Privacy Notice
Mortality Manifest Limited

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.mortalitymanifest.co.uk and through the provision of our services.

Mortality Manifest Limited ('MM', 'we', 'us', 'our') is the data controller in respect of website interactions and may act as a processor or sub-processor when delivering services to clients.

Contact Details: Hello@mortalitymanifest.co.uk | Chapel House, St Ives, Cambridgeshire

1A. HOW THIS POLICY APPLIES

This Privacy Policy applies in two distinct contexts:

  • Website Use – where MM acts as Data Controller.
  • Client Services – where MM acts as Processor or Sub-processor on behalf of pension schemes, administrators, or other clients.

In service delivery, the relevant client acts as the Data Controller and determines the lawful basis for processing.

2. WHAT DATA DO WE COLLECT

Personal data means any information capable of identifying an individual. We may process:

  • Communication Data – communications sent to us.
  • Customer Data – identity, contact, and transaction data.
  • User Data – website usage and interaction data.
  • Technical Data – IP address, browser, device and analytics data.
  • Marketing Data – preferences and engagement data.

We process this data under lawful bases including contract, legitimate interests, consent, and legal obligation.

Sensitive Data

In general website interactions, we do not intentionally collect Special Category Personal Data. However, in delivering our Overseas Proof of Life service, Special Category Personal Data may be processed, specifically biometric data for identity verification and fraud prevention.
Biometric data (including facial recognition and liveness detection) is collected and processed by our identity verification sub-processor Veriff.
Mortality Manifest Limited does not store, retain or have direct access to biometric data. All biometric data is processed and stored within Veriff’s secure systems.
Veriff acts as a processor in respect of biometric processing. Further information is available at: https://www.veriff.com/privacy-notice

Processing of such data is strictly limited, necessary and subject to appropriate safeguards.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data directly from you, through website forms, communications, and indirectly via analytics and third-party providers.

4. MARKETING COMMUNICATIONS

We process marketing data based on consent or legitimate interests. You may opt out at any time.
We may send communications where permitted under applicable regulations.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share personal data with:
All third parties are required to respect data security and process data in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not store or process personal data outside of the United Kingdom or European Economic Area.
Where Overseas Proof of Life services are provided, biometric data is processed within Veriff’s infrastructure under appropriate safeguards.
Where individuals reside outside the UK/EEA, communications may be sent from within the UK/EEA without transferring personal data outside these regions.

7. SERVICE PROCESSING

When delivering services, MM acts as a Processor or Sub-processor.

We process data strictly in accordance with client instructions and do not determine the purposes of processing.

8. DATA SECURITY

We implement appropriate technical and organisational measures including encryption, access controls, monitoring, and incident response procedures in accordance with our ISO27001 certification.

9. DATA RETENTION

We retain personal data only for as long as necessary for legal, contractual, and regulatory purposes.

10. YOUR LEGAL RIGHTS

You have rights including access, rectification, erasure, restriction, portability and objection.

11. COMPLAINTS

You have the right to complain to the Information Commissioner's Office (www.ico.org.uk).