Working to bring funeral costs down 
Silver Clouds Funeral Plans 
 
Privacy Policy 
 
Silver Clouds “Trust” based Privacy Policy Document 
 
YOUR RIGHTS, YOUR INFORMATION AND HOW WE 
USE IT 
Silver Clouds Later Life Planning Limited (“Silver Clouds”) are 
committed to protecting your personal information. Our Privacy 
Policy contains important information about what personal details 
we collect, what we do with that information, who we may share it 
with and why and your choices and rights when it comes to the 
personal information you have given us. We may need to make 
changes to our Privacy Policy from time to time, such as changes to 
where your personal data will be processed, any changes will be 
notified through our website. This privacy policy was published on 
18 May 2018. 
 
HOW TO CONTACT US 
If you have any questions about our Privacy Policy or the 
information we collect or use about you, please contact the 
Data Protection Officer, Silver Clouds Later Life Planning, 16- 
20 South Street, Hythe, Southampton SO45 6EB 
 
INFORMATION WE COLLECT AND USE INCLUDES 
• Information about who you are e.g. your name, date of 
birth and contact details. 
• Information connected to your products or service with 
us e.g. your name and address details. 
• Information about your contact with us e.g. meetings, 
phone calls, emails and letters. 
• Information classified as ‘sensitive’ personal information 
e.g. relating to your health, marital or civil partnership 
status, race, ethnicity and/or religious beliefs will only be 
collected and used where it is needed to provide the 
product or service you have requested or to comply with 
our legal obligations. 
• Information you may provide to us about other people 
e.g. joint applicants, trustees, personal representatives, 
next of kin or beneficiaries. 
 
WHERE WE COLLECT YOUR INFORMATION 
• an application form or contract for a product or service. 
• website enquiry form. 
• telephone conversations with us. 
• emails or letters you send to us. 
• meetings with one of our representatives. 
We may also collect personal information on you from places such 
as business directories and other commercially or publicly 
available sources e.g. to check or improve the information we hold 
(like your address) or to give better contact information if we are 
unable to contact you directly. 
 
WHAT WE COLLECT AND USE YOUR INFORMATION 
FOR 
We take your privacy seriously and we will only ever collect and 
use information which is personal to you where it is necessary, fair 
and lawful to do so. We will collect and use your information only 
where: 
• you have given us your permission (consent) to send you 
information about products and services offered by us 
which we believe may be of interest and benefit to you. 
• it is necessary to provide the product or service you have 
requested e.g. for the provision of your funeral plan 
contract. 
• it is necessary for us to meet our legal or regulatory 
obligations e.g. to tell you about changes to our terms 
and conditions or for the detection and prevention of 
fraud. 
• it is in the legitimate interests of Silver Clouds to deliver 
appropriate information and guidance so you are aware 
of the options that will help you get the best outcome 
from your products or services or future products or 
services. We may also need to process your information 
to better understand you and your needs so we can send 
you more relevant communications about the products 
and services you have with us. 
• it is in the legitimate interests of a third party e.g. sharing 
information with your nominated funeral director. 
If you do not wish us to collect and use your personal information 
in these ways, it may mean that we will be unable to provide you 
with our products or services. 
 
WHO WE MAY SHARE YOUR INFORMATION WITH 
We may share your information with third parties for the reasons 
outlined in 'What we collect and use your information for' 
These third parties include: 
• Your nominated professional advisers, personal 
representatives, next of kin, custodians, attorneys and/or 
funeral director. 
• Companies we have chosen to support us in the delivery 
of the products and services we offer to you and other 
clients e.g. agents, consultants, funeral directors, 
crematoriums, burial plot providers, places of worship, 
florists, solicitors, custodians, investment managers, 
trustees, accountants, auditors, compliance firms, 
technology companies, payment service providers, 
couriers, or companies who help us in our contact with 
you, for example an internet service provider or cloud 
provider. 
• Marketing analytics, business development and customer 
service companies that assist us with marketing analysis 
and customer surveys. 
• Our regulators, supervisory authority, quality assurance 
companies and trade bodies including the Information 
Commissioner’s Office for the UK (ICO). 
• Law enforcement or other authorities, credit and identity 
check agencies for the prevention and detection of crime. 
WHERE YOUR INFORMATION IS PROCESSED 
Your information is processed in the UK and the European 
Economic Area (EEA). However, some of your information may 
be processed by us or the third parties we work with outside of the 
EEA. Where your information is being processed outside of the 
EEA, we take additional steps to ensure that your information is 
protected to at least an equivalent level as would be applied by UK 
/ EEA data privacy laws e.g. we will put in place legal agreements 
with our third-party suppliers and do regular checks to ensure they 
meet these obligations. 
 
HOW WE PROTECT YOUR INFORMATION 
We take information and system security very seriously and we 
strive to comply with our obligations at all times. Any personal 
information which is collected, recorded or used in any way, 
whether on paper, online or any other media, will have appropriate 
safeguards applied in line with our data protection obligations. 
Your information is protected by controls designed to minimise 
loss or damage through accident, negligence or deliberate actions. 
Our employees also protect sensitive or confidential information 
when storing or transmitting information electronically. Our 
security controls are aligned to good practice standards providing a 
controlled environment that effectively manages risks to the 
confidentiality, integrity and availability of your information. 
©Silver Clouds Later Life Planning Privacy Policy Ver.180520182 
 
HOW LONG WE KEEP YOUR INFORMATION 
We will keep your personal information only where it is necessary 
to provide you with our products or services while you are a client. 
We may also keep your information after this period but only 
where required to meet our legal or regulatory obligations. The 
length of time we keep your information for these purposes will 
vary depending on the obligations we need to meet. 
 
YOUR INDIVIDUAL RIGHTS 
You have several rights in relation to how Silver Clouds uses your 
information. They are: 
 
RIGHT TO BE INFORMED 
You have a right to receive clear and easy to understand 
information on what personal information we have, why and who 
we share it with and we do this in our Privacy Policy and periodic 
Privacy Notices. 
 
RIGHT OF ACCESS 
You have the right of access to your personal information. If you 
wish to receive a copy of the personal information we hold on you, 
you may make a data subject access request (DSAR). 
 
RIGHT TO REQUEST THAT YOUR PERSONAL 
INFORMATION BE RECTIFIED 
If your personal information is inaccurate or incomplete, you can 
request that it is corrected. 
 
RIGHT TO REQUEST ERASURE 
You can ask for your information to be deleted or removed if there 
is no compelling reason for Reap to continue to have it. 
 
RIGHT TO RESTRICT PROCESSING 
You can ask that we block or suppress the processing of your 
personal information for certain reasons. This means that we are 
still permitted to keep your information but only to ensure we don’t 
use it in the future for those reasons you have restricted. 
 
RIGHT TO DATA PORTABILITY 
You can ask for a copy of your personal information for your own 
purposes to use across different services. In certain circumstances, 
you may move, copy or transfer the personal information we hold 
to another company in a safe and secure way. 
 
RIGHT TO OBJECT 
You can object to us processing your personal information where it 
is based on our legitimate interests or for direct marketing. 
 
HOW TO MAKE A COMPLAINT 
We will always strive to collect, use and safeguard your personal 
information in line with data protection laws. If you do not believe 
we have handled your information as set out in our Privacy Policy, 
please contact us and we will do our utmost to make things right. If 
you are still unhappy, you can complain to our supervisory 
authority. Their contact details are: 
ICO helpline: 0303 123 1113 
ICO website: www.ico.org.uk 
ICO address: Information Commissioner’s Office, Wycliffe House, 
Water Lane, Wilmslow SK9 5AF 
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