This privacy policy sets out how IDR Law Limited uses and protects your personal data when you use the Intentia platform.

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how IDR Law Limited collects and uses your personal data through your use of the Intentia website and services, including where you create or sign a Lifetime Transfer Memo, purchase services through the platform, create an account, or otherwise interact with us.

This website is not intended for children and we do not knowingly collect personal data relating to children.

Controller

IDR Law Limited is the controller and is responsible for your personal data (referred to in this privacy policy as "IDR", "we", "us" or "our").

Intentia is a legal technology platform operated by IDR Law Limited.

Registered address: 46 Tower Street, Harrogate, North Yorkshire, England, HG1 1HS

Company number: 10930161

Contact details:

If you have any questions about this privacy policy or wish to exercise your legal rights, please contact us using the details set out in paragraph 10.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer the following categories of personal data:

• Identity Data: includes name, title, date of birth (where provided) and account login credentials.
• Identity Verification Data: if you sign a Memo or create one, a photo of your passport or driving licence and the details shown on it, which we use to verify your identity.
• Contact Data: includes postal address, email address and telephone number.
• Financial Data: includes payment information, transaction records and billing details.
• Transaction Data: includes details of your purchase of a Lifetime Transfer Memo, payment history and correspondence relating to your order.
• Technical Data: includes IP address, browser information, operating system, device information, website usage information.
• Profile Data: includes username and password, account preferences.
• Memo Data: includes the information you give us to create your Lifetime Transfer Memo, such as details of the gift, when it was made, who gave it and who received it and the reasons for it, and the electronic signatures of the people who sign it.
• Usage Data: includes information regarding how you use the platform and related services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
• Special Category Data: in limited circumstances, information entered into a Lifetime Transfer Memo may contain special category personal data concerning the person making the gift or beneficiaries (for example health information or information revealing religious beliefs). We do not actively request such information, but it may be included by users. Where special category personal data is processed, we will ensure that a lawful basis and an applicable Article 9 condition under UK GDPR are satisfied.
• Personal Data of Third Parties: the Lifetime Transfer Memo may contain information relating to: recipients of gifts; potential beneficiaries; family members; legal advisers; and financial advisers. You must only give us information about other people if you are entitled to do so.
• If you are named in a Memo. If someone has included your details in their Memo (for example, because you gave or received a gift recorded in it), we hold your information as part of that Memo for the purposes described in this privacy policy. If you are invited to sign a Memo, we will give you a link to this privacy policy when we contact you. We rely on our legitimate interests, and those of the person who created the Memo, in keeping an accurate record of lifetime gifts. If you are not invited to sign a Memo through our site, we do not usually contact you, as this would involve disproportionate effort. You have the rights set out in paragraph 9.

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific feature of the platform.

3. How is your personal data collected?

We collect personal data through:

Direct interactions

You may provide personal data when you:

• create an account;
• complete a Lifetime Transfer Memo;
• sign a Memo you have been invited to sign, including verifying your identity;
• purchase services through the platform;
• contact us;
• request support;
• subscribe to updates.

Referrals from professional advisers

You may be referred to Intentia by a solicitor, financial adviser, accountant, will writer or other professional adviser. Where this occurs, we may receive your contact details and referral information from that adviser.

Automated technologies

As you interact with the website, we may automatically collect Technical Data using cookies, server logs and similar technologies.

Third-party service providers

We may receive information from payment providers, hosting providers, analytics providers and our identity verification provider.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

We may send service-related communications concerning your account or transaction.

Where we wish to send marketing communications, we will obtain consent where required by law.

Third-party marketing. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

You can ask us to stop sending you marketing communications at any time by following the opt-out links in any marketing communication sent to you, by contacting us (see paragraph 10).

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example order confirmations and updates to our terms or this privacy policy.

Special Category Data

Where special category data is processed, we will rely on:

1. your explicit consent, which we will ask for when you complete your Memo, if it is likely to include special category data; and
2. the establishment, exercise or defence of legal claims, where a gift is questioned.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

5. Disclosures of your personal data

We may share your personal data with:

• the adviser who referred you to Intentia, where you have authorised us to share your Memo with them;
• the other person named in your Memo, when you invite them to sign it;
• your personal representatives, and the parties to any dispute about your gifts and their advisers, where your Memo is needed as evidence;
• Octopus Legacy, where you have agreed that we can pass your details to them;
• payment processors;
• cloud hosting providers;
• IT support providers;
• software providers;
• our identity verification provider, Stripe;
• professional advisers to IDR Law Limited;
• regulators, courts and law enforcement agencies where required by law;
• third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our third-party service providers may store or process personal data outside the UK.

Where transfers outside the UK occur, we will ensure appropriate safeguards are in place, including:

• UK adequacy regulations;
• the International Data Transfer Agreement (IDTA);
• the UK Addendum to the EU Standard Contractual Clauses.

To obtain a copy of these safeguards, please contact us using the details in paragraph 10.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

As a general rule:

• customer, financial and transaction records will be retained for at least six years after the end of the customer relationship;
• platform usage and technical data may be retained for shorter operational periods;
• records may be retained for longer where necessary to establish, exercise or defend legal claims.

Given the evidential purpose of the Lifetime Transfer Memo, copies of completed memos may be retained for a longer period where reasonably required.

We keep your completed Memo for six years from the date it is completed. If you start a Memo but do not complete it, we delete it 30 days after you last worked on it. We keep copies of identity documents used to verify a signature for six years.

In some circumstances you can ask us to delete your data: see paragraph 9 for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see Direct marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details in paragraph 10.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: [email protected]
• Postal address: IDR Law Limited, 46 Tower Street, Harrogate, North Yorkshire, England, HG1 1HS

11. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can find our complaints form here https://ico.org.uk/make-a-complaint/.

12. Changes to the privacy policy and your duty to inform us of changes

We may update this privacy policy from time to time.

The latest version will always be published on the website. This version was last updated on 16 October 2026.

Please ensure the personal data we hold about you remains accurate and up to date.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.