Xwills.com Ltd Privacy Policy
Last Updated: 7 November 2026
1. Introduction & Our Role
Xwills.com Ltd ("we", "us", or "our") is a "Data Controller" under the UK GDPR. This policy explains how we handle your personal data across our website, QR codes, and legal services. We are committed to transparency and the protection of your privacy in accordance with the Data Protection Act 2018 and the Data (Use and Access) Act 2025.
2. Regulatory & Contact Information
Organisation Name: Xwills.com Ltd
Registered Address: Tilsop Farm, Nash, Ludlow, Shropshire, SY8 3AX
ICO Registration Number: ZB677911
Data Protection Lead: Andrew Walters (info@xwills.com)
3. Data We Collect & Why
We only collect the minimum data necessary for our specific services:
Legal Service Data: Name, address, and contact details for the preparation of Wills, Trusts, and LPAs.
Referral Data: Your name and the name of the person who referred you, specifically to facilitate the £50 referrer reward and client discounts.
Executor & Retrieval Data: When an Executor scans our retrieval card, we collect proof of identity and a Death Certificate. This is used strictly for verification to release secure documents.
Technical Data: IP addresses and device info from QR scans to ensure the security of our retrieval portal.
4. Lawful Basis for Processing
We process data under the following legal grounds:
Contract: To deliver the Will-writing or LPA services you have purchased.
Consent: For referral registrations and marketing communications.
Legitimate Interest: For managing our referral scheme, direct marketing (under the 2025 "Soft Opt-In" rules), and preventing fraud.
Legal Obligation: For HMRC tax records and statutory document retention.
5. Data Sharing & Retention
Sharing: We do not sell your data. We share information with service providers where needed to deliver our services. If you opt into marketing cookies, we also share website event data with Meta as described below.
Retention: Legal documents (Wills/Trusts) are kept indefinitely to ensure they are available when needed. Referral leads are deleted after 6 months if no service is commenced. Financial records are kept for 7 years.
6. Your Legal Rights & Complaints
Under the Data (Use and Access) Act 2025, you have the following rights:
Access & Portability: Request a copy of your data in a machine-readable format.
Erasure & Rectification: Request to have your data deleted or corrected.
New Right to Complain: If you have a concern, email us at info@xwills.com. We will acknowledge your complaint within 30 days and provide a full response without undue delay.
ICO Escalation: You can also complain to the Information Commissioner's Office. You can use the ICO public register search to find registered organisations.
7. Automated Decision Making
We do not use solely automated decision-making processes that have legal or similarly significant effects on you. All referral payouts and legal advice involve human oversight by our expert team.
8. Google Analytics and your choices
We use Google Analytics 4 to understand how this website is used and improve its content and usability. Google Analytics is off unless you allow analytics cookies in the cookie banner or Cookie settings. It measures page use, visits, referral sources and technical device and browser information.
The Google tag uses cookies including _ga and cookies whose names begin _ga_ to distinguish visits and sessions. This website sets the analytics cookie lifetime to 60 days without automatically extending it on each visit. Google Analytics user and event data retention is configured separately within the Analytics account. Advertising storage, advertising user data and advertising personalisation are disabled in this integration, as are Google signals. We do not add remarketing or Customer Match tags.
Manage your choices: select Cookie settings in the footer to turn analytics or marketing cookies on or off separately, or reject all optional cookies. We store your choices in this browser. If you clear browser storage or use a different device, you may need to choose again. Turning analytics off disables collection in that browser and clears accessible Google Analytics cookies for this domain.
Google processes usage information to provide analytics reports and may process information outside the UK. Read how Google uses information from sites that use its services. We do not send enquiry messages, contact details or estate-planning documents through custom analytics events. Website security and enquiry delivery operate separately from analytics. Opting out does not automatically erase previously collected information; contact us about your data rights.
9. Website enquiries and spam protection
Our website enquiry form collects your name, an email address or telephone number, and your message so we can respond. Please do not include sensitive financial or family information in this initial enquiry. Messages are delivered to Xwills using Resend.
Our hosting provider, Vercel, provides BotID protection for enquiry submissions. It uses technical browser and request signals to help distinguish genuine visitors from automated abuse. We use this protection for website security, not marketing. You can contact info@xwills.com or call 0208 064 3806 instead of using the form.
10. Optional Meta marketing cookies
If you allow marketing cookies, we use the Meta Pixel to measure visits from our advertising and build audiences that can see Xwills ads on Facebook and Instagram after visiting this site. The Pixel is off by default and does not load unless you opt in. Declining does not affect the website, enquiry form or booking service.
Meta receives website activity such as the page visited, along with browser and network information and advertising identifiers. The Pixel may set or read cookies such as _fbp and, if applicable, _fbc. We do not send enquiry or booking events, form entries or contact details through the Pixel. Meta explains its processing in its Privacy Policy.
You can withdraw consent at any time in Cookie settings in the footer. Your preference is stored in this browser. Withdrawal stops future Pixel events from this site in this browser and clears accessible Meta cookies set for this site; it does not delete events already received by Meta.