InvoCare Group Privacy Policy

 

Last updated 20 June 2025

 

1. InvoCare Group's commitment to privacy

1.1  The InvoCare Group is committed to managing personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles under the Privacy Act, Health Records and Information Privacy Act 2002 (NSW) and other equivalent state-based privacy laws that apply.

1.2  We understand the importance of being open and transparent with you in the way in which collect, hold, store, use and share your personal information. We take protecting your privacy rights very seriously.

1.3  This document sets out how we handle and protect your personal information and provides information on your rights in relation to your personal information managed by the InvoCare Group. This document is referred to as our Privacy Policy.

1.4  We strongly encourage you to read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this policy, or about InvoCare Group’s handling of your personal information, please contact us using the relevant contact details set out in section 16.

 

2. About the Invocare Group

2.1 The InvoCare Group is committed to honouring life and celebrating memories for generations as a leading provider of funeral services and pet cremation services, as well as operator of private memorial parks and crematoria. In conducting this business, we may collect personal information.

2.2 The InvoCare Group includes the following Australia related entities and subsidiaries:

2.2.1 InvoCare Australia Pty Ltd (ACN 060 060 031);

2.2.2 Bledisloe Australia Pty Ltd (ACN 067 304 545);

2.2.3 InvoCare PetCare Pty Ltd (ACN 645 244 480); and

2.2.4 Family Pet Care Pty Ltd (ACN 137 860 809),

(together, the InvoCare Group).

2.3 In summary, the InvoCare Group has a wide range of key products and services which it provides through its different brand names in Australia, as follows:

 

Brand sector and operations  

Brand names  / Names

Funeral Homes and Crematoria

National brands:

-  White Lady Funerals;

-  Simplicity Funerals; and

-  Value Cremations.

 

New South Wales and Australian Capital Territory brands:

-  Allan Drew Funerals;

-  Ann Wilson Funerals;

-  Batemans Bay & Moruya District Funerals;

-  Boland Funerals a Guardian Funeral Provider;

-  Clarence Valley Funerals;

-  David Lloyd a Guardian Funeral Provider;

-  Galaxy Funerals;

-  Grafton & District Funerals;

-  Guardian Funerals;

-   Hansen & Cole a Guardian Funeral Provider;

-  Hastings District Funeral & Cremation Service;

-  Lester & Son Funeral Directors;

-  Liberty Funerals;

-  Narooma District Funerals;

-  Southern Highlands Funerals;

-  Tobin Brothers a Guardian Funeral Provider;

-  Universal Chung Wah Funeral Directors; and

-  WN Bull Funerals.

 

Queensland brands:

-  Australian heritage Funerals;

-  City Funerals;

-  Drysdale Funerals;

-  Gatton Laidley Lowood Funeral Services;

-  George Hartnett Metropolitan Funerals;

-  Hiram Philip Funerals;

-  Mackay Funerals; and

-  Somerville Funerals.

 

South Australian brand:

-  Blackwell Funerals.

 

Victorian brands:

-  Le Pine Funerals and Le Pine Asian;

-  Lester & Son Funeral Directors;

-  Tuckers Funeral & Bereavement Service;

-  W.D. Rose Funerals; and

-  William Matthews Funerals.

 

Tasmanian brand:

-  Turnbull Funerals; and

-  Vincent Funerals.

 

Western Australian brand:

-  Archer & Sons Funeral Homes;

-  Christian Funerals;

-  Mareena Purslowe Funerals;

-  Oakwood Funerals; and

-  Purslowe & Chipper Funerals.

Memorial Parks and Gardens

New South Wales Memorial Gardens:

-  Broulee Memorial Gardens;

-  Castlebrook Memorial Park;

-  Forest Lawn Memorial Park;

-  Lake Macquarie Memorial Park;

-  Lakeside Memorial Park;

- Northern Suburbs Memorial Gardens and Crematorium;

-  Pinegrove Memorial Park (featuring Lung Po Shan);

-  Newcastle Memorial Park; and

-  Tweed Heads Memorial Gardens. 

 

Queensland Memorial Gardens:

-  Albany Creek Memorial Park;

-  Allambe Memorial Park;

-  Great Southern Memorial Park;

-  Mt. Thompson Memorial Gardens; and

-  Toowoomba Garden of Remembrance.

Pet Cremations

New South Wales brands:

-  Patch & Purr; and

-  Pets at Peace Central West.

Queensland brands:

-  Pets in Peace.

Victorian, Western Australian and South Australian brands:

-  Lawnswood; and

-  Edenhills.

Related Service Offerings

-  MyGriefAssist – InvoCare is proud to provide high-quality information on the subject of grief through its online grief resource website, MyGriefAssist. Convened by noted Australian author and speaker on grief, Doris Zagdanski, the website draws together a wealth of information that is vital for anyone coping with, or helping someone to cope with, grief.

-  My Memorial – The MyMemorial website brings together, in one place, information on the range of cremation and burial memorial options available at InvoCare's New South Wales and Queensland memorial parks and gardens.

