· WHO WE ARE AND WHAT WE DO
We are the data controllers and responsible for your personal data. If you register with us to access any of our services, then we may also act as a data processor in connection with the delivery of our services to you.
We are registered with the Suruhanjaya Syarikat Malaysia (‘SSM’) under registration number 1311678-M.
· INFORMATION WE MAY COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site or correspond with us in person or by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:
o Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender. We may also collect, use, store and transfer details about your will, executors and beneficiaries dependant on the nature of the service that we supply to you;
o Contact Data which includes your billing address, delivery address, home address, email address, telephone numbers and social media account details;
o Financial Data which may include your bank account and/or payment card details;
o Asset Data
o Transaction Data which includes details about payments to and from you and other details of services you have purchased from us;
o Usage Data which includes information about how you use our Site, products and services;
o Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our will writing or funeral comparison services). In this case, we may have to cancel a service you have asked us to provide but we will notify you if this is the case at the time.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
· KEEPING YOUR DATA SECURE
We know that data security is important to you and it is therefore important to us. We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including up to date virus software and personal protection on our computers and devices. 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 in accordance with this policy and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
· HOW WE WILL COLLECT YOUR DATA
We use different methods to collect data from and about you including through:
o Direct interactions. You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us in person or by phone, e-mail, our live chat service or otherwise. This includes personal data you provide when you:
§ register to use our Site;
§ access our price comparison, will writing, online memorial or other services;
§ request marketing communications to be sent to you;
§ give us some feedback or request support services
· WHY WE WILL USE YOUR DATA
We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:
o Consent: you have given clear consent for us to process your personal data for a specific purpose such as marketing communications;
o Contract: the processing is necessary for a contract we have with you (for example, to process and deliver our services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract;
o Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations);
o Vital interests: the processing is necessary to protect someone’s life; and
o Legitimate interests:
the processing is necessary for our legitimate interests (for example to administer and maintain our website) or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We rely on the following legitimate interests when processing your personal data:
§ To manage our business and comply with our obligations to our patients, staff and suppliers;
§ To protect our proprietary and commercially sensitive information;
· DISCLOSING YOUR PERSONAL DATA
Given the nature of the services that we deliver, we will at times have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and in accordance with the law. The third parties that we share data with will be dependant on the nature of the services that we provide to you and examples of our third parties include:
o Sub-contractors for the performance of any contracts we enter into with them or you;
o Service providers acting as processors who provide IT and system administration services;
o Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services;
· CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, then please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data (as outlined above) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.
We will always get your express opt-in consent before we share your personal data with any other company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
· HOW LONG WE WILL KEEP YOUR DATA
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.
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. For certain services that we deliver, we may hold your data for extended periods of time for example our will-writing or pre-plan services where data may be held for the duration of your lifetime.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.