Pure Cremation Privacy Policy

Last Reviewed: 30 June 2026 

We value your privacy. Our privacy notice provides you with the transparency you need to understand how we use your personal information lawfully, what your information rights are, and how to contact us if you have any concerns.   

• 1. Who we are
• 2. Information we collect
• 3. Purpose for processing & lawful basis
• 4. Who we share your personal data with
• 5. Marketing
• 6. Cookies
• 7. Our use of AI
• 8. Automated decision making
• 9. International data transfers
• 10. How long we keep your data
• 11. Your Information Rights
• 12. Data protection complaints
• 13. Contact us
• 14. Changes to this privacy notice

1. Who we are

The Pure Cremation Group is a leading financial services provider in Great Britain focusing on funeral planning and insurance and providing funerals. When we refer to ‘we’ or ‘us’ or ‘our’ in this notice, we mean one or more of our companies within the Pure Cremation Group trading as Pure Cremation or Pure, who act as a data ‘controller’:

• Pure Cremation Group Limited (10723077)
• Pure Cremation Limited (09703301)
• Pure Cremation Funeral Planning Limited (09906976)
• Pure Life Financial Services Limited (13149243)

The registered office for Pure Cremation Group Limited, Pure Cremation Limited, and Pure Cremation Funeral Planning Limited is Charlton Park Crematorium, Charlton Down, Andover, England, SP11 0TA.

The registered office for Pure Life Financial Services Limited is Eagle House, Joule Road, Andover, England, SP10 3UX.

2. Information we collect

When engaging with our services, we or our third-party service providers may collect, use and store the following types of personal information for the purposes listed in section 3:

• Identification and contact details
• Telephone audio recordings
• Payment information
• Vulnerability assessment information
• Special category data (i.e. data concerning health or disability if you request assistance)
• Communication and marketing preferences
• Survey and social media feedback
• Website interactions data
• CCTV and ANPR data when you visit our sites
• Information relating to funeral arrangements, including preferences for optional third‑party services (such as celebrants), and whether you would like us to share your contact details on your behalf.

When you request a product or service from Pure Cremation, you do not have to provide your personal information, but if you do not provide information required for a quote or service, we may not be able to provide it to you.

Personal data we obtain from other sources

Some of the personal data we process is not provided by you directly. We may obtain contact information from these sources:

• Our customers:

  • To provide funeral plan cover for a named individual provided by our customer
  • To record the Nominated Representative requested by our customer (the person who will be made aware of the plan and contact us when it needs to be redeemed)
  • To provide us with authorisation to discuss their service information with another individual acting on their behalf.
• Third party marketing providers
• Publicly available sources
• Third party tracing services

3. Purposes for processing & lawful bases

Personal data is any information that can identify you directly, or indirectly. The UK GDPR Article 6 Lawfulness of Processing details the legal bases for which personal data can only be processed.

Special Category Data

Some personal data is more sensitive, and the UK GDPR gives it extra protection. This is called ‘special category data’. The UK GDPR Article 9 Processing of Special Categories of Personal Data only permits processing of this data for limited purposes.

Where we use more sensitive information (such as health information), we only do this where it is necessary to support you, protect your interests, or meet legal and regulatory requirements.

Processing Purposes

We, or our third-party service providers, process personal data for the following purposes and rely on the following lawful basis.

