Privacy Policy

This privacy policy explains how Thelema Enterprises Limited ("Thelema", "we", "us", "our") collects, uses and protects personal data in connection with this website (thelema-wills.com).

Thelema is currently in a pre-trading, business development phase. We are not yet acquiring will books, and we are not yet processing personal data belonging to will holders or solicitors' clients. This policy covers only the personal data we collect through this website — principally from solicitors, brokers and other professionals who contact us. Before we begin live operations (acquiring will books, operating the will holder portal, or processing payments), we will publish an expanded privacy policy covering solicitor operators, will holders and our data processors, and will notify anyone whose data we hold at that time.

1. Who we are

Thelema Enterprises Limited is a company registered in England and Wales (company number: 17251864), with its registered office at Flat 9, 110 Esher High Street, Esher, KT10 9QL. We are registered with the Information Commissioner's Office (ICO), registration reference ZC178752. For data protection purposes, Thelema is the data controller of the personal data described in this policy.

If you have any questions about this policy or how we handle your data, contact us at enquiries@thelema-wills.com.

2. What personal data we collect

We collect the following categories of personal data through this website:

• Contact details you give us directly — name, email address, telephone number, practice or firm name, and the content of any enquiry — when you email us or get in touch through this site.
• Booking details — if you book a call using our Calendly link, Calendly collects your name, email address and chosen appointment time and shares these with us so we can prepare for and conduct the call. Calendly processes this data under its own privacy policy, as an independent controller of the booking process.
• Technical data — this website does not use analytics, advertising, or third-party tracking cookies. It may use cookies or similar technologies that are strictly necessary for the site to function; these do not identify you personally.

3. How we use your data

We use the personal data described above to:

• respond to your enquiry and arrange or conduct a call;
• keep basic records of business development conversations — for example, with solicitors considering a will book transfer, or brokers introducing us to prospects;
• comply with our legal and regulatory obligations.

We do not use your data for automated decision-making, and we do not use it for marketing beyond responding to your own enquiry.

4. Legal basis for processing

We process personal data on the following legal bases under UK GDPR:

• Legitimate interests (Article 6(1)(f)) — responding to business enquiries and pursuing business development conversations, in a way that is proportionate and does not override your own interests or rights.
• Contractual necessity (Article 6(1)(b)) — where processing is a necessary step towards entering into an agreement with you or your firm.
• Legal obligation (Article 6(1)(c)) — where we need to retain records to meet a legal or regulatory requirement.

5. Sharing your data

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

• Calendly, LLC, to operate our call scheduling, and our email hosting provider, strictly to run this website and respond to enquiries;
• our professional advisers (for example, accountants or solicitors), where necessary;
• regulators or other authorities, where required by law.

Some of these providers may process data outside the UK. Where they do, we require appropriate safeguards to be in place, such as the UK's International Data Transfer Addendum or equivalent standard contractual clauses.

6. How long we keep your data

We keep enquiry and business development records for as long as reasonably necessary to progress the conversation, or until you ask us to delete them, whichever is sooner. We do not retain personal data indefinitely without a genuine business reason.

7. Your rights

Under UK data protection law, you have the right to: access the personal data we hold about you; request correction of inaccurate or incomplete data; request erasure of your personal data in certain circumstances; object to or restrict certain types of processing; and request that your data be transferred to another controller. To exercise any of these rights, contact us at enquiries@thelema-wills.com.

8. Complaints

If you are unhappy with how we have handled your personal data, please tell us first at enquiries@thelema-wills.com. We will acknowledge your complaint within 30 days and aim to resolve it without undue delay. You also have the right to complain directly to the Information Commissioner's Office (ico.org.uk), the UK's independent regulator for data protection.

9. Cookies

This website does not use analytics or tracking cookies. If we introduce them in future, we will update this policy and seek your consent where required by law.

10. Changes to this policy

We will update this policy as our business develops, and in particular before we begin actively acquiring will books or operating the will holder portal. The date at the top of this page always reflects the latest update.

11. Contact us

Email: enquiries@thelema-wills.com
Website: thelema-wills.com