How we look after your data.

Bequest offers two categories of product.

• 01
  (a) Legal documents
  Wills, Enduring Powers of Attorney, and Advance Medical Directives. When you use Bequest for these documents, you enter into two contractual relationships. The first is with Bequest, for the technology platform. The second is with Patricia Ho and Associates ("PHA"), an independent Hong Kong solicitors' firm, for the legal services. Your personal data is processed by both Bequest and PHA, each as an independent data user under the PDPO. PHA's handling of your personal data is governed by PHA's own privacy notice, which will be provided to you when you engage PHA.
• 02
  (b) Non-legal documents
  Final Wishes. This is a personal document expressing your wishes and is not a legal instrument. It is provided by Bequest alone. PHA is not involved. Your data is processed only by Bequest.

Bequest Limited (“Bequest”, “we”, “our”, “us”) operates bequest.love, a life planning platform. Our platform guides users through creating estate planning documents using solicitor-reviewed templates designed for use in Hong Kong.

Bequest Limited is a data user for the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). This Notice explains how we collect, use, store, and share your personal data, and what rights you have under Hong Kong law.

This Notice applies to all users of bequest.love and any related services we provide. It does not apply to third-party services that may be accessible through our platform. Those services are governed by their own privacy policies. In particular, the handling of your personal data by Patricia Ho and Associates in the course of providing legal services is governed by PHA's own privacy notice.

We collect the following categories of personal data in connection with the products and services you use.

• 01
  Account and contact information
  Collected when you register and manage your account with us.
• 02
  Identity and verification information
  Required to produce estate planning documents under Hong Kong law.
• 03
  Estate planning instructions
  Information you provide in connection with the specific product or service you are using, including information about individuals you name in your documents.
• 04
  Payment and transaction information
  Associated with your use of paid services. Card and bank account details are processed directly by our payment processor and are not stored on Bequest systems.
• 05
  Usage and technical information
  Collected automatically through cookies and analytics technologies when you interact with our platform.

Information about other individuals.

Some of our products require you to provide personal information about other people, such as individuals you name in your estate planning documents. When you provide another person's personal data to us for the purpose of completing your document, Bequest processes that data solely for the purpose of preparing your document as instructed by you. We do not use that data for independent purposes and we do not contact those individuals. This limited processing is consistent with Bequest's obligations under DPP1(3) of the PDPO.

We collect personal data through the following means.

• 01
  Directly from you
  When you create an account, complete a product workflow, make a payment, submit an enquiry, or contact us for support.
• 02
  Automatically through your visit
  Through cookies and analytics technologies when you visit or interact with bequest.love. See Section 08 for details.
• 03
  From third parties
  Only where you have directed us to receive data on your behalf, or where permitted by applicable law.

We share personal data only in the circumstances described below. We do not sell personal data to third parties, and we do not share personal data for third-party direct marketing without your explicit consent.

• 01
  Patricia Ho and Associates
  For legal documents (Wills, EPOA, AMD), we share your personal data with Patricia Ho and Associates ("PHA"), an independent Hong Kong solicitors' firm, as necessary for PHA to review and witness your documents and provide legal services to you. Bequest and PHA are independent data users. PHA's handling of your personal data is governed by PHA's own privacy notice, which will be provided to you when you engage PHA.
• 02
  Cloud infrastructure
  Your data is stored on servers operated by Google Cloud Platform in the Asia region. Google operates as a data processor on our behalf and is contractually bound to protect your data.
• 03
  Payment processing
  Payment transactions are handled by Stripe, Inc. Stripe processes card and payment data under its own privacy policy. Bequest does not store card details.
• 04
  Legal requirements
  We may disclose personal data where required by law, court order, or a regulatory authority with applicable jurisdiction. Where permitted, we will notify you before any such disclosure.

Your personal data may be processed or stored outside Hong Kong by our cloud infrastructure and payment processing service providers. While section 33 of the PDPO, which would restrict cross-border transfers of personal data, is not currently in force, the data protection principles under the PDPO apply to personal data wherever it is processed.

We follow the Privacy Commissioner's Recommended Model Contractual Clauses for Cross-border Transfer of Personal Data (May 2022 Guidance) as best practice. Where personal data is transferred outside Hong Kong, we take steps to ensure it receives a comparable level of protection to that required by the PDPO, including contractual safeguards with our service providers.

If you would like further information about our cross-border transfer safeguards, please contact us at Hello@bequest.love.

• 01
  Account information
  Retained while your account remains active. If you close your account, your contact and profile information is deleted within 12 months of account closure, subject to the exceptions below. This retention period allows for account reactivation and resolution of any post-closure matters.
• 02
  Legal document content and estate planning instructions
  Given the long-term nature of estate planning, where a will may need to be located and produced through probate decades after it was signed, we retain your completed legal documents and the instructions you provided to create them for the duration of your account and for a period of 50 years following account closure or your confirmed passing, whichever is later. This reflects the legitimate purpose of ensuring your documents remain accessible to your executors and beneficiaries.
• 03
  Final Wishes content
  Retained for the duration of your account and for a period of 7 years following account closure, unless you request earlier deletion.
• 04
  Payment records
  Retained for 7 years from the date of transaction in accordance with Hong Kong revenue law requirements.
• 05
  Usage and analytics data
  Retained in aggregated form for up to 26 months. Individual-level data is deleted or anonymised within 14 months.

You may request deletion of your account and associated personal data at any time by contacting us at Hello@bequest.love. We will honour deletion requests subject to the retention periods set out above and any overriding legal obligations.

You can manage your cookie preferences through our cookie consent tool when you first visit the site, or at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the platform.

To exercise your rights, contact us at Hello@bequest.love. Please provide sufficient information for us to identify your account and verify your identity.

With your consent, we may send you promotional emails, product updates, and educational content about estate planning. We will obtain your consent separately before including your personal data in any direct marketing activity, in compliance with Part 6A of the PDPO (ss. 35C to 35H).

You may withdraw your consent to receive marketing communications at any time by:

• 01
  Clicking the unsubscribe link in any marketing email we send you.
• 02
  Adjusting your communication preferences in your account settings.
• 03
  Contacting us at Hello@bequest.love.

Withdrawal of consent does not affect the lawfulness of any marketing sent before the withdrawal, and does not affect service communications which we may continue to send in connection with your account.

We implement technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls and role-based permissions, and regular security reviews of our systems.

Despite these measures, no internet-based system can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us immediately if you believe your account has been compromised.

Given the particularly sensitive nature of estate planning data, we apply additional safeguards to legal documents stored on our platform, including access logging. Where document content requires review by a qualified solicitor as part of the legal services provided by Patricia Ho and Associates, access is restricted to authorised PHA personnel.

We may update this Privacy Notice from time to time to reflect changes in our services, our data practices, or applicable law. The date at the top of this page shows when this Notice was last updated.

Where we make material changes to how we collect, use, or share your personal data, we will notify you by email or through a prominent notice on our website before the changes take effect. Continued use of our platform after that date constitutes acceptance of the updated Notice.