1. Who are we?
2. How We May Contact You As part of your Funeral Planning Enquiry
3. How You Contact Us
4. How We Keep You Informed
5. Obtaining Personal Data/Information
6. Customer Communication
7. What Personal Information do we collect?
8. Who do we share your information with?
9. How do we use your information?
10. What cookies do we use?
11. How secure is our site and what steps do we take to keep your information safe?
12. Rights Of Access To Your Personal Information
13. How Long Will We Retain Your Personal Information For?
14. Your Right To Opt Out Of Future Contact From Us
15. Your Right To Be Forgotten/Erasure Of Your Personal Information
16. How To Make A Complaint

1. Who Are We?

Plan For Later Life is a trading name of TFLI Ltd. TFLI Ltd is licenced by the Information Commissioners Office, (Registration Number Z3585914), Registered in the UK, number 08424810. Registered Office Address: Adelphi Mill, Grimshaw Lane, Bollington, Cheshire, SK10 5JB.

planforlaterlife.co.uk are aware how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulation (GDPR). Contained within this statement and set out below are details of the type of information that we at planforlaterlife.co.uk may hold about you our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us, planforlaterlife.co.uk may choose to amend the content of this privacy policy on occasion. If this occurs then we will update the policy and the revised policy will be posted on this website.

2. How We May Contact You As part Of Your Funeral Planning Enquiry

We, and our panel of funeral planning providers, will keep you informed with the progress of your enquiry. Unless you state otherwise you may be contacted via telephone, email, post, SMS and automated message. (see further section on 'How we keep you informed')

Lawful basis for collecting your personal data

We process your personal data on different bases, according the reason for which you have provided your data to us. When you are browsing the Website, we process your data on the basis that you have given your consent to such processing by accessing the Website. When you have submitted your funeral planning enquiry with the TFLI Group, we process this personal data on the basis that we have a legitimate interest in processing your data (i.e. to share your information with our funeral planning providers). When we have submitted the funeral planning enquiry, we process your personal data on the basis that we need this information to fulfill our obligations under the contract we have entered into with you. We will also process this personal data on the basis that you have given your consent to be contacted by the TFLI Group for marketing purposes and their panel of funeral planning providers, for the purpose of processing your funeral planning enquiry.

You can withdraw your consent to us processing your personal data for marketing purposes at any time by clicking the "unsubscribe" option in any marketing SMS, email we, or any associated third party, send to you. Alternatively, you can withdraw your consent by contacting our Data Protection Officer using the contact details stated in section 14 / 15. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you change your mind.

3. How You Contact Us

If you are required to telephone us using the specified telephone numbers on our website under the Contact or advertising/marketing correspondence then your call may be recorded for training, quality and regulatory purposes. We pride ourselves in complete customer care and this gives us the opportunity to continuously improve and monitor our customer experience.

4. How We Keep You Informed

We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest, this contact will be made via telephone, email, SMS, automated messages.

5. Obtaining Personal Data / Information

1. You are free to access and browse our website planforlaterlife.co.uk at your convenience and do not have to provide any personal information/data, however I would like to refer you to the ‘Cookies’ section set out within this privacy policy.
2. The information/data that we collect from you may include the following details:
   1. Name
   2. Residential address
   3. Residential status
   4. Email address (if applicable)
   5. Telephone number (home, mobile, work)
   6. Employment Status
   7. What you do on our website; the results of this will be used to show Plan For Later Life examples of which parts of our website are most and least used (please refer to ‘Cookies’ section)

If you register with us and have a question about our services, or alternatively choose to send an email to compliance@tfli.co.uk may also collect the above personal information/data in this instance in order for us to respond to your enquiry.

6. Customer Communication

Unless the customer states otherwise we will contact the customer via means of telephone, SMS and email to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regards to accuracy and we will endeavour to check your information with you on occasion.

Ensuring your personal details & or preferences are kept up to date.

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact our Compliance Manager as soon as possible (details set out below within ‘Contact’ page).

7. What Personal Information Do We Collect?

We collect personal information about you when you give this to us when applying for a Funeral Planning product online. This might be, for example, to obtain comparative quotes for the Funeral Planning product. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications, together with details of your financial information, for example, bank account or payment details.

In order to provide you with a funeral plan quote we may need to collect personal information. By proceeding with obtaining a quote you give your explicit consent to such information being processed by us and our third-party providers for the purposes stated in this Privacy Policy.

We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits

We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

8. Who Do We Share Your Personal Information With?

When you complete an application, you consent to us disclosing your personal information to the following parties:

1. planforlaterlife.co.uk and TFLI Limited: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.
2. Funeral Plan introducers / providers:
   
   • Avalon Trustee Company Limited trading as Avalon Funeral Plans
   • Luma Media Limited
   • Late Life Planning Limited trading as Prosperous Life
3. Our channel operators: whilst the majority of the channels on our Sites are run by us, some of our channels are designed and maintained for us by our third party service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed with your consent;
4. the Information Commissioners Office and/or other regulatory/governing bodies, for the purposes of compliance monitoring;

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

1. if required or permitted to do so by law;
2. if necessary in connection with legal proceedings or potential legal proceedings; and/or
3. in connection with the sale or potential sale of all or part of our business.

