Privacy Policy

Introduction

We are an online social media platform. People use our Services to create a memorial for deceased family members, friends or other persons to connect with other people and and find information. Our Privacy Policy applies to any Member or Visitor to our Services.

Our registered users (“Members”) share their identities, engage with their network, exchange knowledge and personal insights and post and view relevant content. Content and data on some of our Services is viewable to non-members (“Visitors”).

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

Services

This Privacy Policy, including our Cookie Policy applies to your use of our Services.

This Privacy Policy applies to letem.live, letemlive.net, Let’emLive!-branded apps and other Let’emLive!-related sites, apps, communications and services (“Services”), including off-site Services, such as our ad services and plugins, but excluding services that state that they are offered under a different privacy policy.

Our services are subject to the General Data Protection Regulation of the European Union This Regulation does not apply to the personal data of deceased persons. Member States may provide for rules regarding the processing of personal data of deceased persons.

Data Controllers and Contracting Parties

If you are in the “Designated Countries”, Let’emLive! UG (“Let’emLive! Germany”) will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

If you are outside of the Designated Countries, Let’emLive! Corporation will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.” Let’emLive! (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you want to use payment services, you will need to provide payment (e.g., credit card) and billing information.

Account

To create your account, we will ask you to provide a minimum of personal information (user name, e-mail, payment information). You may upload a picture. You have choices about the information on your account. It’s your choice whether to include personal information and to make that information public. Please do not post or add personal data to your account that you would not want to be publicly available.

You give other data to us, such as relations to other people.

Memorial

By creating a Memorial of a third person, you give information about their biography and further information such as personal data and image information. The General Data Protection Regulation of the European Union does not apply to the personal data of deceased persons. Anyhow, do not post or add data of that third person to the memorial that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey or register for a package of our Services.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Others may post or write about you. Customers and partners may provide data to us.

Content

You and others may post content that includes information about you (as part of posts, comments, pictures, videos) on our Services.

Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates, including Stripe. For example, you may choose to send us payment information.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., commercial video) or ads (on or off our sites and apps), perform a search, install or update our mobile app, share Memorials or request access to other Memorials. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We collect data through cookies and similar technologies.

We use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. If you are outside the Designated Countries, we also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information) so we can provide our Members with relevant ads and better understand their effectiveness. You can opt out from our use of data, from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

1.5 Your Device and Location

We receive data from your devices and networks.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages and notifications in connection with our Services. For example, if you get a request, we track whether you have acted on it. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement or other policies from our Services.

1.7 Sites and Services of Others

We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your Let’emLive! account.

1.8 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect you and the Memorial created by you with others, find and be found for communication opportunities stay informed or send money.

We use your data to authorize access to our Services and honor your settings.

Follow Memorials and share content

Our Services allow you to stay in touch and up to date with family members, friends and other contacts. To do so, you can “follow” Memorials you choose, and who’s Memorial owners also wish to “share” content with you. Subject to your and their settings, when you connect with other Members, you will be able to search each others’ Memorials in order to exchange information.

We use data about you and the memorial created by you (such as your account, memorials you have viewed or partner integrations) to help others find the memorial created by you, suggest connections for you and others (e.g. family members) and enable you to share content of the memorial created by you.

It is your choice whether to invite someone to our Services, share content and send a connection request, or allow other Members to become follower of the memorial created by you. When you invite someone to connect with you, your invitation will include your network and basic account information (e.g., name, photo, photo, region). We will send invitation reminders to the person you invited.

Stay Informed

Our Services allow you to stay informed about news regarding the Memorials you are following. Our Services also allow you to improve your communication with other users. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We also use the data we have about you to suggest contacts or information you could add to your account or to the memorial created by you. We use your content, activity and other data, including your name and photo, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated the memorial, posted content, took a social action, used a feature or made new connections.

2.2 Communications

We contact you and enable communications between Members.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Let’emLive! notification box, and other ways through our Services, including text messages. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example invitations, mail, groups and, notifications and messages between connections.

2.3 Marketing

We promote our Services to you and others.

We use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.

2.4 Developing Services and Surveys

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect family members to each other.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.

2.5 Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.6 Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their geography, to calculate ad impressions served or clicked on, or to publish visitor provenience for a Service.

2.7 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our Terms and Conditions and/or attempts to harm our Members,Visitors or others.

3. How We Share Information

3.1 Our Services

Any data that you include on the memorial created by you and any content you post or social action (e.g., likes, follows, guest book entries, posts, shares, financial contributions) you take on our Services can be seen by others, consistent with your settings.

Memorial

The memorial created by you is fully visible to all Members and customers of our Services, if you choose to option “public”. It can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, access channels and search types (e.g., by name or by keyword) impact the availability of the memorial created by you and whether they can view certain fields in the memorial. If you choose the option “private” for your memorial, it will only be visible for members invited by you.

Posts, Follows, Invitations, Guest Book entries, Family Tree, Financial Contributions

Our Services allow viewing and sharing information including through posts, follows and guest book entries.

• When you share an article or a post (e.g., an update, image, video or text) publicly it can be viewed by everyone and re-shared anywhere. Members, Visitors and others will be able to find and see your publicly-shared content, including the memorials name (and photo if you have provided one).
• In a family, posts are visible to others in the family.
• When you follow a memorial, you are visible to others and that “memorial owner” as a follower.
• We let senders know when you act on their message.
• Subject to your settings, we let a memorial owner know when you visit the memorial created by them.
• When you re-share or comment on another’s content, others will be able to view these “social actions” and associate it with you (e.g., your name or photo if you provided it).

3.2 Others’ Services

You may link your account with others’ services so that they can look up your contacts’, post your shares on such platforms, or enable you to start conversations with your connections on such platforms.

Subject to your settings, other services may look up the memorial created by you. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

Subject to your settings, excerpts from the memorial created by you will appear on the services of others (e.g., search engine results, mail and calendar applications that show a limited memorial, social media aggregators). “Old” memorial information remains on these services until they update their data cache with changes you made to that memorial.

3.3 Related Services

We share your data across our different Services and Let’emLive! affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.

3.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Let’emLive!, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.6 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when actualising every few years, we will retain your information and keep the memorial created by you open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

If you disagree with our Privacy Policy, you can opt out from our services and close your account from your settings.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of the data provided by you, from deleting or correcting data you include in your account and controlling the visibility of your posts to communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Residents in the Designated and other regions may have additional rights under their laws.

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your Let’emLive! account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our policies), enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain depersonalized information after your account has been closed.

Information you have shared with others (e.g., through internal Mail, updates or group posts) will remain visible after you close your account or delete the information from the memorial or notification box, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. The memorial created by you may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of Germany and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to settings or delete your account.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Let’emLive! Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our data security officer: data-protection@letem.live.

5.4. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first contact Let’emLive! online: data-protection@letem.live.