Privacy Policy

Privacy Policy last updated: 2^nd August 2022

Homeland International – PRIVACY NOTICE

1. INTRODUCTION

Welcome to the Homeland International’s privacy notice.

Homeland International respects the privacy of individuals and is committed to protecting personal data. This privacy notice will inform you as to how we look after personal data when a user visits our website homeland-international.co.uk (Website)(regardless of where they visit it from) or correspond with us in relation to any services we offer. It will also tell you about privacy rights of a data subject, including how the law protects them.

The term “personal data” in this privacy notice relates to ‘Data Subjects’ (as defined below and sometimes referred to as the “Customer” in this privacy notice) and does not apply to personal data about the Deceased.

Any defined terms used in this privacy notice shall have the following meanings, or, if relevant, the meaning given to them under the Data Protection Legislation:

“Homeland International” means Homeland International Limited a company registered in England and Wales with company registration number 09790718, having its registered office address at Rampion House, Marchants Way, Burgess Hill, West Sussex, United Kingdom, RH15 8QY;

“Data Protection Legislation” all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) (DPA 2018); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended;

“Data Subject” means a living individual about whom we may process their personal data, not including the Deceased;

“the Deceased” means the deceased person who is, or may be, the subject of our repatriation services, at the relevant time;

“DPO” means Data Protection Officer;

“EEA” means the European Economic Area;

“Specific Notices” means any other privacy notice or fair processing notice we may provide on specific occasions in addition to this privacy notice; and

“UK GDPR” has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the DPA 2018

2. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Homeland International collects and processes personal data about Data Subjects through the use of this Website and any service we may offer, including any personal data provided through our Website or other correspondence with us.

This Website is not intended for children and we do not knowingly collect data relating to children, unless this is in respect of the Deceased or unless we agree with an applicable parent or guardian and then only in respect to our services.

It is important that you read this privacy notice, together with any Specific Notices, when we are collecting or processing personal data about, so that you are fully aware of how and why we are using your personal data. Any Specific Notices shall supplement this privacy notice and shall not be intended to override it.

CONTROLLER & DPO
Homeland International Limited is the controller and responsible for this Website and any personal data processed by it.

We have appointed a DPO who is responsible for overseeing questions in relation to this privacy notice and Homeland International’s compliance with Data Protection Legislation. If you have any questions about this privacy notice, including any requests to exercise legal rights of a Data Subject, please contact the DPO using the details set out below.

CONTACT DETAILS
If you have any questions about this privacy notice or our privacy practices, please contact our DPO:

Full name of legal entity: Homeland International Limited
Name of DPO: Andy Smith, Financial Controller
Email address: Andy.smith@cpjfield.co.uk
Postal address: Rampion House, Marchants Way, Burgess Hill, West Sussex RH15 8QY
Telephone number: 01444 230430

A Data Subject has the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), in respect of the way in which we may process their personal data. We would, however, appreciate the chance to deal with any concerns before an approach is made to the ICO, so please contact us in the first instance.

YOUR DUTY TO INFORM US OF CHANGES AND CHANGES TO THIS POLICY
We keep our privacy notice under regular review and may update our policy from time to time at our discretion.

It is important that the personal data we hold about Data Subjects is accurate and current. Please keep us informed if any personal data we hold about you (as a Data Subject) changes during your relationship with us.

THIRD-PARTY LINKS
This 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.

3. THE DATA WE COLLECT ABOUT DATA SUBJECTS

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or personal data of Deceased persons.

We may collect, use, store and transfer different kinds of personal data about Data Subjects which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to us and other details of services you have requested from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Usage Data includes information about how you use our Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from personal data we hold about Data Subjects but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with personal data about Data Subjects so that it can directly or indirectly identify, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about Data Subjects (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), unless required for the provision of our services and then we will only use this in accordance with our Specific Notices. Nor do we collect any information about criminal convictions and offences.

IF THERE IS A FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or a third party 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. HOW IS PERSONAL DATA COLLECTED?

