- Anything you store in your User Account (“Private Submitted Items”) is private by default. Sharing of Private Submitted Items will always be opt-in. In other words, your Private Submitted Items will always be private unless you specifically choose to share them with someone. We will never make this choice for you.
- Clarity and transparency are the guiding principles for how we design our privacy controls. You will always be able to see who has access to your Private Submitted Items and who does not.
Information We Collect
We collect personal and non-personal information when you provide it to us in the course of using the Site or the Services. The personal information that we may collect includes your name, gender, location, and email address. When you register to use the Site or our Service or otherwise make a purchase from us using our Site or Services we will collect your name, gender, location, email address, mailing address (if necessary) and other information that we request during the registration and/or purchase process.
In addition, if you communicate with us regarding the Site or any of our Services or products, we will collect any information that you provide to us during the course of our communication.
This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Application.
For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate. For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
This Application uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session. In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers – in the linked privacy policies of the respective third-party providers or by contacting the Owner.
Activities strictly necessary for the operation of this Application and delivery of the Service
This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Our Disclosure of Personal Information to Third Parties
We will disclose your personal information to protect or enforce our legal rights and policies, to protect or enforce the legal rights of a third party, or as we in good faith believe we are required to do so by law (such as to comply with a subpoena or court order, for example).
We may contract with various third parties who help us provide, maintain and improve the Site and the Services and the products we sell and such third parties may have access to your personal information in order to perform their services. For example, we may use a third party to host the Site and the Services and provide managed services in connection with the use of the Site and the Services and we may subcontract out production, fulfillment, analytics, reporting or other operations. We may contract with third party contractors to help us manage, monitor and optimize the Site and the Services and products we sell. We may also use third party contractors to help us measure the effectiveness of our advertising, and communications. We will enter into confidentiality and non-disclosure agreements with all third parties that have access to your personal information, which will prohibit them from using or disclosing your personal information except for the purpose of providing the Site and the Services. We intend to take commercially reasonable steps to enforce such non-disclosure and confidentiality agreements if and when we become aware of any violations.
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.
Our Disclosure of Non-Personal Information to Third Parties
We may disclose non-personal Information, in de-identified, aggregate form, to potential strategic partners, advertisers, investors, customers, and others. You may not opt-out of the sharing of this information.
A web beacon is an often-transparent graphic image, usually no larger than a 1×1 pixel that is placed on a web page or in an e-mail that is used to monitor the behavior of the user visiting the Site or receiving the e-mail.
Cookies and web beacons used by us will not be linked to your personal information.
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; phone number; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which the Owner is subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Heat mapping and session recording, Managing contacts and sending messages, Hosting and backend infrastructure, Interaction with external social networks and platforms and Managing support and contact requests.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
The Site and the Services and products we sell are intended for people planning end of life related matters. Therefore, it is unlikely that children under the age of 18 will use the Site or the Services or products we sell. Accordingly, we will not knowingly collect or use any personal information from any person under the age of 18. In addition, we will delete any information in our database that we know originates from a person under the age of 18.
In the context of an onward transfer of data to a third party, we (or any third party acting as an agent on our behalf) will process personal information we receive under the Privacy Shield. We will remain liable under the Principles if our agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to any damage. For more information about transfer of data to third parties, please refer to the section “Our Disclosure of Personal Information to Third Parties” earlier in this document.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Union and UK individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at email@example.com
We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.
The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.
Under certain conditions, you have the possibility to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. See Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Opting-Out From Receiving Communications From Fulfilledrelationships.com
You may opt-out from having your personal information used for certain purposes. For example, if you use the Site or the Services or purchase a product from us but do not wish to receive any additional marketing material from us, you may indicate your preference on our order form.
If you no longer wish to receive any promotional or other communications from us, you may opt-out by following the instructions included in each email communication or by emailing us at firstname.lastname@example.org. We also offer you an opportunity to opt-out of certain communications through the account management screen. If you need assistance you may contact us at email@example.com.