-  Funeral Planner – InvoCare has created a simple, step-by-step digital service called Funeral Planner, to help you plan a fitting funeral to remember a cherished life. Funeral Planner combines InvoCare’s long tradition of leadership in the Australian funeral industry with digital innovation, to make the process of planning a funeral as easy, transparent and personal as possible.

 

-  Guardian Plan – Over 50s Friendly Society is a prepaid funeral plan and is APRA registered. For more than 20 years, Guardian Plan has been working with some of Australia's best-known funeral brands owned by InvoCare. Guardian Plan enables you to prepay selected funeral services for tomorrow’s funeral at today’s prices. By planning ahead for your funeral you can ensure peace of mind for yourself and those you care for.

 

-  LifeArt – InvoCare is proud to extend its care and service choices to families through LifeArt, an innovative company that offers beautiful, personal, emotional and environmentally-friendly coffins.

 

3. When does this Privacy Policy apply?

3.1 This Privacy Policy only applies to the handling of personal information by the InvoCare Group in Australia.

3.2 If you are dealing with another member of the broader InvoCare group of companies, including internationally (for example InvoCare New Zealand Limited or Singapore Casket Company (Private) Limited), you should consult that entity’s separate privacy policy to understand how they handle your personal information.    

 

4. About this Privacy Policy

4.1 This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

4.2 In this Privacy Policy:

- “we”, “us” and “our” refers to the InvoCare Group;

- “you” and “your” refers to any individual about whom we collect personal information; and

- “Pre-Need” refers to funeral plans you purchase from us in the present and which will be redeemed on your behalf by another person you have nominated in the future at the time of your passing, as well as Internment and Inurement Rights purchased for one of our memorial parks ahead of time. Funds in relation to Pre-Need funeral plans are held in an APRA regulated fund until the time of redemption; and

- “At-Need” refers to funeral packages, Internment Rights and Inurement Rights purchased from us in relation to someone who has already passed away.  

- “Interment Rights” refers the right obtained to be buried or interred in a vault or crypt at an InvoCare operated memorial park.

- “Inurnment Right” refers to the right of inurnment following cremation in a permanent memorial located on at an InvoCare operated memorial park.

4.3 This Privacy Policy sets out how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online). For example, this may include information we collect from you:

-  as a purchaser of a Pre-Need funeral plan or At-Need funeral package,  Interment Right or Inurnment Right;

- as the next of kin, executor and/or family member of someone who has purchased a Pre-Need funeral plan, Interment Right or Inurnment Right (whether they are alive or have already passed away);

- as a third-party business that engages us to provide services in relation to specific part of the funeral process (e.g. only mortuary services);

- as a supplier to us;

- when you apply for a job with us, or if you are a staff member; or

-  when you otherwise interacted with us, including by:

  • using InvoCare’s Pet Tracker mobile application available to staff members (Pet Tracker App);
  • attending one of our funeral homes, or other premises that we own or operate;
  • asking us to send you information about our products and services;
  • sending us an enquiry or providing us with feedback;
  • entering into a promotion, competition or special offer with us; or
  • visiting any of the InvoCare Group websites, such as https://www.invocare.com.au/, and including the separate websites we have for each Australian brand listed in the table above at 2.3 (together, our Websites).

4.4 The InvoCare Group will regularly review its policies and procedures regarding personal information and may therefore update and amend this Privacy Policy from time to time, with or without notice to you. However, where we make a material change to this Privacy Policy, we will provide notice to you (including by updating our Websites, and where appropriate, notifying you directly).

4.5 Any updated privacy policy will be made available on our Websites or can otherwise be obtained by contacting us and requesting a copy. We recommend that you visit this Privacy Policy regularly to keep up to date with any changes we make.

4.6 Other privacy related notices and terms and conditions may apply to you, such as a privacy collection notice provided:

- in our Funeral Services Agreement, or other contracts you enter into with us;

-  when you engage with us to purchase pet cremation services;

- in person when you attend one of our brands’ funeral homes;

- when you sign-up for news and offers via our Websites; and

-  when you apply for a role with us or accept a position working for us.

 

5. What is personal information?

5.1 “Personal information” is defined in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

-  whether the information or opinion is true or not; and

-  whether the information or opinion is recorded in a material form or not.

5.2 In this Privacy Policy, whenever we use the term “personal information”, we are referring to this legal definition.

5.3 Personal information does not include:

-  aggregated or de-identified data;

-  if you are a contractor, real estate agent or supplier, your business information that does not identify a person or reasonably identify you (i.e. in certain circumstances, your business payment details); 

-  information about a deceased person; or

- information about your pet (such as your pet’s name, date of birth, medical history or cause of death) except in limited circumstances where you are identifiable from your pet’s information (in which case that information would be personal information and handled by InvoCare in accordance with this Privacy Policy).

Information about a deceased person

5.4 Information about a deceased person is not considered personal information under the Privacy Act and therefore, is not covered by this Privacy Policy.  However, InvoCare Group is sensitive to how the use of this information may affect the next of kin, family members and loved ones of someone who has passed away, and will take steps to ensure that data retained is treated sensitively and with due care. 

 

6. What kinds of personal information do we collect about you and how do we collect this information?

6.1 You may interact with the InvoCare Group in a variety of different ways and the types of personal information that we collect about you will depend on the type of dealings you have with us.

