Who We Are
Terrybear is a leading supplier for distributors, funeral homes, and pet loss professionals. We provide high-quality, beautiful cremation urns and memorial products to help preserve heartfelt memories for families who have lost a loved one or beloved pet. We offer our products, personalization, and technology solutions to distributors, funeral homes, and pet care professionals.
Our corporate website is Terrybear.com (our “Website”) and we also provide a shopping portal for registered distributors, funeral homes, and other memorial services providers (collectively, “Memorial Providers”) through our shopping platform at memoryofalifetime.com (the “Platform”). Memorial Providers with registered accounts may place orders through the Platform on behalf of their business or on behalf of the families they provide services to (“Customers”). The Platform also gives registered Memorial Providers the option to create a personalized site (“Provider Site”) that Memorial Providers may show to Customers in-person or provide login information to their Customers to allow the Customers to browse or place orders on the Platform on their own.
How to Contact Us
Attn: Compliance Department
946 W. Pierce Butler Route
Saint Paul, MN 55104
You may also email firstname.lastname@example.org or call 888-588-8767.
Scope of this Policy
- The Platform, including Provider Sites, and any subdomains or mobile versions;
- Offline services provided by Terrybear, such as ordering or technical support to Memorial Providers.
Categories and Sources of Personal Data
The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”), including the categories of Personal Data, its sources, and the purposes for which we process that data.
The categories of Personal Data we process
The categories of Personal Data we may collect and use include (these are examples may be subject to change):
|Identity Data||Information such as your name; address; email address; telephone number; account login details, including your user name and password; information you provide in connection with your application to register as a Memorial Provider; name, date of birth, and/or date of death of individual being memorialized; your identity, public profile, and similar information from social networks such as Facebook and LinkedIn.|
|Contact Data||Identity Data that relates to information about how we can communicate with you, such as email, phone numbers, physical addresses, social media handles, and information you provide to us when you contact us by email or when you communicate with us via social media.|
|Location Data||Information about your location, including location data from social media tags/posts, data you provide when you register with us, or location data we may infer from your IP address.|
|Device/Network Data||Browsing history, search history, and information regarding your interaction with a web site, application, or advertisement (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs, embedded pixels, and pixel tags.|
|Commercial Data||Information about services and products we provide to you and about transactions you make with us or other companies operating through us or on our behalf, information about purchases, and similar information.|
|Inference Data||Personal Data used to create a profile about you reflecting your preferences, characteristics, market segments, likes, favorites and other data or analytics provided about you or your account by social media companies or data aggregators, including household data, the products and services you use, and your interests.|
|Financial Data||Information such as bank account details, payment card information, and information from credit reference agencies, including similar data defined in Cal Civ Code § 1798.80(e).|
|Audio/Visual Data||Audio/Visual data may include videos or images uploaded by you to our Services or images and videos you tag us in on social media|
|Employment Data||Information about your work experience, past employers, education history, desired salary, and related information contained in a resume you provide to us or submitted through an online application form.|
|User Content||Unstructured/free-form data that may include any category of Personal Data, e.g. data that you give us in free text fields such as comment boxes or other communications sent through our Service, including any other Personal Data which you may provide to us.|
Sources of Personal DataWe collect Personal Data from various sources, including:
|Data you provide us||We receive Personal Data you provide to us, such as when you create a Customer or Memorial Provider account, purchase our products, personalize our products, apply to be a Memorial Provider, submit an application for employment, contact us for customer service, or when you join our mailing list.|
|Data we collect automatically||We collect Personal Data about or generated by any device you have used to access our Website.|
|Data we receive from service providers & Agents||We receive Personal Data from Memorial Providers, for example, when a Memorial Provider orders our products on a Customer’s behalf and has the products shipped directly to the Customer or provides product customization information that includes Customer Personal Data as part of the purchase process. We also receive Personal Data from service providers performing services on our behalf.|
|Data we receive from aggregators and advertisers||We receive Personal Data from ad networks, behavioral advertising vendors, market research, and social media companies or similar companies that provide us with additional Personal Data such as Inference Data.|
|Data we receive from social media companies||We receive Personal Data from Facebook and other social media companies who may transfer Personal Data to us when you interact with that social media company in connection with our Services.|
|Data we create and infer||We, certain partners, social media companies, and third parties operating on our behalf create and infer Personal Data such as Inference Data or Aggregate Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. We may combine any Personal Data about you that we receive from you and from third parties.|
How We Process Personal Data
When you register for an account
When you register for a Memorial Provider or Customer account with us, we generally process Identity Data, Commercial Data and Contact Data. To register for an account as a Memorial Provider, in addition to your business information, we require the full name, email address, and phone number of a primary contact. A Memorial Provider may provide Customers with login credentials which will allow the Customer access to the Platform through the Memorial Provider’s Provider Site. Customer login credentials may include the Customer’s email address. We process this Personal Data to provide you with a secure purchase experience on the Platform and also provide personalized Provider Sites. We may also use this Identity Data, Commercial Data, Contact Data, and Device/Network Data collected in this context for our Commercial Purposes.
