PRIVACY POLICY

Our Privacy Policy valid from June 25th, 2018
PRIVACY POLICY
(Version 1.0, June 2018)
When you write a review on the Funeral Directors Register or otherwise use our Website, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
When we talk about the “Register,” “we,” “us” or “our,” we mean the Funeral Directors Register’s website and our affiliates. We also use “Policy” to refer to this Privacy Policy and “Website” to refer to our applications.
The “Funeral Directors Register Ltd” is the entity responsible for processing your personal data.
1 Personal data - what we collect and what we use it for
1.1 Master data
When you create a profile or write a review on our Website, we collect the following personal data about you (the “Master Data”):

Your persona/username (this will be public)
Your email address.
Telephone number.

This information is mandatory, which means that it will not be possible to write a review on the Website without it.
Our Website is an open review platform and when we display your review we will connect it to your profile so that people can see who wrote the review. Therefore, please be aware that depending on the information you add to your profile and the username you choose, you may or may not be anonymous.
1.2 Information in reviews and ratings
When you write a review about a company and post it on our Website, we collect the information you put in your review. This includes:

Which company you review
The headline and content of your review
Your rating of your Service Experience with the company (1-5 stars)
The date of your review
If we ask you to provide information or documentation verifying your Service Experience and you send us such documentation, we will collect and process the documentation for the purpose(s) stated in the request.

Please don’t share any sensitive personal documents or information with us, either concerning yourself or others.
1.3 Information about views, likes and how useful your review is for others
When you write a review of a company on our Website, people can show that they find your review useful, for example by “liking it” via social media, and we collect this information. We also collect information about how many people read your review. We don’t track the identities of people who aren’t logged in and read the reviews, but we do collect data on the number of consumers who read your review. If you “like” another person’s review we will also collect that information.
1.4 Notifications
If you notify us about a review that you believe violates our User Guidelines, then we collect the information you provide in your notification to us. This can include which review you notified us about, the reason for your notification, the date of your notification, etc.
1.5 Cookies
Our Website uses cookies. Cookies identify your computer or device rather than you as an individual user, and are used for different purposes.
Read more about which cookies the Website uses and for which purposes below (in 8).
1.6 Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We may also use the IP address to approximate your location (at city level).
1.8 Newsletters and digest emails
We collect the information you provide us with when you subscribe to receive our newsletters, digest emails or similar (we collect your name, email address and newsletter preferences). If you no longer wish to receive our newsletters, digest emails or similar, you can unsubscribe by either clicking “unsubscribe” in any of our emails, or email unsubscribe@funeraldirectorsregister.com
1.9 For what purposes do we use your personal information?
We will use the information you provide to us to:

Provide our services to you, including displaying your reviews, and providing you with access to our Website
Verify the legitimacy of your reviews
Improve the Website and our services
Invite you to leave more reviews
Respond to your questions and provide related customer service
Pass on a message to/from the company via the Website
Contact you if your review is flagged by other users or companies and, if necessary, ask you to provide documentation to verify your review or experience
Send you our newsletters
Provide feedback concerning your review
Facilitate the social sharing function
Engage in various internal business purposes, i.e data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, or our services including our TrustBadge , ReviewBox, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
Enforce our Terms & Conditions
Protect our operations or those of any of our affiliates
Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
Allow us to pursue available remedies or limit any damages that we sustain

We will also use the information in other ways for which we provide specific notice at the time of collection.
1.10 On what legal basis do we process your personal data?
We need to process your personal information in order to:

Perform our contract with you (see Article 6.1.b of the GDPR)
Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements.
Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)

Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal information, or ask us to restrict the processing. Please see below, at 13, for more details.
If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) - see 14, below.
2 Disclosure of personal information
2.1 Disclosure of personal information on the Website
We are an open review platform and we share your review on our Website so that others can read about your experience with a specific company. When you write a review, we will disclose your review, your username and other information you have chosen to connect with your public profile. Remember that if you have selected to use your name as your username, this can reveal your identity in full or in part - unless you use a pseudonym.
We recommend that you exercise care in deciding which information to make available for disclosing on the Website, and be aware that depending on the level of information provided, you may or may not be anonymous.
Master Data and other information
When you write a review on our Website, your username, review, photo, location and the number of reviews you have written will be visible on the Website. The companies you review can also receive information about your review.
Geo-location
When you write a review on the Website, we use your computer’s IP address (see 1.7 of this Policy, above) to approximate your location to the nearest city. This information is made available to other users of the Website.
Reviews you found useful
When you find other reviews useful (by “liking” them), other users of our Website can see the review(s) you “liked”.
2.2 Disclosure to other services, websites and companies
One of the Register’s main goals is to increase the exposure and availability of reviews on the Website. We therefore permit other services to show reviews created on the Website. This increases the potential audience for your reviews.
The categories of third party services and companies who can show your review(s) together with your public user profile are:

Search engines, including Google and Bing
Companies reviewed on the Register
Consumer portals and business portals, including price comparison websites, shopping guides, etc.
Application partners and platforms
Other similar websites where, in the Register’s assessment, it will be relevant for users to search for reviews.
Facebook “If your review has been shared on the Social Network”

Once you submit your review, it is published on the Website. This means that the following information is disclosed:

Your review(s), (see 1.2, above)
Your name/username and the additional data you choose to add to your review(s), such as your name and photo.

