Privacy Policy

1. About This Privacy Policy

This Privacy Policy explains how the Funeral Plan Register collects, uses, stores and shares personal information.

It applies when you:

• visit our website;
• register a funeral plan;
• search for a funeral plan;
• create or use an account;
• contact us;
• make a payment;
• provide information about yourself, a family member or another person; or
• otherwise use our services.

Please read this policy carefully so that you understand how your information will be handled.

This Privacy Policy should be read alongside our Cookie Policy and any additional privacy information shown when you use a particular service.

2. Who We Are

The Funeral Plan Register is operated by INFINIREG LIMITED, a private limited

company registered in England and Wales.

Company number: 16352772

Registered office: 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

Email: info@infinireg.co.uk

INFINIREG LIMITED, trading as the Funeral Plan Register, is the data controller responsible for deciding how and why your personal information is used.

In this policy, references to “we”, “us” and “our” mean INFINIREG LIMITED trading as the Funeral Plan Register.

3. Information About Deceased People

UK data-protection law applies to information relating to identifiable living individuals. It does not generally apply to information that relates only to someone who has died.

However, information supplied during a funeral plan search or registration may also identify or relate to living people, including:

• the person carrying out the search;
• the person registering a plan;
• family members;
• nominated representatives;
• executors or administrators;
• funeral directors;
• plan holders who are still living; and
• professional advisers.

We will handle this information in accordance with applicable data-protection law.

Information relating to someone who has died may also remain protected by duties of confidentiality, contractual obligations or other legal requirements.

4. Personal Information We May Collect

The information we collect will depend on how you use the Funeral Plan Register.

Information About You

We may collect:

• your full name;
• postal address;
• email address;
• telephone number;
• date of birth;
• account or username details;
• your relationship to a plan holder or deceased person;
• evidence of your identity;
• evidence of your authority to act;
• correspondence and communications with us;
• records of searches or registrations you carry out;
• payment and transaction details;
• technical information about your device and use of the website; and
• your communication and cookie preferences.

Information Used to Register a Funeral Plan

When a funeral plan is registered, we may collect:

• the plan holder’s name;
• previous names;
• date of birth;
• current or previous addresses;
• telephone number and email address;
• funeral plan provider;
• plan number or reference;
• date the plan was purchased;
• information about the plan’s status;
• nominated family members or representatives;
• funeral wishes associated with the plan;
• supporting records or documents; and
• other information needed to identify and locate the plan.

Information Used to Search for a Funeral Plan

When a search is made, we may collect information about the person who has died, including:

• full name;
• previous names;
• date of birth;
• date of death;
• last known address;
• previous addresses;
• location of death;
• plan provider details, where known;
• copies or details of relevant documents; and
• other information supplied to help identify a possible match.

We may also collect information about the person carrying out the search, including their identity, contact details and relationship to the deceased.

Information From Funeral Plan Providers and Other Organisations

We may receive information from:

• funeral plan providers;
• funeral directors;
• solicitors and probate professionals;
• executors or administrators;
• nominated representatives;
• insurers;
• professional advisers;
• identity and address-verification providers;
• payment providers;
• public records;
• regulatory or government bodies; and
• other organisations involved in locating or administering a funeral plan.

5. Special Category Information

Some information may reveal sensitive details about a living individual, such as:

• religious or philosophical beliefs reflected in funeral wishes;
• health information;
• ethnicity;
• sexual orientation; or
• other information treated as special category data under the UK GDPR.

We will only collect or use this information where it is necessary and where both:

• a lawful basis under Article 6 of the UK GDPR applies; and
• an additional condition under Article 9 applies.

Depending on the circumstances, we may rely on explicit consent or another condition permitted by law.

We will not request sensitive information unless it is relevant to the service being provided.

6. How We Use Personal Information

We may use personal information to:

• register a funeral plan;
• search for and identify a funeral plan;
• compare search details with registered plan information;
• contact a funeral plan provider about a potential match;
• notify an authorised person that a possible plan has been located;
• connect a plan holder with nominated family members or representatives;
• record funeral wishes;
• verify identities and authority to act;
• manage user accounts;
• process payments and issue receipts;
• respond to questions, complaints and support requests;
• prevent fraud, misuse and unauthorised access;
• maintain the accuracy and security of the register;
• improve our website and services;
• monitor technical performance;
• comply with legal, regulatory and reporting obligations;
• establish, exercise or defend legal claims; and
• keep appropriate records of searches, registrations and communications.

