Privacy Policy – Bare Funeral Group Pty Ltd

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our services, including our website (Services) to you.

We know that privacy policies can be confusing and difficult to follow; we’ve written this to make it as easy as possible to understand how we collect, use and protect your personal information.

In this Privacy Policy, we, us or our means Bare Funeral Group Pty Ltd ABN 57 635 013 286 and our related bodies corporate.

How we use AI. We use artificial intelligence and machine learning technologies in our business operations and services, including to transcribe and analyse call recordings for quality assurance, training and administrative purposes. The Use of AI technologies section below explains how we use AI and the safeguards we apply.

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‍Types of information

‍Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

‍Sensitive information is a sub-set of personal information that is given a higher level of protection. It includes information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

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The information we collect

The types of personal information we may collect about you include:

‍Where you are a customer, potential customer or use our tributes pages:‍

• Your name;
• Your contact details, which might include your email address, mailing address and/or telephone number;
• Your credit card or payment details (through our third party payment processor);
• Your preferences and/or opinions;
• Information you provide to us through customer surveys;
• Details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• Recordings and transcripts of telephone conversations you have with us, including where those conversations are analysed using automated or AI tools for quality assurance, training and administrative purposes;
• Photographs provided for use in tribute pages;
• Copies of identification documents, such as driver's licences; where legally required to perform services
• Documents such as wills;
• Emails and names for the purposes of capturing RSVPs for funeral and memorial services, as well as collecting shared memories and comments on tribute pages;
• We may also ask optional questions about the deceased's estate to determine legal options and eligibility for Bare Law services;

‍In addition to the above, where you are a potential customer or customer for our prepaid funeral services:‍

• Your date of birth;
• Your next of kin;
• Any other personal information necessary to plan your funeral;

In addition to the above, where you are a potential customer or customer for our informal will generation services:‍

• Your marital status;
• Your family details (including your partner’s name, your children’s names), including whether you have any children with disabilities;
• Your estate preferences (for example detail of any gifts (including to religious or trade union organisations), beneficiaries of your estate, Your preferred executors, your preferred guardians and any other information you choose to include in your will);
• Your funeral preferences which may include information regarding your religious beliefs;

Where you apply for a job or position with us:‍

• Your name, contact details, working history and resume details and relevant records checks;

Where you opt in to receive marketing communications:‍

• Your name;
• Your email address;
• Your state of residence;
• Any other information which you provide in the sign up form at the time of sign up.

Where you are a user of our website:‍

• Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• Information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• Additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• Any other personal information requested by us and/or provided by you or a third party.
• You can view our full Website Terms and Conditions at bare.com.au/terms/website-terms-of-use‍

Where you go on to become a customer of Bare Law for estate administration or probate services: you will be governed by the Privacy Policy set out at barelaw.com.au/terms/privacy-policy

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Sensitive information

We only collect sensitive information from you with your consent and we will only use it with your consent or as required or authorised by law.

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How we collect personal information

We collect personal information in a variety of ways, including:‍

Directly‍
We collect personal information which you directly provide to us, including when you register on our website or when you communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites.

‍Indirectly‍
We may collect personal information which you indirectly provide to us while interacting with us, such as when you interact with our sites, services, content and advertising, in emails, over the telephone (including where calls are recorded and transcribed) and in your online enquiries.

‍From third parties‍

We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies or where you apply for a job or position with us from any recruitment consultant, your previous employers and others who may be able to provide information to us.

