Lifetime Guardians™ Privacy Policy

This Privacy Policy explains how personal information is collected, used, stored, shared and deleted in connection with Lifetime Guardians™ and the Lifetime Guardians Document Care Service™.

It applies to personal information processed through the Service.

This Privacy Policy explains how personal information is handled. It does not itself constitute consent. Where consent is legally required for a particular activity, it will be requested separately.

1. Definitions

In this Privacy Policy:

BTIC means BTIC, trading as Brian Tracy International Club by Paul Martin.

Estate Planning Professional means the Estate Planning Professional associated with the relevant Lifetime Guardians™ arrangements and identified on the Lifetime Guardians™ document.

Parent means the person using Lifetime Guardians™ to put arrangements in place concerning their minor child or children.

Participant means a person nominated or invited to take part in Lifetime Guardians™ arrangements, including a guardian, trusted person or witness.

Service means Lifetime Guardians™ and, where applicable, the Lifetime Guardians Document Care Service™.

User means any person using the Service, including a Parent, Grandparent, Participant, a person who knows a Parent and introduces them or Estate Planning Professional.

2. Data Controller and Data Processor

The Estate Planning Professional associated with the relevant Lifetime Guardians™ arrangements:

- is the Data Controller for personal information processed for the purpose of providing and maintaining those arrangements

- is identified on the relevant Lifetime Guardians™ document

- determines the purposes for which personal information is processed and is responsible for its obligations as Data Controller under applicable data-protection law

- instructs BTIC to operate the Lifetime Guardians™ infrastructure and processing activities on its behalf.

For those activities, BTIC:

- acts as Data Processor and processes personal information on the documented instructions of the Data Controller

- operates the technology, workflows, communications, document-production processes, User administration, Lifetime Guardians Document Care Service™ and operational privacy processes used to provide the Service

- uses third-party technology providers to carry out processing required to operate the Service

Data Controller:
JP Estate Planning - Privacy Policy Contact BTIC: Email - [email protected]

3. Personal information we process

The personal information processed depends upon the individual’s role and what is required for the relevant Lifetime Guardians™ arrangements.

It may include:

- name, address, email address and telephone number;

- date of birth where required;

- family and relationship information;

- information concerning children relevant to the arrangements;

- details of Users and their roles;

- information required to create, complete or maintain a Lifetime Guardians™ document;

- communications and responses;

- document and electronic-signature information;

- document status and completed documents;

- Lifetime Guardians Document Care Service™ preferences;

- information voluntarily provided when requesting optional information, reports, products, services or introductions; and

- limited technical and system information generated or required to operate and secure the Service.

Only information reasonably required for the relevant purpose should be processed.

4. Where personal information comes from

Personal information may be provided directly by the individual concerned.

It may also be provided by another User, including a Parent, Grandparent, Participant, a person who knows a Parent and introduces them, or the Estate Planning Professional.

For example, a Parent may provide the details of a Participant, or another User may provide a Parent’s details so that they can be contacted about Lifetime Guardians™.

Information may also be generated through the operation of the Service, including document status, communications and electronic-signature information.

Where personal information is obtained from somebody other than the individual concerned and Lifetime Guardians™ communicates with that individual, access to this Privacy Policy will be provided with the first communication.

Where no earlier communication occurs, the required privacy information will be provided within the period required by applicable law unless an exemption applies.

5. Why personal information is processed

Personal information may be processed to:

- provide and administer Lifetime Guardians™;

- contact Users;

- create, complete, sign and issue Lifetime Guardians™ documents;

- maintain active Lifetime Guardians™ arrangements;

- provide the Lifetime Guardians Document Care Service™;

- enable arrangements to be updated without unnecessarily repeating the complete process;

- provide service communications and reminders;

- notify a Parent where a Participant does not proceed or withdraws, provided BTIC is notified;

- respond to requests and questions;

- operate, maintain and secure the Service;

- prevent misuse;

- administer privacy rights and complaints;

- maintain proportionate operational, audit and compliance records;

- comply with legal obligations;

- establish, exercise or defend legal claims; and

- respond where an individual actively requests optional information, reports, products, services, introductions or other assistance.

Some information is necessary to create, complete or maintain a Lifetime Guardians™ arrangement.

If required information is not provided, the relevant document, process, update or Service may not be capable of completion.

6. Lawful bases for processing

The lawful basis depends upon the purpose of the processing and the individual’s relationship with Lifetime Guardians™.

Legitimate interests: Processing may be necessary to provide and administer Lifetime Guardians™, manage Participants, contact individuals whose details have been supplied as part of an arrangement, maintain current arrangements, operate the Lifetime Guardians Document Care Service™, protect the Service, prevent misuse and maintain proportionate operational and compliance records.

Those interests are considered against the rights and interests of the individuals concerned.

Legal obligation: Personal information may be processed or retained where necessary to comply with applicable law.

Consent: Where applicable law requires consent for a particular activity, consent will be requested separately. Where processing relies upon consent, that consent may be withdrawn.

7. Information concerning children

Lifetime Guardians™ necessarily processes personal information concerning children because the Service relates to arrangements made for minor children.

Children’s personal information is processed only where reasonably required for the relevant Lifetime Guardians™ arrangements.