Purpose	Lawful Basis
To calculate and generate funeral plan pricing	Legitimate interest - Article 6(1)(f)
To enter into or perform a contract with you	Contract – Article 6(1)(b)
Accounting and tax purposes	Legal obligation – Article 6(1)(c)
Compliance monitoring and audit	Legitimate interest - Article 6(1)(f) Legal obligation – Article 6(1)(c)
Quality monitoring and training	Legitimate interest - Article 6(1)(f)
Profiling and marketing	Legitimate interest - Article 6(1)(f) Consent –Article 6(1)(a)
Prevention and detection of crime	Legitimate interest - Article 6(1)(f) Legal obligation – Article 6(1)(c)
Customer services queries and complaints handling	Legitimate interest - Article 6(1)(f) Legal obligation – Article 6(1)(c)
To assess ability to make a financial decision (vulnerability assessment)	Legal obligation – Article 6(1)(c) Legitimate interest - Article 6(1)(f) Schedule 1 DPA 2018 – protecting economic well-being of certain individuals Schedule 1 DPA 2018 – Substantial public interest Explicit consent (9(2)(a))
Safety and security monitoring	Legal obligation – Article 6(1)(c) Legitimate interest - Article 6(1)(f)
Business monitoring and performance analysis	Legitimate interest - Article 6(1)(f)
Website user activity and performance analysis and provide enhanced features or relevant communications where permitted	Legitimate interest - Article 6(1)(f) Consent – Article 6(1)(a)
Service improvement and customer feedback surveys. To help us improve.	Legitimate interest - Article 6(1)(f)
Billings and payments.	Contract – Article 6(1)(b)
Individual safeguarding and emergency situations	Vital interests – Article 9(2)(c)
To establish, exercise, or defend legal claims	Legitimate interest - Article 6(1)(f) Legal claims – Article 9(2)(f)
Information system, digital infrastructure and data integrity monitoring	Legitimate interest - Article 6(1)(f)
Debt Management / Tracing	Legitimate interest - Article 6(1)(f) Contract – Article 6(1)(b)
To assess and provide additional service support	Legal obligation – Article 6(1)(c) Legitimate interest - Article 6(1)(f) Schedule 1 DPA 2018 – protecting economic well-being of certain individuals Schedule 1 DPA 2018 – Substantial public interest Explicit consent (9(2)(a))
To provide information about independent third-party celebrant services, including sending an information leaflet and, where you ask us to do so, passing your contact details to a celebrant at your request so they can contact you directly	Legitimate interest - Article 6(1)(f)

Where we rely on legitimate interests, this includes operating and improving our services, ensuring fair and consistent pricing, responding to customer needs, preventing fraud and misuse, and managing our business effectively.

4. Who we share your personal data with

Some of the personal data we process for the purposes given in section 3 may involve sharing it with third parties:

Who	Purpose
Professional and Legal advisors	For example, external auditors; lawyers; and consultants.
Insurance companies	For example, Life insurance providers; pension providers; company vehicle insurance companies.
Regulators	For example, the Financial Conduct Authority; Financial Ombudsman; Information Commissioners Office (ICO); The Health and Safety Executive (HSE); Equality and Human Rights Commission (EHRC); Competition Markets Authority (CMA).
Credit Reference Agencies	Tracing and deceased record checks
Third party service providers	For example: Logistics providers IT and Cloud service providers Printing fulfilment providers Data marketing providers Technical support providers Social media and advertising partners (see section 6 Marketing) Sanctions and Politically Exposed Persons checks
Buyers of our business	In the event we decide to sell any of the group companies or assets.
Social Media Platforms	For example, LinkedIn; Meta; Instagram (with your consent).
Government or law enforcement	For example, HMRC, DVLA, police, and agencies involved in preventing and detecting crime, including reporting suspected fraud to organisations such as the National Crime Agency and Action Fraud.
Pure Cremation Group companies	See section 1 Who we are.
An authorised person	For example, a person with power of attorney; or someone you nominate to handle your affairs with you or on your behalf.
Independent Celebrants	Where you ask us to do so, we may share limited contact details (such as your name, email address and/or telephone number) with an independent third‑party celebrant so that they can contact you directly about their services. We will only share your details where you have requested this. If you choose not to, this will not affect the cremation services or funeral plan you receive from us. Independent celebrants act as separate data controllers. They will provide you with their own privacy information explaining how they use your personal data.

