This policy explains how Silvertime Legal Ltd collects, uses and protects your personal data when you use this website, create an account, or use our online will drafting and lasting power of attorney (LPA) preparation services. We are committed to handling your information carefully and transparently, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who we are
LPAs Online (a trading name of Silvertime Legal Ltd) is the data controller of the personal data described in this policy.
- Registered in England and Wales, company number 15499649
- Registered office: 115–116 Spon End, Coventry, England, CV1 3HF
- ICO registration number: ZB942014
- Contact for privacy matters: help@lpasonline.co.uk / 024 7699 1828
2. The personal data we collect
Account information. When you register for an account (which is required before using either service) we collect your name, email address and phone number.
Your instructions. When you use the will or LPA questionnaires we collect the information needed to prepare your documents. Depending on your answers this can include details about your family and relationships, the people you wish to appoint or benefit (such as executors, attorneys, guardians and beneficiaries), your assets, and your wishes.
Screening information. Both questionnaires include screening questions about your circumstances — for example whether you own business or foreign assets, have children from a previous relationship, wish to exclude a close family member, want tax planning or a trust, or (for LPAs) whether there are concerns about capacity, family disagreement or pressure, or complex appointment arrangements. We record your answers to these questions, including where your answer is "no", so that our records accurately reflect what you told us.
Health information. Some answers may reveal information about health — for example, concerns about mental capacity, or that a beneficiary is disabled or receives means-tested benefits. This is "special category" data and we handle it with extra care, as described in section 4.
Payment information. Payments are processed by our payment provider, Stripe. We do not see or store your full card details. We record the fact and date of your payment and an order reference.
Documents and correspondence. We keep the documents we draft for you, notes summarising your instructions, records of our review and approval decisions, and correspondence with you (including a note if you request a call with us).
Technical data. Like most websites we collect limited technical information (such as IP address and browser type) and use cookies. See section 9.
3. Information about other people
To prepare your documents you will need to give us information about other people — for example your partner, children, executors, attorneys, witnesses and beneficiaries. Typically this is limited to names, relationships, contact details and, occasionally, information relevant to how you provide for them (such as a disability). You should only give us information about others that is accurate, and you should not provide more than we ask for. Where practicable, please let them know that their details will be included in your documents and shared with us. This policy applies to their data too.
4. Why we use your data and our lawful bases
We use your personal data:
- To provide the services you have ordered — preparing, checking and releasing your documents, screening suitability, processing payment, and providing signing guidance and checks. Lawful basis: performance of a contract (Article 6(1)(b) UK GDPR).
- To contact you about your order — including where our review raises a question, where we place your documents on hold, or where you request a call. Lawful basis: performance of a contract.
- To follow up on an account or document you have started — if you create an account or begin a will or LPA questionnaire and don't finish, we may contact you by email or phone to remind you, answer questions or help you complete it. We tell you this when you create your account. Lawful basis: legitimate interests (Article 6(1)(f)) — helping you complete a service you began. You can object to this contact at any time and we will stop.
- To keep records that protect you and us — retaining your instructions, screening answers, drafts and approvals so that there is an accurate record of what you asked for and what we did, in case questions arise later (for example, after a death). Lawful basis: legitimate interests (Article 6(1)(f)) — keeping proper professional records and being able to establish, exercise or defend legal claims.
- To comply with our legal obligations — including accounting, tax and consumer law requirements. Lawful basis: legal obligation (Article 6(1)(c)).
- To send you marketing about our services, only where you have opted in (or where permitted for similar services you have bought from us, with a clear opportunity to opt out in every message). Lawful basis: consent / legitimate interests. You can opt out at any time.
Special category (health) data. Where your instructions include health information, we process it on the basis of your explicit consent (Article 9(2)(a)), which we ask for in the questionnaire before you provide it, and — where the data is needed in connection with actual or prospective legal claims — Article 9(2)(f) (establishment, exercise or defence of legal claims). You can withdraw consent at any time, although without the relevant information we may not be able to complete or retain your documents.
