This privacy notice sets out details of the information we collect about you, how we may use it, how we ensure its kept secure, who we share it with, and what rights you may have in respect of that information.
- We mainly use your personal information to provide our services to you, to meet our legal obligations, and to help improve our interests.
We only want to hold as much personal information as we need to do the above.
- We want our personal information relationship to be reciprocal where we both benefit and not be an exploitative one.
- Where we share your data, we only do so with organisations who have a right to see it or offering you a requested quote and who will use it fairly.
- We take security seriously.
- You can contact us at any time about anything relating to this notice or the information we hold about you, you can do this by emailing: firstname.lastname@example.org
Who we are:
We are registered with the Information Commissioners Office (‘ICO’) under registration number ZA298415.
Information we collect and why.
The basis of why we are using your information
We will only use your personal information where:
We have your consent
For example, we might rely on your consent in order to send you direct marketing communications. Where we do, you can withdraw your consent at any time by unsubscribing.
The purposes of our legitimate interests
These interests are set out below and we will only use such data where those interests are not outweighed by your own interests or fundamental rights and freedoms.
It's necessary for the performance of a contract
Either when we're preparing a funeral plan for you or the deceased or procuring a price for your funeral or to take steps as requested by you prior to entering a contract.
It's necessary for compliance with a legal obligation we have
The types of information we hold about you
Almost all the information we have is the information you've given to us. That might be when you build a funeral plan, product, service, offers or news from us via our website, emails, telephone conversations, and written and verbal communication.
Obviously, the types of information you give us will vary depending on the service you’ve requested but typically could include:
- name, address, and contact details
- We may also collect, use, store and transfer details about your will, executors and beneficiaries dependant on the nature of the service that we supply to you;
- details of products and services you've bought from us or, details about your health and medication, details of your end of life wishes and contacts for planning/editing and sharing your end of life wishes.
- details of your interactions with us through contact centres, online or by using one of our apps
- payment details
- call recordings
- information about how you interact with our communications
As well as obtaining information from you, we may also collect it from:
- someone else acting on your behalf who gives us the information directly
- publicly available sources such as social media and the electoral register
- fraud prevention and detection agencies, organisations and databases
- government and law enforcement agencies and regulators
- NHS organisations and systems such as your GP and Summary Card Record
- When using the funeral planner you may disclose Special Categories of Personal Data about you. This may include details about your
- race or ethnicity,
- religious or philosophical beliefs,
- sex life or sexual orientation.
- We do not collect any information about criminal convictions and offences.
It's also possible we might process other types of information that might be considered even more private, such as end of life notes, memories, photos and contacts that you have added to your account.
Sharing your personal information
When we share your information, we only do so in accordance with our legal, data protection and privacy obligations. Given the nature of the services that we deliver, dependant on your requests, we will at times have to share your personal data with the parties below in order to provide our services to you.
Your information may be disclosed to the following:
- Service providers. We use several other organisations who carry out work on our behalf to help us provide our products and services. We ensure any third parties we may share your data with have at least the same privacy and security standards as ourselves and will only use your information for the specific reasons we ask them to.
- Sub-contractors for the performance of any contracts we enter into with them or you;
- Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services;
- Funeral Directors or cremation providers;
- Finance Brokers;
- Estate Administration providers;
- Certainty – The National Will Register;
- Charities & Partner - if you are using a charity referral code, we share your email address with the charity in question. This is for reporting purposes only to allow us to record charitable commission donations and you will not be marketed to without specific consent;
- Executors of you or your loved ones will or residuary beneficiaries of the will (as appropriate)
- Funeral Directors. We will have the facility for you to request quotes for your bespoke funeral plan from our members, this is only if you wish for us to send them. In these instances, we will send your wishes to our members/requested funeral directors with the needed information to provide you with a quote for your funeral. This will be at your request.
- Companies, brands and businesses within Legacy of Lives Group. We may also share information throughout the Legacy of Lives for the reasons outlined such as core administration and activities that have been identified as being within our legitimate interests. We may also share information where we decide to restructure part of our business and, for example, we transfer responsibility for the services we provide to you to another business within the Legacy of Lives Group - these entities are the same as those listed as controllers in this notice.
