PRIVACY POLICY

Last Modified: November 1, 2024

IMPORTANT
This Privacy Policy governs your access to and use of all websites and digital applications (collectively, the “Sites” or “Service”) that link to or reference this Privacy Policy. By accessing or using the Sites, you signify that you have read, understood, and agree to be bound by our Terms of Service and to the collection and use of your information by Foveo Memorial Services Inc. (“Foveo”) or a Foveo subsidiary or affiliated entity (collectively, “Company”), as set forth in this Privacy Policy, whether or not you are a registered user of our Service. The Company offers the Sites, including all information, tools and services available from the Sites, to you, the user, conditioned upon your acceptance of all terms, conditions, policies, and notices stated here. If you are unwilling or unable to be bound by this Privacy Policy and the Terms of Service, do NOT access or use the Sites.

Throughout this Privacy Policy and the Sites, the terms “we,” “us” and “our” refer to the Company. The terms “User,” “you” and “your” refer to the User of the Sites and Service. The term “Content” refers to text, images, photos, audio, video, or other digital assets. The terms “Registration,” “Registered”, or “Account” refer to User accounts created by a User or by the Company for the purpose of accessing the Sites, the Content, or the Services, which may require a User to provide us with information.

Our Commitment

We are committed to operating the Company and Services in accordance with the privacy and personal information protection principles, standards, and guarantees contained in the General Data Protection Regulation (GDPR), Canada’s Anti-Spam Legislation (CASL), and in comparable pieces of state legislation across the United States of America.

Why We Collect Information

Through the Sites, you can engage in various activities related to the live stream broadcast or recording of funeral services being provided for a bereaved family or individual. In so doing, you will provide certain information to us.

We collect personal information to ensure that we are able to provide the Services to you and our clients in a personal, professional, and meaningful way and to enable our clients to offer, provide, and demonstrate modern, high-quality, family- and guest-oriented funeral care services, information, advice, and related resources.

When you register to attend a funeral ceremony via live stream on the Sites, we will request that you enter your name, email address, and information about the number of people who will be attending online with you. This information, for example, is collected for the benefit of the bereaved family. It is made available, by secure access, to a designated family member or an authorized representative (the “Family Account Admin”) and the company providing the funeral services, so that they can be aware of your online participation. This information is not available to other guests.

The Information We Collect

We collect information that identifies, relates to, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). Content you provide when using the Sites may be utilized on the Sites by the Company. If you provide information or Content to us about other people, you represent that you have permission from those people to do so.

When you use the Sites, we may also use a variety of technologies to collect certain information. Although this information does not specifically identify you, it can be used to assign a unique number to you. It can then be used to connect your use of the Sites to other information about you, including your Personal Information.

We also may collect the following information: your session history; your usage patterns (traffic data, location, data, server logs, and other communication data); information about your online activities on the Sites and third-party sites, including the Sites you visited before and after visiting the Sites; information about your computer such as device type, screen size, browser type, operating system, memory, language and other settings, plug-ins, TCP configuration, carrier code, and information regarding software on your device; your internet connection information, such as IP address, which can be used to identify your geographic area; your interactions with email messages we send you (such as whether you opened an email and, if so, when, whether you forwarded the email, and the device you used to open the email); search terms you use on the Sites and any site that referred you to the Sites; and unique identifiers, such as mobile device identification numbers. We may collect this information through the cookies and other tracking technologies described below.

How We Collect Information

Data and/or Personal Information that we collect from Users who register or attend a funeral ceremony (or similar event) via live stream or sign in to the Sites to arrange a live stream are categorized as identifiers (i.e., a real name, email address, Internet Protocol address, and other potentially personally identifiable information). We collect it in the following ways:

  • Directly from you or your agent (User-provided information)
  • Indirectly from you or your agent (Information collected in the course of providing the Services)
  • Directly and indirectly from User activity on the Sites (Information collected through User submissions or website usage, collected automatically)

Beyond the direct or indirect collection of identifiers noted above, when you use the Sites, we may use a variety of technologies to collect certain information. Although this information does not specifically identify you, it can be used to assign a unique number to you. It can then be used to connect your use of the Sites to other information about you, including your Personal Information.

We and our service providers may use “cookies” to customize your experience on the Sites. “Cookies” are small computer files that are transferred to your computer’s hard drive and contain information such as your preferences and the pages you have visited and the activities you have performed while using the Sites. You may block cookies in your browser and/or delete cookies from your hard drive. By disabling cookies, however, you may not be able to access all of the features of the Sites.

We and our service providers may use small pieces of code on the Sites called “web beacons,” also known as “pixel tags” or “clear gifs.” Web beacons collect anonymous and aggregate advertising data. Web beacons recognize certain types of information such as a user’s cookie number, date and time of page view, and description of the page where the web beacon is placed. You may block web beacons by blocking cookies in your browser and/or deleting cookies from your hard drive.

Data Storage and Security

We have implemented security procedures to help protect the Personal Information on the Sites. The Company uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information and implement your privacy settings. However, no method of transmitting or storing electronic data is ever completely secure, and we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this Privacy Policy. You acknowledge that you utilize the Sites, and provide your personal information at your own risk.

