Serene Funeral Planning Limited is a controller and processor of data, we are registered with the Information Commissioners Office, (Registration Number ZB248387 ), Registered at Companies House, number SC699656 . Registered Office Address: 6th Floor, Gordon Chambers, 90 Mitchell Street, Glasgow G1 3NQ.

We are aware how important your privacy is and based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website or by making an application for a funeral plan will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulation (GDPR). Contained within this statement and set out below are details of the type of information that we at Serene Funeral Planning may hold about you our customer. It describes how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us. We may choose to amend the content of this privacy policy on occasion. If this occurs then we will update the policy and the revised policy will be posted on our website.

We will keep you informed with the progress of your enquiry. Unless you state otherwise, you may be contacted via telephone, email, post, SMS and automated message. (see further section on ‘How we keep you informed’).

We rely upon a different lawful basis to process your personal data according to the reason for which you have provided your data to us. Our use of your personal data will always have a lawful basis.

Initially when you submit your application with us , we will process and store your personal data on the basis that you have provided your consent to be contacted by us in relation to your application. You can withdraw your consent by contacting us at info@serenefp.co.uk or by using the contact details stated in this document. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

If you engage our service and provide you with a funeral plan your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by introducing you to a funeral service provider who will supply the service you request. Therefore we will share your personal data with your nominated funeral service provider and your nominated representative if you choose to have one. We may also need to share your data with our regulator in the their course of supervising our authorisation.

We will from time to time contact you about products and services associated with your initial enquiry and subsequent contract. In this case we would have a legitimate interest in processing your data (i.e. to share your application with our panel of providers) to obtain the product and/or service you have applied for. You are not automatically placed on our marketing list. If you wish to be contacted about other associated products and services, you will be asked to “opt in” to our marketing. You not obligated to do so and if you did “opt in” you could simply “opt out” at any time by letting us know.

It also includes processing your data for identification purposes to ensure that we never disclose your information to any other person that may have a similar or the same name.

You can ask us to stop processing your data in this way by contacting us. If you engaged us and hold a funeral plan with us, we will continue to contact you but only in relation to your plan and normal business reasons.

You can telephone us using the specified telephone numbers on our website under the Contact Tab and your call will be recorded for training, quality and regulatory purposes. We pride ourselves in complete customer care and this gives us the opportunity to continuously improve and monitor our customer experience. You can also email us or write to us.

We are required to contact you at least annually to review your plan and make any amendments you may wish to make. This contact will be made via telephone, email, SMS, depending on your stated preferences.

1. You are free to access and browse our website at your convenience and do not have to provide any personal information/data, however I would like to refer you to the ‘Cookies’ section set out within this privacy policy. Some “ cookies” are required in order to allow you to navigate our site. You can always control the “cookies” we use by clicking here.

2. The information or data that we collect from you may include the following details:

• Name
• Residential address
• Residential status
• Email address (if applicable)
• Telephone number (home, mobile, work)
• Date of Birth
• IP Address
• What you do on our website and where you visit; the results of this are anonymous but will be used to show us examples of which parts of our website are most and least used (please refer to ‘Cookies’ section)

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your marketing preferences to be updated then please contact us the details are set out below.

When you complete an application, you consent to us disclosing your personal information to the following parties:

1. Serene Funeral Planning (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.

2. The providers as listed on the specific product and/or service website page you are making an enquiry from.

3. Our channel operators: whilst the majority of the channels on our Sites are run by us, some of our channels are designed and maintained for us by our third party service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed with your consent;

4. the Information Commissioners Office and/or other regulatory/governing bodies, for the purposes of compliance monitoring;

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

• if required or permitted to do so by law;
• if necessary in connection with legal proceedings or potential legal proceedings; and/or
• in connection with the sale or potential sale of all or part of our business.

If you decide to enter into a service product with a third party provider through any of the providers, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third party provider, will be held by the provider for the purposes set out in that provider’s privacy policy. Therefore, you are strongly advised to read your chosen provider’s privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the product, service or plan. We have no responsibility for the uses to which a provider puts your personal information

If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

We may use your personal information:

1. to enable you to access and use the Services;

2. to personalise and improve aspects of our Services;

3. for research, such as analysing market trends and customer demographics;

4. to communicate with you, including some or all of the following:

5. to process an application between you and us or a third party such as the company on our panel providing the service you applied for

6. to track applications, which may involve us sharing data with your product provider relating to the product(s) you have chosen. Your product provider may also send us information they hold relating to the product(s) you have chosen for this purpose;

7. to match our data with data from other sources – we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible.

Cookies and Web Beacons

This section sets out our use of Cookies when you use our sites. Please read it carefully as it explains how we and third parties may make use of your data collected by such Cookies. If you wish to understand how we make use of your data, more generally please refer to section 8.

