Privacy Policy

1. Introduction

Since its creation in 2010, the Funecap group has offered a comprehensive and consistent range of products and services related to the funeral industry. Leveraging our structures, brands, expertise and the professionalism of our teams, we support and advise families with post-bereavement procedures and funeral arrangements. We also manage funeral insurance plans to best meet your expectations and wishes.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person, whether directly or indirectly, such as their name, telephone number, customer number, email address or date of birth.
• Personal Data Processing: Any operation or set of operations, whether or not carried out by automated means, applied to Personal Data, such as collection, recording, storage, consultation or disclosure.
• Data Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of personal data processing.
• Data Processor: Any natural or legal person, agency or body that processes data on behalf of and under the instructions of the data controller, within the framework of a service or contract.
• Recipient: The natural or legal person, public authority, agency or any other body to which Personal Data are disclosed, whether or not a third party.
• European Economic Area (EEA): The Member States of the European Union together with Norway, Iceland and Liechtenstein.
• Sensitive Data: Categories of personal data revealing racial or ethnic origin, political opinions, philosophical or religious beliefs, trade union membership, genetic data, data concerning a natural person's sex life, or health data.
• Data Transfer outside the EEA: Transfers of personal data to a third country, where such data are or are intended to be processed.

3. Purpose

This policy (hereinafter the "Policy") is intended to describe how Funecap Holding processes the personal data of users browsing this website (hereinafter "the Website").

Funecap Holding, as data controller, attaches particular importance to the protection of the data entrusted to it and undertakes to process such data in accordance with applicable regulations, in particular:

• Loi n° 78-17 relative à l'informatique, aux fichiers et aux libertés du 6 janvier 1978 (French Data Protection Act, known as "Loi Informatique et Libertés"),
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the GDPR (General Data Protection Regulation).

4. Amendments and Lifecycle

This Policy may be amended, supplemented and/or updated by Funecap Holding, in particular to comply with any legislative, regulatory, case law or technical developments. We invite you to consult it regularly on our website for any updates. If the amendments are of a significant nature, we will publish a visible notification on our website(s) including, where we deem it appropriate, an electronic notification of the changes made to the privacy notice.

Personal Data will, however, always be processed in accordance with the Policy in force at the time of their collection, unless a mandatory legal requirement provides otherwise and applies retroactively.

5. Processing of Your Data

As data controller, Funecap Holding undertakes to comply with the following principles:

• You will be informed of the processing of your data in a clear, fair and transparent manner, from the moment your data are collected,
• Your data are used for explicit, legitimate and specified purposes,
• Your data are limited to what is necessary in relation to the purposes for which they are processed,
• Your data are kept for a period limited to what is necessary for the purposes for which they are processed, or as required by applicable regulations,
• Your data are accurate and kept up to date. Any inaccurate data will be rectified without delay,
• Your data are disclosed only to recipients who demonstrate a legitimate need, including our subcontractors and partners.

In accordance with applicable regulations, Funecap Holding processes your data on the following legal basis:

Legitimate interest: The processing of your contact requests.

In the context of processing your contact requests, we collect and process your identification data (surname, first name, email) and any other personal data you may wish to voluntarily communicate.

Data collected in the context of this processing are retained only for the period necessary for the purposes for which they were collected. These periods may, however, be extended in the event of changes in applicable regulations, or to assert the rights of Funecap Holding in court.

6. Data Recipients

To achieve the purposes described above and within the limits necessary for the pursuit of these purposes, data collected by Funecap Holding may be disclosed to:

• Our teams whose activity requires the processing of your data,
• Our subcontractors, namely our technical service providers and service providers.

We require our subcontractors to maintain an adequate level of data protection and security.

We may also be required to share personal data with any supervisory authority or authorised public body, including judicial, tax or data protection authorities, where required by law, regulation, court order or where such disclosure is necessary to establish, exercise or defend our rights.

7. Data Security

We take all necessary physical, technical, organisational and operational measures to ensure the security and confidentiality of your Personal Data against unauthorised destruction, loss, alteration, disclosure, reproduction or access. We require our partners and subcontractors to implement measures guaranteeing a level of security at least equivalent to our own.

Funecap Holding also implements appropriate internal procedures to raise awareness and train its employees in personal data protection and to ensure compliance with these rules within its organisation.

8. Data Transfers

Funecap Holding may transfer some of your data outside the European Union.

In order to protect your data and in accordance with applicable regulations, these transfers are governed in particular by:

• Standard contractual clauses as published by the European Commission,
• Adequacy decisions adopted by the European Commission.

9. Data Subject Rights

In accordance with applicable regulations, you have the following rights over your data:

• Right of access,
• Right to rectification in the event of error,
• Right to erasure,
• Right to restriction of processing,
• Right to data portability,
• Right to object, on grounds relating to your particular situation, to the processing of your data.

You also have the right to issue instructions regarding the fate of your data after your death.

Funecap Holding undertakes to respond to your requests to exercise your rights within 30 days of receiving the complete request. We reserve the right not to follow up on a manifestly unfounded or excessive request; you will be informed accordingly.

If you believe, after contacting us, that your data protection rights are not being respected, you may lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés – French Data Protection Authority).

Funecap Holding has also appointed a Data Protection Officer whom you may contact for any question relating to the processing of your data and your privacy:

• By email: donnees-personnelles@funecap.com
• By post: Data Protection Officer – Funecap Holding, 17 rue de l'Arrivée, 75015 Paris, France.

10. Cookie Management

Cookies are small data files that enable a website or mobile application to collect and store a range of data on your desktop computer.

Cookies are used to enable websites to function or to improve their operation. They allow websites to recognise your device and record information relating to your browsing (for example: chosen language, font size, or other preferences).

We only collect cookies that are strictly necessary for the proper functioning of the website, namely: cookies to ensure the security of the website; session cookies to facilitate your navigation on the website.