This Privacy Policy describes how ForeverLoved (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or become a subscriber of ForeverLoved (the "Site") or otherwise communicate with us (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect and have collected personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly From You

Information that you directly submit to us through our Services may include:

• Basic contact details including your name, address, phone number, email. When you sign up for the Subscription, we ask for your name, gender and email address, as well as birth year and country. The birth year is collected to ensure that you comply with the Terms and Conditions with regards to underage and minor users.
  
  

• Account information: including your username, password, security questions.
  
  

• Payment Information: Credit/debit card details, bank account information, and transaction history. If you purchase a subscription, we will need to know your postal address, phone number and payment details to facilitate payment and fulfilment.

• Transaction Information: Details of transactions processed through our services.
  
  

• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
  
  

• Identification Information: Government issued Identification Documents, date of birth.
  
  

• Information on Your Family and Others: You may also enter additional personal information about yourself and others in the course of building your memorial and family tree on the Site, for example names, relationships, dates and places of birth and death, contact information such as email address, and photos.
  
  

If you choose to invite a family member or another person to view or edit your family tree, we will ask you for the individual's email address and name. You must first make certain that you have obtained their consent to pass on their details to us before you invite them.

When building a memorial or family tree, you decide which relatives to add to the memorial or family tree, whether to add deceased relatives, living relatives or both, and which information to include about them. Adding living relatives to the memorial or family tree requires you to obtain their prior consent. Before adding living relatives below legal age to the memorial or family tree, you must obtain the consent of their parent or guardian.

If you choose to add an audio recording to a photo or a profile in your memorial or family tree, such recordings will be stored and made available for listening only to you and to members in your memorial or family site. You can delete them at any time.

• Your Communications: Your communications with other users through the site’s features, as well as information you provide us in communications with our customer support team, other representatives and/or information you provide while interacting with us, will be collected and recorded by us.
  
  

Information We Collect Through Cookies

We also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, operating system, device identifiers, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain From Third Parties

Finally, we may obtain information about you from third parties, including from service providers who may collect information on our behalf, such as:

• Companies who support our Site and Services, such as Credence (https://credence.com.mt/), Quaife (https://www.quaife.co.uk/ ), banking institutions and others.
  
  

• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfil your orders and provide you with services you have requested, in order to perform our contract with you.
  
  

• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
  
  

• You may link an account from Google/Facebook/Apple or other to your account on our Site, for authentication. This will allow you to use your credentials from the other service to create a ForeverLoved account or to sign in to ForeverLoved, without having to enter details manually such as your email address. If you choose to do so, we will collect and use the information you authorized to share with us via that service, (for example, the email address for a connected Google/Facebook or Apple account), in accordance with this Privacy Policy.
  
  

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links.

Why We Use Your Personal Information

We use your personal information for the following purposes, and our lawful bases for processing your personal data are outlined below in accordance with Article 6 of the General Data Protection Regulation (GDPR):

• Providing Services: We use your personal information to provide you with the Services in order to perform our contract with you and to fulfil the purpose(s) for which you have provided the personal information to us, including but not limited to process and manage transactions with you.
  
  

• Security and Fraud Prevention: We use your personal information to verify your identity and to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. Please refer to the ‘Registration’ section of the Terms and Conditions.
  
  

• Communicating with you: We use your personal information to provide you with support in relation to your account and all your transactions, to improve our Services, to seek feedback from you about the Service and to inform you of any updates or additions to the Service. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.
  
  

• Marketing and Advertising: We use your personal information for marketing and promotional purposes, such as sending marketing, advertising and promotional communications by email, telephone or postal mail, and to show you advertisements for services. If you do not want to receive or continue receiving marketing offers via email, please refer to the ‘Marketing of our Services’ section of the Terms and Conditions.
  
  

• To improve our services and enhance user experience: In order to improve the Service and to develop new products and services, we may use your personal information for internal data analysis, for studying how the Website is used, to help us diagnose problems and secure the Service, identifying usage trends and determining the effectiveness of promotional campaigns. For example, we may examine how much time visitors spend on each page of the Website and how they navigate through the Website and use this information to improve the Website.
  
  

• To comply with legal obligations and regulatory compliance.
  
  

Cookies

Like many websites, we use Cookies on our Site. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• Service Providers: With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, IT support, software developers or cloud storage).
  
  

We use several reputable third parties to perform various tasks for us, under the protection of appropriate agreements (such as Quaife, Nuvei and Paypal to process payments for you and Amazon, Google Cloud for cloud storage services).

• Legal Obligations: To comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
  
  

• For Business Transactions: We may need to disclose information in connection with a business transaction such as, in case of a merger or in case of bankruptcy.
  
