PRIVACY POLICY ‐ Hoskins Funerals Direct Ltd

1.Introduction

1.1 We are committed to safeguarding the privacy of [our website visitors and service users].

1.2 This policy applies where we are acting as a data controller with respect to the personal data of

[our website visitors and service users]; in other words, where we determine the purposes and

means of the processing of that personal data.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) [in the case of personal data that we did not obtain directly from you, the source and specific

categories of that data];

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage

data may include your IP address, geographical location, browser type and version, operating

system, referral source, length of visit, page views and website navigation paths, as well as

information about the timing, frequency and pattern of your service use. The source of the usage

data is our analytics tracking system. This usage data may be processed for the purposes of analysing

the use of the website and services. The legal basis for this processing is our legitimate interests,

namely monitoring and improving our website and services

3.3 We may process your account data (“account data“). The account data may include your name

and email address. The source of the account data is you. The account data may be processed for

the purposes of operating our website, providing our services, ensuring the security of our website

and services, maintaining back‐ups of our databases and communicating with you. The legal basis for

this processing is our legitimate interests, namely the proper administration of our website and

business.

3.4 We may process your information included in your personal profile on our website (“profile

data“). The profile data may include your name, address, telephone number, email address, profile

pictures, gender The profile data may be processed for the purposes of enabling and monitoring

your use of our website and services. The legal basis for this processing our legitimate interests,

namely the proper administration of our website

3.5 We may process information that you post for publication on our website or through our

services (“publication data“). The publication data may be processed for the purposes of enabling

such publication and administering our website and services. The legal basis for this processing is our

legitimate interests, namely the proper administration of our website and business

3.6 We may process information contained in any enquiry you submit to us regarding goods and/or

services (“enquiry data“). The enquiry data may be processed for the purposes of offering,

marketing and selling relevant goods and/or services to you. The legal basis for this processing is

[consent]

3.7 We may process information that you provide to us for the purpose of subscribing to our email

notifications and/or newsletters (“notification data“). The notification data may be processed for the

purposes of sending you the relevant notifications and/or newsletters. The legal basis for this

processing is[consent at your request, to enter into such a contract

3.8 We may process information contained in or relating to any communication that you send to us

(“correspondence data“). The correspondence data may include the communication content and

metadata associated with the communication. Our website will generate the metadata associated

with communications made using the website contact forms. The correspondence data may be

processed for the purposes of communicating with you and record‐keeping. The legal basis for this

processing is our legitimate interests, namely the proper administration of our website and business

and communications with users.

3.9 We may process any of your personal data identified in this policy where necessary for the

establishment, exercise or defence of legal claims, whether in court proceedings or in an

administrative or out‐of‐court procedure. The legal basis for this processing is our legitimate

interests, namely the protection and assertion of our legal rights, your legal rights and the legal

rights of others.

3.10 We may process any of your personal data identified in this policy where necessary for the

purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our

legitimate interests, namely the proper protection of our business against risks.

3.11 In addition to the specific purposes for which we may process your personal data set out in this

Section 3, we may also process any of your personal data where such processing is necessary for

compliance with a legal obligation to which we are subject, or in order to protect your vital interests

or the vital interests of another natural person.

3.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies, this means our

subsidiaries, our ultimate holding company and all its subsidiaries, insofar as reasonably necessary

for the purposes, and on the legal bases, set out in this policy.

4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose

your personal data where such disclosure is necessary for compliance with a legal obligation to

which we are subject, or in order to protect your vital interests or the vital interests of another

natural person. We may also disclose your personal data where such disclosure is necessary for the

establishment, exercise or defence of legal claims, whether in court proceedings or in an

administrative or out‐of‐court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data

may be transferred to countries outside the European Economic Area (EEA).

5.2 You acknowledge that personal data that you submit for publication through our website or

services may be available, via the internet, around the world. We cannot prevent the use (or misuse)

of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help

ensure that we comply with our legal obligations in relation to the retention and deletion of

personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is

necessary for that purpose or those purposes.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal

data will be retained. In such cases, we will determine the period of retention based on the following

criteria:

(a) the period of retention of personal data will be determined based on continued business and or

interest in doing business at a later date with regular reviews of this decision

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data

where such retention is necessary for compliance with a legal obligation to which we are subject, or

in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this

policy.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law.

Some of the rights are complex, and not all of the details have been included in our summaries.

Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a

full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and,

where we do, access to the personal data, together with certain additional information. That

additional information includes details of the purposes of the processing, the categories of personal

data concerned and the recipients of the personal data. Providing the rights and freedoms of others

are not affected, we will supply to you a copy of your personal data. The first copy will be provided

free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into

account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue

delay. Those circumstances include: the personal data are no longer necessary in relation to the

purposes for which they were collected or otherwise processed; you withdraw consent to consentbased processing; you object to the processing under certain rules of applicable data protection law;

the processing is for direct marketing purposes; and the personal data have been unlawfully

processed. However, there are exclusions of the right to erasure. The general exclusions include

where processing is necessary: for exercising the right of freedom of expression and information; for

compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data.

Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but

you oppose erasure; we no longer need the personal data for the purposes of our processing, but

you require personal data for the establishment, exercise or defence of legal claims; and you have

objected to processing, pending the verification of that objection. Where processing has been

restricted on this basis, we may continue to store your personal data. However, we will only

otherwise process it: with your consent; for the establishment, exercise or defence of legal claims;

for the protection of the rights of another natural or legal person; or for reasons of important public

interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your

particular situation, but only to the extent that the legal basis for the processing is that the

processing is necessary for: the performance of a task carried out in the public interest or in the

exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by

us or by a third party. If you make such an objection, we will cease to process the personal

information unless we can demonstrate compelling legitimate grounds for the processing which

override your interests, rights and freedoms, or the processing is for the establishment, exercise or

defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing

purposes; including profiling for direct marketing purposes. If you make such an objection, we will

cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical

research purposes or statistical purposes on grounds relating to your particular situation, unless the

processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in

order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal

data from us in a structured, commonly used and machine‐readable format. However, this right does

not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws,

you have a legal right to lodge a complaint with a supervisory authority responsible for data

protection. You may do so in the EU member state of your habitual residence, your place of work or

the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent,

you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of

processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data [by written notice to us]

9. About cookies

9.1 A cookie is a file containing an identifier; a string of letters and numbers, that is sent by a web

server to a web browser and is stored by the browser. The identifier is then sent back to the server

each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be

stored by a web browser and will remain valid until its set expiry date, unless deleted by the user

before the expiry date; a session cookie, on the other hand, will expire at the end of the user

session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal

information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for

doing so vary from browser to browser, and from version to version. You can however obtain up‐todate

information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en  (Chrome);

(b) https://support.mozilla.org/en‐US/kb/enable‐and‐disable‐cookies‐website‐preferences

(Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/  (Opera);

(d) https://support.microsoft.com/en‐gb/help/17442/windows‐internet‐explorer‐delete‐managecookies

(Internet Explorer);

(e) https://support.apple.com/kb/PH21411  (Safari); and

(f) https://privacy.microsoft.com/en‐us/windows‐10‐microsoft‐edge‐and‐privacy (Edge).

[additional list items]

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1 This website is owned and operated by Hoskins Funerals Direct Ltd

12.2 Our principal place of business is at 129, Astwood Road, Worcester WR3 8HD

12.3 You can contact us:

(a) by post, to the postal address given above

(b) [by email, using [the email address published on our website from time to time.

13. Data protection officer

13.1 Our data protection officer’s contact details are: As listed in point 12