SECURITY

Privacy Policy

Updated September 18, 2023

1. Introduction
Your privacy is important to us.   Trust & Will strives to ensure your information is secure and handled appropriately and in line with this policy.  This privacy policy is intended to let you know how we collect, use, disclose and process your data.  This policy covers your use of the Trust & Will website, products, and services as well as our customer service features, including phone calls and chats.

When you use our website, you may provide us with personally identifiable information, or “Personal Information”.  “Personal Information” refers to information about you that can be used to contact or identify you.  Data collected on the Trust & Will site that relates to Personal Information is referred to as “Personal Data” in this policy.

This Privacy Policy is incorporated into our Terms of Service and governs your use of Trust & Will’s services.  If you have any questions about this policy or any other aspect of Trust & Will’s policies and services, please contact us at hello@trustandwill.com

2. Application

A. If you are using our site and services, this policy applies to you.  If you disagree with any aspect of this policy, please do not use our site, products or services.

B. Our Responsibilities: To protect your data, to honor your requests related to permissible limitations regarding the use of your Personal Data, to ensure you have the information you need to understand our use of your Personal Data, and to ensure you understand how to exercise your privacy rights.

C. Your Responsibilities: Read this privacy policy, as well as our corresponding security policy and terms of service.  Confirm that your use of our services indicates that you understand our policies and agree to the terms they describe.

3. When we collect data

A. We collect Personal Information from you when you submit it into our forms and questionnaires.  We may also collect additional Personal Information you provide by interacting with technical or customer support via chat or phone, and when you opt into our marketing emails and messages.  We record chats and phone calls for quality assurance and legal purposes.  Our servers also automatically record information that your browser sends whenever you visit our website.  We also may receive information about you from our marketing partners, when they provide the information to us, and from social media websites if you use the social media function to log into our website.

4. Types of data we collect- We collect the following types of data.  We collect and retain your data only long enough to complete the business activities and purpose for which you provided the data.

A. Basic identifying information-like your name, address, telephone number, username, and email address.

B. Government issued identifiers- such as your drivers license, passport number, or other issued government identification

C. Financial information-like your account number, credit card or other billing information, account balance when linked through a secure third party, the account type, institution and ownership information.

D. Device  information and unique identifiers- like your IP address, login information, login or account information you submit into your estate plan, browser type, time zone, general geolocation data that we collect and that you provide when you sign up, when you sign in, and how you interact with marketing messages.

E. Geolocation Data-  information that relates to your location, or the location from which you access our site.

F. Purchase information- like which of our products or services you have purchased 

G. Sensitive data-this data is defined as any Personal Information that reveals an individual’s government issued identification, finances, precise geolocation, race, religion, union membership, private communications, genetics, biometrics, health, or sexual orientation.  We use your sensitive data only as reasonably necessary to provide the services, and in a manner limited to the business purpose for which the sensitive data was collected.

If the documents you upload via the the document upload feature contain sensitive information, we will store that data on your behalf, inline with the purpose and function of the document upload feature,  but for no other purpose.  If that changes, we will update this policy and give you prior notice and a direct opportunity to opt out of any share of sensitive information.

H. Audio and Visual Information- We record your voice when you call in for support regarding our products and services. We also capture your interaction with our websites via screen recording software from FullStory.

I. Data on how you use Trust & Will- We may collect information about how you interact with Trust & Will’s website–including how you interact with specific web pages– to improve your user experience, to track page response times and download errors.

J. Data you share about someone else- When you share the contact information of someone else through our shared access functions or within your estate plan documents, you assert that you have obtained that person’s consent to share their Personal Information with Trust & Will.  Please do not share the Personal Information of anyone without their consent or permission.   We use information you’ve shared on behalf of someone else in accordance with this policy.

5. Types of data we DO NOT collect

A. Children’s data- our services are intended for use only by those who are over 18 years of age.  We do not target Trust & Will to children, and we do not knowingly collect, share, or sell any Personal Data from any person under the age of 18.  Our documents allow for you to enter information regarding your dependent children, but we don’t collect that information without your direct consent to do so.  We restrict use of any data you submit regarding your minor children to the specific business purpose of helping you create your estate plan.

B. Data belonging to citizens of the European Union- Our services and products are designed, developed, and intended for use by adults in the United States.  We do not intentionally or knowingly collect any data from any person who is a citizen or resident of the European Union.

6. Why we use your data

A. We follow data protection laws to ensure that your data is only used where legally permitted.  Specifically, we use your data for the following purposes:

I. To provide you with a seamless and easy user experience; we use the data you provide, including Personal Information,  to assemble and deliver your personalized estate planning documents. We securely store the documents you upload using the document upload feature.  We also use site metrics and data about your use of the website to make sure the process runs smoothly, to ensure your information is always secure, to process payments, and to maintain the back-end of our site.