5. Marketing

Websites

We use Meta (Facebook and Instagram) for the purpose of advertising our services to certain groups of Facebook users, and to measure the performance of our advertising. We may allow Meta to use cookies, web beacons, pixels or other similar storage technologies to collect or receive information to help optimise advert targeting and to measure campaign performance. We rely on your consent to process this information for these purposes.

More information about how we use cookies and similar technologies on our website, and how to manage your consent preferences, is available in section 6 Cookies.

Facebook users can also manage their advertising preferences – see Meta Privacy Policy: https://www.facebook.com/privacy/policy

Mail

We use third party services to provide contact details for our direct mail campaigns and to manage those campaigns. We do not hold this data in our own systems.

To meet our transparency requirements, mailings contain the name and contact details of our data source.

We rely on a lawful basis ‘legitimate interests’ to send mail marketing – see section 3.

You have the right to opt out of mail marketing - see section 13 (Contact us). When you exercise this right, we will add your name and address to a suppression list to ensure future mail is not sent by us.

All third-party sourced data is screened against the Mail Preference Service to remove anyone registered; and our own suppression list.

Email, SMS text, telephone

When you request a quote for yourself, we inform you of our intention to use your information to keep you updated with our news and offers, and your right to opt out of this at any time.

If you do not opt out, we rely on a lawful basis ‘legitimate interests’ to send information electronically – see also section 3. We will always provide a way for you to stop further communications in each message we send. For example, providing an ‘unsubscribe’ link in emails.

If you provide someone else’s details for the purpose of a quote, or purchase, we will not use their details for marketing purposes.

If we collect your information directly from you for reasons other than a sales enquiry or purchase, i.e. to send a guide or other information requested, we will rely on the UK GDPR Article 6 legal basis ‘consent’ instead. We will ask for your consent and tell you of your right to withdraw consent at any time. See section 11 Your Rights.

We will check if you are registered with the Telephone Preference Service before making unsolicited calls if we don’t have your prior consent.

Marketing Preferences

You’re in control - you can choose your preferred way to receive marketing. For example, you can opt to receive communication by email, but not by text. And you can opt out of receiving communications at any time by:

• using the links provided in emails or text communication
• using our online contact form
• Emailing, telephoning or writing to us directly - section 13 (Contact us).

6. Cookies

A cookie is a small file of letters and numbers that is downloaded onto your device (i.e. mobile, computer) when you visit a website. They’re widely used to make websites work, or work more efficiently, as well as provide website owners with information.

The rules on use of cookies also cover similar technologies for storing or accessing information, such as ‘flash cookies’ (small pieces of information stored and accessed by Adobe Flash) or ‘tracking pixels’ (snippets of code embedded in web pages, emails, or advertisements).

Most cookies and similar technologies require your consent to use them. Our websites use the following categories of cookies:

Category	Overview
Strictly Necessary	These are essential to use in order for our websites to work and provide core functionality, such as security and network management. We won’t ask for your consent to use these types of cookies, and we can’t switch them off in our systems. You can, however, disable them in your web browser. but some parts of the website won’t work.
Performance Analytics	These collect anonymous data about how users engage with our website to help us improve our content and services. For example, they can tell us how you got to the site, the pages visited, how long is spent on each page, and what is clicked on. You can switch off these cookies at any time.
Functional	These are optional cookies which provide enhanced personalisation and functionality for the user. For example, remembering your preferences and settings and making browsing easier. We won’t set these cookies without asking for your consent first. You can change your consent preferences at any time.
Advertising Marketing	These may be used to build a profile of your interests and show you more relevant advertising on our websites or our partners. We won’t set these cookies without asking for your consent first. You can change your consent preferences at any time.

How to manage your preferences

We provide a simple mechanism for you to update your consent preference settings at any time:

Cookie Settings

 

You may need to refresh your page for changes to take effect.

Alternatively, most web browsers allow you to update settings to control the use of cookies on your device such as:

• Delete all cookies
• Block cookies
• Allow all cookies
• Block ‘third-party cookies (i.e. cookies set by online service other than the one you’re visiting)
• Clear all cookies when you close your session
• Open a ‘private browsing’ / ‘incognito’ session, which won’t then record your browsing history or allow storing cookies.

