Privacy Statement, effective as of May 17, 2020
At VeteranGraves.com, Inc. trust is our #1 value. This VeteranGraves Privacy Statement ("Privacy Statement") describes our privacy practices for the activities set out in this Privacy Statement.
Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals ("Personal Data"), and to learn about your rights and choices regarding our
processing of your Personal Data.
A reference to “VeteranGraves,” “we,” “us,” “our,” or the “Company” is a reference to VeteranGraves.com, Inc.
1. Responsible VeteranGraves entity
VeteranGraves is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.
For the avoidance of doubt, this Privacy Statement does not apply to the extent we offer our customers various cloud products and services through which our customers may create their own websites
and applications running on our platforms, sell or offer their own products and services, send electronic communications to other individuals, and collect and analyze
Personal Data from individuals.
2. Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
- Visit our websites that display or link to this Privacy Statement;
- Visit our branded social media pages;
- Visit our offices;
- Receive communications from us, including emails, phone calls, texts or fax;
- Register for, attend and/or otherwise take part in our events, webinars; or
- Participate in community and open source development.
Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services,
or of social media networks that host our branded social media pages, are governed by third parties' privacy statements, which you should review to better understand those third
parties' privacy practices.
3. What Personal Data do we collect?
3.1 Personal Data we collect directly from you
The Personal Data that we collect directly from you includes the following:
- If you express an interest in obtaining additional information about our services, request customer support, use our
"Contact Us" or similar features, register to use our websites, sign up for an event, webinar, or download certain content, we may require that you provide
to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
- If you make purchases via our websites or register for an event or webinar, we may require that you provide to us your financial and billing information, such as
billing name and address, credit card number;
- If you attend an event, we may with your further consent scan your attendee badge, which will provide to us your information, such as name, title, company name,
address, country, phone number and email address;
- If you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, social media profiles,
company name and areas of expertise;
- If you use and interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies,
web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the "What device and usage data we process" section, below);
- If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies.
- If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in
accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact
us by using the information set out in the “Contacting us” section below.
4. What device and usage data we process
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Data
from your computer or mobile device as you navigate our websites, our services or interact with emails we have sent to you.
4.1 Device and usage data
As is true of most websites, we gather certain information automatically on connection with the use of the website by individual users. This information may include IP address (or proxy server),
device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration
information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued
In addition, we gather certain information automatically as part of your use of the cloud products and services. This information may include IP address (or proxy server), device and application identification
numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches and other actions you take, operating system and system configuration information and
date/time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services,
to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements,
to identify customer opportunities and for the security of VeteranGraves generally (in addition to the security of our products and services). Some of the device and usage data collected within the services,
whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each
user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services
to our customers (where we act as a processor).
4.2 Cookies, web beacons and other tracking technologies on our website and in email communications
emails from us.
When you visit our websites, we may place a cookie on your browser and/or device, which collects information, including Personal Data, about your online activities
over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience.
We use both session-based and persistent cookies on our websites. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your
computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. To change your cookie settings and preferences for the site you are visiting,
features or functions on our websites and services.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:
|Type of Cookies
Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies.
If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into
the websites and to process your online transactions and requests.
Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.
Functional cookies enhance functions, performance, and services on the website. Some examples include: cookies used to analyze site traffic, cookies used for market research,
and cookies used to display advertising that is not directed to a particular individual.
Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications.
These cookies collect information about how our websites are used, including which pages are viewed most often.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications,
and to track the performance of our advertisements.
For example, we use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google's
privacy practices by going to www.google.com/policies/privacy/?partners/
and the pages on our websites to which visitors navigate. This information is used by us to improve our websites.
VeteranGraves may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they
store, and how they store it.
To manage the use of functional cookies on our websites, consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our websites.
To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.
To learn how to control functional cookies using your browser settings click here
To learn how to manage privacy and storage settings for Flash cookies click here
|Targeting or Advertising cookies
Targeting or advertising cookies track activity across websites in order to understand a viewer’s interests, and to direct specific marketing to them. Some examples include: cookies used for remarketing,
or interest-based advertising.
performance of our advertisements. For example, these cookies collect and remember information such as which browsers have visited our websites.
VeteranGraves also contracts with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and
on third-party websites. Advertising networks follow your online activities over time and across different websites or other online services by collecting device and
or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests.
You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our
|See Section 4.3, below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.
4.3 Notices on behavioral advertising and opt-out for website visitors
As described above, we or third parties may place or recognize a unique cookie on your browser when you visit our websites for the purposes of serving you targeted
advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising, advertising networks and
your ability to opt out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative, here, and the
Digital Advertising Alliance, here.
To manage the use of targeting and advertising cookies on this website, consult your individual browser settings for cookies. To learn how to manage privacy and storage
settings for Flash cookies click here. Various browsers
may offer their own management tools for removing HTML5 local storage.
4.4 Opt-Out from the setting of cookies on your individual browser
You may opt-out from the collection of non-essential device and usage data on your web browser (see "What device and usage data we process" section above) by managing your cookies at the individual
browser level. In addition, if you wish to opt-out of interest-based advertising click here, or if located in the
European Union click here). Please note, however, that by blocking or deleting cookies and similar technologies used
on our websites, you may not be able to take full advantage of the website.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these
features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not
currently commit to responding to browsers' DNT signals with respect to our websites. VeteranGraves takes privacy and meaningful choice seriously and will make efforts
to continue to monitor developments around DNT browser technology and the implementation of a standard.