II. We use identifying data including Personal Information to verify your identity and carry out the requests you make throughout your use of  the website or our Services.

III. We use identifying data to notify the people you choose about your estate plan. (This is the “Shared Access” feature, which only shares your estate plan with your direct consent, to an email address you choose.)

IV. Marketing purposes, when you opt into receiving marketing emails and never after you have unsubscribed.  We use identifying data like your email address and first and last name to send customized marketing messages to you.

V. Member Support- when you need help with our products and services, our member success team may look at the information provided by you and captured by our systems to make sure that you get the answers you are looking for, and to solve any problems you encounter.

VI. If you sign up through one of our affiliates, or entities that use online referral links to send users to our site and services, we may share identifying information with the affiliate or entity.  Such information is limited to your name, email address, and the type of estate plan you purchase.  If you’d prefer we not share information with affiliates, please send your request to opt out of affiliate information sharing to optout@trustandwill.com.

7. How we disclose your information -We disclose your personal information in the following circumstances

A. Service Providers. We work with third parties to ensure we can deliver on the promises we make, such as printing and mailing off your estate planning documents, facilitating filing of legal documents at your direction, or by connecting you with an attorney if you’ve purchased a form of attorney support and performing the services we’ve agreed to via the support of other similar service providers. We limit the information we share to only that which is  necessary to fulfill our service obligation to you, and deliver the products and services you purchase on our website.

B. Site improvements and efficiency- We  engage third parties to assist us in operating our website, conducting and improving our business, and providing service to you.  In some cases, we may provide a third party with access to your Personal Information as necessary to perform a specific task as it relates to the purpose and function of improving the efficiency and useability of our website, services and products.

C. Corporate merger or acquisition- We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a corporate transaction such as a merger, acquisition, reorganization, or sale of assets.  In such an event, you will receive notice if your data is transferred and becomes subject to a different privacy policy.

D. Legal compliance- We may release your Personal Information when necessary to comply with the law, enforce our site policies, or protect our rights or the rights of others regarding property or safety. 

E. Obscured or anonymized data-We may use or provide anonymized data to other parties for marketing, advertising, or other uses.  This data is stripped of any personally identifying characteristics and does not include Personal Information.

F. Third-party services-  We might link to or offer third-party services on our website.  If you click on any of those third-party offerings, we may facilitate sharing of your information and documents you choose to use with those services if we have your consent to do so.  Your use of those services is not governed by our Terms of Service or this Privacy Policy.  We do not control the services of those third parties or how they use your information and documents.  Be sure to review the terms and conditions, and privacy policy before using any third-party services.

G. Affiliate links- If you sign up for Trust & Will through an affiliate or referral link on another website, we may share some Personal Information with that affiliate or referral source.  The Personal Information shared is limited to your name, email address and type of product you purchase. This information is shared for joint marketing purposes. If you want to opt out of sharing information with affiliates and/or referral sources, email a request to opt out to: optout@trustandwill.com

H. Advisor Platform. If you sign up for Trust & Will’s advisor platform as a financial advisor, we may share your name and email address with the financial services organization with which the financial advisor is affiliated for joint marketing purposes. If you want to opt out of sharing information with your advisor’s financial services organization, email a request to opt out to: optout@trustandwill.com

I. Google analytics- We use Google Analytics to collect information about the use of our website.  Google Analytics is a service offered by Google that collects data to track and report website traffic.  This data is shared with other Google services.  Google may use the collected data to contextualize and personalize the ads of its own advertising network.  This data may include pseudonymous identifiers that can be connected to other data that we have about you.  By continuing to use our web site or any service offered by us, you agree and consent to our implementation and features of Google Analytics that we use.  You can opt-out of making your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on here.

8. Summary of our privacy practices for CA residents. Trust and Will has collected the following categories of Personal Information from its consumers in the last twelve (12) months:

A. Identifiers

I. Source: consumers

II. Who info may be shared with: Service Providers, Business Partners, Government Entities, Required by Law, Related Parties

B. Protected characteristics

I. Source: consumers

II. Who info may be shared with: service providers, business partners, government entities, required by law, related parties

C. Commercial information

I. Source: consumers, service providers, business partners

II. Who info may be shared with: service providers, business partners, government entities, required by law, related parties

D. Internet activity

I. Source: consumers, service providers

II. Who info may be shared with: service providers, business partners, government entities, required by law, related parties

E. Geolocation data

I. Source: consumers, related consumers, service providers, business partners 

II. Who info may be shared with: service providers, business partners, government entities, required by law, related parties

F. Audio/video information

I. Source: consumers, service providers

II. Who info may be shared with: service providers, government entities, required by law, related parties

G. Commercial information

I. Source: consumers, service providers

II. Who info may be shared with: service providers, business partners, government entities, required by law, related parties.

