Privacy Policy

Who We Are

Avalon Funeral Plans, Lifelocker and Expat Funeral Plans are trading styles of Avalon Trustee Company Limited (Company No: 02836336), and Avalon (Europe) Limited (Company No: 03773923) both with their registered Head Office in England: Brooke Court, Lower Meadow Road, Handforth Dean, Wilmslow, SK9 3ND.

Avalon Group Companies are authorised and regulated by the Financial Conduct Authority (FCA). Our UK plans are provided through The Avalon Trustee Company Limited and its FCA registration number is 965284. Our European plans are provided through Avalon (Europe) Limited and its FCA registration number is 965286.

Avalon has a European regional office in Spain: Avalon (Europe) Limited, Calle Albatera 1-68, Urb La Finca Golf, 03169 Algorfa, Alicante, Spain.

When we refer to “Avalon”, “Avalon Funeral Plans”, “we”, “us” or “our” we mean all the Avalon Group of companies including Avalon Trustee Company Limited and Avalon (Europe) Limited and their trading styles. Services to you may be provided by any Avalon Group company for all plans and you can execute your rights detailed in this privacy policy in the same way for any Avalon Group company.

Avalon is registered with the Information Commissioners Office in the UK under Z2182327 (The Avalon Trustee Company Limited) and Z2182344 (Avalon (Europe) Limited).

You can contact us through our website www.avalonfuneralplans.com, by email at [email protected] or by phone: 0161 486 2020.

Our Data Protection Principles

Avalon has adopted the following principles to deal with your personal data:

1. Personal data shall be processed fairly and lawfully and in a transparent manner.
2. Personal data shall be obtained only for one or more specified explicit and legitimate purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose or purposes for which they are processed.
4. Personal data shall be accurate and, where necessary, kept up to date.
5. Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose or those purposes.
6. Personal data shall be processed in accordance with the rights of data subject.
7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
8. Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
9. Avalon shall be responsible for, and be able to demonstrate compliance with, its data protection principles.

Personal data you give us

Personal data means data that identifies you as an individual. You should only provide your data to Avalon if you are happy for us to process it in accordance with this Privacy Policy and the consent you’ve provided to us.

We may collect, use and store different kinds of data about you which we have grouped together as follows:

• Identity Data – your first name(s) and surname along with other names you may provide, your date of birth, your passport details or other relevant identity information
• Contact Data – including your address(s), email address(s) and telephone number(s)
• Your Avalon Plan ID
• Your payment details when you apply for and pay for a funeral plan online or if you pay by direct debit.
• Special Categories of Personal Data – We do not routinely collect special categories of personal data but if you choose to tell us or there’s a legal basis for us to collect the information, we may record health details, details connected to characteristics of vulnerability, your religion or racial or ethnic origin.

We may also collect, use and share aggregated data such as statistical or demographic data for our business purpose. Aggregated data is usually derived from customer’s personal data but does not in any way identify those individuals concerned. For example, aggregated data used to calculate the percentage of users accessing a specific website feature.

Personal Data you give about others

During the lifecycle of your plan, we may need to collect information about others connected to you, such as nominated representatives, Next of Kin, friends and family. In all cases we will process their data in the same way we would yours.

When you purchase a plan for someone else, we will only collect and process their information to administer the plan purchased and they can request for their data to be removed, in which case we will notify you as the purchaser.

If you nominate a “nominated representative” for your plan, we will process their data to send them a pack that relates to your plan. They will have the option to opt-out of data processing and in that case we will notify you and give you the option to nominate someone else.

How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity data, contact and marketing and communications data by filling in online forms or by corresponding with us by post, phone, email or otherwise.

Third party interactions. You may give us your identity data, contact and marketing and communications data by filling in online forms from websites operated by third-parties such as social media service providers. When you provide your data via a third party you accept that your data will be processed under the terms of both Privacy Policies.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our cookie policy for further details.

Technical Data from analytics providers such as Google.

Personal Data we collect automatically

Whether or not you end up buying a plan, when you visit our website, we might automatically collect certain information.

This includes your IP address, the date and time you accessed our services, and information about your computer’s hardware and software (such as the operating system, the internet browser used, software/application version data and your language settings). We also collect information about clicks and which pages have been shown to you.

If you’re using a mobile device, we might collect data that identifies the device, as well as data about your device-specific settings and characteristics, and other system activity. When you buy a plan using this kind of device, our system registers how you bought your plan (on which website), and/or which site you came from when you entered the www.avalonfuneralplans.com website.