4.5 Social Media Features
Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be
given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third party
social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted
directly on our website. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website,
the latter may receive information showing that you have visited our website. If you are logged into your social media account, it is possible that the
respective social media network can link your visit to our websites with your social media profile.
VeteranGraves also allows you to log in to certain of our websites using sign-in services such as Facebook Connect. These services will authenticate your identity and
provide you the option to share certain Personal Data with us such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.
5. Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the purposes and on the legal bases identified in the following:
Providing our websites and services: We process your Personal Data to perform our contract with you for the use of our websites and services and to
legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., to download content from our websites);
Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated,
non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate
interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites and services; where we have not
entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required during your use of
our websites and services;
Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of
performing our contract with you according to applicable terms of service;
Handling contact and user support requests: If you fill out a “Contact Me” web form or request user support, or if you contact us by other means including via a
phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating
Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend,
including sending related communications to you, to perform of our contract with you;
Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent
that doing so is necessary to complete a transaction and perform our contract with you;
Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and
services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service
offerings, or where we seek your valid consent;
Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information
about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in
advertising our websites or, where necessary, to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn
how you can control how the processing of your Personal Data by VeteranGraves for personalized advertising purposes);
Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional
communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products,
promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the "Your rights relating
to your Personal Data" section, below, to learn how you can control the processing of your Personal Data by VeteranGraves for marketing purposes); and
Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators
in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights,
and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies
available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.
Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may
not be able to perform our contract with you.
6. Who do we share Personal Data with?
We may share your Personal Data as follows:
- With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and
data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in the countries in which we operate (available here: https://www.VeteranGraves.com/company/contact-me/);
- If you use our websites to register for an event or webinar organized by a one of our affiliates, we may share your Personal Data with the affiliate to the
extent this is required on the basis of the contract with you to process your registration and ensure your participation in the event; in such case, our affiliate
will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required.
A list of companies within the VeteranGraves corporate group is available here;
- If you attend an event or webinar organized by us, we may share your information with sponsors of the event if: (1) you consent to such sharing via an event registration
form; or (2) you allow your attendee badge to be scanned at a sponsor booth. In that event, your information will be subject to the business partners' respective
privacy statements. If you do not wish for your information to be shared, you may choose not to opt-in via event registration or elect not to have your badge scanned
at our events;
- With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that VeteranGraves can market and advertise on
third party platforms and websites;
- We may also share your Personal Data with other affiliates within the VeteranGraves corporate group to the extent this is necessary to fulfill a request you have
submitted via our websites, or for customer support, marketing, technical operations and account management purposes; a list of companies within the VeteranGraves
corporate group is available here;
- If we are involved in a merger or reorganization, sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by
another company, we may transfer some or all of your Personal Data to such third party. In accordance with applicable laws, we will use reasonable efforts to notify
you of any such transfer of Personal Data to an unaffiliated third party as processing of your Personal Data will be required for the purposes set out in "Purposes
for which we process Personal Data and on which legal bases" section above.
Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has
provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal
Data from our systems.
8. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for which we process Personal Data and the legal
bases on which we rely" section, above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data
processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well
as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from
our systems, we will put in place appropriate measures to prevent any further use of such data.
9. Your rights relating to your Personal Data
9.1 Your rights
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA,
these rights may include:
- To access your Personal Data held by us (right to access);
- To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
- To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
- To transfer your Personal Data to another controller, to the extent possible (right to data portability);
- To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data
for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to
such processing without having to provide any specific reason for such objection;
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated
Decision-Making currently does not take place on our websites or in our services; and
- To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting
the lawfulness of the processing based on such consent before its withdrawal.
If you are a resident of Florida, under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to
our websites. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have
been reposted by another visitor to our websites.
9.2 How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contacting us” section, below. We try to respond to all legitimate requests within one month and will
contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number
of requests we receive. If you are an employee of a VeteranGraves customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please
contact us by using the information in the “Contacting us” section, below.
9.3 Your rights relating to Customer Data
As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Statement
or in a separate disclosure, we process such Personal Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data
concerned (see the "Responsible VeteranGraves entity" section above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ
from those set forth in this Privacy Statement. If your data has been submitted to us by or on behalf a VeteranGraves customer and you wish to exercise any rights you may have under applicable data
protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly
to us, please provide to us the name of the VeteranGraves customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your
request within a reasonable timeframe.
9.4 Your preferences for marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from
VeteranGraves by clicking on the “unsubscribe” link located on the bottom of VeteranGraves marketing emails, by replying or texting ‘STOP’ if you receive VeteranGraves SMS communications,
or by unsubscribing here.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as
communications about your subscriptions or event registrations, service announcements or security information.
10. How we secure your Personal Data
We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized
disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password,
limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the
information in the “Contacting us” section, below.
11. Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the
“effective date” at the top of this Privacy Statement. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a
conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
12. Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please fill out this form or
mail us at:
VeteranGraves Data Protection Officer
PO Box 3816
Bluffton, SC 29910