Privacy Policy

Contents

overview

Pure Cremation is committed to ensuring that your privacy is protected and we comply with applicable laws including the UK General Data Protection Regulation (“UK GDPR”) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together the "Data Protection Laws").

This privacy policy applies to your interaction with our internet sites: https://www.purecremation.co.uk; www.purelife.uk and www.purememories.co.uk (Our "Websites"). It also applies to the processing of personal data by Pure Cremation and each member of its Group which we may otherwise collect about you, including when you:

A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. The controller for personal data collected under this privacy policy is Pure Cremation Group Limited and/or the relevant Pure Cremation Group entity that you are dealing with, or with whom your data may be shared as explained further in this policy.

This policy explains how we use, store and share the information we collect about you, how you can exercise your rights in respect of that information and the procedures that we have in place to safeguard your privacy. This policy supplements any other fair processing or privacy notice that may be provided to you from time to time. Please contact us by email at: [email protected] if you have any questions, comments or concerns about this policy or how we handle your personal data, or if such information changes at any time.

Who is this policy addressed to?

References in this notice to “you” or “your” are references to individuals whose personal data Pure Cremation and the members of its Group collects and processes.

If you have provided your personal data to Pure Cremation for recruitment activities (whether directly or through a third party) this policy is only designed to provide you with information about how we will process your personal data during the application and recruitment processes.

References in this notice to “Pure Cremation”, “we”, “us” or “our” are references to Pure Cremation Group Limited (10723077) whose registered office is at: Charlton Park Crematorium, Charlton Down, Andover, SP11 0TA, and each other Group entity. For the avoidance of doubt, our Group entities are:

Group entity Registered address
Pure Cremation Limited (09703301)
Pure Cremation Funeral Planning Limited (09906976)
Pure Life Financial Services Limited (13149243)
Pure Life Legal Services Limited (13000850)

Charlton Park Crematorium

Charlton Down

Andover, SP11 0TA


Eagle House, Joule Road, Andover,

England. SP10 3UX

Please note: this policy does not cover third party websites that we may link to from our Websites or the processing of personal data by third parties with whom we may share your data which shall in each case be governed by each third party s own privacy notices, unless specifically mentioned in this policy.

We are not responsible for the privacy policies and practices (including use of cookies) of such third parties even if you accessed the third party website using links from our Websites. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.

The information we collect and how we use it

Under the Data Protection Laws, we are required to explain what information we collect from you and how and why we use your personal data (the "processing activity"). We are also required to have a "lawful basis" on which to process your personal data. This is summarised in the table below.

We will only use your personal data for the purposes for which we collected or received it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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.

We may also anonymize or aggregate any of the information we collect and use it for any purpose, including for research, training, and product development purposes. Such information will not identify you individually.

Processing activity: Why we use your information? What information is collected? Lawful basis of processing Where is the information collected from? How long do we keep the information for?
To enter into and administer our contracts with clients, including setting up client accounts, administering our services, and collecting payments due to us.
  • Name;
  • Address (incl. postcode);
  • Telephone number;
  • Email address;
  • Billing information including: signature, transaction, bank account details and/or payment card information;
  • Identity data (which in addition to the above may also include maiden name, marital status, date of birth and gender);
  • Your relationship to the deceased;
  • In relation to will writing services, data relating to beneficiaries, next of kin;
  • Your unique client reference number;
  • Information that you volunteer to us when you make an enquiry; and
  • Next of kin Information.
We process this information as it is necessary for us to enter a contract with you and to perform that contract; or otherwise for our legitimate interests (to recover debts due to us). From you via our Websites or when you call, email or otherwise send or provide information to us.

From a customer of ours if you are named by them as an individual with whom we should correspond.

From providers of technical and payment and delivery services.

From a third party with your consent e.g. your bank.

From The Department for Work and Pensions in respect of payment for services.

Subject to your consent from your GP if we need to obtain any opinion on your testamentary capacity before we can provide the will writing services to you.
Contractual information including billing information, client reference number and other information volunteered as part of an enquiry is retained for the duration you have an agreement in place with us or where you have an account for the duration for which you hold an account with us and in each case for 6 years following the end of the agreement or the closure of your account.

In the event that a plan holder passes away, we retain information noted on the Cremation Certificate (including name of the deceased, date of death and a statement regarding the ashes and next of kin details) indefinitely.
When you call or email us directly to enquire about our services.
  • Name;
  • Address (incl. postcode);
  • Telephone number;
  • Email address;
  • Your relationship to the deceased; and
  • Information that you volunteer to us when you make an enquiry.
The processing is necessary for our legitimate interest to promote our business and our products and services and to deal with your enquiry. From you when you call, email or otherwise send information to us. Where a general enquiry is made but no services are engaged, we retain name, phone number and address for such amount of time as is reasonable in order for us to provide our service and/or respond to on going enquires. Such time shall not exceed 5 years.

