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Privacy Policy

  1. The data we collect about you and how we collect it.
  2. How we use your Personal Data
  3. Disclosures of your Personal Data
  4. International transfers
  5. Data security
  6. Data retention
  7. Your legal rights

Introduction

This Privacy Policy is applicable to Affordable Funerals (AF), a company registered in England and Wales with company registration number 10119791 and registered office address at The Pool House, Bicester Road, Stratton Audley, Bicester OX27 9BS.

This is AF’s privacy policy and in it, we refer to AF as AF, “we”, “us” or “our”. The term “you” or “your” refers to the individual interacting with us and/or applying for or using our services and may also refer to those personnel working for funeral directors who also contact us.

AF respects your privacy and is committed to protecting your Personal Data. This privacy policy (“Policy”) explains how we use the personal information you give us when you interact with us, use our website at low-cost-funeral.co.uk, or any subdomain or any such related website for such website (together the “Website”), or when you make an application to us (whether directly or via a funeral director) for services.

This privacy policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We may update this Policy from time to time.

This website is not intended for children and we do not knowingly collect Personal Data relating to children.

Controller

AF will be a data controller in relation to the personal data collected and processed from you. Any information that is collected by us is shared and held by us in accordance with this Policy. As a data controller, we are responsible for, and control, the processing of your Personal Data in accordance with the General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018 (Act) and any other applicable law in the United Kingdom relating to data protection and / or privacy. “Personal Data” means any information that identifies or makes identifiable a natural (living) individual.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights, please contact the data privacy manager using the following details:

Email address: JPeirson@memoria.org.uk

Postal address: The HR Manager, Affordable Funerals, The Pool House, Bicester Road, Stratton Audley, Oxfordshire, OX27 9BS

Telephone number: 01869 695131

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( website at : www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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

We keep our privacy policy under regular review. This version was last updated on 22 April 2021. Historic versions may be viewed here.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Please note that the display of any hyperlink and/or reference to any third-party website, system, product or service does not mean that we endorse that third party’s website, products or services and any reliance you place on such hyperlink, reference or advert is done at your own risk. Clicking on those links or enabling those connections may allow third parties to collect or share (personal) 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.

  1. The data we collect about you and how we collect it

Personal Data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

When you use our services, the web-booking portal, the Website, or otherwise deal with us (including where you have made an application via a Funeral Director), we may collect the following Personal Data about you either through direct interactions with you, from third parties or using technologies:

1.1. personal information including first and last name and contact information including current residential address, primary email address and/or primary phone number;

1.2. technical information including IP address, operating system, browser type and related information regarding the device you used to visit the Website, the length of your visit and your interactions with the Website;

1.3. information obtained through our correspondence and monitoring in accordance with clause 1.5 below; and

1.4. details of any enquiries made by you through the Website, together with details relating to subsequent correspondence (if applicable).

1.5. we may monitor your use of the Website through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the Website. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. See below for further information on our use of cookies.

Occasionally we may receive information about you from other sources, for example from any third-party websites and applications that integrate or communicate with our Website in relation to you. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending our or third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer Personal information Performance of a contract with you
To operate, administer and provide our services to you.

To contact you to arrange the collection of cremated remains in accordance with your wishes.

Technical information

Personal information

Performance of a contract with you and to be able to provide services contracted for
To process information of personnel at Funeral Directors in order to provide our services. Personal information Legitimate interests in running our funeral and crematorium services and co-ordinating services with funeral directors
To investigate and address any comments, queries or complaints made by you regarding the services provided by us. Personal information

Technical information

Performance of a contract with you and to enable us to provide services contracted for. Legitimate interests in running our funeral and crematorium service, subject to your rights in clause 11.
To operate, administer, maintain, provide, analyse and improve the Website and the services available through the Website.

To ensure that content from the Website is presented in the most effective matter for you and your device.

To conduct research, statistical analysis and behavioural analysis (including anonymizing data for these purposes).

To provide insights based on aggregated, anonymous data collected through the research and analysis.

To notify you about changes to the Website.

To allow you to participate in interactive features of the Website, including inputting information.

Technical information

Personal Information

Performance of a contract with you and to enable us to provide services contracted for. Legitimate interests in running our funeral and crematorium service, subject to your rights in clause 11.
To disclose your information to selected third parties as permitted by this Policy. Personal information

information relating to the product or services you require

Legitimate interests in running a funeral and crematorium service, also subject to your continued consent to the processing of your data for that purpose (see ‘Marketing and opting out’ below).

 

Performance of a contract with you : To enable investment in life insurance policies in relation to funeral plans you have entered into with us.

Where required by (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity. Personal information

Technical information

Legal obligations
To contact you for marketing purposes by both LCF and third parties. Personal information

information obtained from correspondence or through technologies (cookies), marketing information

Where you have consented to the use of your personal data for this purpose.

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Where you are a funeral director dealing with us in your professional capacity on behalf of a limited company or LLP, for business purposes, then we may contact you by email to your corporate email address about similar or related products that we offer. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).

Where you have previously ordered products or services from us we may contact you by telephone and post about similar or related products, services, promotions and special offers that may be of interest to you. We will inform you (during the sale process) if we intend to use your data for such purposes and give you the opportunity to opt-out of receiving such information from us. In addition, and if you have given permission, we may also contact you by mail and telephone about our other products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such additional marketing purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).

We will get your express opt-in consent before we use your Personal Data for marketing purposes or share your Personal Data with any third party for marketing purposes. If you have given permission, we may use your Personal data for marketing to you and share your Personal Data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) by mail, telephone and email about products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to ourselves use, or disclose your data to third parties, for such purposes. If you prefer not to receive direct marketing communications from us or our business partners, or you no longer wish to receive them, you can opt out at any time (see below).

