Last updated: June 12, 2023

Consolidated Funeral Services is committed to protecting your personal information. This privacy notice describes the personal information that we collect about you, how we use and disclose it, and the steps we take to protect it. For this Privacy Notice, (a) "personal information" is any information that is about you and can be used to identify you, and (b) "Consolidated Funeral Services," "CFS," "we," "us," and "our" all refer to the legal entity mentioned in the "Applicable Entity" section of this Privacy Notice below. This Privacy Notice covers our collection and use of personal information through this website, related platforms, and any other means that reference this Privacy Notice at the time of collection.

Our Services

CFS's primary business is to provide software-as-a-service funeral technology services, including websites, payment processing, and e-commerce services, to funeral homes and other funeral professionals (our "clients"). In connection with this facet of CFS's business, CFS collects and stores personal information regarding individuals who visit and utilize certain functions or features of our and our Clients' websites ("End Users"). This Privacy Notice applies to CFS's collection and use of Client and End User personal information but not to our Clients' or any other third party's use of such personal information.

CFS maintains an online presence, including an e-commerce store for funeral products and the Tribute Archive for obituaries and funeral-related content, from which personal information may be collected from users ("CFS Users"). This Privacy Notice also applies to CFS's collection and use of personal information from CFS Users and other individuals who interact directly with CFS.

Personal Information We Collect

When you access or use the Services or otherwise interact with us, whether as a Client, End User, CFS User or other individual, we may collect certain categories of personal information about you from a variety of sources.

Categories of personal information that we may collect from you directly include:

• Contact information (for example, name, phone number, mailing address, email address)
• Payment-related details (for example, billing address and other credit card details)
• Communications (for example, submitted questions or other posts and marketing preferences)
• Recruitment data (for example, resumes and other details regarding an applicant's qualifications)

We may automatically collect the following categories of personal information when you use the Services:

• Technical information (for example, browser type, IP address, cookies, and operating system)
• Usage information (for example, pages visited, search terms entered, and frequency of visits)

Categories of personal information that we may collect from other sources, including our clients, in connection with their use of the services include:

• End User contact information (for example, name, phone number, mailing address, email address)
• End User account information (for example, username and password and transaction history)
• End User payment-related details (for example, billing address and other credit card details)
• End User funeral contributions, including tribute video data, data entered in funeral register books, obituaries and posts and comments

We use Google Analytics to collect and analyze information about use of the website and to help us understand activities and trends; this includes use of Google Analytics performance reports relating to demographics and interests. As part of this service, we share a unique identifier with Google Analytics. You may opt out of Google Analytics by installing a Google Analytics opt-out browser add-on available for download here: https://tools.google.com/dlpage/gaoptout.

Finally, we may collect personal information pursuant to a legal or contractual requirement, and failure to provide such information may impact our ability to fulfill our obligations.

How We Use Your Personal Information

We may use the personal information we collect for the following purposes:

• Provide the services and improve them.  We may use your personal information to provide and improve the Services, including to fulfill your orders and requests and to post your comments and other funeral contributions. We may also use your personal information for the administration of our business, for business development purposes, and to fulfill our contractual obligations.
• Risk mitigation and security.  We may use your personal information for risk mitigation and security purposes, which include maintaining the privacy and security of our data, conducting internal audits or investigations, performing data security testing and business continuity planning, and ensuring the safety and security of our clients, staff, and assets, as well as those of our affiliates.
• Communication and marketing.  We may use your personal information to communicate with you about the Services, respond to your questions, or offer you additional products or services.
• Comply with the law and exercise our rights.  We may use your personal information as needed to check and make sure we follow the law, legal rules, and our company policies; to protect our and our partners' property; to look into or defend against any claims of illegal activity (including getting legal advice or to establish, use, or defend our legal rights); and in response to a court order or government request.
• Corporate transaction.  We may use your personal information in the event we undertake or are involved in or contemplating any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event.

We may also aggregate, anonymize, or otherwise de-identify your personal information and use it for any purpose permitted by applicable law.

Some jurisdictions require that we determine a "lawful basis" for processing personal information. When there are rules about how to handle personal information, we base our actions on these reasons: you agreed to it, it's needed to fulfill our contract with you, we have a legal duty, or we have a valid reason to provide and enhance our Services and run our business. Our Clients are responsible for determining the lawful basis for processing End users' personal information.

Use of Cookies

When you use the Services, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device to help analyze our web page flow, customize our content, measure promotional effectiveness, and promote trust and safety. You are always free to decline our cookies if your browser permits, although doing so may interfere with your ability to use the Services or certain features of the Services. We may also use Google Analytics or a similar service that uses cookies to help us analyze how users use the Services.

We may also allow certain third parties, such as advertising and analytics providers and widget providers, to place cookies to collect information about your online activities over time and across different websites when you access or use the Services. Currently, various browsers offer a "Do Not Track" option, but there is no standard for how "Do Not Track" should work on commercial websites. Due to the lack of such standards, the Services, including this website, do not respond to "Do Not Track" consumer browser settings.