Should you proceed to instruct us for our services, your data is retained for the duration you have an agreement in place with us or where you have an account for the duration for which you hold an account with us and in each case for 6 years following the end of the agreement or the closure of your account.

In the event that a plan holder passes away, we retain information noted on the Cremation Certificate (including name of the deceased, date of death and a statement regarding the ashes and next of kin details) indefinitely.
To enter into contracts with suppliers that provide services or goods to us (where, for example, you are a sole trader, partnership or where you are providing services or goods on behalf of your employer/contractor), including setting up supplier accounts, and making payments to suppliers.
  • Name;
  • Address (incl. postcode);
  • Telephone number;
  • Email address;
  • Job title;
  • Job location;
  • Billing information including: signature, transaction, bank account details and/or payment card information; and;
  • Information that you volunteer to us when we engage your services.
We process this information as it is necessary for us to enter a contract with you for your services. From you directly when you call, email or otherwise send information to us.

From providers of technical and payment and delivery services.

From a third party with your consent e.g. your bank.
We retain your data for the duration we have an agreement in place with you or your employer and for 6 years following the end of the agreement with you or the business you represent.
To manage our relationship with you which will include (where appropriate) notifying you about changes to our terms of business or privacy notice.
  • Name;
  • Email address;
  • Address (incl. postcode); and
  • Telephone number.
We process this information as it is necessary for the performance of our contract with you and to ensure that we can provide updated service information to you. From you via our Websites or when you call or email us. We will retain your data for the duration you have an agreement in place with us or where you have an account for the duration for which you hold an account with us and in each case for 6 years following the end of the agreement or the closure of your account.

In the event that a plan holder passes away, we retain information noted on the Cremation Certificate (including name of the deceased, date of death and a statement regarding the ashes and next of kin details) indefinitely.
To administer our services in the absence of any contractual arrangement.
  • Next of kin/ representative of deceased name;
  • Next of kin/ representative of deceased address (incl. postcode); and
  • Next of kin/ representative of deceased telephone number.
The processing is necessary for our legitimate interest to administer our services. From a third party such as:
  • Nursing Homes or Hospices;
  • Registrars;
  • Coroners;
  • Hospitals;
  • Doctors;
  • Department for Work and Pensions;
  • Local Authorities;
  • Ambulance Service; and
  • Police.
We retain your data In relation to our administration of services for as long as required to administer our services and for 6 years following the end of the provision of such services.

In the event that a plan holder passes away, we retain information noted on the Cremation Certificate (including name of the deceased, date of death and a statement regarding the ashes and next of kin details) indefinitely.
To promote our products and services, including by sending you emails or postal communications, and contacting you by phone.
  • Name;
  • Address (incl. postcode);
  • Email address; and
  • Telephone number.
The processing is necessary for our legitimate interest to promote our business and our products and services.

You have a right to stop us from sending you direct marketing at any time. You may do so by emailing us at: [email protected] or calling Customer Care on: 0808 501 6368.
From you via our Websites or when you call, email, write to us or otherwise send information to us.

From third parties who collect your information in the course of providing you with products and services, and who are permitted by you to share your information with us.
We retain your data for as long as required to promote our products and services to.
To send promotional and service information guides, reports and other material, relating to our funeral, will writing, financial and insurance and probate services, as may be requested by you during a call with one of our team or where you make a request for such information via our Website or in writing. We will use this information to contact you following your receipt of the information you have requested.
  • Name;
  • Email address;
  • Address (incl. postcode);
  • Telephone number; and
  • Whether you are interested in hearing about our other products.
The processing is necessary for our legitimate interest to promote our business and our products and services.

From you via our Websites or when you call, email or otherwise send a request to us. We retain your data for as long as required to promote our products and services to.
For testimonials on our Website or contained within our brochures or service communications.
  • Name;
  • Email address;
  • Address (incl. postcode); and
  • Telephone number.
The processing is necessary for our legitimate interest to promote our business and our products and services. To note only your first name [and county /city location would be included within the testimonial. From you via our Websites or when you call, email or otherwise send information to us.