We use a single first party cookie, named ‘PHPSESSID’. This cookie is vital for the operation of the website, as it allows us to track different page loads to yourself, which allows the form and application process to work. To find out more about accepting or refusing cookies please visit www.allaboutcookies.org.

We also use Google Analytics to collect non-personally identifiable information, in aggregate form, to understand website/page visit volumes in terms of source, geography, browser, etc.

Google Analytics employs a software technology called web beacons, that help us better manage content on our site by informing us what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users or responses to emails. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons cannot be disabled in same manner as cookies may. We do not tie the information gathered by web beacons to our customers’ personally identifiable information.

Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website.

Important: Read the Google Analytics privacy document for more details about the data collected by Google Analytics. Google Analytics supports three JavaScript libraries (tags) for measuring website usage: gtag.js, analytics.js, and ga.js. The following sections describe how each use cookies.

We use the “visitor action pixels” from Facebook Inc (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.

This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we

do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

On our websites functions of the service Instagram are embedded. These functions are offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link contents of our websites to your Instagram profile by clicking the Instagram button. By this ,Instagram will associate the visit of our websites with your user account. We would like to point out that we, as providers of these websites, do not obtain knowledge about the contents of transmitted data as well as their use by Instagram.

For further information, please review the Privacy Policy of Instagram: http://instagram.com/about/legal/privacy/

On our website, we use the Conversion Tracking Service of Twitter Inc. (1355 Market Street #900, San Francisco, California 94103, “Twitter”). Twitter stores a cookie on the user’s computer to enable an analysis of the use of our online products and services. Twitter Conversion Tracking tracks the actions of users after they have viewed ads or interacted with ads on Twitter. Twitter’s Conversion Tracking allows you to assign conversions such as link clicks, retweets or “like” data.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to tracking, you can do so using the Digital Advertising Alliance tool at optout.aboutads.info.

Twitter is certified under the Privacy Shield Agreement and thus guarantees its compliance with European data protection legislation: (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active)

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that by disallowing cookies some functionality on the site may be restricted.

Our Sites are “VeriSign Secure Websites” and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

You have certain rights under the General Data Protection Regulations . For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.

• Right to be informed when we collect your data we have to tell you what we are going to do with it primarily though this Privacy Policy and within the opt in /consent statement.
• Right to Object – because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst our panel of providers. You can object to this processing at any time by sending us an email at info@serenefp.co.uk We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
• Right of Access – you can ask us at any time to confirm whether we hold your personal information, and if so, you can access it by writing to us at the address at the top of this privacy policy called Registered Address.
• Right to rectification – if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
• Right to erasure – if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for. If you have a funeral plan with us we will be unable your delete your data as we would then be unable to provide the service you are paying for.
• Right to restrict our use of your information – you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
• Right to data portability – this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies and utility companies.
• Right to complain to the Information Commissioner’s Office (ICO) – we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Please refer to our Complaints section How To Make a Complaint below for further information.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at info@serenefp.co.uk

The amount of time we retain your information for will depend on the reason it was provided:

• If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
• We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.
• Your information/data will not be used for marketing purposes once 12 months has passed following your application.

If you require further information on our data retention policies please email: info@serenefp.co.uk

You can opt out of future contact from us at any time. All of our marketing messages provide an opt out link – please allow up to 48 hours for us to process your opt out request. Alternatively you can enter your details by email to info@serenefp.co.uk where your details will be removed from any future marketing campaigns.

Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When the individual withdraws consent.
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
• The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
• The personal data has to be erased in order to comply with a legal obligation.
• The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right “to be forgotten” does not apply i.e. where we need to comply with a legal obligation. If you wish to request your “right to be forgotten” please email: info@serenefp.co.uk Our marketing partners will also be informed of your request

We always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we’re keen to resolve it as quickly as possible. You can contact us is any of the following ways:

• By Post: Complaints Department, Serene Funeral Planning Limited, 17 Admiral Street, Kinning Park, Glasgow, G41 1HP
• By Phone: 0330 17519957 (calls are charged at local rates and are inclusive of mobile phone users’ free minutes)
• By Email: info@serenefp.co.uk

We aim to resolve your complaint about any data breach or processing, as soon as possible. Sometimes things take a little more time. Please find below the process that we will adhere to in order respond to your query.

• We will investigate your complaint fully and we always aim to resolve the problem where reasonably possible, sooner than 20 days of receipt if we can.
• If your  complaint is more complex   it will be passed to our complaint handler and may take up to 8 weeks to resolve
• The Final Report from us will include the findings from our investigation and, if applicable, and what actions we will take to put things right.
• Should you remain dissatisfied , you have the right to ask the Financial Ombudsman to review your case
•  Contact details for the financial ombudsman:
• By post: Financial Service, South Quay Plaza, 183 Marsh Wall, London, E14 9SR
• By Phone:   0800 023 567
• By  Email:   https://www.ombudsman-services.org