6.2 Generally speaking, the kinds of personal information InvoCare Group collects may include:

Type of personal information

What this includes

How / when we collect this information

Personal and contact details 

This may include your:

 - full name;

 - address;

 - telephone number;

 - email address;

 - date of birth;

 - details of your familial / next of kin relationships;

 - occupation;

 - martial status (at the time of death);

 - marriage details (the city, state, country, full name of spouse and age at the time of marriage, for all marriages);

 - parents’ names and occupations; and/or

 - children’s names, dates of birth and ages.

We may collect this information (as relevant) directly from you in person, over the phone or via our Websites:

 - during our interactions with you, for example, if you speak to us at a pop-up stall we operate at local shopping centres and other venues;

 - when you submit a “Contact Us” form or otherwise make an enquiry (including by calling one of our Brands via the general enquiry phone number);

 - when you enter into a contract with us, for example, our Funeral Services Agreement;

 - when you visit a property or premises owned or occupied by us, such as our corporate offices, one of our Brands’ funeral homes, our cemeteries and crematoria, or a memorial park/garden we operate;

 - if you sign the guestbook or attendance register at a funeral service provided by us (including if you attend via an online livestream);

 - if you apply for a job position at an InvoCare Group entity; or

 - when you otherwise interact with us on a commercial basis, including as a supplier to us.

We may also collect this information about you indirectly from third parties, for example:

 - from your next of kin or your loved one whom has contacted us;

 - from third parties where the deceased person received care or resided in at the time of their passing including aged care facilities or hospitals;

 - coroners, if appliable;

 - if you have been appointed by another person as their next of kin, the executor or beneficiary of their will or otherwise;

 - from veterinary clinics we partner with; or

 - from other third parties who are involved in the marketing, promotion and sale of our products and services (including our sales agents).

 

 Details of your burial preferences

This may include:

 - details for your religious beliefs this is sensitive information;

 - details of how you want your body to be handled after you pass away (e.g. whether you want to be buried or cremated, and the relevant location);

 - mortuary requirements (including your height, weight, coffin details, body preparation required and/or make-up/clothing preferences);

 - a photograph or video of you to be used for your memorial; and/or

 - if you plan to be cremated, the identity of the person appointed to pick up your ashes.

 

We may collect this information directly from you:

 - when you enter into a contract with us as a Pre-Need funerals customer ,  or purchase an Internment Right or Inurnment Right on either a Pre-Need or At-Need basis;

 - during our interactions with you, if you are interested in purchasing our products or services, for example, a funeral package (including by phone, email or in person); and/or

 - for deceased persons, from your will.

 

We may also collect this information about you indirectly from third parties, for example:

 - your family members and/or next of kin;

 - from third parties where the deceased person received care or resided in at the time of their passing including aged care facilities or hospitals;

 - your authorised representatives, including the executor of your will; or

 - other third parties who are involved in the marketing, promotion and sale of our products and services (for example, where we are engaged by a third-party to provide mortuary services)

 

Information about the circumstances of your death

This may include sensitive information, such as health information.

 In particular, this may include:

 - your medical cause of death;

 - details of any health conditions you had (for example, genetic illnesses, which may also be personal information about your family members / next of kin);

 - information about any infectious diseases you had;

 - medical certificates and discharge documentation;

 - information about any hazardous material or battery operated devices in or attached to your body at the time of your death (for example, cardiac pacemakers or drug infusion devices); and/or

 - your location of death.

 

This is information about someone who is deceased, and therefore, we may collect this information indirectly from third-parties, including:

 - your family members and/or next of kin;

 -  doctors and other medical practitioners;

 - from third parties where the deceased person received care or resided in at the time of their passing including aged care facilities or hospitals;

 - coroners, if applicable; and/or

 - other third parties who are involved in the sale of our products and service (for example, where we are engaged as a third-party to provide mortuary services).

Details of your estate

 This may include:

 - copies of your will;

 - details of the executor appointed for your estate;

 - information about your assets;

 - the identity of your beneficiaries; and/or

 -  details of who you have appointed to be the guardian of your children (if relevant).

 

We may collect this information directly from you:

 - when you enter into a contract with us as a Pre-Need customer;

 - during our interactions with you, if you are interested in purchasing our products or services, for example, a funeral package (including by phone, email or in person); and/or

 - for deceased persons, from your will.

 

 We may also collect this information about you indirectly from third parties, for example:

 - your next of kin; or

 - your authorised representatives, including the executor of your will.

 

Photos and Videos

We may collect photographs and videos you feature in.

We may collect this information directly from you via physical or electronic means, including USB and third party photo/video sharing platforms, when:

 - you provide it to us for use and display at a funeral service, in a memorialisation video, memory book or Memories Timeline page, or other agreed funeral service; and/or

 - you attend a memorial service that is livestreamed online – if you do not wish for this information to be collected, do not attend the location where the funeral service is being held.

 

We may also collect this information about you indirectly from third parties, for example, where you feature in photographs/videos provided to use by the purchaser of a funeral package because you were friends with or family of the deceased person.