We will not use personal information for purposes that are incompatible with those for which it was collected unless permitted or required by law.

7. Our Lawful Bases

We must have a lawful basis for each way in which we use personal information.

Depending on the purpose, we may rely on the following bases.

Contract

We may process information where it is necessary to:

• provide a funeral plan registration or search requested by you;
• process a payment;
• manage an account; or
• take steps at your request before entering into a contract.

Legal Obligation

We may process information where necessary to comply with a legal or regulatory obligation, including requirements relating to:

• financial records;
• fraud prevention;
• data protection;
• law-enforcement requests;
• court orders; and
• regulatory enquiries.

Legitimate Interests

We may process information where it is necessary for our legitimate interests or those of another organisation, provided those interests are not overridden by your rights.

Our legitimate interests may include:

• operating and maintaining the Funeral Plan Register;
• helping users locate funeral plans;
• maintaining accurate registration and search records;
• protecting the website and its users;
• preventing fraud and misuse;
• improving our services;
• managing complaints and legal claims; and
• supporting the effective administration of funeral plans.

Where we rely on legitimate interests, we will consider the necessity of the processing and its likely effect on the people concerned.

Consent

We may rely on consent where you have been given a genuine choice, including for:

• optional marketing communications;
• non-essential cookies;
• certain uses of sensitive information; or
• optional sharing or notification features.

You may withdraw your consent at any time. Withdrawal will not affect processing that took place before consent was withdrawn.

Vital Interests

In exceptional circumstances, we may process information where necessary to protect someone’s life.

8. Providing Information About Another Person

You may provide information about another person when:

• registering a funeral plan;
• nominating a family member or representative;
• searching on behalf of a deceased person;
• acting as an executor, administrator or professional representative; or
• helping someone use our services.

You should only provide information that is relevant and that you are entitled to provide.

Where appropriate, you should make the person aware that their information has been provided to the Funeral Plan Register and direct them to this Privacy Policy.

We may contact that person to explain how their information is being used, unless an exemption applies or doing so would be impossible or involve disproportionate effort.

9. How Funeral Plan Matching Works

We may compare the information submitted in a search with information held on the Funeral Plan Register or supplied by participating funeral plan providers.

Matching may involve details such as:

• name;
• previous names;
• date of birth;
• address history;
• plan reference;
• provider details; and
• other identifying information.

A potential match may be reviewed before information is released.

We may ask for further information or evidence to confirm identity, the relationship to the deceased or the authority to receive plan information.

Submitting a search does not guarantee that a plan will be found. A negative result does not necessarily prove that no funeral plan exists, particularly where a plan has not been registered or relevant information has not been supplied to us.

10. Automated Decision-Making

We may use automated tools to compare information and identify possible funeral plan matches.

We do not intend to make decisions that produce legal or similarly significant effects about living individuals solely through automated processing without appropriate safeguards.

Potential matches may be subject to additional checks or human review before plan information is released.

11. Who We May Share Information With

We may share relevant information with:

• funeral plan providers;
• funeral directors;
• payment-processing providers;
• identity and address-verification providers;
• cloud-hosting and IT providers;
• website developers and technical-support providers;
• email and communication providers;
• analytics and security providers;
• professional advisers, including solicitors, accountants and insurers;
• regulators and supervisory authorities;
• law-enforcement agencies;
• courts and tribunals;
• government departments;
• a purchaser, investor or successor in connection with a business sale, restructuring or transfer; and
• other organisations where sharing is authorised by you or required by law.

We will only share information that is reasonably necessary for the relevant purpose.

Where another organisation processes personal information on our behalf, we will require it to protect that information and use it only in accordance with our instructions and applicable law.

A funeral plan provider may act as a separate data controller when it uses information for its own purposes. Its own privacy policy will explain how it handles that information.

12. Payment Information

Payments made through the website may be processed by an independent payment-services provider.

The provider may collect payment-card, billing and transaction information directly. We may not receive or store your complete payment-card details.

We may retain information such as:

• the amount paid;
• the date and time of payment;
• a transaction reference;
• payment status; and
• limited billing details.

The payment provider will handle your information in accordance with its own privacy policy.

Payment provider used: Stripe

13. Identity and Security Checks

To protect funeral plan information, we may ask you to provide evidence of:

• your identity;
• your address;
• your relationship to the plan holder or deceased;
• the death;
• your status as executor or administrator; or
• your authority to act for another person.