When you make a purchase
If you make a purchase on our Platform, we generally process Identity Data, Financial Data, Commercial Data and Contact Data. We may also collect or create Device/Network Data and Inference Data. We process this Personal Data as necessary to fulfill your order, and also for our legitimate business interests, such as ensuring the security of our Services, preventing fraud, providing information about our products and services, contacting you about administrative matters, and responding to queries, complaints, or correspondence you send us. We may also use this Identity Data, Commercial Data, Contact Data, and Device/Network Data collected in this context for our Commercial Purposes.
When you access or use our Services
The Services may, with your consent when required, process Location Data. We use this data, together with Inference Data, and Device/Network Data in order to provide contextual information to you, such as estimated shipping costs and prices in your local currency. We may also use this information in connection with our legitimate business interests, such as, creating aggregate information about users’ location and patterns, which we use to help improve our Website. We may also process Identity Data, Contact Data, and User Content if you interact with or identify us on social media platforms.
We may also use Identity Data, Device/Network Data, Location Data, Inference Data and Contact Data collected in this context for Commercial Purposes.
Cookies and other tracking technologies
- for “essential” or “functional” purposes, such as to enable certain features of our Website and Platform (for example, an essential purpose may include allowing you to maintain a basket when you are preparing to place an order through Memory of a Lifetime and a functional purpose may include allowing Memory of a Lifetime to provide a you a list of items recently viewed);
- for “performance” and “analytics” purposes, such as to analyze the traffic to and usage of our Website and Platform for example, identifying unique visitors to the site, how many people have looked at a page, how visitors move around the Website and Platform, what website they visited prior to visiting ours, and use this information to understand user behaviors and improve the design and functionality of the Website and Platform;
- for “retargeting” or similar advertising or commercial purposes;
- for social media integration e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Websites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter;
- to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising;
- to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website but have not purchased); and
- to allow us to know when you visit our site or make a purchase after clicking on one of our ads on social media or another website.
When you contact us or submit information to us
We collect and process Identity Data, Contact Data, and any Audio/Visual data or User Content you provide as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes. We may further collect and process Employment Data you provide when applying for employment to evaluate you for the position for which you applied. Additionally where you consent, if relevant to your request (such as an inquiry regarding a purchase, becoming a Memorial Provider, etc.) or if otherwise permitted by law, we may send you marketing communications as described further below, and use this information for Commercial Purposes.
Managing Provider Site
If you are a Memorial Provider, we may process Identity Data, Contact Data, Device/Network Data, and User Content in connection with your Provider Site. We collect your Personal Data, including username (which may be an email address) and password, in order to generate an account to allow you to securely manage your Provider Site. We also collect Personal Data and User Content you provide to us for inclusion on your Provider Site and for our communications with you.