If you decide to enter into a funeral plan product with a third party provider through any of the funeral planning providers, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third party provider, will be held by the provider for the purposes set out in that provider's privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the funeral plan. We have no responsibility for the uses to which a provider puts your personal information

If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

9. How Do We Use Your Personal Information?

We may use your personal information:

1. to enable you to access and use the Services;
2. to personalise and improve aspects of our Services;
3. for research, such as analysing market trends and customer demographics;
4. to communicate with you, including some or all of the following:
1. sending you a confirmation email - when you submit an enquiry with us, you will automatically be sent confirmation of your enquiry by email or SMS so that you have a record of it
2. sending you funeral planning information in order to provide this service to you, we may also send that information to our partners such as funeral planning introducers/ providers offering funeral planning solutions
5. to process an application between you and a third party such as the funeral planning company
6. to track applications, which may involve us sharing data with your product provider relating to the product(s) you have chosen. Your product provider may also send us information they hold relating to the product(s) you have chosen for this purpose;
7. to match our data with data from other sources - we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible.

10. What Cookies Do We Use?

A cookie is a very small text file placed on your computer or device. Cookies help us to:

1. understand browsing habits on the Sites;
2. understand the number of visitors to the Sites and the pages visited; and
3. remember you when you return to the Sites so we can provide you with access to previously saved quotes.

Most cookies are deleted as soon as you close your browser or mobile application - these are known as session cookies. Others, known as persistent cookies, are stored on your computer or device either until you delete them or they expire. The cookie used to keep you signed in to your account expires after 90 days. Every time you visit planforlaterlife.co.uk, you will be kept signed in for a further 90 days. By using the Services, you consent to us using cookies.

You can choose to block or delete cookies through your browser settings. If you decide to block or delete our cookies, you will not be able to benefit from the full range of our Services and this may affect the performance of our Sites on your system. For more information on the cookies we use, please see our Cookie Policy.

11. How Secure Is Our Site And What Steps Do We Take To Keep Your Personal Information Safe?

Our Sites are "VeriSign Secure Websites" and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

12. Rights Of Access To Your Personal Information

You have certain rights under data protection legislation. For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at compliance@tfli.co.uk.

In order to ensure the Services we provide you continue to meet your needs we may ask you for feedback on your experience of using the Sites. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Sites.

Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Sites is correct, complete, accurate and not misleading and that you disclose all relevant facts.

You have a right to have inaccurate personal data rectified, you can also request to have incomplete personal data completed (Right to rectification).

We will process your request within one month from date of receipt. If you wish to make any changes please contact our Customer Services Team at compliance@tfli.co.uk

This Privacy Policy shall be governed and construed in all respects in accordance with the laws of England and Wales.

We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the Sites.

13. How Long Will We Retain Your Personal Information For?

The amount of time we retain your information for will depend on the reason it was provided:

• If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
• We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.
• Your information/data will not be used for marketing purposes once 12 months has passed following your application.

14. Your Right To Opt Out Of Future Contact From Us

You can opt out of future contact from (Website name) at any time. All of our marketing messages provide an opt out link – please allow up to 48 hours for us to process your opt out request. Alternatively you can enter your details via www.removeme.co.uk or email compliance@tfli.co.uk where your details will be removed from any future marketing campaigns.

15. Your Right to be Forgotten / Erasure Of Your Personal Information

Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When the individual withdraws consent.
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
• The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
• The personal data has to be erased in order to comply with a legal obligation.
• The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right “to be forgotten” does not apply i.e. where we need to comply with a legal obligation.

If you wish to request your “right to be forgotten” please email: compliance@tfli.co.uk

Our marketing partners will also be informed of your request

16. How To Make A Complaint

Plan For Later Life always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we're keen to resolve it as quickly as possible. You can contact us is any of the following ways:

By Post:

Complaints Department
Plan For Later Life
Complaints Department
Adelphi Mill,
Grimshaw Lane,
Bollington,
Cheshire,
SK10 5JB

By Phone:

01625 32 22 74 (calls are charged at local rates and are inclusive of mobile phone users' free minutes)

By Email: complaints@tfli.co.uk

How Plan For Later Life Limited will deal with your complaint...

We aim to resolve your complaint as soon as possible. Sometimes things take a little more time. Please find below the process that Plan For Later Life Ltd will adhere to respond to your query.

Within 7 Working Days of Receipt of Your Complaint You Will Receive From Us...

We will acknowledge receipt of your complaint within 7 Working days.

Within 30 Days You Will Receive From Us…

We will investigate your complaint fully and aim to resolve this, where reasonably possible, within 30 days of receipt.

The final response from us will include the findings from our investigation and, if applicable, what actions we will take to put things right.