Privacy Policy

Last updated: 10 May 2025

At WESS EUROPE LTD (“Willston,” “we,” “our,” “us”), your story is sacred. This Privacy Policy explains how we collect, use, and protect your personal information when you interact with our digital legacy platform via www.willston.com.

1. Who We Are

WESS EUROPE LTD is a private company registered in England and Wales under company number 14016022.

Registered Office: 4 Princes Street, Mayfair, London, England, W1B 2LE.

We are the Data Controller of your personal data and are committed to respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), the EU GDPR, and other applicable data protection laws.

2. Information We Collect

We may collect and process the following categories of data:

  • Identification Data: Government-issued documents, live video (via Onfido).
  • Biometric Data: Your voice recordings used for voice cloning (via ElevenLabs).
  • Personal Legacy Data: Will documents, family trees, written narratives, recorded stories, preferences, and associated media.
  • Relationship Data: Contact details and assigned permissions for legacy contacts.
  • Usage Data: Platform activity, preferences, and interactions with the Digital Persona.
  • Communication Data: Emails and messages sent via our platform.
  • Technical Data: IP address, browser, session details (via Google Analytics).
  • Financial Data: Subscription and billing information (via Stripe).

3. How We Use Your Information

We use your data to:

  • Authenticate and verify your identity securely.
  • Record, store and manage your legacy, including written and spoken content.
  • Enable you and your contacts to interact with your Digital Persona.
  • Notify and grant access to assigned legacy contacts upon your passing.
  • Process payments and manage subscriptions.
  • Improve platform experience and security.
  • Comply with legal and regulatory obligations.

4. Legal Basis for Processing

We process your data based on:

  • Contractual necessity - for account creation and subscription services.
  • Legitimate interests - to improve and secure our platform.
  • Consent - for optional features like voice cloning or sharing personal content.
  • Legal obligations - where required by authorities or regulation.

5. How We Share Your Data

We do not sell your data. We may share it with:

  • Onfido for identity verification.
  • Google Analytics for platform usage insights.
  • Brevo for transactional and service emails.
  • Twilio for secure SMS communications.
  • ElevenLabs for voice cloning functionality.
  • Stripe for secure payment processing.
  • Authorised legacy contacts, based on your configured preferences.
  • Authorities, when legally compelled to do so.

All partners are bound by strict data protection agreements and act in accordance with relevant laws.

6. International Data Transfers

Where data is processed outside of the United Kingdom or European Economic Area (e.g., via third-party providers), we ensure appropriate safeguards are in place, including Standard Contractual Clauses or other lawful mechanisms.

7. Retention Policy

We retain your data:

  • As long as your account remains active.
  • For up to 10 years following account inactivity, for reactivation and archival continuity.
  • For 2 years post-mortem for access by designated legacy contacts, with possible extension upon request.

You may delete your account and associated data at any time via your account settings.

8. Your Rights

Under data protection law, you have the right to:

  • Access your personal data.
  • Correct or update your information.
  • Delete your data (“right to be forgotten”).
  • Object to processing or request restriction.
  • Withdraw consent at any time.
  • Lodge a complaint with the UK Information Commissioner's Office or relevant supervisory authority.

9. Children's Privacy

Willston is not intended for individuals under the age of 13. We do not knowingly collect data from children. If we learn that a child has submitted data to our platform, it will be promptly deleted.

10. Data Security

We uphold your trust with rigorous safeguards:

  • Encrypted data storage and transfer.
  • Two-factor authentication and secure identity checks.
  • Segmented access for contacts and internal personnel.

11. Contact Us

If you have questions, concerns, or wish to exercise your rights, you may contact us at:

legal@willston.com
WESS EUROPE LTD, 4 Princes Street, Mayfair, London, England, W1B 2LE.