Privacy Policy
Effective Date: January 1, 2024
Table of Contents
- Scope and application.
- What is “Personal Information”?
- What categories of Personal Information do we collect?
- How do we collect your Personal Information?
- How do we use your Personal Information?
- When do we share your Personal Information with other organizations?
- What are your privacy choices?
- How do we protect your Personal Information?
- How long do we keep your Personal Information?
- No Use by Children under the Age of 18
- Job Applicants Personal Information
- Cross-Border Transfers of Personal Information
- Accessing and correcting your Personal Information
- Changes to the Privacy Policy
- Contact us
1. Scope and application
Service Corporation International (Canada) ULC and its affiliates and subsidiaries (including regional entities operating under the Dignity Memorial®, DignitéMD, Cremation Direct, First Memorial Funeral Services®, Making Everlasting Memories®, Modest Cremation, Service de cremation Direct and other brands) (“SCI,” “we,” “us”) respect the privacy of our clients’ families and website visitors including job applicants. We value our relationships with existing and prospective clients (“you”), and recognize that an essential element of those relationships is the trust and confidence you place in us to serve you and your family during your time of need.
This Privacy Policy applies to the Personal Information you provide to us or that we obtain on our websites and any mobile applications linking to this Privacy Policy (“Sites”) and to the Personal Information you provide to us or that we obtain from you in person at one of our funeral home or cemetery locations or other locations, by phone, and by mail in Canada.
This Privacy Policy does not apply to Personal Information that you submit to websites belonging to our business partners or any other third parties or to any Personal Information that our business partners or third parties collect from you through the third-party websites, even if those third-party websites are linked to our Sites.
The Sites may contain links to other websites, and other websites may link to the Sites. Please be aware that we are not responsible for the privacy practices of such other websites. Whenever you visit another website – via a link from the Sites or otherwise – you should review the privacy policy of that other website. This Privacy Policy applies solely to information provided or obtained on our Sites.
2. What is “Personal Information”?
"Personal Information" means information that identifies, relates to, is reasonably capable of being associated with, or describes, directly or indirectly, a particular individual, such as: name, address, email address, or telephone number, among others. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be Personal Information, if it is, at all times, reasonably foreseeable in the circumstances that this information irreversibly no longer allows the individual to be identified directly or indirectly.
3. What categories of Personal Information do we collect?
We limit the collection of Personal Information to what is reasonably required to fulfill the purposes for which it was collected.
Depending on your interaction with us, we may collect personal identifiers, message content, audio and visual information, financial information, commercial transaction information, geo-location information, health information, other information including sensitive information and Internet or other electronic network activity information. We collect Personal Information in a variety of ways detailed below under How do we collect your Personal Information.
- Personal identifiers, such as your name, address, phone number, email address, billing address, shipping address, date of birth, insurance policy number, signature, client number and social insurance number in certain instances.
- Message content, such as the messages you submit to us through contact, sign-up, and purchase forms on the Sites, customer service requests, messages you would like us to provide to delivery recipients, and delivery instructions;
- Audio and visual information, such as any digital photographs and audio files you submit through the Sites, or at the locations where we employ surveillance cameras in public areas.
- Financial information, such as payment card and bank account information, credit-related information (credit scores), life insurance policy information and other financial information (such as payment history) when we assist with financing your pre-need or at-need contract or when you apply for insurance or other financing.
- Commercial transaction information, such as records of merchandise and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies when you make purchases on the Sites;
- Geo-location information, such as the location of the device you are using to access our Sites;
- Health Information, such as health condition and medical history of the insured individual;
- Other information including sensitive information, such as ethnicity and religion;
- Internet or other electronic network activity information (i.e. technical information when you visit our Sites), such as cookies and similar technology to automatically record personal identifiers (such as your IP address and device identifiers), information about your device (such as your browser type, locale preferences, and mobile carrier) and information concerning your usage activity on the Sites (such as your interaction with our Sites, the link you used to reach our Sites, and content displayed on our Sites and on other websites and online services). To learn more about how we collect and use this type of information, see How do we use your Personal Information? below.
