Privacy Policy

Last Updated: 03 January 2025

At Plan with Grace Limited (“we,” “our,” or “us”), we take your privacy seriously and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your personal information when you visit our website www.funeralswithgrace.com or www.thefuneralmarket.com (“Websites”), interact with us, or use our services. It also informs you about your rights under the UK General Data Protection Regulation (UK GDPR) and how you can exercise them.

When we use (“we,” “our,” or “us”) in the Policy, we mean one or more of the following companies:

• Funerals with Grace: sells and administers prepaid funeral plans.
• With Grace: sells and administers prepaid funeral plans.
• The Funeral Market: provides ‘at need’ cremation and funeral services and administers the fulfilment of prepaid funeral plans provided by Funerals with Grace and With Grace.

In all cases Plan with Grace Limited acts as the Data Controller.

1. Introduction

We are committed to protecting your personal data and respecting your privacy. This privacy notice explains how we collect, use, and protect your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA). This Privacy Policy outlines the types of personal data we collect, the purposes for which we use it, the legal basis for processing, and how we protect your data.

2. Our Business: Supplying At-Need and Prepaid Funeral Plans

At Plan with Grace Limited, we specialise in providing funeral plans, both at-need and prepaid, to meet the varying needs of our clients.

• At-Need Funeral Plans: We offer services to individuals and families who require funeral arrangements immediately due to the passing of a loved one. This service includes organising the necessary funeral arrangements, working closely with you to ensure that all aspects of the funeral are managed according to your wishes.
• Prepaid Funeral Plans: Our prepaid funeral plans allow individuals to plan and pay for their funeral services in advance, helping to alleviate the burden on loved ones during a difficult time. These plans offer peace of mind by fixing the cost of funeral services at today’s prices and ensuring that all aspects of the funeral are arranged according to your specific preferences.

Both services require sensitive handling of personal data to ensure that we provide the appropriate services to meet your needs and comply with legal and regulatory requirements.

3. Independent Management Firm

We engage with an independent Management Firm to manage or hold assets on your behalf. Our ring fenced trust is managed by Saranac Partners, an independent Investment Management Firm, regulated by the Financial Conduct Authority providing you with peace of mind that your assets are being managed responsibly and transparently, and your money is protected by the Financial Services Compensation Scheme.

We ensure that our independent management firm meet the following criteria:

• Integrity: carefully selected for their reputation for trustworthiness and their commitment to ethical business practices.
• Transparency: required to provide clear, understandable information regarding their charges, ensuring you are fully aware of any fees or costs associated with their services.
• Financial Reporting: required to maintain transparent financial reporting practices, allowing you to review their financial activities, the management of assets, and any related transactions.

Our Trust is overseen by independent Trustees who make sure all funds go toward your funeral.

4. Legal Basis for Collecting Data

We collect and process your personal data based on one or more of the following legal bases:

• Consent: Where you have given us explicit consent to process your personal data (e.g., when you agree to cookies).
• Contractual necessity: Where processing is required to fulfil a contract with you or take steps at your request before entering into a contract (e.g., providing services you have requested).
• Legal obligation: Where processing is necessary to comply with a legal obligation (e.g., regulatory, tax reporting).
• Legitimate interests: Where we have a legitimate interest in processing your personal data and our interest is not overridden by your rights and freedoms. For example, we may use your contact details for marketing purposes if you have used our services in the past.

5. Legitimate Interests

We may process your personal data based on our legitimate interests, which include:

• Improving our Website and services.
• Preventing fraud and ensuring security.
• Communicating with you regarding your use of our products and services.
• Responding to customer inquiries and providing customer support.

Where we rely on legitimate interests, we ensure that the processing does not infringe on your rights and freedoms. You have the right to object to processing based on legitimate interests at any time.

6. Types of Data We Collect

We may collect the following types of personal data:

• Contact information: Name, date of birth, email address, phone number, mailing address, next of kin.
• Sensitive Information: To help us support you and/or your funeral requirements we will ask for your consent to record i.e. medical, mental health, ethnic origin and religion.
• Account details: Username, password.
• Payment information: Credit/debit card details, billing address.
• Technical data: IP address, browser type, device type, operating system, and other technical identifiers collected through cookies.
• Usage data: Information about how you use our Website, products, and services.
• Marketing preferences: Information on how you wish to receive marketing communications from us.

7. IP Addresses

We collect your IP address when you visit our Website or interact with us online. An IP address is a unique identifier for your device on the internet and is used for various purposes, including:

• Enhancing the security of our Website.
• Analysing trends and visitor behaviour on our Website.
• Diagnosing technical problems.

We may also use IP addresses for the purposes of targeted advertising, but only with your consent where required.