Feedback and Surveys
We may process Identity Data, Contact Data, Inference Data, and User Content collected in connection with surveys. We generally process this Personal Data to respond to requests/concerns, and create aggregate analytics regarding Customer and/or Memorial Provider satisfaction. We may also use this data for Business Purposes and Commercial Purposes.
How we Process Personal Data for Business Purposes
Service Provision and Contractual Obligations
We process any Personal Data as is necessary to provide our services, to provide you with the products and services you purchase or request, to authenticate users and their rights to access the Platform, or various data, features, or functionality, and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request.
Internal Processing and Service Improvement
We may use any Personal Data in connection with improving our Website, Platform, and email communications, for customer service purposes, to understand what parts of our Services are most relevant, how you interact with our Website and Platform, and how our Website and Platform perform.
Security and Incident Detection
We may process any Personal Data we collect in connection with detecting security incidents, or to protect against, and respond to malicious, deceptive, fraudulent, or illegal activity.
We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials.
We process Personal Data about our customers and users in order to identify trends (to create aggregated and anonymized data about our customers/users, buying and spending habits, use of our Services, and other similar information (“Aggregated Data”). We may pass Aggregated Data to certain third parties to give them a better understanding of our business and to improve our Website. Aggregated Data will not contain information from which you may be personally identified.
We process certain Personal Data and Location Data in connection with our legitimate business interest in personalizing our Website, Platform, and online communications. Aspects of the Website and Platform may be customized to you based on your interactions with our Website, Platform and other content. For example, prices of our products may be customized to be in the currency of your current location. This processing may involve the creation and use of Inference Data relating to your preferences.
We may process Personal Data as is necessary to evaluate your application for employment that you submit to us.
Other Business Purposes
How we Process Personal Data for Commercial Purposes
Personalization & Consumer Profiles
In order to understand our customers’ preferences, and better recommend products and services to our prior customers, we may create a “Consumer Profile” by linking together and analyzing Personal Data collected in the following contexts:
- When you make a purchase
- When you register for a customer account, apply to be a member of our trade program, or a wholesaler
- When you access our Website
- When you subscribe to receive communications from us
- Cookies and other tracking technologies
- When you contact us or submit information to us
We may also augment Consumer Profiles with Personal Data that we create (such as Inference Data) or that we receive from third parties. We use Consumer Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services. We may also use this information for other Commercial Purposes.
Consistent with our legitimate business interests, we or our third-party partners may send you marketing and promotional communications if you sign up for such communications, or where allowed, if you register an account with us, make a purchase from us, or in connection with your communications with or submission of User Content to us. These communications may be personalized or customized based on your Consumer Profile. We may also collect Device/Network Data and Contact Data so that we can determine whether you have opened an email or interacted with our communications, and we may generate Inference Data based on these interactions. We may also process this Personal Data for targeted advertising. However, where consent to processing is required by law, we will link and process this information only with appropriate consent.
We may engage in targeted advertising. This form of advertising includes various parties and services providers, including third parties, engaged in the processing of Personal Data in connection with advertising. These parties may be able to identify you across sites, devices, and over time. The parties that control the processing of Personal Data for behavioral advertising may create or leverage information derived from personalization and profiling. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to and determine whether and how ads you see are effective.
