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Privacy Policy

01/01/2025

This Privacy Policy applies to information collected by Repose Technologies, Inc. (“Repose” "we" or “us” or “our”) through your use of the Repose website at https://www.repose.io/ and any subdomains thereof (the “Site”) and the services, features, and information available on the Site and/or any mobile applications we may offer now and in the future including a funeral planning platform designed to connect individuals and service providers in the funeral industry such as funeral homes, (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the “Service”). As used herein, “you” or “your” mean a user of the Service, including a consumer in the funeral planning industry (“Consumer”) and users associated with service providers in the funeral planning industry (each, a “Provider”).

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Repose or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

What information about me is collected?

Where and when is information collected (including through the use of cookies and action tags)?

Is information submitted to the Public Areas of the Service private?

Does Repose collect information from children under 13 years of age?

What does Repose do with the information it collects?

When does Repose disclose information to third parties?

Does this Privacy Policy apply when I link to other websites or services?

Is the information collected through the Service secure?

Could my information be transferred to other countries?

For how long will my information be kept?

What choices do I have regarding my information?

How will I know if there are any changes to this Privacy Policy?

Who do I contact if I have any privacy questions?

WHAT INFORMATION ABOUT ME IS COLLECTED?

In connection with your use of the Service, we may collect information about you. Depending on your use of the Service, and whether you are a Consumer or Provider, such information may include your name, e-mail address, password, Google account information (if you use the Google Login feature), the contents of any optional message you send through the Service (including any optional message intended for any Provider or Consumer, as applicable), and telephone number. If you are a Consumer, this may also include funeral plans you create through the Service, as well as Providers with whom you engage. Additionally, our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly. We may also collect non-identifiable demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages and products you view, the date and time of your visit, domain names, search preferences, Providers saved (if you are a Consumer), and statistical data involving the use of the Service.

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect information that you submit to us. We may also receive information about you from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service.

Registering to Use the Service and in the Course of Using the Service.

You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information such as e-mail address and password. We may also receive information about you from third parties providing credit and debit card authorization and fraud screening services as part of the registration process. In addition, we may obtain your information from you if you identify yourself to us by communicating with us including by sending us an e-mail with questions or comments. Also, we will have access to any information that you choose to share through the Service.

If you choose to access certain portions of the Service using the Google Login feature, you may be providing us with access to all information, attributes, and data in your Google public profile. We may freely store and use such information in accordance with this Privacy Policy. Such information may be stored by us and may be used in connection with providing the Service or to contact you.

Cookies and Action Tags.

We may collect information passively using “cookies” and “action tags.”

Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, or to determine the popularity of certain content.

Generally, we employ two kinds of cookies: (1) Necessary Cookies and (2) Marketing and Performance Cookies. The Service cannot function properly without Necessary Cookies. Accordingly, these cookies cannot be disabled. Use of Necessary Cookies is required in order for us to make the Service available to you, and for this reason, these Necessary Cookies do not require your consent. Marketing and Performance Cookies are used for analysis, as well as to provide personalized content and/or services to you. Information supplied by these cookies helps us to understand visitor and user preferences and how our Service is used, enabling us to continually improve the Service.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services or to collect information in order to provide analytics-related services. In the course of providing such analytics-related services, such third-party analytics providers could place or recognize unique cookies on your browser.

Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Service may use third-party service platforms (including to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here is a link to the main third-party platform we use:

https://www.google.com/policies/privacy/

"Action tags", also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

Finally, you should be aware that other third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.

Log Files.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

Public Areas.

