Privacy Policy

1. Who we are

Independent Funeral Plans, a trading name of The Independent Funeral Partnership 2020 Ltd. operate this platform to enable independent funeral directors to offer a bespoke range of funerals and funeral plans for their customers.

To provide funeral directors and their clients with Independent Funeral Plans products and services, we need to collect and process information about the funeral directors and their clients.

You can contact us at:

Independent Funeral Plans
The Independent Funeral Partnership 2020 Ltd.
The Pool House Bicester Road,
Stratton Audley,
Bicester,
Oxfordshire,
England,
OX27 9BS

If you wish to contact our Data Controller you can do so by emailing support@independentfuneralplans.co.uk

2. Our Privacy Promise

Independent Funeral Plans is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it. It's important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.

This Privacy Policy explains:

• What information Independent Funeral Plans collects about you;
• How Independent Funeral Plans collects and uses information about you;
• Whether Independent Funeral Plans discloses your details to anyone else;
• The choices available to you regarding the personal information you provide to us; and
• When and how your data may be shared with third parties.

Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.

We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended and the General Data Protection Regulations (GDPR).

3. Your consent

Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by funeral directors.

Where you have given consent for Independent Funeral Plans to process your personal data you may withdraw consent at any time by emailing support@independentfuneralplans.co.uk. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.

If you have given consent for your details to be passed to a funeral directors or another third party your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.

4. What we collect and why

We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:

• Contract: To enter into a contract with you and fulfil our contractual obligations to you (e.g. to create and sell a funeral plan). This processing is necessary for us to provide the service you have requested including registering and managing your account and providing service updates and our support services.
• Consent: To provide information and take actions in relation to services which you have opted-in to receive.

We use the information we collect to:

• enable the performance of the contract you are entering into when using our service;
• provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services;
• provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email;

Independent Funeral Plans collects the following information when funeral directors set up an account:

Personal data including your name, address, email address, telephone number and mobile telephone number as well as, where relevant, data on your company to confirm your eligibility to use the platform

This data is collected to register your account and to configure your preferences as well as to send you service communications about your account.

Once you have registered and your account is approved you can edit your personal details in your account. Once you are logged-in to our Website in your use of the Website and your data will be handled in accordance with this Privacy Policy and the Cookie Policy.

We also collect additional personal data which may be generated as a result of the use of your account such as invoices and other records related to payments and transactions.

Independent Funeral Plans collects the following client information when creating funeral plans:

The title, forename, surname, full address and postcode, date of birth, phone number and email address for the plan holder, next of kin and plan holders representative if applicable.

This data is collected to create funeral plans and to manage our process as well as to send you service communications. We may share certain personal data, such as contact details, with funeral directors as part of our process.

5. Disclosure

Independent Funeral Plans will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:

• Information may be shared with people employed by Independent Funeral Plans and The Independent Funeral Partnership 2020 Ltd. where necessary for us to provide you with the products and services that you have signed up to receive.
• We use Independent Funeral Plans to handle sign up, The Independent Funeral Partnership 2020 Ltd. to handle invoicing and payments for certain services provided by Independent Funeral Plans and so we will share certain personal data with them in order for them to do this. In this context The Independent Funeral Partnership 2020 Ltd. operate as a data processor acting on behalf of Independent Funeral Plans
• We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third party platforms (e.g. Facebook). Information about your visit to the Website may be collected by these third-party providers on these pages. If you browse these pages whilst still also logged in to your account on the third-party platform, information collected by the third party may be connected to your account on the third-party platform. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
• Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our terms and conditions and any other agreements.
• If we sell or buy any business or assets, in which case Independent Funeral Plans may disclose your personal data to the prospective seller or buyer of such business or assets.
• We may share your personal information with The Independent Funeral Partnership 2020 Ltd.
• We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies and/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders.
• You acknowledge that we have a legitimate business interest in preventing the use of our platform or services in any manner that may facilitate fraudulent activity or deny consumers of their legal rights under the Consumer Protection from Unfair Trading Regulations 2008 or the Consumer Rights Act 2015. We may share any information that we collect about you and / or the plans that you create on our platform with third parties or their legal representatives to the extent necessary to prevent fraud or any adverse effect to those third parties consumer rights.

We are not responsible for any use of your personal data by these parties except where they act as our processor.

6. Your rights in relation to your personal information

You have the following rights in relation to the personal information Independent Funeral Plans processes relating to you. Where you exercise these rights, Independent Funeral Plans will provide information to you as to what action has been taken, if any, within 30 calendar days of receipt of your request. Where no action has been taken, Independent Funeral Plans will explain our reasons why.

Taking into account the complexity and number of requests, it may take Independent Funeral Plans up to 90 calendar days to respond to your request. Where Independent Funeral Plans intend to extend the deadline for responding, you will be informed within 30 calendar days of receipt of your request

6.1 Right of Access

You have the right to request access to the personal information that Independent Funeral Plans hold about you.