4. How do we collect your Personal Information?
We collect Personal Information in a variety of ways, including directly from you, from a parent, through technologies used at our locations, from business partners and through our Sites.
a. Directly from you
We may collect your Personal Information directly from you, such as when:
- you visit one of our funeral home or cemetery locations;
- you participate at an informational pre-planning seminar;
- you visit one of our Sites, mail us or call us.
b. From a parent
If you are the next of kin of record of an at-need or pre-need contract beneficiary, we may collect your information so that we can contact you in order to obtain your authorization (pursuant to provincial law or company policy) to provide services with regard to your family member or relation and for other point of contact purposes.
c. Through Technologies Used at Our Locations
We may collect personal information through video cameras used at our locations, including your image. We use surveillance cameras in our locations for security purposes.
d. From Business Partners
We may receive some of the personal identifiers, message content, and commercial transaction information listed above from third-party business partners (such as floral, memorial, or insurance providers) related to your transactions with them that involve us providing you with merchandise or services. The Sites may also permit you to log-in and connect to the Sites with your social media account (such as Facebook), and we collect profile information about you from that social media website that you have made publicly available. We use this profile information for the purposes described hereunder. We may also collect financial information from credit reporting or collection agencies.
e. Through our Sites
We or our service providers, that help us maintain and operate our Sites, may also automatically collect the following information relating to your access to and use of our Sites through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; your type of computer or mobile device; pages you view; links you click; your IP address; the length of time you visit or use the service, and how you use the service.
We may use various technological methods to track the patterns of users accessing and using our Sites including the following methods:
Cookies: Cookies are small pieces of information that are stored in your browser on your computer or mobile device. We use cookies to enhance your experience on our Sites. Users may have the opportunity to set their computers or devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. If you set your browser not to accept cookies, you may not be able to take advantage of the full features of our Sites. To find out more about cookies, including how to manage or delete them, visit www.allaboutcookies.org.
Web Beacons: Web beacons are small pieces of data that are embedded in images on websites pages. We may use these technical methods to analyze the traffic patterns on our Sites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to determine whether you have opened those e-mails or clicked on links in e-mails. The information from the use of these technical methods may be collected in a form that is anonymized.
- Advertising and Analytics Technologies
We use third-party advertising services to serve advertisements on our behalf when you visit some of our Sites and other websites, third-party email services to send informational and marketing email to you, and third-party analytics services to help us understand and improve the usage of our Sites and the effectiveness of our marketing efforts (such as Google Analytics). In some situations, we permit the companies providing these services to set and access cookies (and use similar data tools, such “web beacons”) through our Sites and our emails, and these companies may collect, for example, your personal identifiers (such as IP address, device and browser identifiers and characteristics, and anonymous identifiers) and information about your device (such as operating system and language preferences) and your usage activity on the Sites (such as your interaction with our Sites, the link you used to reach them, and the content and advertising displayed on them and our content and advertising on other websites and online services) and use this information to provide advertisements about goods and services of interest to you on our Sites and other non-affiliated websites and/or to provide analytical information for our Sites. Third-party companies also may collect and combine information about your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same companies.
5. How do we use your Personal Information?
We may use this information for typical business purposes (including auditing our interactions with our clients or website visitors, for internal reporting purposes, or security and anti-fraud purposes) or otherwise, with your consent or as permitted or required by law:
a. General business purposes
We may use your Personal Information for general business purposes such as providing or delivering a product or service requested from us, managing our business and Sites, preventing or reducing commercial risk, as well as for purposes relating to information, physical security (including access control), and system or network security.
More specifically, we may use your Personal Information for the following general business purposes:
- To create, administer and maintain new member accounts at your request.
- To provide you with the products and services you request from us pursuant to the terms of an advance (pre-need) or time-of-death (at-need) funeral or cemetery contract.
- To provide you with information about our products and services that you request from us.
- To post information to public areas of the Sites at your direction.
- To process payments for our merchandise and services you purchase on the Sites.
- For internal reporting.
- To create records of your consuming history for audit purposes and in order to fulfill the terms of pre-need and at-need funeral and cemetery contracts you enter into with us, and as required pursuant to provincial funeral and cemetery laws regarding cemetery property and products purchased, and insurance and trust-funding laws.
- To de-identify or create aggregated information.
- To help facilitate a purchase and use of insurance coverage.
- To enable certain features of our Sites.
- To preserve your preferences and customize your experience when you visit and return to the Sites.
- To comply with legal, and regulatory obligations.
- For the protection of our commercial interests, to collect debts and assert our legal rights and interests.
b. Research and development purpose
We may use Personal Information to understand and assess your interests and changing needs with a view to improving our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our websites. For instance, we may use third-party web analytics services, such as Google Analytics, to help us analyze how visitors use our websites. When required by law, we will use anonymized information for these purposes.
c. Marketing purposes
We may use your Personal Information to provide you with personalized content and services, such as tailoring our products and services, our digital customer experience and offerings. More specifically, we may use your Personal Information to create a profile about your preferences to offer you products and services in which we think you might be interested (inferences drawn from Personal Information).
