Privacy Policy

Effective Date: 30th June 2025
When Life Changes Ltd
Website: https://whenlifechanges.com

At When Life Changes Ltd, we are committed to protecting your privacy and handling your data with transparency and care. This Privacy Policy outlines how we collect, use, and safeguard the personal information you provide through our website and related services.

1. Who We Are

When Life Changes Ltd is a UK-based organisation that provides bereavement support services, including a 13-step bereavement email programme delivered in collaboration with funeral directors.

2. What Information We Collect

We only collect and process personal data that is necessary for our service:

Email Addresses – provided to us via your chosen funeral director, for the sole purpose of delivering the 13-step bereavement programme.
Names – provided to us via your chosen funeral director, for personalising the email content within the bereavement programme.

We do not collect any other sensitive personal data, nor do we request phone numbers or other additional identifying information through our website.

3. Legal Basis for Processing

We process your email address based on your consent, which is provided when you or your funeral director submits your email address for the bereavement programme. You can withdraw this consent at any time by unsubscribing from the emails or contacting us directly.

4. How We Use Your Information

We use your personal information as follows:

Email addresses – exclusively to send you the bereavement support content as part of the programme
Names – to personalise the email content and make the support more meaningful and relevant to you

You will not receive any promotional or unrelated emails.

Analytics data (described below) is anonymised and used only to understand service performance and engagement.

5. How We Track Usage

a) Website Analytics

We use Google Analytics to understand how visitors use our website. This includes anonymous data such as:

Pages visited
Time spent on the site
Device/browser information
General geographic location

Google Analytics does not identify individual users. You can opt out of Google Analytics tracking by installing Google’s browser add-on.

b) Email Analytics

We use Kit.com and/or a self-hosted instance of Sendy to deliver the bereavement programme via email. These tools allow us to switch on or off analytics, such as:

Email open rates
Link click-through rates

Analytics are used only in aggregate to understand general engagement with the programme per funeral director. We do not track individuals.

6. Data Location and International Transfers

We understand that data location requirements may vary by jurisdiction and respect the importance of keeping personal data within specific geographic boundaries where required by law or contractual obligations.

Default Processing: Our standard service uses providers that may process data internationally, including Google Analytics and Kit.com, which may transfer data outside your country of residence.

In-Country Processing: Where required by local data protection laws or contractual agreements with funeral directors, we can provide our bereavement programme using infrastructure located within your country of residence. This ensures that your email address, name, and all related processing activities remain within your jurisdiction throughout the entire programme.

When international transfers do occur in our standard service, we ensure appropriate safeguards are in place, including:

Standard Contractual Clauses approved by the relevant authorities
Adequacy decisions, where applicable
Other appropriate safeguards as required by applicable data protection law

Note: The specific data processing location for your programme will be determined by your funeral director’s arrangement with us and any applicable legal requirements in your jurisdiction.

7. Infrastructure and Hosting

The platform that hosts our video content does not log personal data. Only basic error logging is used (e.g. for page loading issues), and no personally identifiable information is stored.

Technical Infrastructure: Helpfully Limited (trading as Helpfully IT) is our appointed data processor. They maintain and manage all servers, backups, and infrastructure to deliver our email programme and host-related content. HelpFully Limited is contractually bound to follow our data protection policies and only processes data under our written instructions, in full compliance with UK GDPR.

8. Data Sharing

We do not sell, share, or rent your personal data to third parties. Your email address is not visible to any other party, including the funeral director, after submission.

9. Your Rights

Under UK data protection law, you have the right to:

Access the data we hold about you
Request correction or deletion of your data
Withdraw your consent and unsubscribe at any time
Object to processing in certain circumstances
Request data portability
Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise any of these rights, please email us at privacy@whenlifechanges.com or use the unsubscribe link included in every email.

10. Data Retention

Email addresses and names are retained only for the duration of the 13-step programme. After this, they are automatically deleted from our systems within 90 days of programme completion.

11. Security

We take appropriate technical and organisational measures to protect your data, including:

Encryption of data in transit and at rest
Access controls and user authentication
Regular security monitoring and updates
Routine security audits and vulnerability assessments
Staff training on data protection

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be notified on this page with a new effective date. We encourage you to review this policy periodically.

13. Contact Us and Complaints

If you have any questions or concerns about this policy, please contact:

When Life Changes Ltd Email: privacy@whenlifechanges.com Website: https://whenlifechanges.com

If you are not satisfied with our response to any privacy concern, you have the right to lodge a complaint with the UK’s data protection supervisory authority:

Information Commissioner’s Office (ICO) Website: https://ico.org.uk Phone: 0303 123 1113