8. Your GDPR Rights and Response Times

Under the UK GDPR, you have several important rights regarding your personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you.
• Right to rectification: You have the right to correct any inaccurate or incomplete personal data we hold.
• Right to erasure: You have the right to request that we delete your personal data, subject to certain conditions.
• Right to restrict processing: You can request that we restrict the processing of your personal data under certain circumstances.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
• Right to object: You can object to the processing of your personal data, including for direct marketing purposes.
• Right to withdraw consent: If we rely on consent to process your data, you can withdraw your consent at any time.

We aim to respond to all valid requests within one month of receipt. In some cases, this may be extended by two months if the request is complex or if we receive a high volume of requests. We will inform you if this is the case.

Grounds for Declining Requests

We can decline requests if:

• The request is manifestly unfounded (e.g., repetitive or excessive).
• The request is excessive (e.g., it places an unreasonable burden on your organisation).
• The request is not covered under GDPR rights (e.g., data is needed for legal obligations, contractual necessity, or legitimate interest).
• The individual’s rights are overridden by other legal obligations or rights.

9. How We Protect Your Data

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. These measures include encryption, secure servers, and regular security assessments.

However, please note that no method of transmission over the internet or electronic storage is 100% secure, and while we strive to protect your personal data, we cannot guarantee its absolute security.

10. Processing Within the European Economic Area (EEA)

We process your personal data exclusively within the European Economic Area (EEA). We do not transfer your personal data to countries outside the EEA, unless necessary for the performance of a contract with you or where you have provided explicit consent for such transfers.

11. Data Retention

We retain your personal data for no longer than is necessary for the purposes for which it was collected or as required by law. For example:

• Account data: Retained as long as your account is active or as necessary to provide services to you.
• Marketing data: Retained until you unsubscribe or withdraw consent for receiving marketing communications.
• Transaction data: Retained for a period necessary to comply with financial, tax, and legal obligations.

12. Data Sharing

We do not sell or rent your personal data to third parties. However, we may share your personal data with member companies, subsidiaries or trusted third-party service providers to help us deliver services, such as:

• Cloud-based technology providers: For the secure storage of data in cloud environments, where applicable.
• Fulfilment companies: To print and send our marketing and post purchase paperwork, and any required Order of Service literature.
• Funeral Directors: For them to arrange your funeral when you pass away in accordance with your wishes.
• Google Analytics and other third-party analytics services: To analyse website usage, improve user experience, and track site performance.
• Government industry bodies: Where required by law to share your personal information with fraud prevention organisations, industry regulators or enforcement bodies or courts.
• Legal services: Through our integration with Honey Legal we are able to provide a range of planning services to our customers.
• Member companies or subsidiaries: We may share your personal data with other companies within our group, including our subsidiaries, for the purposes of providing services, improving customer experience, and managing the business. All companies within our group are committed to protecting your personal data and ensuring it is handled in accordance with this Privacy Policy.
• Marketing platforms: For email campaigns and advertisements, subject to your preferences.
• Third-party payment processors: To process transactions securely.
• IT service providers: To maintain and improve our Website and services.

All third parties with whom we share your personal data are required to protect it and comply with applicable data protection laws.

13. Direct Marketing

We may use your contact details to send you marketing materials or promotional offers that we believe may interest you. You can opt-out of receiving marketing communications at any time by:

• Clicking the “unsubscribe” link in our marketing emails.
• Contacting us directly at privacy@funeralswithgrace.com

14. Checking Your Identity

To ensure that your privacy is protected, we may request additional information to verify your identity when processing requests related to your personal data. This is to prevent unauthorised access to your personal information. This may include third-party identity checks.

15. Disclosure to Potential Purchasers

In the event that we sell or transfer our business or assets, we may disclose your personal data to any potential purchaser or their advisers as part of the due diligence process. We will take steps to ensure that the recipient of the data agrees to maintain the confidentiality and security of your personal data.

16. Contacting UK Regulator

If you believe that we have not complied with the requirements of the UK GDPR in relation to your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection authority.

ICO Contact Information:

• Website: https://ico.org.uk
• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom.
• Phone: 0303 123 1113

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Any significant changes will be posted on this page, with an updated “Last Updated” date.

18.Contact Us

If you have any questions or concerns regarding this Privacy Policy or how we handle your personal data, please contact us at:

Plan with Grace Limited
Registered Company Address: Thomas House, 84 Eccleston Square, Pimlico, London, SW1V 1PX
Email: Support@funeralswithgrace.com
Phone: 0800 471 4689

19. Links to Other Websites

Please note that our Website may contain links to other third-party websites. This Privacy Policy applies only to the services and websites operated by Plan with Grace Limited. We do not control and are not responsible for the content, privacy practices, or policies of other websites. When you click on a link to another website, you will be subject to that website’s privacy policy.