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Collection and use of personal information

‍Personal information:

We may collect, hold, use and disclose personal information for the following purposes:

• To provide our Services to you, including to enable you to access and use our Services, including to provide you with a login or to deliver our products to you;
• To generate documents (such as wills, power of attorneys, advance care directives) upon your request;
• To store your choices and to enable you to access and edit your saved choices in relation to the services we provide to you;
• To enable you to access and use our associated applications and associated social media platforms;
• To generate and display information on tribute pages;
• To determine legal options and eligibility for Bare Law services;
• To contact and communicate with you about our Services, including by telephone, SMS and email, in connection with an enquiry, quote or service you have requested;
• For internal record keeping, administrative, invoicing and billing purposes;
• For analytics, market research and business development, including to operate and improve our Services, associated applications;
• To administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• For advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you, where you have consented to receive this through acceptance of our Terms & Conditions;
• To comply with our legal obligations and resolve any disputes that we may have;
• If you have applied for employment with us; to consider your employment application; and
• If otherwise required or authorised by law.

Sensitive information:‍

We only collect, hold, use and disclose sensitive information for the following purposes:

• Any purposes you consent to;
• The primary purpose for which it is collected;
• Secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you;
• To contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and
• If otherwise required or authorised by law.

Disclosure of personal information to third parties‍

We may disclose personal information to:

• Third party service providers for the purpose of enabling them to provide their services to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, call recording, transcription and AI analysis providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• The third party who manages the Funeral Bond in relation to the Funeral Bond disclosure document;
• Our employees, contractors and/or related bodies corporate;
• Our existing or potential agents or business partners;
• Sponsors or promoters of any promotions or competition we run;
• Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• Courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• Courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• To our related bodies corporate, such as our affiliated estate administration services, where we believe the services may assist you and the disclosure is in connection with a related purpose you would reasonably expect.
• Third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses.
• Any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure‍

Storage and access

We store your personal information in Australia and the United States. Your information may also be accessed from or transferred to other countries in these circumstances:

· When our service providers are located overseas 

· When we work with overseas business partners

· When using cloud-based services or data storage solutions

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information‍

Your rights and controlling your personal information

Your choice‍

Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties‍

If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity‍

Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Direct marketing and electronic messages‍

We may send you electronic messages, including by email and SMS, for the following purposes:

(a) to respond to, progress, or follow up on an enquiry, quote, or service you have requested from us (service messages); and

(b) where you have given your consent, to provide you with marketing and promotional information about our services.

You can withdraw your consent or unsubscribe to receive marketing messages at any time, free of charge, by following the unsubscribe instructions in the message itself, or contacting us at [email protected].

Access‍

You may request access to the personal information that we hold about you by emailing us at [email protected]. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.

Correction‍

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

Complaints‍

How to contact us about your rights or to make a complaint and what happens next

Step 1: Contact our privacy officer

• Email: [email protected]
• Phone: (03) 8820 5678
• Post: Privacy Officer Bare Funeral Group Pty Ltd, Suite 9.04, Level 9 500 Collins Street, Melbourne, VIC 3000⁠

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.

Step 2: Our response

We will:

• Verify your identity before processing your request
• Investigate thoroughly (for complaints) or process your request (for rights)
• Respond to you in writing within reasonable timeframes and as required by law
• Explain what actions we will take and keep you updated on progress
• Not charge you for making a request (except for reasonable access fees if applicable)
• Help you understand and exercise your rights

Step 3: If you're not satisfied (complaints only)

If you're not satisfied with our response to your complaint, you can:

• Ask for a review by our senior management, or
• Contact external bodies:
• Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)

Storage and security‍

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies‍

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can 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 online Services.

Use of AI technologies

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

• Conduct analysis and data processing
• Transcribe and analyse call recordings for quality assurance, training and administrative purposes
• Generate and modify content and coding
• Improve and optimise our services and operations
• Automate routine tasks and communications
• Personalise your experience with our services
• Support quality assurance processes
• Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

• We'll inform you when AI is used to make decisions that may significantly affect you
• We maintain human oversight and review of significant AI-generated decisions
• Our staff are trained to understand AI limitations and verify outputs before relying on them
• We implement processes to verify the accuracy of AI-generated outputs

Security

• We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
• We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

• We regularly assess and document risks associated with using AI to process personal information
• We implement appropriate measures to address these risks
• We continuously monitor AI performance and regularly review their impact

‍Links to other websites‍

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments‍

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.