How and When We Disclose Your Personal Information

We may disclose your personal information to the following categories of recipients, to be used only for legitimate purposes in keeping with this Privacy Notice:

• Group companies and affiliates.  We may disclose, share, or transfer your information to any business entity that is part of our corporate family.
• Clients.  We may share your information with our Clients in connection with our Clients provision of services to you.
• Service providers and professional advisors.  We may disclose your information to third party vendors who provide services in support of our business operations, such as website development and hosting, payment processing, marketing management, service optimization, vendors that fulfill orders for funeral-related items such as flowers, and data analytics. We may also disclose your personal information to our professional advisors such as our attorneys, accountants, and insurance providers.
• Parties involved in a corporate transaction.  We may disclose your information to relevant third parties in the event of a divestiture, merger, consolidation, or asset sale, or in the unlikely event of a bankruptcy.
• Law enforcement or other governmental entities.  We may disclose your information as required by law or in good faith to comply with legal obligations, prevent unlawful activity, defend our rights, or ensure security.
• Other third parties with your consent.  We may disclose your information to any other third party where you have provided consent to such disclosure.

For the avoidance of doubt, no mobile information collected in connection with our Service Detail Texting Program will be shared with third parties for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties except to our service providers as may be necessary to send you messages under our Service Detail Texting Program.

Security, Retention & Transfer of Personal Information

We have implemented and maintain commercially reasonable and appropriate technical and organizational measures designed to protect the confidentiality, integrity, and security of your personal information. Please note, however, that no security measures are perfect or impenetrable. We therefore cannot guarantee and do not warrant the absolute security of your personal information. We retain your personal information only as long as necessary to fulfill its collection purposes or comply with legal requirements.

Depending on your location, the personal information we collect about you may be transferred to a jurisdiction that does not provide the same level of protection as the jurisdiction in which you reside. We may transfer and store personal information, among other locations, in Canada, Australia, and the United States. Transfers from the European Union to Canada are made pursuant to European Commission Decision 2002/2/EC, which determined that Canada is considered as providing an adequate level of protection of personal information.

Your Choices & Rights

If you refuse to share certain information, we may not be able to provide some of the Services' features and functions. Once you have registered for an account with us, you may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the Services. If you do not wish to receive marketing communications from us, you can opt out by using the unsubscribe process provided or described in any such communication, but you may still receive transactional or administrative communications from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for various purposes, including backups and archiving, prevention of fraud and abuse, and analytics.

Depending on your location and subject to local law, you may have certain rights with respect to your personal information. These may include the right to access, correct, and delete your personal information; the right to restrict or object to our use of it; and the right to receive a portable copy of it in a usable format. If you provide us with consent to use your personal information, you may withdraw that consent at any time; however, such withdrawal will not impact the lawfulness of our use of your personal information based on your consent up to that point.

To make a request related to your personal information or otherwise exercise your rights, you may contact us using the contact information provided below. To fulfill your request, we may require additional information from you. We will respond to requests within the relevant times established by applicable law. We pledge to resolve any request, concern, or complaint you bring to our attention in a fair and reasonable manner. However, if you are unsatisfied with our response to your request, you may have the right to lodge a complaint with applicable governmental authorities, subject to local law.

Children's Privacy

We do not knowingly collect or maintain information from persons under 16 years of age ("children"), and no part of the Services is directed to children. If you are under 16 years of age, then please do not use or access the Services at any time or in any manner. If we learn that information has been collected through the Services from children and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child has provided us with personal information without your consent, please contact us using the contact information below to request that we delete the information from our systems.

Applicable Entity

All references to "Consolidated Funeral Services," "CFS," "we," "us," or "our" in this Privacy Notice refer to the applicable entity specified in the table below, which is based on the location of the business address of the Client or other business on whose website this Privacy Notice appears (as posted on such website):

Location of Business Applicable Entity: Canada United States and the rest of the world outside Canada, Tribute Technology Canada, ULC, a British Columbia unlimited liability company, and Tribute Technology US, LLC, a Delaware limited liability company

California Residents

Supplemental to the above, the following additional information pertains to California residents only:

Collection and Use of Personal Information

• Categories of personal information collected about California residents in the past twelve months include identifiers, other identifying information, characteristics of protected class, commercial information, Internet or other electronic network activity information, professional or employment-related information, education information, and inferences drawn from such information. For examples of specific pieces of personal information collected, please see the "Personal Information We Collect" section above.
• Categories of personal information disclosed for a business purpose about California residents in the past twelve months include identifiers, other identifying information, characteristics of protected class, commercial information, Internet or other electronic network activity information, professional or employment-related information, and education information.
• We do not sell personal information, nor do we share personal information with third parties for those third parties' direct marketing purposes.

Your California Privacy Rights

As a California resident, you have the following rights with respect to your personal information:

• You have the right to ask about personal information collected, disclosed, or sold.
• You are entitled to request the deletion of personal information.
• You are entitled to opt out of the sale of your personal information at any time.  Note that we do not currently sell personal information.

Lastly, exercising your privacy rights should not lead to discrimination against you. Accordingly, unless permitted by law, we will provide goods and services at the same price and quality to everyone.

To exercise your rights, you may contact us using the contact information provided below or call 1-888-881-6131. To fulfill your request, we may require additional personal information for purposes of verifying your identity. If you make a request through an authorized agent, we may require additional information to verify your authorization of the agent.

Changes to Privacy Notice

We reserve the right to make changes to this Privacy Notice at any time, without notice. We will notify you about changes that significantly impact our use of your personal information by placing a prominent notice on this website or by sending you an email. Please revisit this page periodically to stay aware of any changes to this Privacy Notice. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Notice in effect at the time the dispute arose.

Contact Us

Please contact us with any questions, comments or concerns about this Privacy Notice or our use of your personal information by e-mail at info@runcfs.com or by mail at:

Consolidated Funeral Services, Inc.
220 Reservoir St., Suite 15
Needham, MA 02494