Employee and workplace information

 This may include:

 - details of your employment history;

 - information about your education, qualifications and certifications;

 - your tax file number (TFN);

 - your working eligibility rights;

 - your suitability for the role you are applying for;

 - details about your referees;

 - details of any workers compensation claims you have made;

 - health information and medical test results – this is sensitive information;

 - records of disciplinary investigations and incident reports – this may include sensitive information;

 - details of leave you have applied for or been approved to take – this may include sensitive information, for example domestic violence leave; and/or

 - other information provided as part of our recruitment process.

We may collect this information directly from you through our recruitment process when you apply for a position with us, or otherwise during your employment (including when you use Pet Tracker as a staff member).

 

We may also collect this information about you indirectly from third parties, for example:

 - third-party recruitment service providers we use;

 - your referees and/or previous employers’

 -  educational institutions and/or professional registration authorities;

 - medical practitioners;

 - Centrelink; and/or

 - third party service providers we use as part of the recruitment process.

Location information

This may include:

 - your geolocation information;

 - the name and location of the InvoCare premises you are at; and

 - the exact date and time you are at the given InvoCare premises.

Only staff members will be able to log in and use Pet Tracker.

 

 If you are a staff member engaged in the provision of pet cremation services and using InvoCare’s Pet Tracker mobile application, we will collect this information directly from you when you use Pet Tracker:

 - on your Zebra device to scan a designated QR code; and/or

 - as a driver delivering pet remains; and/or

 - otherwise, when you use Pet Tracker.

Background check information

Including national police check information (if applicable) – this may include sensitive information, such as if you have a criminal record.

We may collect this information directly from you through our recruitment process, when you apply for a position with us, or otherwise during your employment.

 

We may also collect this information:

 - from third parties (for example, verification providers, referees, previous employers, professional registration authorities, or our contractors that employ you); and/or

 - publicly available information (for example, court decisions).

 

Proof of identity information

This may include:

 - your drivers’ licence;

 - your passport;

 - your visa (if applicable);

 - and/or

 - other similar identity information.

We may collect this information directly from you when you enter into a contract with us as a Pre-Need customer, or if you are a job applicant or employee.

We may also collect this information about you indirectly from third parties, for example, your next of kin.

We may visually sight your ID documents, for example, to verify your identity when you collect someone’s ashes – please note that this is not a collection of personal information and we do not retain copies of such ID documents.

Government-related identifiers

 This may include:

 - your Medicare card number;

 - Centrelink information;

 - Child Support Reference Number; and/or

 - Pensioner/Senior number.

We may collect this information directly from you when you enter into a contract with us as a Pre-Need or At-Need customer, or if you are a job applicant or employee.

Transactional and payment information

This may include:

 - information about transactions that you undertake in respect of any InvoCare Group products and services (for example, details of your purchase of a coffin from LifeArt); and/or

 - your bank account or credit card details.

We may collect this information:

 - if you enter into, or propose to enter into, a transaction with us, including to purchase a funeral package; or

 - during your employment with us.

 

Please note that we do not collect your payment information if you purchase products, for examples, flowers or urns, from third-party vendors you have been re-directed to through a link on our Websites.

 

Call recording / CCTV information

InvoCare Group may collect call recordings and CCTV footage.

We may collect call recording information (including recordings and transcripts) generated  from calls that you make to the InvoCare Group, noting that you will always be advised of the call recording in advance, if applicable.

 

We may collect CCTV footage of you from CCTV surveillance systems that monitor our properties and premises, including our corporate offices, our Brands’ funeral homes, our cemeteries and crematoria, and memorial parks we operate.

 

Information required to be collected by law

This may include:

 - details required to complete your Death Certificate;

 - a copy of your Medical Certificate of Cause of Death;

 - if relevant, a cremation permit; and/or

 - other kinds of personal information as permitted or required by law.

We may collect this information as required, and most likely from the next of kin or a loved one of a deceased person.

Other types of information collected during our interactions

This may include information  that you provide us so that we can provide you with information regarding our products and services, or so that we can undertake dealings with you generally. 

We may collect this information:

 - when you request information about a product or service we offer from us;

 - when you attend a funeral service conducted or provided by us;

 - when you submit a form via the Websites;

 - if you post information to any of our social media sites (e.g. Facebook, YouTube, or LinkedIn), or interact with us on social media;

 - when you make an enquiry, provide feedback,  make a complaint or otherwise speak to one of our funeral specialists (via phone, email or in person); and/or

 - from your responses to customer satisfaction (including our WeCare survey), service development, quality control, research surveys or similar activities.

Company information

This may include:

 - company information such as you company’s ABN or ACN and director details;

 - ASIC search results; and/or

 - information about your company’s employees, contractors or suppliers.

We may collect this information from you as part of our supplier onboarding process if you are a current or prospective supplier, or from publicly available sources such as ASIC.

Online and digital services information

 This may include information (that is not always identifiable on its own) including:

 - network and device information (such as your device ID, type and IP address);

 - geo-location information;

 - browsing information, including information about how you interact with our Websites, pages your visit, what content you view and your session duration;

 - web form inputs such as your name, postcode, email address and phone number;

 - transaction data and/or

 - information collected from cookies and/or online tracking technologies (such as tracking pixels).

