Resting Reef Limited privacy notice

Purpose of this privacy notice

Resting Reef Limited (“Resting Reef”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.

Resting Reef respects your privacy and is committed to protecting your personal data. This privacy notice informs you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or otherwise correspond or interact with us. This privacy notice also tells you about your privacy rights and how the law protects you. Please read this notice carefully to understand our practices regarding your personal data and how we will treat it.

Changes to the privacy notice and your duty to inform us of changes

This version of the Privacy Notice was last updated on the 2nd of September 2026.

The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Controller and contact details

Resting Reef is a controller under applicable data protection laws, such as the Data Protection Act 2018, the UK GDPR and EU GDPR, and is therefore responsible for the personal data we process about you. If you have any questions about this privacy notice, including any requests to exercise your legal rights in respect of your personal data, please contact us using the details set out below.

Full name of legal entity: Resting Reef Limited

Email address: hello@restingreef.co.uk

Postal address: Resting Reef Limited, Studio B03, Mainyard Studios, Unit B1. Curie House, Wallis Road. London, E9 5LN.

Third-party links

Our website may include links to third-party websites. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Information we collect about you

“Personal data” means any information about an identified or identifiable living individual. It does not include data where the identity has been removed (anonymous data). We may collect and process different kinds of personal data about you, which we have grouped as follows:

• Identity Data includes name, username or similar identifier, title, date of birth and gender.
• Contact Data includes address, billing address, delivery address, email address and telephone numbers.
• Financial Data includes your billing address and limited payment card details, such as the card type and the last four digits. Card payments are taken through Shopify’s checkout; we do not receive or store your full card number or bank account details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Cookies

Our website uses cookies to distinguish you from other users of our website. Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. This helps us to provide you with a good experience when you browse our website and also to improve our website.

Our website uses cookies, beacons, invisible tags, and similar technologies (collectively “cookies”) to collect information about your browsing activities and to distinguish you from other users of our website. This aids your experience when you browse our website and allows us to improve the functionality of our website.

We use strictly necessary cookies, which are necessary to make our Website available to you; for example, to display the website and for user authentication and security. We cannot provide you with the website without these types of cookies. We also use cookies for functional purposes in order to maintain and improve your experience of our website.

We also use cookies for analytics, which help collect data that allows us to understand how users interact with our website. Specifically, we use Google Analytics, which uses a set of cookies to collect information and report site usage statistics without personally identifying individual visitors to the website. The main cookie used by Google Analytics is ‘_ga’, which enables us to distinguish one user from another and lasts for 2 years. We use these cookies to help us to improve our content and your experience.

Where you consent, our Google Analytics may also use a feature called Google Signals. Google Signals associates the analytics information we collect with Google account data from visitors who are signed in to Google and who have turned on ads personalisation. This allows us to see aggregated demographic information, such as age and gender bands, and to understand how visitors use our website across different devices. This particular processing relies on your consent, which you can give or withdraw at any time through the cookie banner on our website. If you do not consent, Google Analytics runs in a limited mode that does not use Google Signals and does not collect this demographic information. Any Google Signals data we see is aggregated and subject to Google's minimum-size thresholds, which are designed to prevent any individual from being identified.

We also use HubSpot. HubSpot, Inc. provides our customer relationship management, enquiry handling, live chat and meeting-scheduling tools. HubSpot sets cookies on our website — including __hstc, __hssc, __hssrc and hubspotutk — which help us understand how visitors use the site and, if you later contact us, connect that browsing activity to your enquiry. These are non-essential analytics cookies and are set only where you consent through our cookie banner. If you do not consent, HubSpot tracking is suppressed and no browsing history is linked to your record. Our chat widget uses a further cookie (messagesUtk) to maintain your conversation.

Important. Whatever your cookie choice, anything you actively send us — an enquiry form, a message in our chat, a booking — still reaches us and is handled as described in this notice. Your cookie choice affects tracking, not your ability to contact us.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies (including necessary cookies), please note that some parts of this website may become inaccessible or not function properly. When you first visit our website, you will also be shown a cookie banner that lets you accept or reject non-essential cookies (including analytics and Google Signals cookies) before they are set. Strictly necessary cookies do not require your consent and will always be used so the website works. You can change your cookie choices at any time using the cookie settings link on our website.

How is your personal data collected?

We use different methods to collect data from and about you, including:

• Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Purchase our products or services;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website or digital communications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

How we use your personal data

We will only use your personal data when and how the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although, where required by law, we will get your consent before sending direct marketing communications to you via email or text message. In such circumstances, you have the right to withdraw consent to marketing at any time by contacting us. For non-essential cookies used for analytics and advertising, including Google Analytics with Google Signals and HubSpot’s website analytics cookies, we rely on your consent, which we collect through our cookie banner and which you can withdraw at any time.

For further details on the purposes for which we use your personal data and the legal bases (including legitimate interests) that apply in such circumstances, please see Purposes for which we will use your personal data below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications by email or text from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. In other circumstances, we will get your express opt-in consent before sending such marketing to you.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party so that they can market to you. We do not sell your personal data, and we do not share it with anybody for their own marketing.

There is one narrow exception, and it works in the opposite direction. As described under “Meta (Facebook and Instagram) — keeping our adverts away from you”, we share a coded list with Meta for the sole purpose of stopping our own adverts from reaching people who have already contacted us or arranged a memorial with us. That sharing exists to prevent marketing rather than to deliver it.

