Privacy Notice

This privacy notice (the “Privacy Notice”) describes how FreeWill Co. (“FreeWill”, “we,” “our,” or “us”) obtains, uses and shares personal information and other information in connection with the operation of the sites available at www.freewill.com, www.getestately.com, and www.cryptoforcharity.io, and with related services (collectively, the “Site”). Our Site is intended primarily to provide access to self-help software and materials for users interested in creating and managing an estate plan, and in making charitable contributions to nonprofit organizations.

What personal information we obtain

FreeWill obtains information (i) when you use or visit our Site; (ii) that you provide when you create a FreeWill account; (iii) that you submit when you create a will or other legal document (with or without creating a FreeWill account); (iii) that you submit when using our Stock Gifts, Stock Liquidation, Qualified Charitable Distribution, Outside Bequest, Beneficiary Designation, Donor-Advised Fund, CryptoForCharity platform and other software tools; (iv) that you share about others; and (v) that is automatically collected about your interactions with the Site.

• Personal information you provide when you create a FreeWill account:
  
  • email address; and
  • user password.
• Personal information you choose to submit when you utilize the Site to create a will or other legal document, or to create or facilitate a charitable gift (with or without creating a FreeWill account):
  
  • first, middle and last name;
  • date of birth;
  • city, state, zip code and address;
  • email address;
  • telephone number;
  • gender;
  • marital status and information regarding your family members and pets, if any;
  • names of your elected guardians(s), beneficiary(s), agents, trustees and/or executor(s);
  • estimated value of your estate and information concerning your assets and accounts, such as a description or address of real estate property;
  • charitable donations (specific amount or percentage of total estate);
  • names and addresses of your physicians and preferred hospitals; and/or
  • favorite pastimes, religious beliefs, and preferences for end-of-life care.
• Personal information you share about others:
  
  • You may share personal information about other people, such as the name and email of a friend or contact with whom you want to share information about the Site, the name of an executor or gift recipient, or contact information for your nominated agents. Do not give us information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Notice.
• Information automatically collected about your visit and Site usage:
  
  • We may automatically collect information when you visit our Site or participate in surveys, including through cookies, browser pixels, web beacons and other technologies (collectively “Cookies”). We may use Cookies to administer and understand Site usage and improve our content and offerings. We may also use Cookies to collect aggregate information about site users.
  • The information collected for these purposes may include, (i) http headers, (ii) browser type data, (iii) browser settings, (iv) device information, (v) resolution, (vi) access time stamps, (vii) operating system information, (viii) user site navigation – such as page views, (ix) user button clicks, (x) events defined by various user activity, (xi) IP address, (xii) demographic information, and other information collected by automated means) may be disclosed to or collected directly by our third-party web analytics service providers, such as Google Analytics. For more information about the use of Cookies for Interested-Based Advertising and Cookie opt-outs, see here and here. For more information about our use of cookies, please see our Cookie Policy.

How we use the personal information we obtain

We use the personal information we obtain in connection with the operation of the Site for the following purposes:

• To provide you with the Site and the services you request from us, including managing your FreeWill account or creating your will and other documents;
• To send you transactional communications (such as FreeWill account confirmations and notifications) about the Site or to respond to your questions or requests;
• To track and confirm completion of charitable gifts you’ve initiated, and provide information regarding such gift to their beneficiaries;
• To send you gift acknowledgement communications, evidencing certain charitable contributions for tax purposes;
• For our own marketing and advertising purposes, including interest-based advertising, based on your consent;
• To generate and analyze aggregated and statistical data about your use of the Site and offerings, and to customize your experience with the Site (e.g. based on the type of browser or device you use);
• To generate and analyze aggregated and statistical data about the demographics and attitudes of our non-profit partners’ donor bases;
• To improve the Site, and ensure its availability and proper functioning;
• To provide and support our business operations; and/or
• To detect, prevent and respond to fraud or theft, violations of law, this Privacy Notice, our Terms of Service and other policies

We also may aggregate the personal information we obtain through the Site (the “Aggregated Data”) and use it for analytics, benchmarking and other business purposes. We may augment such Aggregated Data with data we obtain from other sources, however such augmentation will not include personal data. In addition, we may share Aggregated Data with the general public to report on charitable trends. For example, we may produce and share aggregate level information such as correlations between donation rates and demographic factors.

No consumer personal data, such as phone numbers, will be shared with third parties/affiliates for marketing/promotional purposes. Text messaging opt-in data and consents are not shared with any third parties.

Internet-based advertising

On our Site, we and third parties may collect information about your online activities to provide you with advertising about services or products tailored to your interests. You may see certain ads on other websites because we or such third parties participate in advertising networks. Ad networks track your online activities over time by collecting information through automated means, including through the use of Cookies. The information ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites or apps that participate in the ad networks. This process allows us and third parties to deliver more tailored advertising. In addition, it helps us track the effectiveness of our marketing efforts. To learn how to opt out of ad network interest-based advertising, see here. In serving interest-based ads, FreeWill adheres to the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance.

