Date of Publication: 11th April 2025
Last Updated: 11th June 2026
Version 1.1

Important information and who we are 

My Wealth Cloud Limited, trading as Legacy Hub, is committed to protecting your privacy and personal data. 

In this privacy policy, “we”, “us” and “our” means My Wealth Cloud Limited. My Wealth Cloud Limited is a company registered in England and Wales under company number 07562559. Our registered office is 55 Station Road, Beaconsfield, Buckinghamshire, HP9 1QL. 

Our contact email address is info@legacyhub.co.uk. Our ICO registration number is Z2742632. 

This privacy policy explains how we collect, use, store and protect personal data that you provide to us, or that we collect from you, when you use or interact with the Legacy Hub service. 

Legacy Hub is not intended for use by children, and we do not knowingly collect personal data relating to children. 

Please read this privacy policy carefully so that you understand how and why we use your personal data. This privacy policy may be supplemented by other privacy notices that we provide to you on specific occasions. Those notices should be read together with this privacy policy. 

We have appointed a data privacy manager who is responsible for overseeing questions relating to this privacy policy. Our Data Protection Officer is Data Privacy Services, who can be contacted using the details set out in the “Contacting us” section below. 

Changes to this privacy policy and your duty to inform us of changes 

We keep this privacy policy under regular review and may update it from time to time. 

It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during your relationship with us. 

Third-party links 

Legacy Hub may include links to third-party websites, plug-ins or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 

We do not control third-party websites and are not responsible for their privacy notices, policies or practices. When you leave Legacy Hub or visit a third-party website, we encourage you to read that website’s privacy policy. 

Information we may collect from you 

Personal data means any information relating to an identified or identifiable individual. It does not include information where the identity has been permanently removed, known as anonymous data. 

To provide the Legacy Hub service, we may collect and process the following personal data: 

• • your name;
  •  your email address;
  • your mobile telephone number. 

This information is used to create and manage your Legacy Hub account and to associate your account with a unique identifier. We may be unable to provide the full Legacy Hub service without this information. 

We may also collect and process the following personal data: 

• •  your address; 
• •  other telephone numbers; 
• •  your date of birth; 
• •  your IP address. 

This information is processed to help ensure that the records we hold are accurate, complete and up to date. You can update certain information through the profile area of Legacy Hub. 

When creating and using your Legacy Hub account, you may choose to upload additional personal data relating to your digital legacy or other key information that you would like to make available to your loved ones when you die. This may include, for example, information relating to your Will, estate planning, financial matters, accounts, important contacts, personal documents or other matters that you choose to record. 

We may process this information because it is necessary to provide the Legacy Hub service to you, because you have provided your consent, or because we have a legal obligation to do so. 

How we collect personal data 

We may collect personal data in the following ways: 

• •  directly from you when you register for a Legacy Hub account; 
• •  directly from you when you use the Legacy Hub service; 
• •  when you upload documents, notes or other information to Legacy Hub; 
• •  when you share access to your My Folders area with family members, friends or other chosen individuals; 
• •  when you contact us by email, telephone, post or other means; 
• •  when we speak to you by telephone or in person; 
• •  through your use of Legacy Hub and related websites, including traffic data, location data, weblogs, device information, operating system information, communication data and resources accessed; 
• •  through technical data, including IP address, login data, cookies and browsing patterns; 
• •  from third-party organisations where this is permitted and governed by an appropriate processing agreement. 

Lawful basis for processing 

We process personal data where we have a lawful basis to do so under applicable data protection law. 

Depending on the circumstances, we may process your personal data on one or more of the following bases: 

• •  where processing is necessary for the performance of a contract with you; 
• •  where processing is necessary for the performance of a contract between you and a third-party organisation through which you access the Legacy Hub service; 
• •  where processing is necessary to comply with a legal obligation; 
• •  where you have given consent; 
• •  where processing is necessary for our legitimate interests, provided that your rights and interests do not override those interests. 

Where we rely on consent, you may withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing carried out before consent was withdrawn. 

Special categories of personal data 

In some circumstances, you may upload or provide information that includes special category personal data. This may include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for identification, health data, sex life or sexual orientation. 

We cannot always know what information will be included in documents or other content that you choose to upload to Legacy Hub. It is your responsibility to ensure that you understand the nature of the information you upload. 