 

 Please see 12 below for further information on the digital information we collect and when it may become personal information.

We may collect this information when you use our Websites, and/or via use of online behavioural tracking technologies such as cookies and tracking pixels (including from third-party providers we use, such as Hotjar Ltd)  . For further information, see section 12.

Unsolicited information

Unsolicited personal information is personal information we receive that we have taken no active steps to collect.

We may collect this information directly from you. Please note that we may keep records of unsolicited personal information to the extent we are permitted to do so under the Privacy Act.

 

If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable for us to do so.

 

6.3 InvoCare Group may also collect other kinds of personal information that we notify you of at the time of collection.

6.4 In some cases, you may provide us with personal information which relates to another person (for example, your next of kin, a family member, or a job referee). If you do so, you agree that you have received permission from these individuals for us to collect, use, and disclose their personal information in accordance with this Privacy Policy. You should also let them know about our Privacy Policy (including the information in this Privacy Policy). 

 

7. Can you deal with us without providing your personal information?

7.1 You are under no obligation to provide your personal information to InvoCare Group. We will provide individuals with the option of not identifying themselves, if it is lawful and practicable to do so. For example, you can access our Websites, make general phone queries or email us without having to identify yourself.

7.2 However, without certain information from you, the InvoCare Group may not be able to provide you with our full scope of services or information that is tailored to your needs, and we may generally be limited in how we can interact with you. For example, if you do not provide your personal information, you will not be able to purchase a funeral package/s from us. We may also be required by law to collect certain information to provide you with our service. For example, in NSW we will not be able to complete your purchase of a burial plot from us if you do not provide your personal information as Cemeteries & Crematoria NSW, the regulator requires we obtain details of the purchaser of burial plots.

 

8. Why we collect, store and use your personal information

8.1             Generally speaking, InvoCare Group collects and uses personal information so that we can provide, improve and promote our end-to-end funeral services, private memorial parks and crematoria, pet cremation services, and other related offerings.

8.2             We may also use your personal information for purposes which are incidental to the provision, improvement and promotion of our end-to-end funeral services, private memorial parks and crematoria, pet cremation services, and other related offerings, or for other purposes which are within your reasonable expectation or permitted by law.

8.3             The purpose for which we usually collect, store, and use your personal information depends on how you interact with us (for example, whether you are an Pre-Need customer, employee or third-party service provider), but may include the following purposes:

Purpose

Explanation

To sell and provide the  services contained in our funeral policies, or provide you with other funeral-related services (including cremation) 

We may handle your personal information to:

 - sell you an Pre-Need funeral policy;

 - facilitate your redemption of a funeral policy purchased from us;

 - sell and provide you with the funeral services on an At-Need basis;

 - complete the required documentation surrounding your death;

 - collect, transport and provide mortuary services on your body or the body of your loved one;

 - verify your identity, including if you are the next of kin for someone who as purchased a Pre-Need funeral policy from us and now passed away;

 - facilitate your purchase of a Internment Right or Inurnment Right whether purchased on an At-Need or Pre-Need basis;

 - identify and fulfil your burial / funeral preferences from your will;

 - administer, manage and process any transactions you enter into, or propose to enter into, with us, including the purchase of a funeral packages from us and any applicable payments;

 - refund funds in relation to Pre-Need funeral policies purchased but not redeemed;

 - arrange for ongoing memorialisation of you or your loved one, including via a memory book, memorialisation video or Memories Timeline;

 - communicate with you, including by phone, email, or mail, to respond to your queries and provide you with services and information you request from us;

 - keep our records accurate, complete and up-to-date;

 - manage our relationship with you, including by resolving complaints or improving our customer service;

 - test, train improve and develop our technology systems, products and services, including through the use of artificial intelligence tools; and/or

 - develop and improve any part of the end-to-end funeral and related services we provide, including by obtaining your feedback or by conducting market research.

 

To operate and maintain our cemeteries, crematoria, and memorial parks and gardens

We may handle your personal information to:

 - verify your identity if you have been authorised to collect someone’s ashes;

 - keep a record (including an online registry) of burial plots;

 - investigate incidents (including potential incidents) which occur on or at our properties or premises; or

 - otherwise operate our cemeteries, crematoria and memorial parks.

 

To provide you with pet cremation services

We may handle your personal information to:

 - promote our pet cremation services;

 - verify your identify, if you are the primary or secondary pet owner or otherwise authorised to collect a pet’s ashes; or

 - otherwise to provide you with pet cremation services.

 

To manage your working relationship with us (including if you are an employee or contractor)

We may handle your personal information to:

 - verify your identity;

 - recruit employees and contractors;

 - consider your suitability as a prospective employee or contractor;

 - manage our working relationship with you;

 - investigate incidents (including potential incidents) which occur on or at our properties or premises; and

 - collect, store and use your personal information for administration and management purposes.

 

To do business with you

We may collect, store and use your personal information if you interact with us on a commercial basis (such as if you are a service provider, third-party funeral provider who engage us to provide services in relation to specific part of the funeral process (e.g. only mortuary services), or supplier to us), or if you otherwise interact with us on a commercial basis.

