Privacy Policy
This Privacy Policy explains how Oggle Ltd ('we', 'us', or 'our') collects, uses, and protects your personal information when you use our Crypto Will service. We are committed to protecting your privacy and complying with UK data protection laws, including the General Data Protection Regulation (UK GDPR).
1. Who We Are
Oggle Ltd is a company registered in England and Wales with company number 09626206. Our registered office is at London, SW18 3SX, England.
For any data protection queries or to exercise your rights under UK GDPR, please contact us at: [email protected] or write to our registered office address.
2. What Information We Collect
We collect only the minimum personal information necessary to provide our Crypto Will service:
- Personal identification: Your name and email address
- Billing information: Payment details processed securely through trusted payment processors
- Company information: Optional company name if you choose to provide it
- Partial will data: Encrypted fragments of your crypto inheritance information (not complete private keys or recovery phrases)
- Account information: Login credentials and account preferences
- Technical data: IP addresses, browser information, and access logs for security purposes
We do not collect biometric data, behavioural profiling information, or use automated decision-making systems.
3. How We Use Your Information
We use your personal information for the following purposes:
- Service provision: To provide and maintain your Crypto Will account and store your partial inheritance data
- Payment processing: To process subscription payments and manage billing
- Account security: To authenticate your identity and protect your account from unauthorised access
- Service updates: To notify you of important service changes, security updates, or account issues
- Legal compliance: To comply with applicable laws and regulations
- Customer support: To respond to your queries and provide technical assistance
4. Legal Basis for Processing
We process your personal information based on the following legal grounds:
- Contract performance: Processing necessary to provide our service and fulfil our contractual obligations
- Consent: Where you have given explicit consent for specific processing activities
- Legitimate interests: For service security, fraud prevention, and business operations
- Legal obligations: To comply with applicable laws and regulations
5. How We Store and Secure Your Data
We implement robust security measures to protect your personal information:
- Encryption in transit: All data is protected by SSL encryption during transmission
- Encryption at rest: Your data is stored encrypted in secure databases
- Access controls: Role-based access ensures only authorised personnel can access your information
- Regular security audits: We regularly review and update our security practices
- Secure infrastructure: Our servers are hosted in secure, compliant data centres
Your partial crypto will data is stored in an encrypted format that cannot be accessed without proper authentication. We maintain strict internal policies to ensure data security and staff confidentiality.
6. Who We Share Your Data With
We do not sell, trade, or rent your personal information to third parties. We only share your information in the following limited circumstances:
- Payment processors: Trusted services like Stripe or PayPal to process subscription payments (they have their own privacy policies)
- Legal requirements: When required by law, court order, or regulatory authority
- Service providers: Essential technical service providers who assist in operating our platform (under strict confidentiality agreements)
- Business transfer: If our business is sold or merged, your information may be transferred to the new owner
All third-party service providers are carefully selected and bound by data protection agreements to ensure your information remains secure.
7. Your Rights Under UK GDPR
You have the following rights regarding your personal information:
- Right of access: Request a copy of the personal information we hold about you
- Right to rectification: Request correction of inaccurate or incomplete information
- Right to erasure: Request deletion of your personal information (subject to legal obligations)
- Right to restrict processing: Request limitation of how we use your information
- Right to object: Object to processing based on legitimate interests
- Right to data portability: Request transfer of your data to another service provider
- Right to withdraw consent: Withdraw consent for processing activities that require it
To exercise any of these rights, contact us at [email protected]. We will respond within one month and may require identity verification.
8. Data Retention
We retain your personal information for as long as necessary to provide our service and comply with legal obligations:
- Active accounts: While your subscription remains active
- Cancelled accounts: Up to 90 days after cancellation to allow for account reactivation
- Legal requirements: Longer if required by law or for legal proceedings
- Financial records: Payment information retained for tax and accounting purposes as required by law
You can request earlier deletion of your data by contacting us, subject to any legal obligations we may have.
9. Cookies and Tracking
Our website uses essential cookies only to ensure proper functionality of our service. We do not use tracking cookies, analytics cookies, or advertising cookies.
Essential cookies include:
- Session cookies for user authentication
- Security cookies to prevent cross-site request forgery
- Preference cookies to remember your language settings
You can disable cookies in your browser settings, but this may affect the functionality of our service.
10. International Data Transfers
Your personal information is processed and stored within the United Kingdom. If we need to transfer data outside the UK, we will ensure appropriate safeguards are in place, including adequacy decisions or standard contractual clauses.
11. Children's Privacy
Our service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided personal information to us, please contact us immediately.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by email and update the 'Last updated' date below.
Continued use of our service after changes constitutes acceptance of the updated Privacy Policy.
13. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights, or need to make a complaint, please contact us:
- Email: [email protected]
- Post: Data Protection Officer, Oggle Ltd, London, SW18 3SX, England
- Data Protection Authority: You also have the right to complain to the Information Commissioner's Office (ICO) if you believe we have not handled your personal information properly
Last updated: January 6, 2025