We recommend that you use complex passwords for any accounts you have with us, and, if you believe your interaction with us is no longer secure, please notify us by email at [email protected].

How We Use Information

We may use information that we collect about you or that you provide to us, including Personal Information, in the following ways:

  • To provide the services you request, including registration confirmation, event reminders, and access to the live stream broadcast and recording after the event has concluded.
  • To allow you to use interactive features on the Sites, to the extent such features are available;
  • To inform a breaved family of your registration and your intent to attend a funeral ceremony via live stream or access the recording afterwards.
  • To contact you in relation to delivering the Services.
  • To provide you with information and services you request from us or our clients;
  • To contact you about our own and other parties’ services or goods in which you may be interested;
  • To manage and improve the Sites, including performing analytics on the Sites;
  • To notify you about changes to the Sites and about your access or registration;
  • To enforce the legal terms that govern your use of the Sites;
  • To better understand those who use the Sites;
  • To deliver targeted information or advertising and understand how you interact with and use the advertisements and content on the Sites;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information the Company holds is among the assets transferred; and
  • In other ways we describe when you provide the information.

We may disclose your information if we are required to do so by law, for example in response to a court order or subpoena, or in response to a legal agency’s request. We may also disclose your information to protect against misuse or unauthorized use of the Sites or to protect the personal safety of our users or the public.

We may share your information with service providers providing services to the Company, such as email and text message distribution, data processing, mobile and website analytics, website hosting, advertising services, and list management.

We may sell, divest, transfer, assign, or otherwise engage in a transaction that involves some or all of our assets in the course of a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any similar transaction or proceeding. Your information may be transferred in the context of such a transaction.

We may share, sell, or rent your information in aggregate or on an individual basis to Company affiliates and other parties with which the Company has a business relationship as long as such sharing, selling, or rental is permitted by applicable law.

Opt-Out Choices

If you want to opt out from a Company communications list or commercial email list, please use the unsubscribe link at the bottom of each message or send us an email at [email protected] with the email address at which you no longer wish to receive Company communications or commercial emails.

If you wish to disable web beacons in our email messages, turn images “off” in your email system (e.g., Outlook or Outlook Express). You can check the settings or options menu in your email system for more information.

If you requested third-party email through our Sites and no longer wish to receive the email, please follow that party’s unsubscribe link or opt-out instructions which should be included in the commercial message you received.

Sharing Information with Third-Parties

We may integrate with third-party services, like Tukios.com, that enable Foveo to live stream and broadcast directly to other webpages or websites, including funeral home websites, obituary pages, and similar pages or sites.

When you view a live stream broadcast or recording on a third-party platform or website, you are sharing information with those parties and services, not with the Sites. This Privacy Policy does not apply to third-party websites. Our Privacy Policy also does not cover the use of cookies by third parties. The terms of those sites will apply. We recommend that you learn about the privacy policy and security practices of any such third-party websites before using their sites or services.

Data Deletion Requests

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Data Access and Portability

You have the right to request that we disclose certain information about our collection and use of your Personal Information during the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you;
  • The specific items of Personal Information we collected about you;
  • The categories of sources of Personal Information we collected about you;
  • Our business purpose for collecting or selling that Personal Information;
  • The categories of third parties with which we may share Personal Information; and
  • If we sold or disclosed your Personal Information for a business purpose, we will provide a list of the sales with the categories of Personal Information that the recipients purchased and, for disclosures, we will provide a list of the sales with the categories of Personal Information that the recipients received.

You may make a verifiable consumer request for access or data portability only twice within a 12-month period. A verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will use Personal Information provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.

Timing

We endeavor to respond to privacy-related requests within 15 days of their receipt. If we require more time (up to an additional 15 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to verifiable consumer requests unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your information privacy or protection rights. We will not:

  • Deny you services or goods;
  • Provide you a different level or quality of services or goods;
  • Charge you different prices or rates for services or goods, including through granting discounts or other benefits, or imposing penalties; or
  • Suggest that you may receive a different price or rate for services or goods or a different level or quality of services or goods.

Children Under 13

The Sites are not intended for children under 13 years of age, and the Company does not knowingly collect information from children under 13.

If you are under the age of 13, do not the use, or provide any information on, the Sites; make any purchases through the Sites; use any of the interactive or public comment features of the Sites; or otherwise provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

If you believe we might have any personal information from or about a child under 13, please contact us at [email protected].

Amendment

The Company reserves the right to modify or amend this Privacy Policy at any time without notice. We encourage you to review this Privacy Policy whenever you visit the Sites to see if it has been updated since your last visit.

Contact Information

If you have any questions about these terms and conditions, would like us to mail you a paper copy of this policy or are having problems receiving or stopping our emails or text messages, please contact us using the following information:

Foveo Memorial Services Inc.

2 Mission Inn Grove, Suite 200

Ottawa, ON K2R 1C6

Attention: Legal Department

Call: 877-936-8369;

Email: [email protected]