More information about how to do this is available:

• www.aboutcookies.org
• www.allaboutcookies.org
• Microsoft Edge & Microsoft Internet Explorer
• Google Chrome
• Firefox
• Safari – mobile devices and desktops
• Opera.

7. Our use of AI

Artificial Intelligence (AI) refers to a range of technologies capable of performing tasks that a human would typically do.

Chatbots. Our website terms and conditions apply to the use of our online chatbot support tools such as ‘Lost for Words’.

These chatbots use a type of generative AI provided by third party, OpenAI, LLC. The AI has been pre-trained by OpenAI using publicly available data and data is licensed to Open AI. This enables the AI to understand and generate human-like, text-based conversational responses when you interact with our chatbots.

Responses could occasionally lack understanding or contain inaccuracies and are only intended to be used as a helpful guide.

When you use our chatbots, your name and contact information will not be shared with OpenAI. If you choose to give additional information to the chatbot to access our free services, it is securely shared with OpenAI in order to provide you with a response back. We do not use this information to train our own AI systems, and we have contractual controls in place with our providers to restrict how your information is used.

Data exchange with our chatbots will not be used by OpenAI or Pure Cremation to develop or train AI technologies.

8. Automated Decision Making

How we use automated decision-making

We use an automated process to calculate the price of our funeral plans. This type of automated decision is important because it affects the price you are offered and the cost of the plan if you go ahead.

This means that when you request a quote, a system automatically determines the price you are offered based on certain information about you and how you contacted us. No individual employee reviews or adjusts the price at the point it is generated.

What information is used

The price we offer is calculated using a limited number of factors, such as:

• Your date of birth
• Your location (to reflect regional costs)
• How you contacted us (for example, online, phone, or partner channel)

We only use factors that are commercially justified and relevant to pricing.

We do not use:

• Gender
• Behavioural profiling
• Any information intended to identify vulnerability

How we make sure this is fair

To ensure our pricing approach is fair and consistent, we will:

• Use appropriate and limited data
• Regularly review our pricing approach to ensure customers are not unintentionally disadvantaged
• Make sure that trained staff are available to review decisions, understand how the price was calculated, and change the outcome where appropriate.

What this means for you

• The automated decision determines the price you are offered for a funeral plan
• The price forms part of the contract if you decide to go ahead
• Different customers may be offered different prices based on the factors above.
• Once you accept a price, it will normally remain the agreed price for your plan, unless we agree a change with you.

Your rights

You have the right to:

• Ask us to explain how your price was calculated and the factors taken into account
• Provide additional information or explain your situation for further consideration
• Contest an automated price decision
• Request a meaningful human review of the automated decision to re-assess whether the decision is appropriate in your circumstances

See sections 12 (Data Protection Complaints) and 13 (Contact Us) for more information.

9. International data transfers

We may transfer personal data outside the United Kingdom where this is necessary for our recruitment processes, including where we use third-party service providers located outside the UK.

We ensure appropriate safeguards are in place in accordance with UK data protection laws. This may include adequacy regulations issued by the UK Government or the use of approved transfer mechanisms such as the International Data Transfer Agreement (IDTA) or UK Addendum.

You can request more information about these safeguards by contacting us using the details in section 13 (Contact us).

10. How long we keep your data

We only retain your personal information for as long as it is necessary and justified for the purposes outlined above, in line with our Data Retention Policy.

In some cases, we will have a legal requirement to keep information for a specific period of time beyond the original purpose we processed your personal data for. For example, UK tax law will require us to keep VAT records for a minimum of 6 years.