Opting out

You can ask third parties or us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.

These opt-outs apply to marketing messages we send you. The separate advertising arrangement described under “Meta (Facebook and Instagram)” is not a marketing message and has its own objection route, which is set out in that section.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who might Resting Reef share my personal information with?

Resting Reef may transfer personal data to third parties for the purposes set out above as follows:

• Communication with third parties. As necessary in connection with Resting Reef’s operations, Identity Data and Contact Data may be transferred to existing or potential partners, suppliers, clients, intermediaries, professional advisors, government officials and other third parties.
• Regulators, authorities, and other third parties. Where necessary, personal data may be transferred to courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), insurance providers, payroll agents, pensions and benefits providers, and internal compliance and investigation teams (including external advisers appointed to conduct internal investigations).
• Data processors. Personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal data under appropriate instructions (“Data Processors”). The Data Processors may carry out instructions related to administration, IT system support and maintenance, compliance and other activities or services, automated marketing email services, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed by us. The providers we currently use to process personal data on our behalf include: Vercel Inc. (website hosting), Google LLC (Google Analytics, including Google Signals — website analytics), HubSpot, Inc. (customer relationship management, enquiry handling, live chat, meeting scheduling and marketing email), Shopify Inc. (e-commerce, order and payment processing, including card payments taken through Shopify Payments and Shop Pay), and beehiiv Inc. (newsletter communications, where you have joined our mailing list). This list may change from time to time as we adopt new tools; where it does, we will update this notice accordingly.
• Advertising platforms. We share a limited amount of personal data with Meta Platforms Ireland Limited so that our adverts are not shown to people who have already contacted us or arranged a memorial with us. Meta acts as a joint controller for this purpose rather than as our processor, so it is not covered by the paragraph above. This is described in full under “Meta (Facebook and Instagram) — keeping our adverts away from you” below.
• New owners. Personal data may be shared with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Meta (Facebook and Instagram) — keeping our adverts away from you

We advertise on Instagram. So that our adverts are not shown to people who have already contacted us or arranged a memorial with us, we share a list of email addresses with Meta Platforms Ireland Limited for one purpose only: to remove those people from the audience for our adverts.

Before the list leaves our own computer, each email address is converted into an irreversible code. Meta does not receive your email address in a readable form. Meta compares these codes against codes made from its own users’ details, and uses any match only to exclude that person. We share nothing else — no name, no telephone number, and nothing about what you asked us or what you bought.

For this particular use of your data, Meta acts alongside us as a joint controller rather than simply on our instructions. This means Meta is responsible for its own part in the processing.

Our lawful basis is legitimate interests. Our interest is in not placing advertising about memorial services in front of people who have recently lost someone and have already spoken to us, and in not paying to advertise to people who have already made their arrangements. The effect of this processing is that you see fewer of our adverts, not more.

Meta may transfer this information outside the UK. Meta relies on its own safeguards for those transfers, which are described in its privacy policy.

We rebuild this list before each advertising campaign and remove it from Meta when the campaign ends. You can object at any time by emailing community@restingreef.co.uk and we will take you off the list. Please be aware that this means we would no longer be able to stop our adverts from reaching you.

International transfers

We may transfer personal data outside of the UK and/or European Economic Area, including to countries in respect of which the UK Government or European Commission has not issued an adequacy decision. This means that such countries are not deemed to provide an adequate level of protection for your personal data. If such transfers take place, they will be in accordance with Data Protection Laws, including through the use of standard contractual clauses that have been approved by the UK Government, European Commission or other relevant authorities, or where we are entitled to rely on one of the other safeguards permitted by applicable law (such as obtaining your consent to transfer personal data, where the transfer is necessary for the performance of a contract between us or where a contract was entered into on your behalf, or where the transfer is necessary to establish, exercise or defend legal claims).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Where we share personal data with an organisation that acts as a joint controller rather than on our instructions, that organisation is responsible for the safeguards that apply to its own transfers. The only arrangement of that kind we currently have is described under “Meta (Facebook and Instagram) — keeping our adverts away from you” above.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

How long will you retain my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

The Data Protection Laws give you certain rights in respect of the personal information that we hold about you. Details of these rights are set out below:

• Access. You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data, including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others, though, so this is not an absolute right, and if you want to request more than one copy, we may charge a fee.
• Rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you.
• Erasure. In limited circumstances, you may have the right to ask us to erase personal data concerning you.
• Restriction. You also have the right to ask us to restrict the processing of your personal data in certain circumstances, for example, if you believe that your personal data held by us are inaccurate, if processing of your personal data is unlawful, or if we no longer need your personal data for the purposes for which they were collected, but you require your personal data to establish, exercise or defend legal claims.
• Data Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit that data to another entity.
• Right to Object. Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us, and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and contest the decision.
• Marketing. You have the right at any time to ask us not to process your personal data for direct marketing purposes, including profiling, if it is related to such direct marketing. If you object to the processing for direct marketing purposes, we will no longer process your personal data for such purposes. One point of detail. The sharing described under “Meta (Facebook and Instagram)” exists to keep our adverts away from you rather than to send them. You can ask us to stop it at any time, and we explain in that section what the effect of that request will be.

If you wish to exercise any of the rights set out above, please contact us using the details above. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the UK is the Information Commissioner’s Office (contact details are available at: ico.org.uk/global/contact-us). We would, however, appreciate the opportunity to deal with your concerns before you approach a supervisory authority, and so ask you to please contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.