  

• International Transfers: When you provide us with any personal information, that personal information may be transferred to and stored by us in our secure data centers which may provide a different level of protection for personal information than in your country of residence. By providing us with personal information, you should be aware that it will be transferred, processed and stored in our data centers. ForeverLoved takes appropriate steps to ensure that transfers of personal information are done in accordance with applicable law and carefully managed to protect your privacy rights and interests. Accordingly, transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative safeguards are in place to protect your privacy rights. In particular, we rely on the EU Commission standard contractual clauses. You have a right to contact us for more information about the safeguards we have put in place.
  
  

All third parties will be required to adhere to strict data protection standards through contractual agreements.

We will, disclose the following categories of personal information about our users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:

Category – Third Party – Purpose

• Payment and Transactional Information – Stripe – Payment Services Provision

• Payment and Transactional Information – Quaife – Subscription Payment Services Provision

• Payment and Transactional Information – GivenGain – Donation Payment Processing

• Personal Information – Google/Facebook/Apple – Data Storage Services

• Usage Data – Superset – To analyze usage patterns on the Site to improve user experience.

• Transaction Information – PayPal – Payment Services Provision

• Personal Information – Amazon, Google Cloud – For cloud storage and backup services.

• Personal Information – HubSpot – Customer Relationship Management (CRM) services
  
  

User Generated Content

The Services enable you to upload data and information and other user-generated content on a memorial site. If you choose to submit such user generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

Children’s Data

Our site is not directed or targeted to children under the age of 13, and ForeverLoved does not knowingly collect personally identifiable information from children under the Minimum Age (for more information, see section "Underage Users" in our Terms and Conditions).

If ForeverLoved learns that a child under the Minimum Age has provided personally identifiable information to the Site, we will use reasonable efforts to remove such information from our files.

If you provide information about a child, you, as parent or legal guardian, consent to the processing and use of such information by us in accordance with this Privacy Policy.

Parental Verification Process

If you are between the ages of 13 and 18, you must obtain Parental Consent to use the Service. As outlined in our Terms and Conditions, when registering or logging in, a parent or guardian will be required to provide their details, confirm their relationship with the minor, and accept the Terms and Conditions and Privacy Policy. A verification email will be sent to the parent or guardian, and consent will only be valid once they click the verification link.

To enhance the verification process, we may also implement additional steps to authenticate the identity of the parent or guardian. All details provided during this process, including the parent or guardian’s name, surname, email address, identification documents and date of consent, will be securely stored in compliance with applicable data protection laws.

For further information on the parental consent process and data protection measures, please refer to the Minors section in our Terms and Conditions.

Data Security

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

ForeverLoved implements appropriate technical and organisational measures to protect personal data against unauthorized access, loss, destruction, or alteration.

These measures include:

• Encryption of sensitive data

• Secure access controls

• Regular security assessments and audits

• Staff training on data protection practices
  
  

Retention of Your Information

Personal data will be retained only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws and legal obligations. This means that we store your personal information for as long as it is required to deliver our services, except where we have a lawful basis for saving it for an extended period of time (for instance, after your subscription expires, we may still have a legitimate interest in using your contact details for marketing our service to you). We also retain the personal information we need for the execution of pending tasks and to realise our legal rights and our claims, as well as retain certain personal information that we must store for a legally mandatory period of time (in that latter case, the processing of such information by us is limited).

In some cases, where you or we delete your content, copies of that information may remain viewable elsewhere to the extent any such copy has been shared with others, was otherwise distributed pursuant to your privacy settings, or was copied or stored by other users. For example, a part of your family tree may have been copied by other users into their own family tree. Removed and deleted information may persist in backup copies for a limited time for our internal business purposes, but it will not be available to you or other users.

Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information. This right can normally be exercised free of charge. However, we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
  
  

• Right to Delete: You may have a right to request that we delete personal information we maintain about you.
  
  

• Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
  
  

• Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
  
  

• Right to Limit and/or Opt out of Use and Disclosure of Sensitive Personal Information: You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.
  
  

• Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
  
  

• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
  
  

• Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
  
  

• Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
  
  

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

Data Breach Notification

In the event of a data breach, ForeverLoved will promptly assess the situation and take necessary actions to mitigate the breach.

ForeverLoved will comply with applicable laws in the event of any breach of the security, confidentiality, or integrity of your personal information and, where we consider appropriate or where required by applicable law, notify you via email, in the most expedient time possible and without unreasonable delay, insofar as it is consistent with any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

International Users

Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at privacy@foreverloved.com.

For the purpose of applicable data protection laws, we are the data controller of your personal information.