- Credit reference agencies. For example, they may supply anti-fraud and credit-insight information to us.
- Social media companies and our advertising partners. For example, we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms
- Our professional advisors. For example, we may need to share information with our lawyers or auditors when they need it to give us their professional advice.
- Public authorities, agencies and other government bodies. For example, we might need to provide your information to the police or other bodies such as the DVLA, the NHS Business Services Authority or your GP.
- Potential corporate buyers. Where we consider selling any of our Legacy of Lives Group businesses or substantially all its assets to a third party outside the Legacy of Lives group. We may need to disclose documentation and other information that may include your personal information.
Marketing and interests
We always attempt to provide you with choices regarding certain personal data uses, particularly around marketing, guides, information and advertising.
We may use your details (as outlined above) to assist us to form a view on what you may, want or need, or what may be of interest to you. This is how we decide which services and offers from us or our partners that may be relevant for you.
You will receive marketing communications from us if you have signed up to our service or requested information from us, used our planner or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at email@example.com or by following unsubscribe links on any marketing message sent to you or by contacting us at any time.
We know that data security is important to you and it is therefore very important to us. We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including up to date virus software and personal protection on our computers and devices. 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 in accordance with this policy 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.
Data storage and how long we keep your records and data
We only keep your information for as long as it's needed for each of the activities we’ve identified in this Notice, as well as for as long as required in connection with our legal or regulatory obligations.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. For certain services that we deliver, we may hold your data for extended periods of time for example our will-writing or pre-plan services where data may be held for the duration of your lifetime.
In some circumstances we may 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.
Transferring your information outside the European Economic Area (EEA)
If we do transfer your personal information to other jurisdictions, we will take proper steps to ensure that your information is as equally protected as in the UK, such as entering into "standard data protection clauses" with the recipient. These are clauses that have been approved by the European Commission for such transfers.
However, we currently do not transfer your personal data outside the European Economic Area (EEA), this will only be in the instances that the funeral that the user is planning maybe based outside of the EEA.
Your rights about how your personal information is handled
Data protection laws provide you with several rights as set out below.
Right to access your personal data
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to access the ICO website to find out more about these rights:
Right to rectification
You may ask us to rectify any inaccurate information we hold about you.
Right to erasure
You may ask us to delete your personal information.
Right to restriction
You may ask us to restrict the processing of your personal information in certain circumstances.
Right to object
You may object to our processing of your personal information in certain circumstances.
Right to withdraw consent
Where our processing of your personal information is based on your consent, you may withdraw this consent at any time, although this won’t affect the lawfulness of any prior processing where we relied on your consent.
All of the above rights can be requested via firstname.lastname@example.org and our team will do their upmost to assist you with your requests.
We may charge a fee, if
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may request a small admin charge if your request is clearly unsubstantiated, repetitive or disproportionate. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within28 business days. Occasionally it may take us longer than a this if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
You may request confirmation that we hold personal data about you, as well as access to a copy of any such data via email@example.com
Right to make a complaint
You may make a complaint about our processing of your personal data by contacting us via the contact details provided in this Notice. While we hope that we would be able to address any issues you have in respect of this processing, you may also make a complaint to the UK’s data protection regulation - visit the Information Commissioner’s Office.
If you would like to exercise any of your rights, please contact us using the contact details set out below.
Sometimes we use your personal information in automated processes to make decisions about you, or to create a profile of you. If you are a Member, we may also generate a profile, which is designed to provide benefits such as discounts on Legacy of Lives products and services. Our use of automated decision making, for example in respect of our products, is to help ensure that decisions are made accurately, fairly and efficiently.
How you can contact us
To find out what personal information we hold about you, print a subject access request form, fill it in and send it by post to:
Data Protection Team,
The Fuel Tank A4
London SE8 3LE
Changes & updates to this Privacy Notice
We encourage you to check back regularly.