Privacy & Cookie Policy

How we use your data

This website is brought to you by the Avalon Trustee Company Limited. We ask that you read this policy carefully as it contains important information about our website (www.lifelocker.co.uk) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting you consent to the practices set out in this policy.

THE DATA WE COLLECT ABOUT YOU AND HOW WE WILL USE THIS

We will collect and process the following data about you:

1. Information you give to us

We will obtain personal data about you (such as your name, address, date of birth, telephone number and email address) whenever you apply for a ‘LifeLocker’ account, through our web site  by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service and when you report a problem with our site.

2. Information we collect about you.

When you visit our site we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, browser language, Internet Network Provider;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for' page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

3. Information we receive from other sources. 

• This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data in our Privacy and Cookies Policy (mouse over LINK TO Privacy & Cookies Policy).  We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information provider). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
• Information you provide to us in response to questions posed on the site when you build your own profile pages.  

Cookies

We monitor your use of our website through the use of cookies to keep track of your browsing patterns. We use cookies to operate, provide, improve, understand, and customise our services. We gather this information to allow us to provide our services to you. The relevant information is then used by us to communicate with you about the services we provide and for marketing purposes and to tell you about our policies and terms of use.  We may also use the information you provide to contact you by phone, email, mail or SMS and will depend upon the details you have provided to us, including any preferred method of communication. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

USE MADE OF THE DATA WE HAVE COLLECTED

We use information held about you in the following ways:

1. Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you with information about goods or services we feel may interest you;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer. 

2. Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer; 
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

3. Information we receive from other sources. 

• We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR PERSONAL DATA

We agree that we have the right to share your personal data with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Funeral directors and people who are acting as our agents or sub-contractors to fulfil a funeral plan and on the understanding that it will be kept confidential.

Selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience; 
• analytics and search engine providers that assist us in the improvement and optimisation of our site;

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Avalon Trustee Company Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data to comply with legal obligations, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Avalon Trustee Company Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud).

DATA STORAGE AND SECURITY

The data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area ("EEA"). It will also be processed by staff operating within the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We are committed to ensuring that your information is secure.  In order to prevent unauthorised use we have put in place suitable physical, electronic and organisational measures to safeguard the information we collect online and via other electronic communication channels. Our website does contain links to other websites. As this policy applies only to our website, when you access links to other websites you should read their own privacy policies. Although we will do our best to protect your personal data, we cannot guarantee the security of any personal data that you transfer over the internet to us and any transmission is at your own risk. We restrict any link that is made to our website from any external site containing obscene, defamatory, threatening or degrading material. We reserve the right at any time to request that a link to our website is removed from an external site. We also note that the content of any links to external sites on our website are not monitored by ourselves.

You are responsible for the protecting and confidentiality of any username, e-mail verification and password that may be given to you or your nominated keyholders for use on our Website. You or your keyholders should not share these with or transfer them to any third parties. Each party will have their own individual passwords to your account profile. If you become aware of any unauthorised use of passwords or any other breach of security regarding the Website that comes to your attention you should contact us immediately. 

We may occasionally ask for proof of identity before we share your personal data with you.

MARKETING

We may use the information you provide to us to improve our products and services. Additionally, using the contact details you have provided, we may periodically contact you by phone, email, mail or SMS to inform you about our products, any special offers or other information which we think may be of interest to you.

If you would rather not receive this information, or would like to change your preferred method of communication (such as email, SMS, post or telephone), please contact us via email: UK: info@avalon-trustee.co.uk or EU: customerservices@avalonsl.es.

OPT IN OPT OUT 

When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing preferences over the phone or by emailing us or writing to us at any time.     

We are firmly committed to protecting your information. You can be sure that we will never pass on your information to third parties without your express consent.

CONTACTING US

We are a Data Processor under the Data Protection Act 1998 and have a nominated Data Protection Officer. If you are 16 or under you must provide a parent or guardian’s permission before providing any of your personal information to us.

YOUR RIGHTS

The Data Protection Act 1998 creates a right for you to access all personal data relating to you (This is called a Subject Access Request). To access personal data relating to you please send a written request to:

The Data Controller, Avalon Trustee Company Limited, Brooke Court, Lower Meadow Road, Handforth Dean, Wilmslow, Cheshire, SK9 3ND

(We are entitled to charge a fee of £10.00 for answering your request).

Once your request is made we will tell you whether we hold any personal data relating to you, the purposes why it is being processed and to whom the information is to be disclosed.

If you have any other queries relating to our website or services you can send an email to:
UK:   info@avalon-trustee.co.uk 

CHANGES TO THIS POLICY

We keep our privacy policy and legal disclaimer under regular review and will place any updates on this webpage.  This privacy policy was last updated in January 2017.

COOKIE POLICY

Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website.

This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. [By continuing to browse the site, you are agreeing to our use of cookies.]

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We may use the following cookies: 

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. 

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. 

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may also use Google analytical cookies and you can find information about these here;

https://www.optimizesmart.com/google-analytics-cookies-ultimate-guide/

You can find more information about the individual cookies we use and the purposes for which we use below:

ASPXAUTH (Session Cookie or Persistent Cookie (depending on the users browser settings) - This cookie is used to determine whether or not the session has been authenticated. When a user logs into the site, this gets set and is then used to determine who they are when they access certain areas of the site

Request Verification Token (Session Cookie) - This is an anti-forgery token and used to prevent a CSRF (Cross-site request forgery) attack. It guarantees that the poster of a form is the one who gets the form in the first place

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. 

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. 

Except for essential cookies, all cookies will expire after your session 

Looking for more information about Cookies, please visit www.allaboutcookies.org