Children’s personal information is not used to market products or services directly to children.

8. Automation and artificial intelligence

Lifetime Guardians™ is designed as an automated online service.

The Service may use automated workflows, artificial intelligence and other technology in processing personal information required to operate the Service.

These systems may assist with collecting and organising information, communications, document production and maintenance, electronic signing, answering questions and producing requested information or reports.

The Service does not use solely automated processing to make legal or similarly significant decisions about individuals.

9. Optional requests and direct marketing

Lifetime Guardians™ may make optional information, reports, products, services or introductions available.

Where an individual actively requests something, personal information voluntarily provided may be processed for the purpose of responding to that request.

Where an independent provider is required to respond, relevant personal information may be provided to that provider. This will be explained and any consent or other permission required by law will be obtained.

An independent provider receiving personal information for its own purposes may become a separate Data Controller for that information.

Participation in Lifetime Guardians™ is not treated as unrestricted permission to send unrelated direct marketing or disclose personal information for unrelated marketing purposes.

Where electronic direct marketing requires consent or another particular condition under applicable law, that requirement will be followed.

Individuals may object at any time to their personal information being used for direct marketing.

10. Technology providers and information sharing

The Service currently uses third-party technology including:

- HighLevel/GoHighLevel for continuing Lifetime Guardians™ records, communications and workflow infrastructure.

- Make for automation and authorised movement of information between systems.

- Airtable for temporary processing required during aspects of document production.

- Signable for electronic signatures and document completion.

Personal information may also be made available where reasonably necessary to:

- the relevant Data Controller;

- BTIC as Data Processor and operator of the Service;

- Parents or Participants where information is genuinely required for the relevant arrangements;

- legal, regulatory or governmental authorities where required by law; and

- an independent provider where an individual has requested information, assistance, a product, service or introduction requiring that provider’s involvement.

Technology providers may change where reasonably necessary to operate Lifetime Guardians™.

Lifetime Guardians™ does not make personal information available as an unrestricted general marketing list.

11. Retention and deletion

Personal information will not be retained for longer than is necessary for the purpose for which it is processed.

Information required to provide and maintain an active Lifetime Guardians™ arrangement or the Lifetime Guardians Document Care Service™ may be retained while the arrangement, Service or relevant role remains active and the information remains necessary for that purpose.

Information used temporarily through Make, Airtable or Signable for automation, document production or electronic signing will be retained only for as long as it remains necessary for that processing. When the purpose has ended and there is no other lawful reason to retain the information in that system, it will be deleted from ordinary operational use.

Information relating solely to an incomplete or abandoned process will be retained only while there remains a reasonable purpose for administering or attempting to complete that process. When that purpose ends and there is no other lawful reason for retention, the information will be deleted.

Where a Parent’s Service ends, completed documents and personal information held solely for those arrangements will be deleted when they are no longer required for any lawful purpose.

Ending a Parent’s own Service does not affect any separate role they may have as a Participant in another person’s active Lifetime Guardians™ arrangements. Information required for that separate role may continue to be retained for as long as it remains necessary for those arrangements.

Limited information may continue to be retained where reasonably necessary to comply with law, record a cancellation, withdrawal or objection, prevent unwanted future contact, deal with a privacy request or complaint, maintain a proportionate audit or compliance record, or establish, exercise or defend a legal claim.

Deletion from an active system may not result in immediate deletion from every encrypted backup or disaster-recovery copy independently maintained by a technology provider. Any residual copy remains subject to that provider’s controlled retention and security arrangements and is not retained for ordinary Lifetime Guardians™ operational use.

12. International processing and security

Lifetime Guardians™ uses established technology providers with compliant organisational and technical measures designed to protect personal information.

Personal information may be accessed or processed outside the United Kingdom. Where this constitutes a restricted transfer, the transfer is protected using the Information Commissioner's approved International Data Transfer Agreement (IDTA) - Copy here: 

13. Data-protection rights

Depending upon the circumstances and the processing involved, individuals may have rights including:

- access to their personal information;

- correction of inaccurate personal information;

- deletion where applicable;

- restriction of processing;

- objection to certain processing;

- data portability where applicable;

- withdrawal of consent where processing relies upon consent; and

- rights relating to automated decision-making where applicable.

These rights are subject to the conditions and exemptions contained in applicable law.

Where a Participant withdraws from an active Lifetime Guardians™ arrangement, the relevant Parent may need to be informed so that a replacement can be considered.

14. Privacy requests and complaints

BTIC operates the Lifetime Guardians™ support, privacy and complaints process, including operational work carried out on behalf of the relevant Estate Planning Professional.

Requests concerning personal information processed through Lifetime Guardians™ should be directed to:

Email: [email protected]

BTIC will carry out the operational steps required to deal with the request and involve the relevant Data Controller where legally necessary.

Where a request concerns personal information held independently by an Estate Planning Professional outside Lifetime Guardians™, it may need to be referred to that professional.

Privacy complaints should also be sent to the contact above.

An individual also has the right to complain to the Information Commissioner’s Office (ICO) where applicable.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version will be made available through the Service. Where applicable law requires additional notice or consent before new processing begins, that will be obtained as required.