Xwills.com Ltd Privacy Policy

Last Updated: February 18, 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 only share with third parties (like Zoho Forms or HMRC) where strictly necessary for service delivery.

• 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 at www.ico.org.uk.

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. Cookies & Third-Party Advertising

We use cookies and similar tracking technologies to analyze website traffic and optimize your ad experience.

• Google Ads & Retargeting: We use Google Ads “Remarketing” and “Customer Match” services. This allows us to show relevant ads to users who have previously visited our site when they search on Google or visit other websites.

• Data Shared: This involves sharing pseudonymized identifiers (like a hashed cookie ID) with Google.

• Google’s Role: Google uses this data to show you our ads and to help us measure the performance of our campaigns. You can learn more about how Google uses data here: Google’s Business Data Responsibility Site.

• Your Choice: We only enable these marketing cookies if you click “Accept” on our cookie banner. You can withdraw your consent at any time via the “Cookie Settings” link in our footer.