You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to info@low-cost-funeral, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively, you can follow the unsubscribe instructions in emails you receive from us or them.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving marketing messages, this will not prevent other uses of your Personal Data made by AF on other legal bases and for other purposes.

Cookies

For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your Personal Data

We may share your Personal Data with the third parties set out below for the purposes set out in the table above, always subject to entering into the appropriate data processing or data sharing agreements with them.

  1. Memoria Limited or its group companies, where this is necessary for us to perform the services contracted for and where we believe it is in our legitimate interests to do so and have conducted an impact assessment to evaluate whether our proposed sharing of your Personal Data will cause harm to your interests.
  2. Life insurance policy providers, being The Royal London Mutual Insurance Society Limited and Scottish Friendly Assurance Society.
  3. Third Parties for marketing purposes, only with your express permission. The third parties will be notified to you at the time of requesting your consent.
  4. Third parties to whom we may choose to sell, transfer or merge part of, or the whole of, our business or our assets. The new owner may use your Personal Data in the same way as set out in this privacy policy.

 

  1. International transfers

We do not usually transfer your Personal Data outside the UK, however if you require funeral arrangements that involve an international element, it may become necessary to transfer Personal Data outside the UK to provide our services to you.

As such transfers of Personal Data are not routine or regular, we do not have particular contractual arrangements in place with the recipients of the Personal Data, and therefore will rely on either (i) the explicit consent of the data subject to the transfer of their Personal Data out of the UK or (ii) where the data subject is also the person we are contracting with, we may transfer their Personal Data on the basis of necessity in order to perform our services under the contract.

You should be aware that when we transfer your Personal Data out of the UK to a territory outside the EEA where there is no “adequacy” decision granted, we cannot guarantee that the receiving party will provide the same degree of protection to your Personal Data as is provided in the UK (or the EEA).

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK.

  1. 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 and professional advisers 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.

  1. Data retention

By law we are required to keep your information for a period of 15 years from the date the services are provided to you, to comply with legal and regulatory obligations which we are subject to. Whilst you have the legal right to ask us to stop processing your information for direct marketing purposes (as further detailed in this Policy), we may still be required to hold your information in accordance with this Policy for the purposes of complying with our legal or regulatory obligations.

Where we hold information based on your express consent and have no other legal basis for holding your information, we will keep it until consent is withdrawn.

If required, we will be entitled to hold information for longer periods in order to comply with our legal or regulatory obligations.

In some circumstances you can ask us to delete your Personal Data: see your legal rights below 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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. This section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us giving us enough information to identify you and respond to your request.

  1. You have the right to request access to information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
  2. You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the information that you have provided changes, or if you become aware of any inaccuracies in such information, please let us know in writing giving us enough information deal with the change or correction.
  3. You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case, we will let you know.
  4. You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing.
  5. You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is available where processing is carried out by automated means and applies to Personal Data you have provided to us, and where the Personal Data is held in reliance on “consent” or “Performance of a contract” as the legal basis for our processing. If you request the right to data portability and it is not available to you, we will let you know.
  6. You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
  7. You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we will let you know.
  8. You have the right to object to direct marketing.

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.

How this web site uses cookies

Session Cookies

This web site sets temporary “Session” cookies, essential for the operation of the web site which are used to ‘remember’ session specific information only during the time that a user is using the web site. These cookies are deleted when you close your browser. No personally identifiable information is stored in these cookies once you have closed your browser and your browser has cleared its cache. These are ‘Category 1’ cookies within European legislation.

Please note that your own browser settings can cause session cookies to persist, even after you close your browser.

Google

Google Analytics and other Google Products use cookies to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site and to help serve relevant on-line advertisements. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

For more information on the use of Google cookies visit https://policies.google.com/.

By using our website and online services, you agree that we can place these types of cookies on your device.

Bing

Microsoft Bing uses cookies to collect information about how visitors find our site. We use the information to compile reports and to help us improve the site and to help serve relevant on-line advertisements. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

For more information on the use of Microsoft Bing cookies visit https://privacy.microsoft.com/en-gb/privacystatement.

By using our website and online services, you agree that we can place these types of cookies on your device.

Hotjar

When someone visits this web site, Hotjar may collect standard internet log information and details of visitor behaviour patterns. This is to find out things such as the number of visitors to the various parts of the site. This information is collected in a way which does not personally identify anyone.

For more information on the use of Hotjar cookies visit https://www.hotjar.com/legal/policies/cookie-information.

By using our website and online services, you agree that we can place these types of cookies on your device.

AddThis

We allow visitors to our website to bookmark and share content via a number of bookmarking and social media sites like Facebook, LinkedIn and Twitter through a service called AddThis. Visitors can choose to use this service and, when this is used, AddThis sets cookies in the visitors’ web browser.

For more details visit the AddThis support page at https://www.addthis.com/privacy.

By using our website and online services, you agree that we can place these types of cookies on your device.

What is a cookie?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

You can find more information about cookies by visiting www.allaboutcookies.org or www.youronlinechoices.eu

Cookies are defined in four categories:

Category 1 – Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features. Without these cookies essential services like shopping baskets, e-billing, secure areas of the web site etc. cannot be provided.

Category 2 – Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. We use these cookies to help us to improve how our website is found and works.

By using our website and online services, you agree that we can place these types of cookies on your device.

Category 3 – Functionality Cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personalised features.

By using our website and online services, you agree that we can place these types of cookies on your device.

Category 4 – Targeting Cookies or Advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Our web site does not use these cookies.

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