Pure Cremation Privacy Policy
We value your privacy, so our privacy notice provides you with the transparency you need to understand how we use your personal information lawfully, what your rights are, and how to contact us if you have any concerns.
- Who we are
- Information we collect
- Lawful basis for processing
- What we use your information for
- Who we share your information with
- Marketing
- Cookies
- International data transfers
- How long we keep your data
- Your rights
- How to contact us
12. Complaints
Pure Cremation Group is a leading financial services provider in Great Britain focusing on funeral planning and insurance and providing funerals.
When we refer to ‘we’ or ‘us’ or ‘our’ in this notice, we mean one or more of our companies within the Pure Cremation Group trading as Pure Cremation, Pure and Funeral Plan Compare, who act as a data ‘controller’:
- Pure Cremation Group Limited (10723077)
- Pure Cremation Limited (09703301)
- Pure Cremation Funeral Planning Limited (09906976)
- Pure Life Financial Services Limited (13149243)
The registered office for Pure Cremation Group Limited, Pure Cremation Limited, and Pure Cremation Funeral Planning Limited is Charlton Park Crematorium, Charlton Down, Andover, England, SP11 0TA.
The registered office for Pure Life Financial Services Limited is Eagle House, Joule Road, Andover, England, SP10 3UX.
We, or our third-party service providers, may obtain the following categories of information about you for our purposes listed in section 4 What we use your information for:
- Name and contact details
- Date of birth
- Employment status
- Marital status
- Nominated representative or applicant name and contact details
- Details of your interaction with us through our contact centres via audio recordings
- Billing information including; signature, transaction, bank account/card details
- CCTV images at our Premises
- Vulnerability information (which may include a health condition if you have disclosed this)
- Marketing consent preferences
- Your feedback
- Your interaction with our website
We obtain information the following ways:
- When you, or someone else acting on your behalf, provide us with your information when requesting a quote online, by telephone, or by post.
- When you purchase our products and services.
- When you use our websites or social media. For more information about website cookies see section 7 Cookies.
- From third party data marketing service providers.
- When you submit a job application.
- Survey questionnaires
We rely on the following lawful basis to process personal data for our purposes listed in section 4 What we use your information for:
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Legal Obligation |
The processing of your personal data is necessary for us to comply with the law. |
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Consent |
You have given clear consent for us to process your personal data for a specific purpose. |
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Contract |
The processing of your personal data is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract, for example to give you a quote. |
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Legitimate Interests |
The processing of your personal data is necessary for our legitimate interests or the legitimate interests of a third party, which we consider not to outweigh your privacy rights and interests. When relying on this basis, we will carry out a Legitimate Interests’ Assessment (LIA) to ensure we have weighed your interests and any risk posed to you, against our own business interests; ensuring that they are proportionate and appropriate. |
Special category data
Due to the nature of our services, we may need to process information relating to health. This type of data is more sensitive and known as special category data. We will only collect the minimum information necessary to identify potential vulnerabilities and additional communication requirements in line with our legal and regulatory obligations, and with your explicit consent.
We, or our third-party service providers, process personal data for the following purposes:
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Purpose |
Lawful Basis |
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Delivery of products and services requested by you. For example, when you purchase one of our products and services or ask us for a quote. |
Contract |
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Accounting and tax purposes. |
Legal Obligation |
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Legal, regulatory and compliance monitoring and reporting. |
Legitimate Interests; Legal Obligation |
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Quality assurance and training. We record the details of your interaction with our call agents for training, quality assurance, security and compliance monitoring purposes. |
Legitimate Interests |
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Profiling and marketing activities – see section 6 Marketing for more details. |
Legitimate Interests; Consent |
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To prevent and detect crime. |
Legal obligation. |
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Customer services queries and complaints handling. |
Legitimate Interests; Legal Obligation; contract |
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Regulatory and law enforcement requests. |
Legitimate Interests; Legal Obligation |
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Billing and mailing. |
Contract |
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Vulnerability assessment |
Legal Obligation |
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CCTV site security monitoring to ensure the safety of employees and clients and property. |
Legitimate Interests; Legal Obligation |
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To analyse our business performance and how you interact with us. |
Legitimate Interests |
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Market research and customer feedback surveys to help us improve. |
Legitimate Interests |
|
Billing and payments |
Contract |
When you request a product or service from Pure Cremation, you’re not obligated to provide your personal information, but it may mean we won’t be able to provide you with the service you want.
We may share your information with the following third parties:
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Our third-party service providers |
For example: · Logistics providers · IT and Cloud service providers · Printing fulfilment providers · Data marketing providers · Technical support providers · Social media and advertising partners · Sanctions and Politically Exposed Persons checks |
|
Regulators |
· Financial Conduct Authority (FCA) · Information Commissioner’s Office (ICO) Financial Ombudsman · Competition Markets Authority (CMA) |
|
Credit reference agencies |
Tracing and deceased record checks |
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Government or law enforcement |
· For example, we occasionally receive information requests from the police in relation to criminal investigations, to disclose CCTV footage. · Reporting suspected fraud to the National Crime Agency and Action Fraud. |
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Pure Cremation Group companies |
|
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An authorised person |
For example, a person with power of attorney; or someone you nominate to handle your affairs with you or on your behalf. |
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Buyers of our business |
In the event we decide to sell any of the group companies or assets. |
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Professional and legal advisers |
For example: · External auditors · Lawyers · Consultancy |
You can choose your preferred way to be contacted. For example, you can opt to receive communications by email, but not by text.
Post
We rely on the lawful basis ‘legitimate interests’ to send you details of our products and services by post. If you do not wish to receive these, let us know and we will add you to our suppression list to ensure you don’t receive any more. See section 11 How to contact us.