We use different methods to collect data from and about Data Subjects, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide about Data Subjects when you:
  • apply for services, through this Website or by completing one of our forms;
  • request marketing to be sent to you;
  • give us some feedback.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties sources. We may receive personal data about you from various third parties. Including Technical Data from analytics providers, advertising networks and search information providers based inside and outside of the UK including Google.

5. HOW WE USE PERSONAL DATA 

We will only use personal data of Data Subjects when the law allows us to. Most commonly, we will use personal data of Data Subjects in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and interests and fundamental rights of a Data Subject do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

6. PURPOSES FOR WHICH WE USE PERSONAL DATA

In the table below we have set out a description of all the ways we plan to use personal data of Data Subjects, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process personal data of Data Subjects for more than one lawful ground depending on the specific purpose for which we are using the personal data. Please contact our DPO 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 in the table below.

7. CHANGE OF PURPOSE

We will only use personal data about Data Subjects 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 for which it was collected. If you or a Data Subject wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.

If we need to use personal data about Data Subjects for an unrelated purpose, we will notify the Data Subject and we will explain the legal basis which allows us to do so.

Please note that we may process personal data about Data Subjects without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. MARKETING

We strive to provide choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data 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 goods or services from us and, in each case, you have not opted out of receiving that marketing. If you have not opted in to receiving marketing communications from us we may contact you to inform you of any promotions, discounts or events we are running that we think may be of interest to you.

THIRD-PARTY MARKETING
We will get express opt-in consent before we share personal data of Data Subjects with any third party marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving marketing messages from us, this will not apply to personal data provided to us as a result of purchasing a service from us or other transaction, which will be retained for our legitimate interests, or other appropriate legal basis.

9. COOKIES

When you visit the website Homeland International may store some information (commonly known as a “cookie”) on your computer.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

10. DISCLOSURES OF PERSONAL DATA

We may have to share personal data about Data Subjects with the parties set out below for the purposes set out in the table in paragraph 6 above:

• Google – for the purpose of analytics and advertisements. For more information on how Google uses such data please see: https://policies.google.com/technologies/partner-sites
• Service providers who provide support services to Homeland International – such as third parties that may assist us to arrange repatriations in countries other than the UK. These third parties are funeral directors overseas who form our global provider network. This will also include companies that provide software or other IT services to us;
• Professional advisers used by Homeland International, including our marketing agents AwfulGood and Calibre Marketing; and NotJustSeo.
• HMRC, regulators and other authorities, including (but not limited to) clearance authorities, Customs & Excise.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use personal data about Data Subjects in the same way as set out in this privacy notice.

We require all third parties listed above to respect the security of personal data about Data Subjects and to treat it in accordance with the law, including Data Protection Legislation. We do not allow our third-party service providers to use personal data about Data Subjects for their own purposes and only permit them to process personal data about Data Subjects for specified purposes and in accordance with our instructions.

11. INTERNATIONAL TRANSFERS

By sharing personal data about Data Subjects with Homeland International, and with the third parties listed above at paragraph 10, this may involve transferring your data outside the UK or EEA. If we transfer your data outside the UK or EEA we aim to ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are in place.

Please contact our DPO if you want further information on the specific mechanism used by us when transferring personal data about Data Subjects out of the UK or EEA.

12. DATA SECURITY

We have put in place appropriate security measures to prevent personal data about Data Subjects from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data about Data Subjects to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data about Data Subjects on our instructions 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.

13. DATA RETENTION – HOW LONG WILL WE USE PERSONAL DATA FOR?

We will only retain personal data about Data Subjects 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 the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise personal data (so that it can no longer be associated with an individual) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

14. DATA SUBJECT’S LEGAL RIGHTS

Under certain circumstances Data Subjects, have rights under Data Protection Legislation in relation to their personal data. A Data Subject (referred to as ‘you‘ or “your” below), has the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED
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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
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.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could 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.

HOMELAND INTERNATIONAL LIMITED
August 2022