We may also use your Personal Information to communicate with you in a variety of ways (for example, by email, telephone, direct mail) about our products, services, special offers, promotions, contests or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see What are your privacy choices?
6. When do we share your Personal Information with other organizations?
We may share your Personal Information with our business partners, affiliates, and third parties with your consent or not, when it is required for providing products and services to you, including to process transactions, deliver products at your request, or to help us market products and services to you.
In certain circumstances, we may share Personal Information without your consent, when authorized by law, such as:
- In situations involving threat to the safety of individuals.
- To comply with a warrant or other order from a court or a governing regulatory authority.
- To collect money owed.
- To investigate the breach of an agreement or applicable law (for example, investigating potential theft).
- To provide requested information to a person conducting an audit, reviewing an application for accreditation or reviewing accreditation.
- To detect, suppress or prevent fraud.
- When required in the context of a prospective or completed business transaction, such as a transfer of assets or shares or merger, in accordance with applicable legal requirements. For example, we may make your Personal Information available to advisors or (potential) buyers of our business if necessary for concluding the transaction and continuing operating the business.
Personal Information you may share
The Sites may provide options allowing you to share information with social networking websites, such as Facebook. Their use of the information you share will be governed by their privacy policies, and we are not responsible for how they treat the information.
7. What are your privacy choices?
By using our services and/or submitting information to us in connection with using our products and services, you are providing your consent to the collection, use and disclosure of Personal Information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information. We will generally obtain consent when we want to use Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific service you signed up for or have agreed to participate in, in compliance with applicable privacy laws.
You have choices about the way we handle your Personal Information.
a. Changing your communication preferences
You can always choose not to receive marketing or promotional messages from us by email by clicking on “unsubscribe” in any email you receive.
Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you a service message, important product information). In addition, it may take up to ten (10) business days to register a change of preference across all our records.
b. Changing your browser settings on your device
We use technology to enhance your experience and present you with offers, including personalised advertising. Through technologies such as cookies, our websites recognize you when you use or return to them and can provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our websites.
Please refer to your browser instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device.
c. Specific Opt-Out
You may opt out of Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on for your web browser, click here.
You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and business partners that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative (“NAI”). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/. To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please remember that when you opt out of personalized advertising, you may continue to see online advertising on the Sites and/or our ads on other websites and online services.
d. Public Disclosure Using Non-Restricted Services.
Our Sites make online and voice-recorded Guest Books, Death Notices, Obituaries, Biographies, Photo Galleries, Moving Memories®, other online memorials, location of funeral, cemetery services, and gravesites, and other postings to our public services available for viewing by all our visitors unless the sponsor or host of a service selects a privacy setting that restricts public access (available as an option only on certain services). When you post any information or other content to the public areas of the Sites, such information is viewable by the public. This public information may be collected and used by others without your or our knowledge, and the security and other protective provisions of this Privacy Policy do not apply. Also, please keep in mind that publicly posting your user ID or contact information may result in the transmission of unsolicited messages to you from persons and entities over which we have no control. Please exercise caution and good judgment when disclosing any Personal Information to any public services. Note that we cannot be responsible for any online postings by a family member, friend, acquaintance or other person or entity outside of our control. Such activities and the associated postings are also outside the scope of this Privacy Policy.
e. Restricting collection, use and disclosure of your Personal Information
You may withdraw your consent to the collection, use and disclosure of Personal Information in accordance with this Privacy Policy at any time upon reasonable notice to us in writing, subject to legal or contractual restrictions.
The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your Personal Information is a necessary part of making the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing consent.
8. How do we protect your Personal Information?
We take appropriate measures and controls aimed at safeguarding your Personal Information. These measures include restricting physical access to our offices and records, restricting access to your Personal Information to only those employees or agents who require access to fulfill their responsibilities, restricting unauthorized access, disclosure, use and misuse of your Personal Information in our custody and control, having archival documents stored with reliable third parties offsite at secure premises, using firewalls, passwords and file encryption for online activities.
Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of Personal Information in our possession. We also use these safeguards when we dispose of or destroy your Personal Information.
a. Data Governance and Security Measures
We maintain policies and practices which ensure the protection of your Personal Information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your Personal Information, including:
• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
- Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
- If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures;
- A designated Privacy Officer to monitor our compliance with applicable data protection laws;
- Employee privacy and data security training;
- Procedures for receiving, investigating and responding to complaints or inquiries regarding our information handling practices, including any security incidents involving Personal Information;
- Framework governing the retention and destruction of Personal Information, as more fully described below in the “How long do we keep your Personal Information?” section of this Privacy Policy;
- Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate privacy protections and standards. For example, we generally require our service providers to limit their use and retention of Personal Information to what is necessary to provide their services and to notify us in case of any actual or suspected security incident. We also try to monitor and audit their compliance with these requirements in various ways (e.g. on-site inspections (if feasible), surveys and interviews, proof of certification).