Email, text or telephone
We rely on the lawful basis ‘consent’ to send information about our product and services electronically. For example, where you have clearly opted in to indicate you’re happy to receive communications.
But if you're an existing customer, or have enquired about buying our products or services, for example, you've requested a quote, we will rely on the lawful basis ‘legitimate interests’ to contact you if you haven’t already stated you do not wish to be contacted.
We will always ensure that you are not registered with the Telephone Preference Service before calling.
You can opt out of receiving communications at any time by using the links provided in email or text communications; or by emailing, telephoning or writing to us. See section 11 How to contact us.
A cookie is a small file of letters and numbers that is downloaded onto your device (i.e. mobile, computer) when you visit a website. They’re widely used to make websites work, or work more efficiently, as well as provide website owners with information.
The rules on use of cookies also cover similar technologies for storing or accessing information, such as ‘flash cookies’ (small pieces of information stored and accessed by Adobe Flash) or ‘tracking pixels’ (snippets of code embedded in web pages, emails, or advertisements).
Most cookies and similar technologies require your consent to use them. Our websites use the following categories of cookies:
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Strictly Necessary |
These are essential to use in order for our websites to work and provide core functionality, such as security and network management.
We won’t ask for your consent to use these types of cookies, and we can’t switch them off in our systems. You can, however, disable them in your web browser. but some parts of the website won’t work. |
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Performance Analytics |
These collect anonymous data about how users engage with our website to help us improve our content and services.
For example, they can tell us how you got to the site, the pages visited, how long is spent on each page, and what is clicked on.
You can switch off these cookies at any time. |
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Functional |
These are optional cookies which provide enhanced personalisation and functionality for the user.
For example, remembering your preferences and settings and making browsing easier.
We won’t set these cookies without asking for your consent first. You can change your consent preferences at any time. |
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Advertising Marketing |
These may be used to build a profile of your interests and show you more relevant advertising on our websites or our partners.
We won’t set these cookies without asking for your consent first. You can change your consent preferences at any time. |
We provide a simple mechanism for you to update your consent preference settings at any time:
You may need to refresh your page for setting changes to take effect.
Alternatively, most web browsers allow you to update settings to control the use of cookies on your device such as:
- Delete all cookies
- Block cookies
- Allow all cookies
- Block ‘third-party cookies (i.e. cookies set by online service other than the one you’re visiting)
- Clear all cookies when you close your session
- Open a ‘private browsing’ / ‘incognito’ session, which won’t then record your browsing history or allow storing of cookies.
More information about how to do this is available:
We, or our third-party service providers may transfer, host, store and/or handle your personal information outside of the United Kingdom and European Economic Area (“EEA”).
We ensure the destination country provides an adequate level of protection to safeguard data, which is equivalent to that applied in the UK and EEA. For example, we will:
- Ensure that the receiving country has been deemed “adequate” by the European Commission under Article 45 of the General Data Protection Regulation (GDPR).
- Put in place a contract with the third party receiving the personal data with appropriate clauses covering these data transfers.
- Carry out due diligence checks of our third-party service providers.
We only retain your personal information for as long as it is necessary and have strict retention policies in place.
In some cases, we will have a legal requirement to keep information for a specific period of time. For example, UK tax law will require us to keep VAT records for a minimum of 6 years.
You have the following rights in relation to the processing of your personal data:
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Right to be informed |
About the collection and use of your data and to be provided with privacy information at the time we collect the data from you. If your data is obtained from other sources, you have the right to be provided with privacy information within a month, unless you already have it, or it would involve a disproportionate effort to give it. |
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Right of access |
To receive a copy of the personal data we hold about you; the purposes we process it for; the categories of personal data we have; where we obtained it; who we share it with and how long we keep it for. |
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Right to object |
To the processing of your data. This isn’t an absolute right, and requests are assessed on a case-by-case basis. You do, however, have an absolute right to stop your data being used for direct marketing purposes. See section 6 Marketing for more details. |
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Right to rectification |
You are entitled to have your personal data corrected if it is inaccurate or incomplete. |
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Right to erasure |
Also known as ‘the right to be forgotten’. You have the right to request the deletion of your personal data. This is not an absolute right, for example we may be legally obligated to keep some information. Requests are assessed on a case-by-case basis. |
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Right related to automatic decision-making including profiling |
You have the right to be told about any automated profiling and decision-making which could have a material impact on you; and for those decisions to be fully reviewed by a person if you wish. |
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Right to restriction |
You have the right to suppress use of your personal data in certain circumstances. Data is stored. but will be restricted from use. |
Requests can be made verbally or in writing. Section 11 How to contact us.
We will process your request without undue delay and no later than one calendar month.
When we receive a request, we may need to ask you to verify your identity to ensure we are carrying out the request lawfully.
If you would like to contact us in relation to your rights or the way we have handled your personal data:
Email: planningahead@purecremation.co.uk
Telephone: 0800 033 7737 – option 2 Customer Services
Post: Eagle House, Joule Road, Andover, England, SP10 3UX.
If you’re unhappy with the way we’ve handled your data and wish to make a complaint, you can contact our Data Protection Officer:
Email: dpo@pure.uk.com
Post: Eagle House, Joule Road, Andover, England, SP10 3UX.
If you’re unsatisfied with how your complaint has been managed, you have the right to lodge a complaint with the UK regulator for data protection and information rights law:
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Telephone: 0303 123 11 13 (local rate) or 01625 545 745 (national rate)
Email: enquiries@ico.org.uk
Website: ico.org.uk