The Service may feature various community areas, public profiles (such as a Provider profile), and other public areas (the "Public Areas") where Service users can share information. These Public Areas are open to the public and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner inconsistent with this Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

ANY INFORMATION YOU SHARE IN A PUBLIC AREA IS BY DESIGN OPEN TO THE PUBLIC AND IS NOT PRIVATE. YOU SHOULD THINK CAREFULLY BEFORE POSTING ANY INFORMATION IN ANY PUBLIC AREA. WHAT YOU POST CAN BE SEEN, DISCLOSED TO OR COLLECTED BY OTHERS AND MAY BE USED BY OTHERS IN WAYS WE CANNOT REGULATE OR PREDICT. AS WITH ANY PUBLIC FORUM ON ANY WEBSITE, THE INFORMATION YOU POST MAY ALSO SHOW UP IN THIRD-PARTY SEARCH ENGINES LIKE GOOGLE, YAHOO, AND BING. IF YOU MISTAKENLY POST INFORMATION IN A PUBLIC AREA YOU CAN SEND US AN E-MAIL TO REQUEST THAT WE REMOVE IT BY CONTACTING US AT privacy@repose.io. YOU SHOULD UNDERSTAND THAT IN SOME CASES, WE MAY NOT BE ABLE TO REMOVE YOUR INFORMATION.

IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICE PRIVATE?

No. Any information shared in the Public Areas of the Service is available to the public, including to all users. Such information is not treated as confidential. If you wish to keep any information private or proprietary, do not submit it to the Public Areas of the Service. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER’S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.

DOES REPOSE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13.

WHAT DOES REPOSE DO WITH THE INFORMATION IT COLLECTS?

We will only use your information to the extent that the law allows us to do so.

We use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, and, unless you “opt out” (to the extent permitted by applicable law), so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you.

We may use your information to send you a welcoming e-mail that may confirm your access credentials. Unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy@repose.io.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to other information about you for internal purposes or to improve your experience with the Service.

In addition, if you are a user of the Service, to the extent you opt in to the receipt of SMS/text messages, we may use your telephone number to send you operational and informational SMS/text messages to assist you in using the Service and to send you essential Service-related communications. Such SMS/text messages may include (depending on whether you are a Consumer or a Provider) account setup instructions, password reset links, business-related confirmations and updates, one-time codes to login to your account, and/or case notifications when you receive a new request. For the avoidance of doubt, we will not share your opt-in consent to receive operational and informational SMS/text messages with third parties (other than to our third-party service provider that sends SMS/text messages on our behalf) or affiliates.

WHEN DOES REPOSE DISCLOSE INFORMATION TO THIRD PARTIES?

We generally disclose information we gather from you through the Service to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Providers.

If you are a Consumer, we may disclose your information to the applicable Provider, including without limitation for order fulfillment purposes in connection with the Service. If we disclose order fulfillment information to a Provider, such information will be subject to the terms of the Provider’s privacy policy and your information may be further disclosed in accordance with the terms of their privacy policy. Although we do not generally disclose individual search queries with Providers, we may choose to do so. We may also disclose de-identified, aggregated information with our Providers to help them analyze and improve their product offerings along with our analysis of search trends, product demands and consumer preferences.

Laws and Legal Rights.

We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

Third Parties Generally.

We may provide information to third parties, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party analytics service providers and commercial partners) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include providers of products or services (including vendors, analytics services providers, and website tracking services), merchants, affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Professional Advisors.

We may provide your information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing credit card processing and fraud screening, including the Payment Services Provider, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of Repose or any of its Corporate Affiliates (as defined below), or that portion of Repose or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in Repose, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.

We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Repose, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?

Our Service may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Service.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States, regardless of your location.

FOR HOW LONG WILL MY INFORMATION BE KEPT?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

We generally use your information as described in this Privacy Policy, as authorized by you, or as otherwise disclosed at the time we request such information from you. You generally must "opt in" and give us permission to use your information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy@repose.io.

If you want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact privacy@repose.io.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

DO NOT TRACK.

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us in any of the following ways:

By e-mail:

privacy@repose.io

By postal mail or courier:

Attention:

Repose Technologies, Inc.

252 NW 29th Street STE. 1004

Miami, FL 33127