With whom we may share your personal information

We may share the personal information we obtain in connection with the operation of the Site:

• With privacy compliant approved service providers who work on our behalf, such as cloud storage providers, and other third-party partners that provide features or functionalities we integrate into our Site, such as email communication providers;
• With bona fide tax-exempt charitable or religious organizations and their planned giving consultants to facilitate and report donations, establish the veracity of gifts entered into the Site, and provide information (in accordance with donors’ preferences) regarding donors, such as the donors’ contact information, birth year, city and state, and donation amounts or percentages. These organizations may use this information for their own solicitation of contributions. Your personal information will only be shared with the organizations designated by you.    
• As necessary or appropriate, with our attorneys, accountants, auditors or other advisors;
• To protect our rights or the rights of others including detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Site, intellectual property infringement or other violations of law, this Privacy Notice, our Terms of Service and other policies;
• To the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets (including in the event of a reorganization, dissolution or liquidation); and
• With third-parties for any purpose subject to your consent or otherwise at your direction.

In addition, we may share Aggregated Data with third parties for any purpose.

Links to other websites, apps or services

Our Site may contain links to other websites, apps or online services operated by companies not affiliated with FreeWill, such as social media functions like Facebook widgets. These functions and widgets may collect information about users, including which pages were visited on the Site and the IP address of the device you use to connect to the Internet. We are not responsible for the content and data handling practices of any third-party websites, apps or services, and we encourage you to review the privacy policies or notices published by relevant third parties.

Children

You cannot sign up for a FreeWill account if you are under 18. If you learn that a child under the age of 18 has created a FreeWill account or provided us with personal information, please contact us as indicated in the “Contact Us” section below. However, in connection with the services we offer through the Site, we may obtain information about children under the age of 13 if a parent or legal guardian submits or shares such information with us. We ask that users of the Site not provide information about a child under 13 without first getting the consent of the parent or legal guardian. By providing information regarding a child under the age of 13, you are affirming that you are legally authorized to do so.

International users

FreeWill is a U.S.-based company that operates exclusively in North America primarily to provide access to self-help software and materials for users interested in creating and managing an estate plan and similar services governed by applicable United States and/or Canadian laws.  Our services are not available to any visitor outside of North America.  If you are an international visitor accessing our site, any personal data you provide will be treated in accordance with the data protection laws in North America.

Protection of personal information

We maintain appropriate administrative, technical, and physical safeguards designed to safeguard the personal information obtained in connection with the Site. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks. In connection with your FreeWill account, you should use passwords that are sufficiently complex and not share your passwords with others.

Your choices, including marketing and interest-based ads opt-outs

You can review and request changes to your personal information obtained by FreeWill at any time by editing your FreeWill account, if applicable. You can have your FreeWill account deleted by sending a request via email to help@freewill.com. You can also review and request changes to your personal information obtained by FreeWill specifically in connection with your use of the CryptoforCharity service by sending a request via email to support@cryptoforcharity.io.

Email Marketing Opt-Out

You may opt out of receiving marketing or promotional emails from us by clicking on the “unsubscribe” link contained in such emails. Please keep in mind that if you opt out of receiving marketing or promotional emails, we may still send you transactional emails or other communications relating to FreeWill and your account (e.g., to inform you of changes to the Site or of legal developments that might impact your documents).

Direct Mail Marketing

You may request that we stop sending you postal mail offers through the US post office by notifying us in writing at FreeWill Co., Attn: General Counsel, 2041 East St, PMB 615, Concord, CA 94520.

Interest-Based Ads Opt-Outs

To learn more about your rights in relation to interest-based advertising on your browser, including your choice to opt out, you can follow the instructions provided by the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”) to place an opt-out cookie on your browser. These opt-out Cookies enable you to block participating companies from installing future Cookies on your computer or browser.

Cookie Opt-Outs

If you do not want Cookies, most web browsers include an option that allows you to not accept them. However, if you set your browser to refuse Cookies, you may not be able to log in successfully and/or some features of the Site may not function properly. Learn more about opting out of these activities.

Dispute resolution / terms

Any dispute concerning the Site (including our use of your personal information) will be resolved per the dispute resolution provision in our Terms of Service. The Terms of Service govern your use of the Site. Please take a few minutes to read our Terms of Service before using the Site.

Changes to this privacy notice

We may modify this Privacy Notice at any time and without prior notice to you. Any changes to the Privacy Notice will be reflected on this page and will become effective immediately upon posting. If we make significant changes to this Privacy Notice, we will notify you by posting a prominent notice on this Site. Please check the last updated date at the top of the Privacy Notice to determine if there have been any changes since you have last reviewed the Privacy Notice.

Contact us

If you have any questions about this Privacy Notice or our use of your personal information obtained through the Site, please contact us at help@freewill.com or at support@cryptoforcharity.io.