Where special category personal data is processed, we will only process it where we have a lawful basis and an applicable condition under data protection law. 

Uploading documents 

You may choose to upload documents to Legacy Hub as part of the service. 

We are unable to know in advance what information will be included in documents that you upload. You should therefore take care when uploading documents and ensure that you are comfortable with the information being stored within Legacy Hub. 

Documents uploaded to Legacy Hub are processed so that we can provide the Legacy Hub service to you. You may delete uploaded documents at any time through your account, subject to any technical, legal or operational limitations that may apply. 

How long we keep your data 

We will retain personal data required to provide the Legacy Hub service for as long as your account remains active. 

Unless personal data is required for legal, regulatory, tax, accounting, reporting or dispute resolution purposes, we will retain your uploaded documents until you delete them or close your account. 

We may retain limited information, such as your name and email address, where this is necessary to comply with legal, regulatory, tax, accounting or reporting obligations, or where we need to retain evidence of our relationship with you. 

IP addresses, cookies and sessions 

Cookies are small files that are placed on your device. They are widely used to make websites and online systems work, to improve efficiency and to provide information to website owners. 

We may collect information about your computer or device, including your IP address, operating system and browser type. This may be used for system administration, analytics and reporting. This information may be aggregated and does not necessarily identify you personally. 

Cookies help us improve Legacy Hub and provide a better and more personalised service. Some cookies are essential for the operation of Legacy Hub. 

We may use cookies to: 

• •  estimate our user population size and usage patterns; 
• •  recognise referred traffic for marketing, promotional and introductory offers; 
• •  speed up searches; 
• •  recognise you when you return to our website; 
• •  make your browsing experience more convenient. 

Cookies we may use 

We may use Google Analytics to estimate audience size and usage patterns. 

We may use PHPSESSID to manage sessions and identify the landing page of a user, including where the user has been referred from marketing, promotional or introductory offers. 

We may use Hotjar to better understand user needs and to optimise the Legacy Hub service and user experience. Hotjar may use cookies and other technologies to collect information about user behaviour and devices, such as device IP address, screen size, device type, browser information, geographic location and preferred language. Hotjar is contractually restricted from selling data collected on our behalf. 

Managing cookies 

You may refuse to accept cookies by adjusting your browser settings so that some or all cookies are refused. 

If you disable or refuse cookies, some parts of Legacy Hub or our website may become inaccessible or may not function properly. 

Unless you have adjusted your browser settings to refuse cookies, our systems may issue cookies when you visit or log in to our website. 

Where we store and process your personal data 

Data submitted to Legacy Hub is stored on cloud-based servers within Amazon Web Services UK-based data centres. 

We may use sub-processors to assist us in delivering the Legacy Hub service and related processing activities. Where we use sub-processors, we do so in accordance with applicable data protection law, relevant contractual terms and any appropriate instructions. 

For example, we may provide your email address to SMTP relay providers so that system-generated notifications and emails can be delivered to you. 

Uses made of the information 

We may use personal data we hold about you for the following purposes: 

• •  to provide the Legacy Hub service; 
• •  to create, manage and administer your account; 
• •  to allow you to upload, store, manage and share information through Legacy Hub; 
• •  to ensure that Legacy Hub content is presented effectively for you and your device; 
• •  to provide information, products or services that you request from us; 
• •  to carry out our obligations and enforce our rights under contracts entered into with you; 
• •  to allow you to participate in interactive features of Legacy Hub where you choose to do so; 
• •  to notify you about changes to Legacy Hub; 
• •  to provide support and respond to enquiries; 
• •  to maintain the safety, security and integrity of Legacy Hub; 
• •  to comply with legal or regulatory obligations. 

If you are an existing customer or user with a direct agreement with us, we may contact you by telephone, email or SMS with information about goods or services similar to those that were the subject of a previous sale or negotiation. 

We will not otherwise contact you electronically with marketing information unless you have consented, or unless another lawful basis applies. 

If you are a new customer, we will only contact you electronically with marketing information where you have consented to this, or where otherwise permitted by law. 

We do not disclose information about identifiable individuals to advertisers. We may provide advertisers or commercial partners with aggregated information about users, provided this does not identify individuals. 

We do not undertake automated decision-making or profiling using your personal data. 

Disclosure of your information 

We may disclose your personal data to members of our group, including subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. 