We may use third-party identity or address-verification services to check information against appropriate databases.

We will only request information that is reasonably necessary for the relevant check.

Identity or verification providers used: [insert providers, if applicable]

14. International Transfers

Some service providers may store or access information outside the United Kingdom.

Where personal information is transferred internationally, we will take steps required by data- protection law to protect it.

These steps may include:

• transferring information to a country recognised as providing adequate protection;
• using approved contractual safeguards;
• carrying out a transfer-risk assessment; or
• relying on another lawful transfer mechanism.

You may contact us for further information about the safeguards used for relevant transfers.

Countries or international providers involved: [insert details or confirm that no international transfers take place]

15. How Long We Keep Information

We will keep personal information only for as long as reasonably necessary for the purpose

for which it was collected, including legal, regulatory, accounting, security and dispute-

resolution requirements.

Retention periods may depend on:

• whether the information relates to an active funeral plan;
• whether a search remains active;
• the status of the plan holder;
• contractual or regulatory requirements;
• the need to prevent fraud or duplicate claims;
• limitation periods for legal claims; and
• the sensitivity and volume of the information.

Our intended retention periods should be confirmed as follows:

We may anonymise information so that it can no longer identify a living individual.

Anonymised information may be retained for statistical, research and service-improvement purposes.

16. How We Protect Information

We use appropriate technical and organisational measures designed to protect information against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure; and
• destruction.

These measures may include:

• encryption;
• access controls;
• authentication;
• system monitoring;
• staff and contractor confidentiality requirements;
• secure hosting;
• backups;
• vulnerability management; and
• incident-response procedures.

Access to personal information is limited to people and organisations that need it for legitimate purposes.

No online system can be guaranteed to be completely secure. You should take reasonable steps to protect passwords, account details and devices used to access our services.

17. Marketing Communications

We may send service-related communications where necessary to administer a search, registration, payment or account.

These are not marketing communications and may still be sent where needed to provide the service.

We will only send optional electronic marketing where permitted by law.

You can unsubscribe by:

• using the unsubscribe option in a marketing message; or
• contacting info@infinireg.co.uk.

We may retain limited details on a suppression list to ensure that your marketing preference continues to be respected.

We will not sell your personal information to third parties for their own marketing purposes.

18. Cookies and Website Information

When you visit our website, we may collect technical information such as:

• IP address;
• browser type;
• device information;
• pages visited;
• dates and times of visits;
• referring website;
• website interactions; and
• technical error information.

We use cookies and similar technologies for essential website functions and, where permitted, analytics, functionality and marketing.

Further information is available in our Cookie Policy.

19. Your Data-Protection Rights

Depending on the circumstances, you may have the right to:

• be informed about how your information is used;
• request access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to erase your information;
• ask us to restrict how your information is used;
• object to processing based on legitimate interests;
• object to direct marketing;
• request the transfer of certain information in a portable format;
• withdraw consent where processing relies on consent; and
• request safeguards relating to certain automated decisions.

These rights are not absolute and may not apply in every situation.

They apply to personal information about living individuals. They do not generally create a right to access information that relates only to a deceased person.

We may ask for information to confirm your identity before dealing with a request.

We will normally respond within one month, although the period may be extended where permitted by law.

To exercise a right, contact:

Email: info@infinireg.co.uk

Postal address: INFINIREG LIMITED, 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

20. Complaints

Please contact us first if you have concerns about how your information has been handled.

Email: info@infinireg.co.uk

Postal address: INFINIREG LIMITED, 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection.

Information about making a complaint is available through the Information Commissioner’s Office website.

21. Children

The Funeral Plan Register is not intended to be used independently by children.

Where information about a child is provided, we will take additional care and will only use it where there is an appropriate lawful basis and the processing is fair and necessary.

22. Links to Other Websites

Our website may include links to websites operated by other organisations.

We are not responsible for the privacy practices or content of those websites. You should review the privacy policy of any external website you visit.

23. Changes to This Privacy Policy

We may update this Privacy Policy to reflect:

• changes to our services;
• changes to the information we collect;
• changes to our providers or systems;
• operational developments; or
• changes to legal or regulatory requirements.

The date at the top of this policy will show when it was last updated.

Where appropriate, we may notify registered users of significant changes.

24. Contact Us

For questions about this Privacy Policy or how personal information is handled, please contact:

INFINIREG LIMITED

Trading as: The Funeral Plan Register

Company number: 16352772

Registered office: 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

Email: info@infinireg.co.uk