9. How long do we keep your Personal Information?
We keep your Personal Information only as long as it is reasonably needed or relevant for the identified purposes, or as permitted or required by law. We may keep certain Personal Information for an extended period of time even when you are no longer our customer (for example, for required tax and financial record keeping, security, fraud prevention, and to manage business operations). Once no longer required, your Personal Information will be securely destroyed or anonymized, in compliance with applicable laws.
10. No Use by Children under the Age of 18
The Sites are not intended for use by children under the age of 18. If you are under the age of 18, you may not use our Sites. If a parent or legal guardian posts an entry on behalf of a child under the age of 18 on an online guestbook or other section of the Sites, the parent or legal guardian must indicate that such entry is being made on behalf of the child by the parent or legal guardian. Caution and good judgment should be used in connection with any information provided concerning the child. We do not knowingly collect, maintain, or use Personal Information from children under 18 years of age. If we believe that any information has been posted by a child under the age of 18, we will promptly delete that information. Parents may contact us using the methods set forth below to request that information concerning their child be removed from our Sites.
11. Job Applicants Personal Information
Job applicants and candidates (collectively, Applicants) may provide Personal Information through our job application process and our Careers website at https://jobs.sci-corp.com/. Personal Information collected on Applicants is collected, used and disclosed for specific purposes below, with your consent or as permitted or required by law. We may also collect Personal Information about you, from third parties such as former and present employers.
These purposes include: to verify your identity, stated credentials, and references; to contact references and conduct background checks; to review your qualifications and credentials; to conduct virtual or in person interviews; and to determine if you might fit a job need of ours and to contact you to see if you might be interested in a job for which you did not apply.
We may also use and disclose your Personal Information: to comply with applicable law including provincial, federal labor, employment, equal employment opportunity, and related laws; to support our recruitment and diversity, equity, and inclusion programs and initiatives; to reimburse you if you travel for a job interview and seek reimbursement; to perform necessary and appropriate internal functions, such as developing or improving our website and services; to help maintain the safety, security, and integrity of our technology assets and business; and to investigate security breaches and misuse of our systems, and to detect and prevent fraud against you and/or us.
Job applicant personal information may be transferred, processed and stored outside Quebec or Canada, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
12. Cross-Border Transfers of Personal Information
Your Personal Information may be transferred, stored, accessed, or used in a jurisdiction outside your jurisdiction of residence (for example, outside your province or outside Canada) in connection with our use of third-party service providers engaged by us. We engage these third-party service providers to assist us in providing our services to you; for example, in order to process payment, fulfill product orders, or manage our communications with you.
We use commercially reasonable efforts to ensure that all of our third-party service providers take reasonable security measures to protect your Personal Information (this includes technical, administrative, and physical safeguards to protect your Personal Information). We use commercially reasonable efforts to ensure our service providers only use your Personal Information for authorized purposes we have made known to you or which are otherwise permitted by applicable law.
Where Personal Information is located outside of your province or outside Canada, it is subject to the laws of that jurisdiction which may differ from those in your jurisdiction and any Personal Information transferred to another jurisdiction will be subject to law enforcement, regulatory, and national security authorities in that jurisdiction. Subject to these laws, we will to the best of our abilities use contractual measures to maintain protections that are at least equivalent to those that apply in Canada.
13. Accessing and correcting your Personal Information
You may be entitled to access your Personal Information and request the rectification information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws.
To access and correct your Personal Information, please contact us in writing using the relevant contact information listed in the Contact Us section below.
14. Changes to the Privacy Policy
We may make changes to this Privacy Policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our Sites. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to use our services or purchase our products after the modified version of the Privacy Policy has been posted or you have been informed of such update, you are accepting the changes to the Privacy Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated.
15. Contact us
If you have any questions or complaints about how we handle your Personal Information, please contact us as indicated below:
Zachary Fletcher
Privacy Officer
Service Corporation International
Data Privacy Office, 10th Floor
1929 Allen Parkway
Houston, Texas 77019
[email protected]
If you are a Canada resident, you may submit an online request form to exercise your rights regarding the protection of your Personal Information here.