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Privacy notice

Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use personal data we are regulated by the Information Commissioner under the Retained Regulation EU 2016/679 (“UK GDPR”) and the UK Data Protection Act 2018 (together, “Data Protection Legislation”).   We are accountable as Controller of that personal data for the purposes of Data Protection legislation.

Key terms
It would be helpful to start by explaining some key terms used in this notice:

We, Untangle Grief, us, our
Untangle Grief Limited, incorporated and registered in England and Wales with company number 13198595, whose registered office is c/o Dragon Argent Limited, 63 Bermondsey Street, London SE1 3XF, United Kingdom.

Personal data
Any information relating to an identified or identifiable natural person
Special category personal data
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation

Personal data we collect
In the course of your interaction with us and your use of our services or those of our partners in the process of dealing with bereavement in all its facets, including connecting with others who are also dealing with grief in private support groups, seeking practical assistance with legal, probate and funereal services, and therapeutic support,  we will collect from you some or all of the following personal data:
Your full name
Your relationship to the deceased, including whether you are executor or next of kin
Your unique ID (generated by us)
Your display name (chosen by you)
Your date of birth
Your occupation (optional)
Your email address and mobile phone number
Your location
Your gender (optional)
The content of the free form messages (if any) you leave in the community forum
Your availability for therapy sessions (if you choose to seek therapeutic support)
If arranging funeral services, whether you wish for any religious or cultural observances.

This personal data (and where appropriate, special category personal data) is required to enable us to provide our services. If we are not provided with the personal data we ask for, it may delay or prevent us from providing the services which you are requesting.

How personal data is collected
We collect your personal data directly when you register with us and interact with our community forum and work with us to obtain our services or those of our partners.

How and why we use personal data
Under Data Protection Legislation, we can only use personal data if we have a legal basis for doing so.  These are mandated by the legislation and include:
your consent;
for the performance of our contract with you or to take steps before entering into a contract;
to comply with our legal and regulatory obligations; or
for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by the data subject’s own rights and freedoms.
The table below explains what we use (process) personal data for (our purpose) and our legal basis for doing so:

Our purpose
Our legal basis
To enable us to understand what services you might need, to assist in the provision to you of those services, to create your account, to identify each user and match you with the relevant services
For the performance of our contract with you or to take steps before entering into a contract with you
To measure metrics such as the conversion from advertising, to website to sale
For our legitimate interests of those of a third party e.g. to measure community interaction and uptake
Operational reasons, such as maintaining the operational effectiveness of our website, understanding customer persona, revenue modelling and website usage
For our legitimate interests or those of a third party, e.g. to identify and remedy problems with the Website
Ensuring the confidentiality of personal data
For our legitimate interests or those of a third party, e.g. to prevent data breaches
To comply with our legal and regulatory obligations
Marketing our services
For our legitimate interests or those of a third party, e.g. to promote our business to existing and future customers

The above table does not apply to special category personal data.   When we collect and process any special category persona data, it will be only processed on the condition that it is with your explicit consent, which you will give to us at the time you provide us with the special category personal data in question, usually on registration via the website, and which you volunteer to us.

Promotional communications
We will always treat personal data with the utmost respect and never sell it to other organisations for marketing purposes.

Who we share personal data with
Where you ask for help with legal, funerary, probate or therapeutic services or support, we will share only relevant personal data with our partner Solicitors, Undertakers, Funeral Providers and Therapists.  If in the future, we are able to make additional services available and join up with other partners, we will update this notice accordingly.
We share personal data with a number of cloud-based storage providers whose security measures have been thoroughly reviewed to meet the standards required by Data Protection Legislation.
We only allow our external third parties to handle personal data if we are satisfied they take all appropriate measures to protect all personal data and only on our written instructions.
We may very occasionally disclose and exchange information with regulatory bodies to comply with our legal and regulatory obligations.

Where personal data is held
Personal data is kept securely in a password-protected environment.

Keeping personal data secure
The privacy and the security of personal data is our utmost priority, and we recognise our obligation to keep it secure and private. We have put in place industry-standard security practices to prevent personal data from being accidentally lost or used or accessed unlawfully.
How long personal data will be kept
We will retain personal data of customers for the duration of our contractual relationship with those customers or for so long as may be required in order to comply with our legal obligations.
When it is no longer necessary to retain personal data, we will delete it.

Transferring personal data out of the UK
We do not intend to transfer any personal data out of the UK.  Where data is stored on servers that are not located in the UK, this is with the protection of either an adequacy decision or the EU Commission’s Standard Contractual Clauses.  If this situation changes, we will update this Privacy Notice.

Rights:
All data subjects have the following rights, which can be exercised free of charge:

Access:
The right to be provided with a copy of personal data held on a data subject

Rectification:
The right to be provided with a copy of personal data held on a data subject

To be forgotten:
The right to require us to delete personal data—in certain situations

Restriction of processing:
The right to require us to restrict processing of certain personal data—in certain circumstances, e.g. if the accuracy of the data is contested

Data portability:
The right to receive the personal data provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

The right to object:
—at any time to personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of personal data, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making:
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning a data subject

To withdraw consent:
The right to withdraw consent as a legal basis for processing, at any time

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under Data Protection Legislation.
To exercise any of those rights, please contact us —see below: ‘How to contact us’.

Cookies
A cookie is a text file containing a small amount of data that is downloaded to your computer when you first visit our website.  Some cookies are essential to enable you to move around our website and use its features.  They also help us arrange the content and layout of our website and recognise those computers that have been to our website before.   These are known as Analytical or Functionality cookies.  They do not “push” advertising to your computer.
You may choose to remove or to block cookies at any time by adjusting your browser settings.  To learn more about cookies including how to manage or delete them, visit www.allaboutcookies.org.

How to complain
We hope that we can resolve any query or concern raised about our use of personal information.
Data Protection Legislation also gives the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/ concerns or telephone: 0303 123 1113.

Changes to this privacy policy
We may change this privacy policy from time to time, when we do we will inform data subjects via our website.

How to contact us
We can be contacted by post or email.
Our postal address is given at the top of this notice.
For all data subject rights, please contact [email protected]

Last updated:  March 2021