6.2 Rights in relation to inaccurate personal information

Where personal information that Independent Funeral Plans holds about you is inaccurate, you have the right to request that those inaccuracies are rectified. Taking into account the purposes for which the personal information is processed, you also have the right to have incomplete personal information about you completed.

6.3 Right to erasure

In certain limited circumstances, you have the right to request that Independent Funeral Plans erase personal information relating to you that Independent Funeral Plans holds. This right only applies if any one of the following circumstances applies:

• Where Independent Funeral Plans no longer require the personal information for the purpose(s) for which it was obtained or otherwise used.
• Where the processing is based on your consent, that consent has been withdrawn and there is no other legal ground for processing.
• Where you have exercised your right to object to the processing and there are no overriding legitimate grounds for the processing.
• Where you have exercised your right to object to the use of your personal information for direct marketing purposes.
• Where the personal information has been unlawfully processed.
• Where Independent Funeral Plans are required to erase the personal information in order to comply with a legal obligation.

The right does not apply where the processing of your personal information is necessary:

• For compliance with a legal obligation requiring Independent Funeral Plans to process your personal information or where the processing is necessary for the performance of a task carried out in the public interest
• For the establishment, exercise or defence of legal claims.

6.4 Right to restriction of processing

You have the right to request that Independent Funeral Plans restrict the processing of your personal information in the following circumstances:

• Where you have contested the accuracy of the personal information. In this case the processing of the personal information will be restricted for a period which enables Independent Funeral Plans to verify the accuracy of the personal information in question.
• Where the processing of the personal information is unlawful, and you have objected to the information being erased and have instead requested the restriction of its use.
• Where Independent Funeral Plans no longer needs the personal information for the purposes set out above but you require them for establishing, exercising or defending legal claims.
• Where you have objected to the processing of your personal information as set out above. In this case, processing of your personal information will be restricted pending verification of whether our legitimate grounds for continuing to process your personal information override your grounds for objecting.

Where processing of your personal information is restricted for any of the reasons above Independent Funeral Plans will not process it, with the exception of storage, unless:

• You have provided your consent,
• For the establishment, exercise or defence of legal claims,
• For the protection of the rights of another natural or legal person, or
• For reasons of important public interest.

Where Independent Funeral Plans have agreed to restrict the processing of your personal information, we will write to you to inform you that we will be lifting that restriction prior to doing so.

6.5 Right to data portability

This right only applies in the following circumstances:

• Where the personal information in question consists of information you have provided to Independent Funeral Plans
• Where the grounds for processing the personal information stated above are consent, explicit consent or for the performance of a contract or to take steps at your request prior to entering into a contract, and
• The processing of the personal information is carried out via automated means.

Where this right applies, you have the right to receive your personal information in a structured, commonly used and machine-readable format. You also have the right to transmit that information to another data controller or, where possible, directly from Independent Funeral Plans to another controller.

6.6 Right to object to processing

You have the following rights in relation to objecting to the processing of your personal information by Independent Funeral Plans:

6.6.1 Right to object to processing

You have the right to object to the processing of your personal information at any time, on grounds relating to your particular situation. This only applies where the grounds for processing are:

• The processing is necessary for the purposes of legitimate interests pursued by the data controller or by a third party, or
• Processing is necessary for the performance of a task carried out in the public interest

6.6.2 Right to object to processing for the purposes of direct marketing

You have the right to object specifically to the processing of your personal information for the purposes of direct marketing. If you object to the processing of your personal information in this way, then Independent Funeral Plans will no longer process it for that purpose.

6.7 Rights in relation to automated decision making & profiling

You have the right not to be subjected to a decision based solely on automated processing, including profiling which would legally affect you or significantly affect you. However, this right will not apply if the decision:

• Is necessary for the entering into, or performance of, a contract between you and Independent Funeral Plans
• Is authorised by or under any law to which Independent Funeral Plans is subject, or
• Is based on your explicit consent.

6.8 Right to complain to the Information Commissioner's office

Where you believe that Independent Funeral Plans has failed to properly comply with its obligations in respect of your personal information, including your rights as set out above, you can complain to the Information Commissioner.

The Information Commissioner's Office's address is:

The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can find more information about their role and how to submit a complaint on their website: www.ico.org.uk.

7. 'Cookies' and related software

7.1 Our software may issue ‘cookies’ (small text files) to your device when you access and use the Website and you will be asked to consent to this at the time (e.g. when you first visit our website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.

7.2 Our Website uses cookies and other tracking and monitoring software to: distinguish our users from one another; collect standard Internet log information; and to collect visitor behaviour information. The information is used to track user interactions with the Website and allows us to provide you with a good experience when you access the Website, helps us to improve our Website, and allows us to compile statistical reports on Website visitors and Website activity.

7.3. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of our Website features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.