We do not use your data for automated decision-making producing legal effects. The screening step in the questionnaire applies fixed rules to your answers to decide whether the online service is suitable; if it is not, the outcome is simply that we invite you to speak to us instead.
We will only use your personal data for the purposes we collected it for, unless we reasonably consider we need it for another compatible reason. We never sell your data.
5. Who we share your data with
We share your data only as needed to run our business and provide the services:
- Zoho Corporation — our customer relationship management (CRM) system, where your account details, screening answers, order records, instruction summaries and draft documents are held.
- Stripe — payment processing.
- Our website hosting and email providers — the suppliers who host our website and systems and enable us to communicate with you.
- Our insurers and professional advisers — where necessary in connection with insurance, legal or accounting matters.
- The Society of Will Writers — if you make a complaint that is referred to them under their complaints procedure.
- Authorities — where we are required to disclose by law.
All our processors act under contracts that require them to protect your data and use it only on our instructions.
6. International transfers
Some of our providers may process data outside the UK. Where they do, we ensure an adequate level of protection through UK adequacy regulations, the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses, or other lawful safeguards. Details are available on request.
7. How long we keep your data
- Client files (instructions, screening answers, drafts, final documents, approvals and related correspondence): we keep these for the lifetime of the client and for at least 6 years afterwards. We keep them this long because questions about a will or LPA — including claims by people affected by it — usually arise only after the person who made it has died, and the file is the record that protects everyone involved.
- Original signed documents you send us for storage: held securely at our head office until you ask for them, or until they are released after your death to your executors or attorneys, or returned to you if the storage service ends.
- Account and enquiry data where no purchase is made: deleted or anonymised after 24 months of inactivity.
- Payment and accounting records: at least 6 years after the end of the relevant financial year, as required by law.
- Marketing preferences: until you opt out or we no longer need them.
When data is no longer needed, we delete it securely.
8. How we protect your data
Access to your data is limited to those who need it to provide the services. Our systems are protected by access controls and encryption in transit, and our processors are selected for their security standards. Documents are released only through your password-protected account. No system is completely secure, but we take reasonable and proportionate measures appropriate to the sensitivity of the data we hold.
9. Cookies
Our website uses cookies that are essential for it to function (for example, keeping you logged in and enabling checkout). With your consent, we also use Google Analytics to understand how visitors find and use the site — which pages are visited, where visitors arrive from, and where they leave — so we can improve it. With your consent we also use the Meta (Facebook) Pixel to measure the performance of our advertising. Analytics and advertising cookies are set only if you choose Accept on the cookie banner; if you decline, none are set and the site works exactly the same. You can change your choice at any time using the Cookie preferences link in the page footer, and you can control or delete cookies through your browser settings. Google's processing is described at policies.google.com/privacy, and Meta's at facebook.com/privacy/policy. The information assistant on our website sets no cookies at all and works whether or not you accept analytics — the question you type is matched against our own library of pre-written answers on our own server, is not sent to any third party, and is not stored. Nothing of a conversation is kept once you close the page. If you ask the assistant for a call back, the name and number you give us are handled in the same way as any other consultation request described above.
10. Your rights
You have the right to:
- access the personal data we hold about you (a "subject access request");
- correct inaccurate or incomplete data;
- request erasure of your data, where there is no overriding reason for us to keep it (note that we will usually need to retain client files for the period in section 7, including where the file relates to documents we have drafted);
- object to processing based on legitimate interests, and to direct marketing (which we will always stop on request);
- restrict processing in certain circumstances;
- data portability — receive the data you provided to us in a machine-readable format; and
- withdraw consent at any time, where processing is based on consent, without affecting processing already carried out.
To exercise any of these rights, contact us at help@lpasonline.co.uk. We will respond within one month. We may need to verify your identity first — this protects your information.
11. Complaints
If you are unhappy with how we have handled your data, please contact us first and we will do our best to resolve it. You also have the right to complain to the Information Commissioner's Office (ICO): ico.org.uk / 0303 123 1113.
12. Changes to this policy
We may update this policy from time to time. The current version will always be published on this page with the date it took effect. If we make significant changes affecting how we use data you have already given us, we will notify account holders by email.