How We Share Personal Information
|Affiliates||We may share Personal Data internally with our current and future affiliated entities.|
|Service Providers & Agents||In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests and business purposes, we may share your Personal Data with service providers who provide certain services or process data on our behalf. For example, we use third parties to host our Website, run our Platform and email server, provide cloud storage, send certain emails, process payments, and deliver packages. These companies only have access to personal information needed to perform their functions, but may not use it for other purposes.|
|Partners||We may offer you the opportunity to use services operated by third parties, and if you choose to use these services, we will disclose the Personal Data requested by such third party, or that you direct us to provide to them.|
|Social Media Platforms||We may share certain Personal Data with current or future affiliated entities and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow third parties (such as Facebook and social media advertisers, ad exchanges, data management platforms, or ad servers) to operate on our Services and process data for targeted advertising. These transfers may be made for Commercial Purposes and in connection with Data Sales. Additionally, If you use any social media plugin, API, or other similar feature, use an event hashtag or similar link, or otherwise interact with us via social media, we may make your post available on our Website or to the general public. We may share, rebroadcast, or redisplay Personal Data or other information in the post to the extent permitted by the relevant social media service.|
|Data Aggregators||In connection with our marketing operations, and subject to your rights and choices, we may share certain Personal Data with data aggregators for Commercial Purposes and in connection with Data Sales. These disclosures/sales can help better personalize our Services, the services of third parties, enrich Consumer Profiles and help ensure that you see advertisements that are more relevant to your interests.|
|Corporate Events||Your Personal Data may be shared in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets|
International Transfers of Personal Data
How We Retain Your Personal Data
We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law.
Your Rights and Choices
Based on your country or state of residence, to the extent applicable law grants you the right to do so, you may have certain rights related to your Personal Data. Please see the sections below for rights available to residents of California or the EEA.
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails. Note that some non-marketing communications are not subject to general opt-out, such as communications related to your user account for this Platform, transactions with Terrybear and product and service updates.
Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalization or providing certain types of advertising, or other services conditioned on your consent or choice not to opt-out.
Our Services do not respond to your browser’s do-not-track request.
How We Protect Your Personal Data
The security of your Personal Data is very important to Terrybear. We have in place physical, administrative and technical safeguards designed to protect your personal information from unauthorized access. In addition, Terrybear uses standard security protocols and mechanisms for the exchange and transmission of sensitive data such as credit card details.
Third Party Websites and Mobile Applications
We are not responsible for the data privacy practices, content or security of Memorial Providers, any linked third party websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.
Our Services and online communications are neither directed at nor intended for use or receipt by children under the age of 18, or older depending on the local jurisdiction. We do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.
We note that we may receive the Personal Data of deceased children or children of the deceased under the age of 18 if such Personal Data is provided by a Customer or Memorial Provider in the course of providing information for personalization of a product for purchase on the Platform. This Personal Data will be used solely for the purpose of providing the purchased product personalized as requested and for no other purpose.
Additional Rights and Disclosures: EU/EEA
Your EU/Other Privacy Rights
Under the GDPR and analogous legislation, you may have the following rights, subject to your submission of an appropriately verified request:
|Access:||You may have a right to know what Personal Data we collect, use, disclose, or sell, and you may have the right to receive a list of that Personal Data and a list of the third parties (or categories of third parties) with whom we have received or shared Personal Data, to the extent required and permitted by law. You may be able to access some of the Personal Data we hold about you directly through the account settings menu.|
|Rectification:||You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided to us using the account settings menu.|
|Delete:||To the extent required by applicable law, you may request that we delete your Personal Data from our systems. We may delete your Personal Data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you. Contact us as part of your request to determine how your Personal Data will be erased in connection with your request.|
|Data Export:||To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.|
|Regulator Contact:||You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.|
Additional Rights and Disclosures: California
Your California Privacy Rights
Under the California Consumer Privacy Act (“CCPA”) and other California laws, California residents may have the following rights in addition to those set forth in the Rights & Choices section above, subject to your submission of an appropriately verified request where required by applicable law (see below for verification requirements):
|Right to Know||You may request any of following, for the 12 month period preceding your request: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.|
|Right to Delete||You have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law|
|Right to Non-Discrimination||You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.|
|Direct Marketing||You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.|
|Opt-Out of Sale||We do not engage in the “sale” (as defined by the CCPA) of Personal Data.|
|Minors||Except to the extent described elsewhere in this Policy, we do not knowingly collect Personal Data from children under 18, nor do we engage in the sale of this Personal Data.|
Submission and Verification of Requests
You may submit any of the above requests by emailing email@example.com or calling 888-588-8767. All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you provide the email address we have on file for you (and verify that you can access that email account) as well as an address, phone number, or other data we have on file, in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
Categories of Personal Data Disclosed for Business Purposes
For purposes of the CCPA, we may disclose to Service Providers for “business purposes” the following categories of Personal Data: Identity Data, Contact Data, Location Data, Device/Network Data, Commercial Data, Inference Data, Financial Data, Audio/Visual Data, Health Data, and User Content.
