• The data we collect about you and how we collect it.
  • How we use your Personal data
  • Change of purpose
  • Disclosures of your Personal data
  • International transfers
  • Data security
  • Data retention
  • Your legal rights

Introduction

This Privacy Policy is applicable to Memoria Funerals, a trading name of Low Cost Funeral Limited. The business is 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 Memoria Funerals’ privacy policy and in it, we refer to Memoria Funerals “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.

Memoria Funerals 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 www.memoriafunerals.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

Memoria Funerals 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: DPO@memoriafunerals.co.uk

Postal address: IT Director, Memoria Funerals, The Pool House, Bicester Road, Stratton Audley, Oxfordshire, OX27 9BS

Telephone number: 0800 007 3580

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (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

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on www.memoriafunerals.co.uk and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend that you check this page regularly to keep up to date. This Privacy Policy was last updated on 1st July 2023

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 (anonymized 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 third party) we may collect the following Personal data about you either through direct interactions with you, from third parties or using technologies: 

  1. Personal information including first and last name, date of birth and contact information including current residential address, primary email address and/or primary phone number.
    We may collect Special Categories of Personal Data which is classed as sensitive data under GDPR, for example we may collect the below information during or after the initial set up of a contract with us.
    Religion – This is sometimes shared to ensure any religious funeral preferences can be fulfilled when the time comes to arrange your funeral.
    Health – We do ask if our clients have any vulnerabilities, we need to be aware of so we can adapt the journey with us to meet their needs. If consent to record these has been given, this information will be recorded on our records.
  2. Information obtained through our correspondence with you and/or third parties you have nominated to speak on your behalf by phone using our call recording systems.
  3. 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, see clause 1.5 below.
  4. Details of any enquiries made by you through the Website, together with details relating to subsequent correspondence (if applicable).
  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.

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 with you (for example, to provide you with products 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. 

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 or have entered 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 rely on performance of a contract, consent, and legitimate interest as a legal basis for processing 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis, we are relying on to process your Personal data.

Purpose/Activity Type of data Lawful basis for processing
To register you as a new customer Personal information

Performance of a contract with you

Consent

To operate, administer and provide our services to you.

Personal information

Performance of a contract with you

Consent

To fulfill the requested wishes of our plan holders and share data with our Funeral Directors/Chosen partners

Personal information (including Representative information)

Legitimate interests in running our funeral and crematorium services and coordinating 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

Consent

Legitimate Interest if we need to discuss your questions, queries, or complaints with any third party, we have shared your data with.

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 operational and functionality of our website, subject to your rights.

To disclose your information to selected third parties as permitted by this Policy. 

Personal Information

Legitimate interests

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. 

We may also be asked to share your information with Regulatory bodies.

Technical information 

Personal information

All communication;

call recordings

Emails

letters etc 

Legal obligations

To contact you for marketing purposes by Memoria Funeral Limited and third parties

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

We rely on consent for the use of our customers personal data for this purpose. Marketing permissions are updated regularly with personal preferences.

We rely on legitimate interests if your data has been shared with us for marketing by third parties.

Right of access

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; this request is called a ‘DSAR’ Data Subject Access Request

Right to rectification

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 as soon as possible.

Right to erasure

You have the right in certain circumstances to request that we delete all Personal data we hold about you (the ‘right to be forgotten’). Please note that this right of erasure is not available in all circumstances.

Right to restriction of processing

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.

Right to data portability

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’).

Right to object

You have the right in certain circumstances to object to the processing of your personal data, for example for marketing purposes. 

Rights related to automated decision-making including profiling

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.

Right to object to direct marketing.

You have the right to object to all marketing from us, you can do so by contacting us on the details provided in this privacy policy.

Marketing

We may use your Personal data for marketing to you and share your data with our sister companies who trade under Memoria Funeral Limited. They may contact you directly by mail, telephone and email about products, services, promotions, and special offers that may be of interest to you.

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 “Opting Out”). 

Opting out 

You have the right at any time to ask us 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 DPO@memoriafunerals.co.uk, alternatively, you can follow the unsubscribe instructions in emails you receive from us. 

Where you opt out of receiving marketing messages, this will not prevent other uses of your Personal data made by Memoria Funerals on other legal bases that are required for performance of a contract.

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 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 unauthorised third party. 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. 

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. 

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.

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.