      2. account data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 3 years following that date;
      3. customer relationship data will be retained for a minimum period of 1 year following the date of termination of the relevant customer relationship and for a maximum period of 3 years following that date;
      4. usage data will be retained for 5 years following the date of collection.
    4. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  6. Security of personal data
    1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    2. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
    3. The following personal data will be stored by us in encrypted form password(s).
    4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
    5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
    6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
  7. Your rights
    1. In this Section 7, we have listed the rights that you have under data protection law.
    2. Your principal rights under data protection law are:
      1. the right to access - you can ask for copies of your personal data;
      2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure - you can ask us to erase your personal data;
      4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
      5. the right to object to processing - you can object to the processing of your personal data;
      6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
      8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
    4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
  8. Third party websites
    1. Our website includes hyperlinks to, and details of, third party websites.
    2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
  9. Personal data of children
    1. Our website and services are targeted at persons over the age of 18.
    2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
  10. Updating information
    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
  11. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  12. Cookies that we use
    1. We use cookies for the following purposes:
      1. authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website. Cookies used for this purpose are: csrftoken campaign_token;
      2. shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are:
        Cookie Duration Description
        __stripe_mid 90 days Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
      3. personalisation - we use cookies to store information about your preferences and to personalise our website for you. Cookies used for this purpose are: csrftoken campaign_token;
      4. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally. Cookies used for this purpose are: csrftoken;
  13. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting google.com/policies/privacy/partners/ and you can review Google's privacy policy at policies.google.com/privacy. The relevant cookies are:
      Cookie Duration Description
      Google AdServices 2 years Used to distinguish users
      _gid 24 hours Used to distinguish users
      _ga_<container-id> 2 years Used to distinguish users
      _gac_gb_<container-id> 90 days Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
    3. We use Google Ads for marketing purposes to display search results for our website when you search online for the topics or types of services we offer. We do this to create greater awareness of WeWill UK and our services. The cookies stored makes it possible to recognise a visitor when you visit websites belonging to the Google advertising network and track user registrations. You can view How Google uses cookies in advertising at policies.google.com/technologies/ads, manage the Google ads you see and opt out of Ads Personalisation through Google’s Ads Settings at support.google.com/My-Ad-Center-Help/answer/12155451. You can find out more about Google's privacy policy at policies.google.com/privacy. The relevant cookies are:
      Cookie Duration Description
      _ga 2 years Used to distinguish users
      _gid 24 hours Used to distinguish users
      _ga_<container-id> 2 years Used to distinguish users
      _gac_gb_<container-id> 90 days Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
    4. We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website for advertising and analytics. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at facebook.com/policies/cookies/ and the Facebook privacy policy at facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at facebook.com/help/568137493302217.
    5. We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the 'about Hotjar' section help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar. The relevant cookies are:
      Cookie Duration Description
      _hjFirstSeen 30 minutes or more Identifies a new user's first session
      _hjIncludedInSessionSample_{site_id} 2 minutes, extended every 30 seconds Set to determine if a user is included in the data sampling
      _hjSessionUser_{site_id} 365 days Set when a user first lands on a page
      _hjSession_{site_id} 30 minutes or more Holds current session data
      For details of all cookies Hotjar uses, please see the 'Cookies Set by the Hotjar Tracking Code' help.hotjar.com/hc/en-us/articles/6952777582999-Cookies-Set-by-the-Hotjar-Tracking-Code. For further details, please see the 'about Hotjar' section help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar.
    6. We use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the 'about Hotjar' section help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar. The relevant cookies are:
      Cookie Duration Description
      _hjFirstSeen 30 minutes or more Identifies a new user's first session
      _hjIncludedInSessionSample_{site_id} 2 minutes, extended every 30 seconds Set to determine if a user is included in the data sampling
      _hjSessionUser_{site_id} 365 days Set when a user first lands on a page
      _hjSession_{site_id} 30 minutes or more Holds current session data
      For details of all cookies Hotjar uses, please see the 'Cookies Set by the Hotjar Tracking Code' help.hotjar.com/hc/en-us/articles/6952777582999-Cookies-Set-by-the-Hotjar-Tracking-Code. For further details, please see the 'about Hotjar' section help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar.
    7. We use HubSpot in order to better understand our users' journey and to store and process information for marketing, sales and account management. HubSpot is a technology service that helps us manage users' interaction with our website and platform (e.g. how much time they spend on which pages, which links they choose to click, forms, user registration, purchasing, etc.) and this enables us to build and maintain our service. HubSpot uses cookies and other technologies to collect data on our users' behaviour and their devices. These include Analytics cookies and Chatflow cookies. HubSpot stores and processes this information on our behalf. The relevant cookies are:
      Cookie Duration Description
      __hstc 6 months The main cookie for tracking visitors
      hubspotutk 6 months This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts
      __hssc 30 minutes This cookie keeps track of sessions
      __hssrc session Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser
      For further details, please see the HubSpot Knowledgebase page for Cookies set in a visitor's browser by HubSpot. knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser.
    8. We use Cloudflare in order to improve network resources, bot management, manage traffic, and protect our website from malicious traffic. All the Cloudflare cookies listed below are strictly necessary to provide the security features and services and cannot be turned off. The cookies do not correspond to any user information on the website and does not store any personally identifiable information. The relevant cookies are:
      Cookie Duration Description
      __cflb session
      up to 24 hours      		 Cloudflare a unique value on the first visit, then routes future requests to the same origin, optimizing network resource usage
      __cf_bm 30 minutes identifies and mitigates automated traffic to protect from bots
      cf_ob_infocf_use_ob 30 seconds for Cloudflare Always Online handling information between our website and Cloudflare
      cf_clearance unknown Clearance Cookie stores the proof of challenge passed
  14. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. Chrome: support.google.com/chrome/answer/95647;
      2. Firefox: support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop;
      3. Opera: help.opera.com/en/latest/security-and-privacy/;
      4. Internet Explorer: support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
      5. Safari: support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac; and
      6. Edge: support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy.
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our website.
  15. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of significant changes to this policy by email.
  16. Our details
    1. This website is owned and operated by Abstractis Ltd. WeWill is a trading name of Abstractis Ltd
    2. We are registered in England and Wales under registration number 13447190, and our registered office is at 8 Spur Road, Cosham, Portsmouth, Hampshire PO6 3EB.
    3. You can contact us:
      1. by post, to the postal address given above;
      2. by email, using the email address support@wewill.co.uk.
  17. Data protection registration
    1. We are registered as a data controller with the UK Information Commissioner's Office.
    2. Our data protection registration number is ZB247594.

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