9. Transmission of information to other countries- If you submit your personal information to Trust & Will, your personal information may be processed in a foreign country, where privacy laws may be less restrictive.  By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including but not necessarily limited to the United States.

10. Privacy Rights- Residents of some states have enumerated privacy rights relating to Personal Information. We want to ensure that you know exactly how and why your data is collected and used, so you may fully exercise your privacy rights if you choose to do so.  We only use your information with your permission to do so as described within this policy.  If you wish to exercise your privacy rights, you can send a description of your request to legal@trustandwill.com, or communicate with us via phone at 866-908-7878.  We will provide you with a response within 45 days or with an explanation as to why an extension might be necessary.  Depending on your state, you may have the following rights regarding how we capture and use your data:

A. Right to access your Personal Information- You have the right to request access to the Personal Information we have collected about you.  That information includes: the category of information, source of information, the business or commercial purpose for which the information is collected, whether and how that information may be shared with third parties, and what specific types of Personal Information are collected.  You also have the right to request a copy of that information. 

We will provide this to you unless legal exceptions apply.  If you wish to access your information, please send a description of the information you wish to see to legal@trustandwill.com. All requests subject to identify verification.  Verification includes, at a minimum: verification of Name via government issued identification, e-mail,  and other account information that would only be known to the account owner or legally appointed representative.

B. Right to know how and why we use your Personal Information- This policy describes how, when, where and why we collect your Personal Information.  We ask that you not use our services or site if you disagree with any aspect of this policy.

C. Right to opt out of selling or sharing of your data with a third party - You have the right to opt out of having your information shared or sold with  third parties for a non “business purpose” as that term is defined under the CCPA, for example for cross-behavioral advertising or with our affiliates as described above. If you wish to opt out of sharing of your Personal Information for commercial purposes, please send your request to opt out to: optout@trustandwill.com or submit your request here.  You can also visit our “Do Not Sell” page for information about opting out of commercial use of your personal information, as well as how to opt out of cookies.

D. Right to correction- You have the right to request corrections be made to any inaccuracies you see in your Personal Data stored by Trust & Will.

E. Right to deletion- You can request your Personal Data be deleted at any time.  We may need to retain some data for legal purposes, but we will make every effort to comply with your request.  If you wish for us to delete your Personal Information, please email your request to: optout@trustandwill.com or submit a request to delete your account through your Trust and Will account.  You can also call us at 1 (866) 908-7878.  Your request to delete is subject to identity authentication.

F. Right to non-discrimination- Trust & Will will not discriminate against you for exercising your privacy rights.  This means that we will not deny you goods or services, charge you differently, penalize you, or subject you to different treatment as a result of you exercising your privacy rights.

11. Securing and storing your data- We take reasonable steps to maintain the safety of your Personal Information. For example, sensitive Personal Information is transmitted via Secure Socket Layer (SSL) technology and access to your account information requires a username and password. You must keep your password confidential and you should always log out and close your browser when you finish your session.

Though no service is impenetrable, our service is built on top of Amazon Web Services (AWS). Amazon maintains ISO 27001 and SAS70 Type II certification for the AWS infrastructure, and has years of experience managing and securing large-scale data centers. More details about AWS security are available here.

12. Cookies and other technologies- We use cookies, web beacons, pixels, and other similar online technologies (collectively referred to as “Cookies”)  to store your preferences, analyze and improve your experience with Trust & Will, to authenticate and secure your account, to gather demographic information about our user base, to maintain quality assurance, to target content and advertisements that are relevant to you, to  analyze trends, maintain the website, to gather demographic information about visitors to the website, and to validate third party advertising and affiliate marketing links.  

We also use session replay technology for quality control of our site and services called FullStory.  FullStory records your interactions with our website and services, including clicks and internal site navigation on our domain, that allow us to evaluate issues, provide quality control and technical support, and improve the site and services.  You can opt-out of session recording by visiting: https://www.fullstory.com/optout/.

To the extent that Cookies are deemed to be a “sale” or “sharing under applicable U.S. laws, you can opt out of these tracking technologies by submitting an opt-out request, and/or adjusting your cookie settings in your browser preferences.

Note that some Cookies are essential for the operation and function of our website, and opting out of such cookies will impact your ability to use and access the basic functions of our website.  Opting out of some Cookies may have an effect on your browsing experience.   If you don’t opt out of Cookies, Trust & Will will issue Cookies when you interact with our website. 

13. Employee and Applicant Privacy.  To learn how we collect and use employee and/or applicant data, please review our Employee and Applicant privacy policy here.

14. Policy modification-Online Privacy rules and regulations are changing rapidly, and we are committed to ensuring our policy changes with the laws and expectations of privacy on the web.  We will post all updates here, and we may contact you through other methods to alert you of more significant changes to this policy.  Any questions you have regarding this policy should be directed to: legal@trustandwill.com 

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