If you write a review on the Register in response to an invitation sent by a company, the company who sent you the invite will be able to link your review with the invitation.
If we need to verify your review, we will contact you and ask for documentation that shows that you have had a Service Experience with the company that you have reviewed. We therefore recommend that you keep such documentation for 12 months from the date of your review. The type of documentation could be, but not limited to:

Order confirmations
Invoices or receipts
Delivery notes or reports
Screenshots of your logged in user profile
Your email conversation with the reviewed company

If you don't have one of the documents listed here, you can send us what you do have if you believe that it demonstrates a buying or service experience with the company - and we’ll be happy to consider it. If there's enough information to verify your experience and get your review back online, we'll do our best to make sure that happens.

We do not share the documentation you send to us with the reviewed company. However, if you have a reference number or order ID, we may pass that on to the company, unless you ask us not to.
2.4 Other disclosures
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:

To allow third party vendors, consultants and other service providers to perform services on our behalf
To the Register’s subsidiaries and other affiliated companies
To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards, and The Competition and Markets Authority, in connection with investigations or case referrals
To third parties in connection with enforcement of our Terms & Conditions and Guidelines
To third parties in order for us to protect our operations or those of our affiliates
To third parties in order for us to pursue available remedies, or limit damages that we may sustain
To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website
To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).

3 Data controller
3.1 Information for which we are the data controller
We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, password and email address, as well as the registration of your IP address.
We are also the data controller of the information which is disclosed to other services (see 2.3). England’s data protection laws govern our collection of your data.
3.2 Information for which you are the data controller
You are the data controller for the content you choose to disclose on the Website
4 Links to websites
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.
5 Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as long as the business(es) you review is active, or unless you ask us to remove such data. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion. We will keep the log for 3 years. All other information will be deleted.
6 Security measures
We use reasonable organizational, technical and administrative measures to protect your personal information within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.
7 Cookies
The Website uses cookies and similar technologies (“Cookies”). By using our Website, you accept that we use Cookies as described below.
7.1 What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer's hard disk, on your tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5 sessionStorage objects are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the Website. HTML5 localStorage objects are permanent in nature and remain on your computer until they are deleted.
8.2 What do we use Cookies for?
We use Cookies for:
Generating statistics
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Monitoring Website performance and your use of our Website
Monitoring the performance of the Website, our applications and TrustBoxes and how you use our Website, applications and TrustBoxes.
Authentication and improving the functionality of our Website
Optimizing your experience with the Website, which includes remembering your username and password when you return to the Website, and remembering information about your browser and preferences (e.g. which language you prefer).
Connecting you to Social Networks
We give you the option of connecting with Social Networks, such as Facebook.
Quality assurance
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
Targeted advertisements
Displaying relevant advertisements on the Website, including interest-based advertisements, which we believe are of interest to you. We use third parties to provide these advertisements when you visit the Website and other websites. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about your use of our Website and other websites.
8.3 Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:

Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google

8.4 Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you're on a Mac.
If you do not accept Cookies from our Website, you may experience inconvenience in your use of the Website, and you may be prevented from accessing some of its features.
9 Access and insights into the personal data we have about you
If you don’t have an Account, you can email privacy@funeraldirectorsregister.com and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.
10 Download your personal data (data portability)
If you have a user profile on the Register, we can provide the personal data that you have provided to us, on request by email to privacy@funeraldirectorsregister.com
11 Correction and deletion of your personal data
If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can correct most of the information yourself via your Account. We recommend that you make any the correction(s) yourself. Otherwise, you are welcome to ask us to assist with correcting your information (privacy@funeraldirectorsregister.com).
You may at any time correct or delete any content and personal information on the Website for which you are the data controller (see 3.2). If your personal information changes, or if you no longer wish to appear on the Website, you can update or delete the information by logging in to your Account.
If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data on the Website.
We reserve the right to block access to your Account and/or delete it if the Account and/or IP Address, or the content associated with your Account or your review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.
12 Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:

You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at privacy@funeraldirectorsregister.com

In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
13 Children’s information
Our Website is not intended for children. If you become aware that a child under the age of 13 has provided us with their personal information, or that information about a child has been made public, please contact us (privacy@funeraldirectorsregister.com).
14 Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: privacy@funeraldirectorsregister.com.
15 Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
16 Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us at: support@funeraldirectorsregister.com