Personal data we get from other companies

We may also receive information about you from other sources these include business partners, social media sites (such as Facebook, Instagram, YouTube WhatsApp, etc.), other companies of the Avalon group of companies and other independent third parties. Anything we receive from these partners may be combined with information provided by you.

We also integrate with third party service providers to facilitate payments and to do credit checks. These service providers share payment information so we can administer and handle your plan, making sure everything goes as smoothly as possible for you.

Additionally, we collect information in the regrettable case that we receive a complaint from you or about you from Funeral Director, regulator or other relevant third-party.

We may also receive information about you in order to show you more relevant ads, such as the additional cookie data Avalon’s social media partners make available to us. Please read the section Why do we collect and use your personal data? for more information.

Funeral Directors may share information about you with Avalon too. This could happen if you have support questions about enacting a plan on someone else’s behalf, or if disputes or other issues arise about a plan or associated services. In addition, Funeral Directors may need to share information about the person arranging the funeral (at the time of redemption), for example, in order to manage payments for products/services which are not covered by the funeral plan.

Why do we collect and use your personal data?

The main reason we ask you for personal details is to help you with your funeral plan and ensure you get the best service possible.

We use the information collected about you for a variety of purposes. Your personal data may be used in the following ways:

1. Buying and Administering your Funeral Plan: We use your personal data to facilitate the sale of and administration of your funeral plan contract, and to forward the necessary details to the company that provides your funeral. This includes sending you communications in relation to your plan, such as confirmations, modifications and reminders for payment.
2. Customer service: Our customer service teams need your details so they can help you with your plan, reply to any queries you may have about your plan, or deal with any complaints.
3. Marketing activities: We use your information for marketing activities. These activities include:
   • Using your contact information to send you updates about our products and services (and/or those of our group companies or affiliate business partners). You can unsubscribe from email marketing communications quickly, easily and at any time – just click the “unsubscribe” link in any email or email us at [email protected]
   • Based on your information, individualised offers might be shown to you on the avalonfuneralplans.com website or on third-party websites/apps (including social media sites) and the content of the site displayed to you might be personalised.
   • Contacting you by phone, email or SMS/WhatsApp or other communication method with information our products and services.
   • Inviting you to participate in promotional activities (such as referral programmes or competitions). When you participate in other promotional activities (such as referral programmes or competitions), only the relevant information will be used to administer these promotions.
   • For the purpose of advertising services provided by advertising service provider’s organisations such as Google, Facebook, Snapchat, Experian, Outbrain, Verizon Media and Taboola.
   • Sharing information on trusted business partners, such as legal firms to provide you with information on their products and services.
4. Communicating with you: There might be other times when we get in touch, including by email, by post, by phone or by texting you. Which method we choose depends on the contact information you’ve previously shared. We process the communications you send to us. There could be a number of reasons for this, including:
   • Responding to and handling any requests you have made.
   • If you have started but not finished a purchase, or you’ve cancelled a plan, in the last three years, we might contact you to invite you to continue with your purchase or reinstate your plan. We believe that this additional service benefits you as it allows you to pick up the process where you left off without having to search for a funeral plan or fill in your details again.
   • After you or your nominated representative contact us, we might send you a questionnaire or invite you to provide a review about your experience with avalonfuneralplans.com or the Funeral Director.
   • Sending you other material related to your plan, such as how to contact us if you need assistance and information that we feel might be useful to you.
   • Following up on outstanding payments due on your plan, if you’re paying by instalments.
   • Sending you information as required by relevant regulation, such as a summary statement of your plan and contractual documents.
5. Market research: We sometimes invite our customers to take part in market research. Please see the information that accompanies this kind of invitation to understand what personal data will be collected and how that data is used.
6. Improving our services: We also use personal data for analytical purposes and product improvement. This is part of our commitment to making our services better and enhancing the user experience. In this case, we use data for testing and troubleshooting purposes, as well as to generate statistics about our business. The main goal here is to get insights into how our services perform, how they are used, and ultimately to optimise and customise our service offering to ensure they’re more meaningful and meet the target market of our products. As much as possible, we strive to use de-identified data for this analytical work.
7. Call/Video monitoring: During calls with our customer service teams, live listening might be carried out or calls might be recorded for quality control and training purposes. This includes the usage of the recordings for the handling of complaints, legal claims and for fraud detection. Not all calls are recorded and recordings are kept for a limited amount of time before being deleted unless we determine before then that the recorded calls need to be retained for fraud investigation or legal purposes.
8. Promotion of a safe and trustworthy service: To create a trustworthy environment for you, your nominated representatives, Funeral Directors and other relevant third-parties, we continuously analyse and use certain personal data to detect and prevent fraud and other illegal or unwanted activities. Similarly, we use personal data for risk assessment and security purposes, including for the authentication of plan holders. When we do this, we may have to stop or put certain plans on hold until we’ve finished our assessment.

