PRIVACY NOTICE

Purple Patch Management Limited (referred to below as we, our or us) is the owner and operator of www.memorygiving.com (the Website). We are committed to respecting your privacy. This statement explains our policy regarding the personal information we collect from you from forms you complete and submit to us, information you provide to us over the telephone and/or in connection with your use of our Website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1. About us

   Our contact and registration details are as follows:
   Company Name: Purple Patch Management Limited
   Country of Registration: England and Wales
   Company Number 07445937
   VAT Number: 115 0800 62
   Registered office: Eldon House, 36 Eldon Road, Reading RG1 4DL
   Tel: 0118 979 9633
   Email: theteam@memorygiving.co.uk

2. How this policy works
   1. We may be collecting personal information from you because you are:
      1. a donor using the Website/service to make a donation in memory of the deceased;
      2. a funeral director using the Website/service to facilitate the collection of donations in memory of the deceased;
      3. a charity that has registered with the Website for the purpose of receiving donations made in that charities name in memory of the deceased; or
      4. the next of kin of the deceased and we have been given your personal information by the funeral director arranging a funeral for the deceased.
   2. This policy is structured to allow you to easily see what personal information we are collecting depending on which of the above categories you fall into.
3. Personal information we collect about you
   1. We may collect the following types of personal information from you either via the Website, via paper forms, by email or over the telephone:

      Type of information	Charities	Funeral Directors	Next of Kin of the deceased	Donors
      Contact Details	Information that allows us to contact you directly such as your name, email address, telephone number, and addresses associated with your account	Information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account	We receive information about you from the Funeral Director arranging the deceased’s funeral such as your name, your relationship to the deceased and your email address	Information that allows us to contact you directly such as your name, address* email address, telephone number *only collected if you are opting to Gift Aid your donation
      Social security details	National Insurance number - required for completion of the ChV1 form in respect of Gift Aid	Not Applicable	Not Applicable	Not Applicable
      Security details	Such as your password and other security-related information used to access your account	Such as your password and other security-related information used to access your account	Not Applicable	Not Applicable
      Records of your discussions with our customer support teams	When you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our support team	When you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our support team	When you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our support team	When you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our support team
      Payment Information	Not Applicable	Not Applicable	Not Applicable	Credit/debit card details and bank account details you provide to make payment for your donation
      Donation history	Not Applicable	Not Applicable	Not Applicable	Records of your donation
      How you use the Website	When you use the Website we collect information about the pages you look at and how you use them.	When you use the Website we collect information about the pages you look at and how you use them.	When you use the Website we collect information about the pages you look at and how you use them.	When you use the Website we collect information about the pages you look at and how you use them.
      Location Information	Your computer's IP address may tell us an approximate location when you connect to our Website but this will be no more precise than the city, state or country you are using your device in.	Your computer's IP address may tell us an approximate location when you connect to our Website but this will be no more precise than the city, state or country you are using your device in.	Your computer's IP address may tell us an approximate location if you connect to our Website but this will be no more precise than the city, state or country you are using your device in.	Your computer's IP address may tell us an approximate location when you connect to our Website but this will be no more precise than the city, state or country you are using your device in.

      You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use the full functionality of the Website or our services.
4. How we use your personal information
   1. Charities

      Purpose Personal	information used	Lawful basis
      Contact you about donations that have been made to the charity	Contact details.	This is necessary to fulfil our contract with you.
      Maintain your account	All the personal information we collect.	This is necessary to fulfil our contract with you.
      Answer your queries or complaints	All the personal information we collect.	We have a legitimate interest to answer your query and improve the services we provide.
      Administration of the Website including content presentation	All the personal information we collect.	We have a legitimate interest to improve the services we provide to you.
      Develop new products and services	All the personal information we collect.	We have a legitimate interest to improve the products and services we provide.

   2. Funeral Directors

      Purpose	Personal information used	Lawful basis
      Contact you for the purposes of providing the services to you	Contact details.	This is necessary to fulfil our contract with you.
      Maintain your account	All the personal information we collect.	This is necessary to fulfil our contract with you.
      Answer your queries or complaints	All the personal information we collect.	We have a legitimate interest to answer your query and improve the services we provide.
      Administration of the Website including content presentation	All the personal information we collect.	We have a legitimate interest to improve the services we provide to you.
      Develop new products and services	All the personal information we collect.	We have a legitimate interest to improve the products and services we provide.

   3. Donors

      Purpose	Personal information used	Lawful basis
      Contact you about donations you have made	Contact details.	This is necessary to fulfil our contract with you.
      Take payment of your donation	Transaction and payment information.	This is necessary to fulfil our contract with you.
      Answer your queries or complaints	All the personal information we collect.	We have a legitimate interest to answer your query and improve the services we provide.
      Administration of the Website including content presentation	All the personal information we collect.	We have a legitimate interest to improve the services we provide to you.
      Develop new products and services	All the personal information we collect.	We have a legitimate interest to improve the products and services we provide.