 

To manage our relationship with you if you are an attendee or guest

We may collect, store and use your personal information, including photos/ videos you feature in or personal information you enter into a guestbook at a funeral service you attend, to:

 - provide a livestream and/or video recording of the funeral service, at the request of the person who entered into a Funeral Services Agreement with us;

 - keep an attendance record of the funeral service; and/or

 - otherwise manage our relationship with you as an attendee or guest at an funeral service arranged by InvoCare or which takes place on InvoCare’s premises.

 If you attend a funeral service that is being recorded or livestreams, we will notify you at the entrance, for example, via signage.

 

To manage and improve our operations and business

We may collect, store and use your personal information to:

 - conduct the general operation and management of InvoCare Group, and to supply our services to you;

 - use the location of staff involved in providing the pet cremation services and provide real-time updates to our Client Care about where in our 7 point cremation journey a customer’s pet is;

 - train staff (including IT, development, legal and finance teams);

 - maintain appropriate work, health and safety standards at our properties and premises;

 - test, train and maintain information technology systems (including artificial intelligence tools);

 - protect the security of our offices, employees, customers and the property held on our premises;

 - administer our Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

 - manage payments and debt recover.

 

To create de-identified or aggregate data for data analytics

We may collect, store and use your personal information to create deidentified or aggregate data sets (which is no longer personal information). We do this by de-identifying or aggregating your information such as combining your information with information we have about our other customers, for example purchasing information, and with data we obtain from other sources. We use this deidentified or aggregate data to assist with our business decisions, such as to:

 - help us in understanding trends in customer behaviour (such as the success of our funeral services, and our different marketing campaigns);

 - create look-a-like audiences for the purposes of providing targeted advertising to other customers;

 - perform research and statistical analysis, including for customer satisfaction and service improvement purposes;

 - improve the products and services we offer; and

 - improve our services to better meet our customers’ preferences and behaviours.

 

To assist with any business, share sale or corporate restructure

We may collect, store and use your personal information for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale.

 

To comply with legal and regulatory obligations

We may collect, store and use your personal information for the purpose of complying with our obligations under any applicable laws and regulations, including privacy laws and laws specific to our industry (such as state-based laws for the registration of births, deaths and marriages, and laws governing licensed cemetery and crematorium operators).

 

8.4 In addition to the purposes listed above, InvoCare Group may use your personal information for other purposes which we notify you of when we collect your personal information and for purposes otherwise permitted or required by law.

8.5 InvoCare Group only uses and discloses your personal information for the purpose for which it was collected, including related secondary purposes as permitted by privacy laws.

 

9. Who do we share your personal information with and why?

9.1 InvoCare Group may share your personal information with third parties:

- for the purpose for which we collect it, as set out in section 8 of this Privacy Policy;

- for other purposes, if we notify you of such when we collect the information; or

- where we have otherwise received your consent, or the disclosure is required or authorised by law.

9.2 Some of the third parties we may share your personal information with includes the following:

Recipient

Explanation

Other members of the broader InvoCare group of companies, our subsidiaries and associated entities

We may share your personal information across the InvoCare group of companies based in Australia.

 

The executor of your will, your next of kin or appointed family members

We may share your personal information with the executor of your will, your next of kin, family members or anyone else you have appointed to redeem your Pre-Need funeral plan with us, in order to arrange for redemption of your funeral plan and provide the relevant services.

 

External funeral director

If you have engaged a funeral director outside of the InvoCare Group, but we have been engaged to provide services as part of the funeral and burial process (for example, collection and transport of the body or mortuary services), we may share your personal information with the third party funeral director as required to fulfil the services we have been engaged to provide.

 

Government agencies

We may share your personal information with relevant Government agencies following your death or the death of your loved one, for example to apply for a death certificate or have the death registered on the relevant state-based Births, Deaths & Marriage registry. In some cases, we may be required by law to share such information with Government agencies.

 

Conexum Data Management Services Pty Ltd

We may share your information with Conexum Data Management Services Pty Ltd, the company that manage the Australian Bereavement Register. The Australian Bereavement Register is a register of Australians who have passed away, created so that deceased people are removed from direct mailing lists and no longer receive mail addressed to them. We encourage you to read their privacy policy on the Australian Bereavement Register’s website for further information, including information on how they handle such information.

 

Members of the public wishing to pay respects at your place of burial or attending a livestreamed funeral service online

If you are buried at one of our cemeteries, memorial parks or gardens, we may share the location of your burial (for example, the park name and plot number where you are buried) with your loved ones who make an enquiry or via a publicly accessible online registry on our Websites.

 If you attend a funeral service arranged by InvoCare or on InvoCare premises that is livestreamed at the request of the loved ones of the deceased person, video footage featuring you may be shared by us with attendees of the livestream.

 

Our service providers, advisors and other entities we do business with

We may share your personal information with our:

 - service providers, contractors, and other third parties that provide services to us, including data analytics services; and

 - professional advisors, including legal and accounting firms, auditors, consultants, insurers and other professional advisers.

 Please note that we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant services.

 

Corporate restructure

We may share your personal information with people or entities considering acquiring an interest in the InvoCare Group or any business or assets of the InvoCare Group, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business, or if we undergo any kind of corporate restructure.  In this context, your personal information may be transferred to another entity.

