Privacy policy

Willing® is a trading name of 1st Citizen Ltd, a company registered in England and Wales under company registration number 08752437 with registered office is 90 John Bright St, B1 1BN, UK. We affirm our commitment to protecting and respecting your privacy.

For the purposes of data protection laws in the UK, the data controller is 1st Citizen Ltd. We’re registered as a data controller with the Information Commissioner’s Office under number ZA030249.

This privacy policy (together with our terms and conditions) explains why and how we process any personal data we collect from you, or that you provide to us:

Entering into and perform contracts with you: Where you use our tools and/or services, we will process your personal data to provide these tools and/or services to you. We need certain personal information about you for the tools and services to work for you. In case you don’t wish to give your personal data in this way, you will not be able to use our tools and/or services.

Quality assurance and functioning of website, tools, services: We will also process your personal data so we can deliver a tailored experience when you visit or use our website, tools and online services. For instance, tailoring our website, displaying it correctly on your devices, making our website secure, administering our website, tools and online services, internal operations to provide the tools including quality assurance, troubleshooting, data analysis, testing, research and statistical and survey purposes, etc.

We also employ various third-party cookies to help us improve our website, tools and services (details below).

However, we will never share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website, tools and online services.

The legal basis on which we process your personal data therefore is our legitimate interest to provide you with the best possible services, tools and website we can, and to make sure our website, tools and services are secure.

Disclosing your personal data: Given the nature of the services that we deliver, we will at times have to share your personal data with the parties below to provide our tools, products, and services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and in accordance with the law. The third parties that we share data with will be dependant on the nature of the tools and services that we provide to you and examples of our third parties include:

Sub-contractors for the performance of any contracts we enter into with them or you;

Service providers acting as processors who provide IT and system administration tools and services;

Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services;

Finance Brokers;

Estate Administration providers;

Funeral Directors or cremation providers;

Certainty – The National Will Register;

Executors of a will or residuary beneficiaries of the will (as appropriate).
We do not transfer your personal data outside the European Economic Area (EEA).

Change of purpose: We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, then please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

User research: We have a legitimate interest to contact you in relation to your experience of using our products and services. We will use the relevant analysis and feedback to customize and improve our tools, website and services. We may also do research to create new products, tools and services with input from users’ experience informing our methodology.

Marketing: Where you have signed up to receive marketing communications from us, we will process your personal data to deliver these in line with the preferences you have provided.

Where you have signed up for marketing communications from third parties of our choice, we will transfer your personal data to them to enable them to send you such communications.

The legal basis on which we process your personal data for marketing purposes is your consent.

You are not under any obligation to give your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at hello(at) or, where relevant, by clicking unsubscribe link in any marketing communication you receive from us. If you withdraw your consent, this will not be retrospective so our processing of your personal data before that won’t be unlawful.

Anonymised data sets: We will also process your data into an anonymised format where it can be used for case studies, research, and or  press publication (for example to show the age range of our users, geographical areas etc.)

Tracking and attribution of referrals and campaigns from our commercial partners: Where you have been referred to us by one of our commercial partners we will share some basic information relating to you (name and contact details) to enable them to attribute referrals. This will be in addition to your communication preferences and this information will not be used for marketing purposes if you have not given consent for that purpose.

Mergers & Acquisitions and third party licensors: If we buy, license, or sell any business, tools, or assets, in which case we will disclose your personal data to the prospective seller, licensor, or buyer of such business, tools, or assets (at all times in accordance with all applicable data protection laws); or if 1st Citizen Ltd, Willing, or substantially all of our tools, websites, and or assets are acquired by a third party, in which case personal data held by us about our users will be form part of the assets transferred.

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 function, and or can be continued by a purchaser. If you are opposed to our use of your personal data in this way, our tools, services, products and services may not be delivered to you.

Information we collect from you

We will collect and process the following data about you:

  • Information you provide. You provide this information by filling in forms on our websites and tools including, etc., (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 document and/or services 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 and credit card information and other information related to your assets or relating to your involvement in the estate of someone who has died. We do not store credit card details. Your payments are processed by a third party (PayPal) whose terms and privacy policy as their users are independent of ours.
  • Information we collect. 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.


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: Willing

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: Facebook, Google, Mouseflow

Functionality cookies

Purpose: these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Cookies we use: None yet

Targeting cookies

Purpose: these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties in order to make advertising displayed on other websites (such as Facebook) more relevant to your interests.

Cookies we use: Facebook and 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, Facebook, Google Analytics and Mouseflow.

Most browsers let you turn on ‘Do Not Track’

Uses made of the information

We will combine the information you provide to us with 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.

Period of storage

Where you register on our Website and enter personal data but do not complete the process and create your will, we will retain your data for a period of 6 years after to ensure that we are able to assist you should you have any questions or feedback in relation to our services.

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.

Where we have processed your personal data to provide you with marketing communications with your consent, we may contact you at least every 12 months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our list.

Your rights under data protection laws


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; and for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.


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.


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.


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.


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.


You will not have to pay to access your personal data. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. We may also decline to comply with your request in these circumstances.

What we may ask for

We may need to request specific information from you to verify your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Whilst we strive to respond to all legitimate requests within one month, it may sometimes take us longer if your request is particularly complex or if you have made a number of requests in which case we will notify you and keep you updated.


You have the right to require 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.

You also have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.

Exercising your rights

You can exercise such rights by contacting us at hello(at)

Links on our website

Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects you to different websites. If you follow a link to any of these websites or use our service, 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.


Questions, comments and requests regarding this privacy policy are welcomed and should be address to hello(at)

This privacy policy was last updated on 10th June 2018