We may also disclose your personal data to third parties in the following circumstances: 

• •  if we sell or buy any business or assets, in which case personal data may be disclosed to the prospective seller or buyer; 
• •  if we or substantially all of our assets are acquired by a third party, in which case personal data held by us may be one of the transferred assets; 
• •  if we are required to disclose or share personal data to comply with a legal obligation; 
• •  if disclosure is necessary to enforce or apply our terms and conditions or other agreements; 
• •  if disclosure is necessary to protect the rights, property or safety of us, our customers, users or others; 
• •  where we use third-party service providers or sub-processors to host, support, maintain or deliver Legacy Hub; 
• •  where otherwise described in this privacy policy. 

This may include exchanging information with other companies and organisations for fraud protection, fraud prevention, credit risk reduction, debt recovery or legal compliance purposes. 

Your rights 

Under data protection law, you may have the following rights in relation to your personal data: 

• •  the right to request access to your personal data; 
• •  the right to request correction of inaccurate or incomplete personal data; 
• •  the right to request erasure of your personal data; 
• •  the right to request restriction of processing; 
• •  the right to object to processing; 
• •  the right to withdraw consent where processing is based on consent; 
• •  the right to data portability, where applicable. 

For further information on these rights, please refer to our Data Subject Access Request Policy. 

If you wish to exercise any of these rights, please email us at info@legacyhub.co.uk. 

We may need to request specific information from you to confirm your identity and ensure that you are entitled to exercise the relevant right. This is a security measure to ensure that personal data is not disclosed to someone who has no right to receive it. 

We may also contact you to ask for further information in relation to your request so that we can respond more effectively. 

You will not normally have to pay a fee to access your personal data or exercise your other rights. However, we may charge a reasonable fee where a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in those circumstances. 

We try to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or you have made several requests. In that case, we will notify you and keep you updated. 

Data Protection Complaints Handling Process 

We are committed to handling data protection complaints fairly, transparently and effectively. 

This section explains how you can raise a complaint with us if you are concerned about how we collect, use, store, share, retain or otherwise process your personal data. 

This process is intended to ensure compliance with applicable data protection law, including: 

• •  the UK General Data Protection Regulation; 
• •  the Data Protection Act 2018; 
• •  the Data (Use and Access) Act 2025; 
• •  guidance issued by the Information Commissioner’s Office. 

This complaints process applies to data protection complaints received on or after 19 June 2026. We may also apply the same approach before that date as a matter of good practice. 

How to make a data protection complaint 

If you have a data protection complaint, you can contact us by email at: 

info@legacyhub.co.uk 

Please include “Data Protection Complaint” in the subject line where possible. 

To help us review your complaint, please provide as much relevant information as you can, including: 

• •  your full name; 
• •  your contact details; 
• •  the nature of your complaint; 
• •  the personal data or processing activity your complaint relates to; 
• •  any relevant dates, correspondence or supporting evidence; 
• •  the outcome you are seeking, where applicable. 

You do not have to use any specific wording to make a data protection complaint. If it is clear that you are raising a concern about how we process personal data, we will treat it as a data protection complaint. 

How we will handle your complaint 

When we receive a data protection complaint, we will: 

• •  acknowledge receipt of your complaint within 30 days; 
• •  take appropriate steps to consider and investigate your complaint without undue delay; 
• •  make reasonable and proportionate enquiries based on the nature, seriousness and complexity of the complaint; 
• •  keep you informed about the progress of your complaint where appropriate; 
• •  tell you the outcome of your complaint without undue delay. 

We may contact you for further information if we need clarification or additional details to investigate your complaint properly. 

The outcome of your complaint may include an explanation of our position, details of any action we have taken or intend to take, or confirmation that we do not consider further action to be necessary. 

Complaints to the Information Commissioner’s Office 

If you are unhappy with how we have processed your personal data, or if you are unhappy with how we have handled your data protection complaint, you have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection matters. 

The ICO’s website is www.ico.org.uk. 

We would appreciate the opportunity to deal with your concerns before you contact the ICO, so please contact us in the first instance where possible. 

Contacting us 

If you would like further information about this privacy policy, wish to exercise your rights under data protection law, or wish to make a data protection complaint, please contact our Data Protection Officer, Data Privacy Services, using the following details: 

Email: info@legacyhub.co.uk