 

Referees

We may share your personal information with your nominated referees to validate details you have provided us with, including your resume, qualifications, experience, training or abilities.

 

Marketing organisations

We may share your information with marketing organisations that assist us with our marketing communications or who send you marketing communications on our behalf. Please see the “Do we use your information for direct marketing” section below for further information on how we engage in direct marketing.

 

9.3 If you post information or other content to public sections of our Websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant Website or social media site.

 

10. Overseas disclosures

10.1  As set out above at 9.2, we may share your personal information with entities in the InvoCare group of companies located in New Zealand and Singapore (i.e. InvoCare New Zealand Limited and Singapore Casket Company (Private) Limited).

10.2 We do not currently store personal information outside of Australia. However, in limited cases, our service providers located in the United Kingdom, USA, Canada and New Zealand may be able to access your personal information from those jurisdictions in order to provide secondary support services to InvoCare. In some cases, this may include disclosure of your personal information overseas to those jurisdictions.  

10.3 If you engage us in relation to the in-bound or out-bound repatriation of a deceased person’s body, we may need to disclose your personal information (for example, if you are the deceased person’s next of kin) to third parties located in the relevant country the body is being repatriated to or from to the extent necessary to enable us to facilitate the body’s repatriation.

10.4 In the situation described at 10.3, we will only ever share your personal information outside of Australia in accordance with the Privacy Act.  This means that we will take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act. If this happens, this Privacy Policy will be updated accordingly. 

 

11. Links to other websites

11.1             When you access our website or other online services, we may provide, as a convenience to you, links to third party websites, including sites operated by our partners, associates, or independent third parties. Each website has its own privacy practices, as described in that website’s privacy policy. Those practices may be different than the practices described in this Privacy Policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site.

11.2             Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site. We encourage you to read the relevant third party’s privacy policy before supplying any personal information to them.

 

12. Cookies, Pixels and other third-party online tracking technologies 

12.1 InvoCare Group may collect statistical information when you access and use our Websites and any online platforms available via our Websites, by utilising features and technologies of your internet browser, including cookies and tracking pixels. We use these tracking technologies for a variety of purposes, including to:

- collect data about our website traffic;

- analyse how our Websites are being used,

- improve our Websites; and

- provide more user friendly Websites and online services.

12.2 These features and technologies do not specifically identify you unless you otherwise provide personal information to us that enables identification. As such, information collected through these tracking technologies may be personal information.

Cookies

12.3 A ‘cookie’ is a small file stored on your computer’s browser, which helps us better understand our users and assists us to deliver content via our Websites. We collect certain information via cookies, such as your device type, browser type, IP address, and pages you have accessed on our Websites. Our websites contain cookies from third party providers we use, including Shopify and WordPress.

Tracking pixels

12.4 A tracking pixel is a piece of code that a business or third-party provider can place on its website or in email to collect information about a users’ activity, including the site pages they visit time spent on each page, IP address, and/or form inputs (as relevant). When users visit pages with pixels, the pixel “loads” and send the information it is designed to collect back to the server of e.g. in the case of third-party pixels this would be to the third-party service provider.

Opting out

12.5 If you do not wish to receive any cookies (other than those that are strictly necessary) you can change your web browser preferences to control how the bowser deals with cookies. For example, depending on which browser your device uses, you may be able to disable certain third-party cookies. Please note that if you disable certain cookies, you may be unable to access certain pages or content on our Websites.

12.6 To change your web browser preferences, please visit the relevant preferences or settings page on your browser and amend the privacy settings in relation to cookies and site data. It may be necessary for you to opt out separately from each device and browser that you use to access online content.

12.7 We also use third-party service providers, such as Adobe and Hotjar Limited, that may collect data related to your use of our online services through a suite of tracking technologies, such as third-party cookies, tracking pixels and web beacons, for analytic and/or marketing purposes.

12.8 These third party providers may update their policies and settings from time to time, so we encourage you to review their terms and policies for more information on their data collection practices and options available to you for managing your privacy. Please note that how these third parties handle and use your data is governed by their own privacy policies, not ours.

12.9 In addition to opting out of cookies via your browser as described at 12.5 and 12.6, you can opt out of the following third-party analytical tools we use via the instructions available at the links below:

Provider

Description

Adobe Analytics

http://www.adobe.com/au/privacy/opt-out.html - follow the prompts ‘for End-users of business using Adobe Experience Cloud’ to opt out. 

 

Hotjar

https://www.hotjar.com/policies/do-not-track/ - follow the relevant ‘Do Not Track’ instructions for your browser type.

 

Alphabet Inc

If you use YouTube, Google or any other platforms owned by Alphabet, you can manage how tracking technologies are used by checking your browser or account settings and adjusting your ‘privacy & safety’ and ‘search personalisation’ settings.  

 

Meta Platforms Inc

If you use Facebook, Instagram, Threads or any other platforms or networks owned or used by Meta, you can generally adjust your ‘ad preferences’ in the account settings of the respective platform that you access and see ads in.