11. Your information rights

You have the following rights in relation to the processing of your personal data:

Right to be informed	About the collection and use of your data and to be provided with our privacy notice information at the time we collect the data from you. If your data is obtained from other sources, you have the right to be provided with privacy information within a month, unless you already have it, or it would involve a disproportionate effort to give it. Requests will be processed without undue delay and no later than one calendar month.
Right of access	To receive a copy of the personal data we hold about you; the purposes we process it for; the categories of personal data we have; where we obtained it; who we share it with and how long we keep it for. Requests will be processed without undue delay and no later than one calendar month.
Right to object	To the processing of your data. This isn’t an absolute right, and requests are assessed on a case-by-case basis. You do, however, have an absolute right to stop your data being used for direct marketing purposes. Requests will be processed without undue delay and no later than one calendar month
Right to rectification	You are entitled to have your personal data corrected if it is inaccurate or incomplete. Requests will be processed without undue delay and no later than one calendar month
Right to Erasure	Also known as ‘the right to be forgotten’. You have the right to request the deletion of your personal data. This is not an absolute right, for example we may be legally obligated to keep some information. Requests are assessed on a case-by-case basis. Requests will be processed without undue delay and no later than one calendar month
Right related to automatic decision-making including profiling	You have the right to be told about any automated profiling and decision-making which could have a material impact on you; and for those decisions to be fully reviewed by a person if you wish – see section 9. Requests will be processed without undue delay and no later than one calendar month
Right to restriction	You have the right to suppress use of your personal data in certain circumstances. Data is stored but will be restricted from use. Requests will be processed without undue delay and no later than one calendar month
Right to data portability	This applies to data you have provided to us electronically. For example, data you have typed in, as well as data gathered from monitoring our activities. You have the right to get your electronic personal data in a way that is accessible, portable, in a commonly used machine-readable format, such as a CSV file. For example, provided with data in a way that allows transfer of electronic payroll information to a new employer in a portable format. Requests will be processed without undue delay and no later than one calendar month
Right to withdraw ‘Consent’	In most cases, we process your data under lawful bases other than consent (such as legal obligation or performance of a contract). However, where consent is needed, you are free to withdraw it any time. This will not affect the lawfulness of any processing carried out prior to withdrawing your consent.
Right to complain	You have the right to raise a concern about how we use your personal data. If you have a complaint, you can contact us and we will investigate it. We will acknowledge your complaint within 30 days and respond without undue delay. If you remain unhappy after we have responded, you have the right to complain to the Information Commissioner’s Office (ICO). The ICO will usually expect you to have raised your concern with us first before contacting them.

Rights requests can be made verbally or in writing see section 13 (Contact us) and will be processed without undue delay and no later than one calendar month.

When we receive a request, we may need to ask you to verify your identity to ensure we are carrying out the request lawfully.

12. Data Protection Complaints

If you have a concern about how we have handled your personal information, you have the right to make a data protection complaint to us. We encourage you to contact us first so that we can investigate and try to resolve the issue.

When we receive your complaint, we will:

• acknowledge it within 30 days;
• investigate it without undue delay;
• keep you informed where appropriate; and
• tell you the outcome once our review is complete.

If you are not satisfied with our response, you can raise your concerns with the Information Commissioner’s Office (ICO). The ICO will usually expect you to have given us the opportunity to deal with your complaint first.

Information Commissioner’s Office (ICO)

Wycliffe House

Water Lane

Wilmslow

SK9 5AF

Telephone: 0303 123 1113
Website: ico.org.uk

13. Contact Us

If you would like to contact us in relation to your rights or the way we have handled your personal data:

Email: planningahead@purecremation.co.uk

Telephone: 0800 033 7737 – option 2 Customer Services

Post: Eagle House, Joule Road, Andover, England, SP10 3UX.

You can also use these contact details to make a data protection complaint.

Alternatively, our Data Protection Officer (DPO) can be contacted at DPO@pure.uk.com.

14. Changes to this privacy notice

We may change this privacy notice from time to time. In the event of a significant change, we will draw your attention to these for transparency, for example, sending you an e-mail.

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