Draft review copy. Not in force and not an offer. A contract is made only through a signed CremTrack order form. # CremTrack™ Platform Privacy Notice **Version 1.0 — draft | Last updated 2 November 2026** This notice explains how ANC Perpetua Holdings Ltd, company number 17366895, 66 Paul Street, London, EC2A 4NA (**ANC**) uses personal information in the CremTrack platform. Contact: **hello@cremtrack.com**. ## 1. Who is responsible Responsibility depends on the journey: - For a crematorium's own clients and records, that crematorium normally decides why the information is used and is the controller. ANC normally provides the platform as processor. - For a case arranged directly through ANC, ANC normally acts as controller and may share necessary information with the selected fulfilment crematorium. - ANC is controller for accounts, service administration, billing, security, fraud prevention, support and its own legal obligations. - Veterinary practices and regulators may be separate controllers for their professional or statutory functions. Ask the organisation that arranged the service if you are unsure who controls your particular record. ## 2. Information used We may process: - family names, phone numbers, email addresses, collection/return addresses and communication choices; - companion name, species, breed, age, sex, colour/markings, microchip where supplied, photograph, service and care instructions; - bookings, prices, statuses, numbered-tag and custody checks, collections, transfers, equipment/cycle evidence and ashes-return records; - optional memorial words, photograph, publication and sharing choices; - staff, driver, veterinary and inspector names, organisations, roles, account and audit records; - active driver location while an authorised journey is running, exact for permitted dispatch users and reduced/approximate for a relevant family where enabled; - messages and delivery records; - invoices, credits and transaction references; - device, IP, sign-in, security and diagnostic information; - uploaded documents, photos, inspection requests, findings, responses and visit arrangements. Please do not submit human medical details, payment-card details in free text, or information unrelated to the care service. ## 3. Why and lawful bases Depending on the responsible controller and facts, information is used to: - take steps at a person's request and perform the arranged service; - identify and care for a companion and maintain a clear chain of custody; - run accounts, subscriptions, support, communications and billing; - meet legal and regulatory record-keeping, inspection and reporting duties; - protect families, workers, organisations and the platform from mistakes, misuse and security incidents; - establish, exercise or defend legal claims; - publish an optional memorial only with the recorded choice/consent where consent is the appropriate basis. These purposes may rely on contract, legal obligation, legitimate interests and, where required, consent. A controller must identify the correct basis for its own processing. Consent can be withdrawn for optional memorial publication and optional family-facing location without affecting earlier lawful processing. ## 4. Who can see information Access is limited by organisation and role. It may include the arranging organisation, the assigned crematorium, an assigned driver, an authorised veterinary practice, ANC support or oversight users with a documented need, approved service providers, and a regulator or inspector with lawful, temporary and scoped access. Families see only the private journey linked to their care code or secure link. We do not sell personal information. Public memorial content is visible to anyone only when publication has been chosen and approved. ## 5. Driver location Location starts only after the authorised driver actively starts an eligible journey and grants device permission. It is intended for dispatch and, where enabled, an approximate family view during that journey. It stops or expires when the journey ends, permission is withdrawn, the assignment changes or the maximum session is reached. The browser pilot does not promise uninterrupted background tracking. ## 6. Messages The responsible organisation may send service texts or emails about intake, collection, arrival in care, progress and return. Operational messages are separate from marketing. Marketing requires its own lawful basis and choice and must not be inferred from accepting a care service. ## 7. Retention Operational and regulatory records are kept for the period selected by the responsible controller and required by applicable law. Account, security, location, message, memorial and backup data have shorter or specific periods in the CremTrack retention schedule. When information is no longer required it is deleted or anonymised, subject to legal holds and backup expiry. The final production retention schedule will be published or provided on request before external onboarding. ## 8. International transfers The final production provider list will identify where information is processed. If information is transferred outside the UK, the responsible organisation will use a lawful transfer mechanism and appropriate safeguards. ## 9. Security Measures include role and organisation separation, protected authentication, encryption, audit records, controlled support access, backups, monitoring, expiry controls and incident response. No online service can promise absolute security. Users must protect credentials, devices and care codes. ## 10. Rights Depending on the law and circumstances, a person may ask for access, correction, deletion, restriction, portability, or object to use of their information, and may withdraw consent. Requests about a crematorium's own case should normally go to that crematorium; ANC will assist it. Requests about ANC accounts or ANC-originated cases may be sent to **hello@cremtrack.com**. Identity may need to be checked. A person can complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/. ## 11. Children CremTrack is not intended for children to create accounts or submit bookings. An adult with appropriate authority must arrange the service and manage any memorial choice. ## 12. Changes Material changes will be dated and communicated to affected organisations. A new purpose incompatible with the original purpose will not be introduced without the transparency and lawful basis the law requires.