 

 

13. Do we use or share your personal information for direct marketing?

13.1 InvoCare Group may use and share your personal information for the direct marketing through various channels, such as via post, email, SMS, telephone or social media (through targeted advertisements on certain websites, mobile applications and social media channels).

13.2 Where you provide personal information to the InvoCare Group via one entity or Brand, we may share this personal information to another entity or Brand under the InvoCare Group so that they may undertake direct marketing as set out in 13.1, including to send you marketing materials about products and services that may be of interest to you. For example, if you purchase a Pre-Need funeral package from the White Lady Funerals, Castlebrook Memorial Park may send you marketing material about purchasing a burial plot as well, as both are brands owned and operated by the InvoCare Group.  

13.3 We will only send these communications in accordance with the Privacy Act (including Australian Privacy Principles 7) and the Spam Act 2003 (Cth), and only where you have not opted out from receiving such communication from the InvoCare Group entity or relevant Brand.

13.4  You are always in control of the direct marketing communications which you receive from us and can opt-out at any time using the methods described at 12.5 to 12.9 and 13.5.

13.5  You can also visit Your Online Choices and do a blanket opt out from targeted advertising based on your browsing history for the organisations who have signed up to Your Online Choices. When you opt out of receiving targeted ads via Your Online Choices, this information is usually saved on a cookie. This means that if you clear your cookies, you will have to opt out again.

13.6 Generally, you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message). You can also contact us using the details set out in section 16 of this Privacy Policy to tell us you would like to stop receiving direct marketing communications from us.

13.7 If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

Important points regarding opting out –

13.8           Importantly:

13.8.1         if you are a customer of multiple Brands across the InvoCare Group (for example, you have engaged Patch & Purr for your pet’s cremation and separately purchased a Pre-Need funeral plan from White Lady Funerals), even if you opt out from receiving direct marketing communications from Patch & Purr, this will not mean you are opted out from receiving direct marketing communications from White Lady Funerals; and

13.8.2         regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if required by law to provide you with information, or in relation to the products or services we are providing to you.

 

14. How do we store and protect your personal information?

14.1 We are committed to protecting your personal information and ensuring that we securely store any personal information we collect (in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form.

14.2 InvoCare Group takes steps reasonable in the circumstances to ensure that the personal information it holds is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Security and storage of personal information

Form

Explanation

Paper-based files

We store personal information in paper-based files in secure storage, and maintain physical security measures to ensure that such personal information is protected, such as physical locks on drawers and cabinets, and security systems at our premises. Paper files may also be archived in boxes and stored offsite in secure facilities.

Electronic records

Your personal information will be stored on databases held on servers located in a technologically secured environment, accessed only by authorised personnel or contractors (with login and password protection). We also maintain physical security measures in relation to storage of our electronic records (such as locks and security systems), and maintain computer and network security, by using firewalls, anti-virus software and conducting routine penetration testing of said systems. InvoCare Group also has polices and procedures in place in relation to document storage and security.

Our Websites (including for making online payments)

Our Websites use encryption and other technologies to ensure that your personal information is securely transmitted via the internet.

We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

 

15. How can you access or seek correction of your personal information?

15.1 You are entitled to request access to any of your personal information held by InvoCare Group. To make such an access request, please contact us using the contact details below at section 16.

15.2 InvoCare Group takes reasonable steps to ensure the personal information it holds is accurate, up-to-date, complete, relevant and not misleading. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you, and informing us of any change in your personal details.

15.3 In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by InvoCare Group. If at any time you consider any personal information we have about you is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request correction of that information using the contact details in section 16. InvoCare Group will grant access to the extent required or authorised by the Privacy Act and will take reasonable steps to correct your personal information.

15.4 If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.

15.5 InvoCare Group will respond to your request within 30 days. We may decline your request to access or correct your personal information in certain circumstances in accordance with applicable privacy laws, however if we do so, we will provide you with written reasons for the refusal and details of complaint mechanisms.

15.6 If you are dissatisfied with InvoCare Group’s refusal to grant access to, or correct, your personal information, you may complain to us using the contact details at section 16 below.

 

16. How can you contact InvoCare Group?

16.1 For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact us using any of the following details:

Contact InvoCare Group

Email

Privacyofficer@invocare.com.au

Phone

1300 363 992

Postal address

InvoCare Australia Pty Ltd

Attention: Privacy Officer

Level 6, Building A, Rhodes Quarter

1 Homebush Bay Drive

Rhodes NSW 2138

 

17. Privacy complaints and questions

17.1 If you have any questions or concerns about this Privacy Policy or how we have handled your personal information, you may contact us at any time using the relevant contact details set out above in section 16.

17.2 Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur:

No.

Step

1.    

We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally acknowledge your complaint within a week.

 

2.    

If your complaint requires more detailed consideration or investigation:

 - we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly.; and

 - we may ask you to provide further information about your complaint and the outcome you are seeking. If your initial complaint was not written, we may ask you to submit your complaint in writing.

 

3.    

We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.

 

4.    

In most cases, we will respond to your complaint within 30 days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know, and tell you when we expect to provide our response.

 

17.3 If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).

17.4 The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992, or you can fill out this form to make a complaint about our handling of your personal information. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.