Via third party consumer review providers, such as Trust Pilot (where you can choose to give your full name if you wish).
When provided directly to us, for as long as required to promote our products and services and for no longer than 6 years.
To provide you with memorial page services.
  • Name;
  • Email address;
  • your image, as provided in photographs that you or others upload;
  • any information provided in comments posted on a memorial page.
The processing is necessary for our legitimate interest in providing our services to you. From you or third parties (such as your family members and friends) via our Websites when posting material (such as photographs or comments) to a memorial page. For as long as the memorial page remains active, and for no longer than 6 years following that date.
To answer questions or comments via our online contact forms or when you call or write to us.
  • Name;
  • Email address;
  • Address (incl. postcode); and
  • Telephone number.
The processing is necessary for our legitimate interest to provide our services to you and to provide you with a good level of service. From you via our Websites or when you call, email or otherwise send information to us. For as long as required to provide our services and for no longer than 6 years.
To analyse the response to our marketing, whether sent by post or email, or other communications in order to improve our products and services and to help us manage our business e.g. in relation to our financial performance, customer base, product range or other efficiency measures. For Mail Marketing:
  • an identifier [or code] within the information we send.


For Email Marketing:
  • an identifier [or code] within the email we send to you which enables us to identify if you have opened the email and clicked through to our Website.
  • To present targeting advertising to you when you browse the internet or visit third party websites, including social media.
The processing is necessary for our legitimate interests to provide our services to you and to understand our customers and potential customers engagement with our business and our services and help us improve our services.

You may withdraw consent through the Cookie Consent Manager or Websites settings at any time.
From you via our Websites or when you call, email or otherwise send information to us.

[We also collect information from analytics providers;

advertising networks; and

search information providers].
The data will be aggregated [and anonymised] after a maximum period of 1 year from when it is collected.
To build a profile of you to enable us to send relevant marketing and service information, including using cookies and other technologies to collect data about you.
  • An identifier that corresponds to your device;
  • Information about the device you use e.g. operating system, model, language settings;
  • Duration, frequency and time of use;
  • Click through information - the way you browse through and use our Website; and
  • Region.
The processing is necessary for our legitimate interest to customise the marketing information we send to you.

Where the data is collected via cookies or from social media sites this will be subject to consent you provide to us or the social media platform to collect such information and share the same.
From you when you visit our Website.

From third party sources such as public databases, social media platforms, third party data providers. Some of the information we collect may depend on the privacy settings you have with the social network site. We take steps to ensure that such parties are legally able to disclose such information to us.

We also collect data for this purpose via the Cookies placed on our Websites by Us and third party analytics companies (as described further below).
We retain your data for as long as required to promote our products and services to you and for no longer than 5 years.
When you visit our sites/buildings.
  • Name;
  • Email address;
  • Address (incl. postcode);
  • Telephone number;
  • Footage of you may be recorded on our CCTV systems.
The processing is necessary for our legitimate interest to provide our services to you.

In relation to CCTV, in order to protect our business, the local community, customers and colleagues.
From you when you visit our sites. We retain your data for as long as required to promote our products and services to you and for no longer than 5 years
To comply with legal and regulatory obligations.
  • All data provided by you;
  • Next of kin/ representative of deceased name;
  • Next of kin representative of deceased address (incl. postcode); and
  • Next of kin representative of deceased telephone number.
The processing is necessary for us to comply with our legal obligations. From you via our Websites or when you call, email or otherwise send information to us

From a third party such as:

  • - Nursing Homes or Hospices;
  • - Registrars;
  • - Coroners;
  • - Hospitals;
  • - Doctors;
  • - Department for Work and Pensions;
  • - Local Authorities;
  • - Ambulance Service; and
  • - Police.
We retain your data for as long as required to promote our products and services to you and for no longer than 5 years.
To prevent and detect unlawful activities such as fraud and money laundering.
  • Name;
  • Account number;
  • Information relating to your use of our services; and
  • Payment transaction reference; and
  • Transaction data including transaction history.
The processing is necessary for our legitimate interests to protect our business and co-operate with law enforcement authorities. From you via our Websites or when you call, email or otherwise send information to us.

From providers of technical and payment and delivery services.

From the Police or other law enforcement authorities.
We hold this information for 6 years after the relevant issue arises or, if litigation is pursued, until the issue is finally resolved.
To process job applications of prospective employees of Pure Cremation and our Group that contact us via the career section of our Websites or by email or telephone.
  • Name;
  • Email address;
  • Address (incl. postcode);
  • Telephone number;
  • References;
  • Correspondence with you relating to any application; and
  • Information collected by a third party providing DBS checking service.
The processing is necessary for our legitimate interest to review and interview job candidates. From you via our Websites through our careers page or via email or otherwise where you telephone us or you send information to us or which may be provided to us from a recruitment agent. For unsuccessful job applicants: 6 months from the date on which we confirm no job will be offered.

