- 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 Limited (“Memoria”), a company registered in England and Wales with company registration number 06803359 and registered office address at The Pool House, Bicester Road, Stratton Audley, Bicester OX27 9BS.
Memoria’s group is made up of different legal entities, named below. This privacy policy is issued on behalf of Memoria and in it, we refer to Memoria as Memoria, “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 respects your privacy and is committed to protecting your Personal Data. This privacy policy (“Policy”) explains how we and the companies within our group use the personal information you give us when you interact with us, use our website at www.memoria.org.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 or use of services at one of our memorial parks and crematoriums (those currently managed by us are):
- Memoria Cardiff and Glamorgan Memorial Park & Crematorium
- Memoria Kirkleatham Memorial Park & Crematorium
- Memoria South Oxfordshire Crematorium & Memorial Park
- Memoria Amber Valley Memorial Park & Crematorium
- Memoria South Leicestershire Memorial Park & Crematorium
- Memoria Waveney Memorial Park & Crematorium
- Memoria Denbighshire Memorial Park & Crematorium
- Memoria North Herts Memorial Park & Crematorium
- Memoria Flintshire Memorial Park & Crematorium
- Memoria Barnby Moor Memorial Park & Crematorium
- Memoria North Oxfordshire Crematorium & Memorial Park
- Memoria Paisley Woodside Memorial Park & Crematorium
- Memoria Doncaster & South Yorkshire Memorial Park & Crematorium
- Memoria Faversham & Mid Kent Memorial Park & Crematorium
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 Limited, and each of the group companies listed above, will be data controllers in relation to the personal data collected and processed from you. Any information that is collected by those memorial parks and crematoriums is shared with and held by each entity in accordance with this Policy. As data controllers, each entity is responsible for, and controls, 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@memoria.org.uk
Postal address: Data Protection Officer, Memoria, The Pool House, Bicester Road, Stratton Audley, Oxfordshire, OX27 9BS
Telephone number: 01869 278 780
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (website at: 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.memoria.org.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 October 2023.
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.
1. 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 services of a memorial park or crematorium listed above, the web-booking portal, the Website, or otherwise deal with us (including where you have made an application via a Funeral Director), we may collect the following Personal Data about you either through direct interactions with you, from third parties or using technologies:
1.1 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 arranging a funeral.
1.2 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, email and written correspondence.
1.3 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;
1.4 Details of any enquiries made by you through the Website, together with details relating to subsequent correspondence (if applicable). We may also receive information about you from other sources, for example from any third-party Funeral Directors.
1.5 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 into 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.
2. 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 into or have entered into 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 ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
| 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: We may share your details with our Funeral Director partners and 3rd party crematorium sites |
| 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 Low Cost 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. |
Marketing
We may use your Personal data for marketing to you and share your data with our sister companies who are part of the wider Memoria Group if you have given consent. They may contact you directly by mail, telephone and email about products, services, promotions, and special offers that may be of interest to you.
Where you are a funeral director dealing with us in your professional capacity on behalf of a limited company or LLP, for business purposes, then we may contact you by email to your corporate email address about similar or related products that we offer. 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
You have the right at any time to ask us, or any third party, 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 info@memoria.org.uk or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively, you can follow the unsubscribe instructions in emails you receive from us or them.
Cookies
For more information about the cookies we use, please see our cookie policy.
3. Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4. Disclosures of your Personal Data
We may share your Personal Data with the third parties set out below for the purposes set out in the table above, always subject to entering into the appropriate data processing or data sharing agreements with them.
- Memoria group companies, where this is necessary for us to perform the services contracted for and where we believe it is in our legitimate interests to do so and have conducted an impact assessment to evaluate whether our proposed sharing of your Personal Data will cause harm to your interests.
- Funeral Directors/Our chosen partners
- IT support services
- Print vendors
- Third party payment processors
- Third Parties for marketing purposes, only with your express permission.
- Third parties to whom we may choose to sell, transfer or merge part of, or the whole of, our business or our assets. The new owner may use your Personal Data in the same way as set out in this privacy policy.
- Regulatory, government and industry bodies such as (if required under our legal obligations)
- Information Commissioners Office (ICO)
- HM Revenue & Customs
- Law Enforcement bodies
- Fraud Prevention Organisations
If any of your Personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
5. International transfers
We do not usually transfer your Personal Data outside the UK, however if you require funeral arrangements that involve an international element, it may become necessary to transfer Personal Data outside the UK to provide our services to you.
As such transfers of Personal Data are not routine or regular, we do not have particular contractual arrangements in place with the recipients of the Personal Data, and therefore will rely on either (i) the explicit consent of the data subject to the transfer of their Personal Data out of the UK or (ii) where the data subject is also the person we are contracting with, we may transfer their Personal Data on the basis of necessity in order to perform our services under the contract.
You should be aware that when we transfer your Personal Data out of the UK to a territory outside the EEA where there is no “adequacy” decision granted, we cannot guarantee that the receiving party will provide the same degree of protection to your Personal Data as is provided in the UK (or the EEA).
6. Data security
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees and professional advisers who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
Whilst you have the legal right to ask us to stop processing your information for direct marketing purposes (as detailed in this Policy), we may still be required to hold your information for the purposes of complying with our Legal or Regulatory obligations.
We will keep your information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for the necessary time period to:
- Maintain business records for analysis and/or audit purposes; or
- Comply with record retention requirements under the law; If required, we will be entitled to hold information for longer periods in order to comply with our Legal or Regulatory obligations.
- Investigate any complaints regarding our products or services.
In some circumstances you can ask us to delete your Personal Data: see your rights below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your rights
- Under the Data Protection Legislation, you have the following rights, which we will always work to uphold. If you wish to exercise any of your legal rights, you should put your request in writing to us giving us enough information to identify you and respond to your request.
| 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. |
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 clearly 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 person who has no right to receive it. 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.
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 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.
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.
Our web site does not use these cookies.