Providing your personal data to Avalon is voluntary. However, we may only be able to provide you with certain services if we can collect some personal data. For instance, we can’t process your plan if we don’t collect your name, address and payment details.

If we use automation to process personal data which produces legal effects or significantly affects you, we will always implement the measures required to safeguard your rights and freedoms. This includes the right to obtain human intervention.

Security and Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In accordance with applicable UK and European data protection laws, we observe reasonable procedures to prevent unauthorised access to and misuse of personal data.

Our business systems and procedures ensure we take all reasonable steps to protect your personal data in accordance with UK and European data protection laws. We also have specific security procedures and technical and physical restrictions on accessing and using the personal data on our servers. Only authorised personnel are permitted to access personal data in the course of their work.

We will retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you, to comply with applicable laws, to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this statement.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data Transfers to Third Countries

The data that we collect from you will be transferred to, and stored at, a destination within the UK or European Economic Area (“EEA”). It will be processed by staff operating within the UK or EEA and who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Where your personal data is collected through a third party, such as Facebook, then the location and transfer of your personal data will be governed by their privacy, storage and transfer policies.

The transmission of personal data as described in this Privacy Notice may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the United Kingdom and countries within the European Union. Where required by UK law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with UK and European standards. You can ask us to see a copy of these contractual agreements using the contact details below.

Security and Cookies

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, agents, contractors and other third-parties 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.

Where we suspect that your data has been breached, we will notify you and the applicable regulator of this breach when we are legally required to do so.

Opting Out

If you would rather not receive marketing contact or would like to change your preferred method of communication (such as email, post, telephone or SMS), please contact us via email or phone including your contact details: [email protected] or +44 161 486 2020

Rights and Your Data

Under UK and European data protection laws you have:

The right to be informed: In other words to be told how we use your data.

The right to rectification: This means the data we hold on you should be up to date, accurate and complete. When we amend or update your information, we will do this without delay and confirm this to you.

The right to erasure: Sometimes referred to as the right to be forgotten. You can ask us to remove your data from our business process and your request will be extended to any party we may have shared your data with. We may retain your data when it is necessary for establishing, exercising or defending legal claims (In affect this will mean your data is segregated from our business process and cannot be processed).

The right to restrict processing: You can limit the way we use your personal data if you are concerned about the accuracy of the data or how it is being used. You can also exercise your right to restrict the erasure of the data we hold about you.

The right to object: You can withdraw your consent to the processing of your data either in part or in total at any time by contacting us.

The right to access the data we hold about you: This is known as Subject Access Request.

To obtain a copy of your personal information, please write to us at the contact address below. We will tell you what personal information we hold relating to you, the purposes why it is being processed and to whom the information has been disclosed. We will normally provide this information within 30 days of your request and the service is free, unless your request is complex or numerous.

In terms of our Privacy Policy your consumer rights are not restricted in any way. If you have a concern about the way we have used your data please tell us using our contact details below.

The Data Controller, Avalon Funeral Plans Brooke Court, Lower Meadow Road, Handforth Dean, Wilmslow, SK9 3ND or email us at: [email protected]

You also have the right to contact the Information Commissioners Office (ICO) in respect of any concerns you may have relating to how we have used your data by going to their website at: https://ico.org.uk/, calling them on: 0303 123 1113

Writing to them at: Information Commissioner’s Office, Water Lane, Wilmslow, SK9 5AF.

How to control and delete cookies

You can manage your cookies through your own browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor any third-parties will transfer cookies to your browser. However, if you choose to do this, you may have to manually adjust your preferences each time you visit our website and unfortunately some aspects of our website may not work for you.

For further information on our use of cookies, please visit www.allaboutcookies.org

We may use the following cookies and technologies in the delivery of our website:

• Strictly necessary cookies: Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Statistics cookies: Help us to understand how visitors to our website interact by collecting and reporting information anonymously.
• Marketing cookies: Are used to track visitors to our websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
• Preferences cookies: Enable us to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Analytical/performance cookies: Allow us to recognise and count the number of visitors and see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Google Cookies: Google Analytics helps us measure how users interact with our website content. Avalon may use cookie data to remarket to website visitors across the Google search network. This feature allows Google to display an Avalon ad to previous website visitors. You can opt out of Google’s cookies by visiting Google’s Ads Settings. Here you will be able to opt out of cookies and control the data Google stores on you.

You can find information about these here https://www.optimizesmart.com/google-analytics-cookies-ultimate-guide/