For those to whom a job offer is made and accepted until the end of employment and 6 years thereafter.
To reply to and deal with complaints and queries.
  • Name;
  • Email address;
  • Address (incl. postcode);
  • Relationship to the client;
  • Telephone number; and
  • Account number.
The processing is necessary for our legitimate interest to provide clients with a good service and to deal with any issue raised by you or your representative. From you via our Websites or when you call, email or otherwise send information to us If the data relates to a complaint, we will retain this information for 6 years from the date that the complaint was received.

Where we process personal data on the legal basis of legitimate interests (as indicated in the above table), we have determined, acting reasonably and considering the circumstances, that we are able to do so after carrying out a balancing exercise to make sure that our legitimate interests are not overridden by your interests, rights and freedoms. Where we rely on this legal basis, (a) we process the data only to the extent that is necessary for the relevant purpose; and (b) the relevant processing activities are of a type that you would reasonably expect. The legitimate interests we pursue are specified in the above table with respect to each relevant purpose.

Where we process personal data on the legal basis of consent (as indicated in the above table), you may refuse to consent to our processing and you may also withdraw your consent at any time, by emailing us at: [email protected], calling us on 0808 501 6368, or writing to us at Charlton Park Crematorium, Charlton Down, Andover, SP11 0TA. This would not affect your ability to use any features of our Websites or to receive our Services. Withdrawing consent does not affect any processing carried out without your consent.

Sharing your personal data

We will only disclose your personal data to:

We may also disclose your personal data to third parties:

International transfers of your personal data

We may transfer personal data to countries other than the country in which the data was originally collected (for example, outside the UK/EEA) in order to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection. If you would like more information about the appropriate safeguards used to protect your personal data in such circumstances, please contact us using the details provided in this policy.

Your rights

Right Description
To be informed You have the right to be informed about the personal information we hold about you.
Of access You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
To rectification You have the right to request that we rectify your personal data if it is not accurate or not complete.
To erasure You have the right to ask us to delete the personal information we hold about you. This right will only apply where (for example):
  • We no longer need to use the personal information to achieve the purpose we collected it for;
  • Where you withdraw your consent if we are using your personal information based on your consent; or
  • Where you object to the way we process your data (in accordance with your right to object as detailed below).
To restrict processing In certain circumstances, you have the right to restrict our processing of the personal information we hold about you. This right will only apply where (for example):
  • You dispute the accuracy of the personal information held by us;
  • Where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead; or
  • Where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims.
To data portability In certain circumstances, you have the right to receive the personal information you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
To object You have the right to object to our processing of the personal information we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims.
In relation to automated decision making and profiling You have the right not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing however, we do create profiles to understand our customer base and potential new customers so that we can ensure that all of our products and services are marketed respectfully and appropriately. We engage the services or third-party social media providers such as Facebook to assist us with such profiling.
To withdraw You have the right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).

We welcome your views about our Websites and this policy. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please email us at [email protected] or write to us at: Saba Munir, Regulatory Compliance Manager, Eagle House, Joule Road, Andover, SP10 3UX.

If you would like this notice in another format (for example audio, large print) please contact us using the details above.

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal data. However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to our supervisory authority, which is the UK s Information Commissioner s Office. Their address is: First Contact Team, Information Commissioner s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

Cookies

We and our partners use cookies and similar technologies, such as tags and pixels (“cookies”), to personalise and improve your customer experience as you use our Websites, to present advertising to you online through social media or otherwise and to enable us to analysis use of our Website and engagement with us and our Services. Our Cookies Policy (linked here) provides more information about cookies, including how we use them and how you can exercise your choices about our use of cookies.

Changes to this policy

We will take reasonable measures to communicate any changes to this policy to you, and you and will post any updated privacy policies [on this page].

This policy was last reviewed and updated in May 2022.

Our Registered Office

Eagle House
Joule Road
Andover
Hampshire
SP10 3UX

Pure Life Financial Services Ltd is part of the Pure Cremation Group Ltd.

Pure Life Financial Services Ltd. Company number 13149243. Registered Office: Eagle House, Joule Rd, Andover, SP10 3UX. Pure Life Financial Services Ltd is an appointed representative of CBS AR Ltd which is authorised and regulated by the Financial Conduct Authority (FCA No: 601222). Your policy is issued, underwritten and administered by Scottish Friendly Assurance Society Limited. Scottish Friendly Assurance Society Limited is a friendly society incorporated and registered under the Friendly Societies Act whose registered office is at Galbraith House, 16 Blythswood Square, Glasgow G2 4HJ. They are authorised by Prudential Regulation Authority and regulated by Financial Conduct Authority and Prudential Regulation Authority. Registration number 110002