   4. Next of Kin

      We share your personal information with the charity/charities nominated by you to receive donations in memory of the deceased. This is to allow the nominated charity/charities to send you an acknowledgement of the total raised in memory of the deceased.

      Anonymised and aggregated data

      We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and services. We may also use anonymised and aggregated information to inform charities and funeral sector on the penetration of online donations.

5. Change of purpose
   1. We will only use your personal data for the purposes for which we 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, please contact us.
   2. 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.
   3. 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.
6. Where we collect your personal information from

   We will collect personal information from a number of sources. These include the following:

   • Directly from you: when complete electronic and/or paper forms we provide to you, enter our competitions and promotions, contact us by phone, email or communicate with us directly in some other way.
   • Our Website: provides us with information about how you use it and the devices in your home that you connect to it.
   • Our payment provider: will provide details as to whether your payment has been accepted.
7. Who we share your personal information with:
   • Funeral Directors: if you are a donor we may share your name with the funeral director that is arranging the funeral of the deceased.
   • Other service providers and advisors: such as companies that support our IT, help us analyse the data we hold, send communications to our customers, provide us with legal or financial advice and generally help us deliver our services to you.
   • Purchasers of our business: buyers or perspective buyers who we sell or negotiate to sell our business to. In that case, we shall require that they abide by the terms of this Privacy Policy.
   • The Government or our regulators: where we are required to do so by law or to assist with their investigations.
   • Police and law enforcement: to assist with the investigation and prevention of crime.

   In common with most websites, our Website logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp.

   We may use this information to analyse trends, administer the Website, track your movement around the Website and gather broad demographic information. However, we do not link this information to personally identifiable information.

   We also use Google Analytics which sets cookies to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

   We do not disclose personal information to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

8. Transferring your personal information internationally

   We will not transfer your information to, or store it, outside of the European Economic Area.

9. Retention, updating and removal of your personal information
   1. Where you provide us with personal information during the course of your usage of the Website, we may retain this information for future use in line with our data retention policy.
   2. Funeral Directors and Charities
      1. We will keep your personal information for as long as you have an account with us. After you close your account with us we will keep your personal information for a reasonable period to maintain our records and legal obligations to you. 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.
      2. If you wish to close your account with us please contact us. The closure of your account will result in the deletion of some of the personal information that we hold about you, but we may still retain some personal information, for example for record keeping purposes or where it is included in content that you have submitted to us and have agreed that we can publish on our Website or elsewhere in accordance with our terms of use.
   3. Donors: we will keep your personal data for a period of up to 5 years from the date of your donation.
   4. Next of Kin: we will keep your personal data for a period of up to 5 years from the date we receive it from the funeral director handling the funeral of the deceased.
   5. You are responsible for ensuring that the personal information that we hold about you is accurate and up-to-date, and you should check it on a regular basis. Much of the personal information that we hold about you can be updated through our Website, and where this personal information changes you can update it yourself. If you are unable to do this however you can contact us using the details in paragraph below called “Contacting us” and, where appropriate, we will update the relevant personal information for you.
   6. We will notify you and any applicable regulator of a breach of our obligations under data protection laws, where we are legally required to do so.
10. Security
    1. Our Website has numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity of the information you provide.
11. Your rights in relation to your personal information
    1. You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; (iii) the right to opt-out of receiving direct marketing messages; (iv) the right to request the correction of inaccurate personal information we hold about you; (v) the right to request the blocking or deletion of your personal information where the processing does not comply with applicable data protection laws and; (vi) the right to request that we port elements of your data either to you or another service provider.
    2. To exercise any of the above rights, or if you have any questions or concerns relating to your rights, please contact us by using the details set out in the "Contacting us" section below.
    3. If you make a complaint about our handling of your personal information, it will be dealt with in accordance with our complaints handling procedure. In the first instance it will be reviewed by our customer care team who will respond to you within 28 days. If you are dissatisfied with this response you may request that your complaint be escalated, in which case it will be passed to a senior person in our business who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
    4. If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns/ for more information.
    5. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    6. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    7. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. Links to third party sites

    Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit so that you can understand how they treat your personal data.

13. Changes to this privacy notice

    We reserve the right to alter this privacy policy at any time. Such alterations will be posted on the Website by us and notified to you by email. Such changes will come into effect 3 business days after posting/emailing you. It is important that you read any such alterations as and when they are posted on the Website by us and should you object to any alteration, please contact us as described in paragraph 14 to ask us to cancel your account with us.

14. Contacting us

    Our data protection officer is Julian Walker. If you need to contact us about this policy or any matters relating to the personal information we hold on you, you can write to us at the address at Eldon House, 36 Eldon Road, Reading RG1 4DL or email at us theteam@memorygiving.co.uk.