Categories of Personal Data sold
For purposes of the CCPA, we do not sell your Personal Data.
Right to Know
|Category of Data||Context||Category of Sources||Business Purposes||Commercial Purposes||Category of Recipients|
|User Content||· When you access or use our Website · When you make a purchase on the Platform · When you make a registered account on the Platform · When you customize your Provider Site on the Platform · When you contact us or submit information to us||From you; Service providers; Agents and partners; Social media companies||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Social Media Companies; Agents; Data Aggregators; Successors; Lawful Recipients|
|Location Data||· When you access our Website or Platform||From you; Service Providers||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Lawful Recipients|
|Inference Data||· When you make a purchase or other transaction through our Platform · When you access our Website or Platform · Cookies and other tracking technologies · Interactions through social media||From you; Automatic collection; Service providers; Agents and partners; Aggregators and advertisers; Social media companies; Data we create/infer||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Social Media Companies; Lawful Recipients|
|Identity Data||· When you make a purchase or other transaction through our Website or Platform, such as creating a registered account, apply to be Memorial Provider · When you access our Website or Platform · Cookies and other tracking technologies · When you subscribe to communications from us · When you contact us or submit information to us||From you; Automatic collection; Service providers; Agents and partners; Aggregators and advertisers; Social media companies; Data we create/infer||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Social Media Companies; Lawful Recipients|
|Financial Data||When you make a purchase or other transaction||From you; Service Providers||Service Provision and Contractual Obligations; Security and Incident Detection; Compliance; Aggregated data; Other Business Purposes||Personalization & Consumer Profiles; Targeted advertising||Affiliates; Service Providers; Agents; Successors; Lawful Recipients|
|Device/ Network Data||· When you make a purchase or transaction through our Website or Platform · When you access our Website or Platform · Cookies and other tracking technologies||From you; Automatic collection; Service providers; Agents and partners; Aggregators and advertisers; Social media companies; Data we create/infer||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance, health, safety, public interest; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Lawful Recipients|
|Contact Data||· When you make a purchase or other transaction through our Platform or for shipment · When you apply to be a Memorial Provider · When you create a registered account on the Platform · Cookies and other tracking technologies · When you subscribe to communications from us · When you contact us or submit information to us||From you; Automatic collection; Service providers; Agents and partners; Aggregators and advertisers; Social media companies; Data we create/infer||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Social Media Companies; Lawful Recipients|
|Commercial Data||· When you make a purchase or other transaction · When you visit our Website or Platform||From you; Automatic collection; Service providers; Agents and partners; Data we create/infer||Service Provision and Contractual Obligations; Internal Processing and Service Improvement; Security and Incident Detection; Compliance, health, safety, public interest; Aggregated data; Personalization; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Lawful Recipients|
|Audio/Visual Data||· When you provide audio or pictures to us via the Website, Platform, online communication, or social media||From you; Service Providers||Service Provision and Contractual Obligations; Security and Incident Detection; Compliance; Aggregated data; Other Business Purposes||Personalization & Consumer Profiles; Marketing Communications; Targeted advertising||Affiliates; Service Providers; Successors; Lawful Recipients|
|Employment Data||· When you submit information to us · When you apply for employment through the Website||From you; Service Providers; Agents and Partners||Service Provision and Contractual Obligations; Security and Incident Detection; Compliance; Employment; Other Business Purposes||None||Affiliates; Service Providers; Agents; Data Aggregators; Successors; Lawful Recipients|