Privacy Policy

Back2Us attaches great importance to the protection of your privacy and personal data. This Privacy Policy explains which personal data is collected, for what purposes such data is processed, and how such data is used, stored and protected in connection with the use of the Service.

Company info

Cofita Uitvaartkisten, trading under the name Back2Us

Marshof 28

3255 TD Oude-Tonge

The Netherlands

Dutch Chamber of Commerce (KvK) registration number: 73218103

Contact details

Email: back2us.contact@gmail.com

Website: https://www.back2us.app

Processing of personal data

Personal data is processed in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws and regulations. Back2Us handles personal data with due care and processes such data solely for specified, explicit and legitimate purposes.

Personal data we process

Back2Us processes personal data relating to users of the Service, visitors of the website and individuals who otherwise contact Back2Us, whether electronically or in writing. Such personal data is generally obtained directly from you, for example when you create an Account, use the Service or communicate with Back2Us via email or other communication channels.

In addition, the Service may involve the processing of personal data uploaded, submitted or otherwise provided by users themselves, including personal data relating to third parties and deceased individuals.

Personal data may furthermore originate from other users or partner organisations that provide content through the Service. Such data may include audio materials, visual content, text files and contact details relating to identifiable individuals.

Back2Us may process the following categories of personal data:

• first and last name
• username and email address
• age and country of origin
• data relating to the Account and use of the Service
• communication data, including messages, correspondence and support requests
• payment and transaction data, insofar as processed through third-party payment service providers
• Content uploaded or otherwise provided by the User, including audio recordings (voice data), videos, images, text files and other materials
• personal data relating to website visitors, including IP addresses, device information, browser data and information regarding the use of the website and Service
• any other personal data voluntarily provided by the User.

Personal data of minors

Back2Us is not directed at individuals under the age of 16 and does not knowingly collect personal data from minors. If you believe that personal data relating to a minor has been collected without the consent of a parent or legal guardian, please contact Back2Us via back2us.contact@gmail.com so that the relevant data can be removed.

Special categories of personal data

In connection with the Service, Back2Us may process special categories of personal data within the meaning of Article 9 GDPR, insofar as such data is voluntarily uploaded, submitted or otherwise provided by Users through the Service. This may include audio materials, visual content, text files or other materials containing sensitive information.

Back2Us processes such data solely to the extent necessary for the provision and functioning of the Service and only where permitted under applicable laws and regulations.

Users remain solely responsible for the content and lawfulness of any data submitted through the Service and warrant that, where required under applicable law, a valid legal basis exists for such processing, including, where applicable, the explicit consent of the relevant data subject or their rights holders.

Back2Us does not intentionally collect special categories of personal data on its own initiative and does not actively seek to obtain such data.

The GDPR generally does not apply to personal data relating exclusively to deceased individuals. However, content uploaded by Users may also contain personal data relating to living individuals. To the extent such information qualifies as personal data under applicable law, this Privacy Policy shall apply in full to the processing of such data.

Purposes and legal bases for processing personal data

Back2Us processes personal data solely for specified, explicit and legitimate purposes and only where a valid legal basis for such processing exists in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

The principal purposes for which personal data may be processed include:

• Communication and customer support: to respond to enquiries, provide support, handle contact requests and maintain communication with Users.
• Performance of the agreement and provision of the Service: to create and manage an Account, provide access to the Service and make its functionalities available, including the creation and use of AI personas and the facilitation of interactions with such personas.
• Processing of User Content: to process data uploaded or otherwise provided by the User, including audio materials, visual content and text files, for the purpose of generating AI personas and related Output. Such data may also relate to third parties and deceased individuals.
• Relationship management and service provision: to maintain user relationships, monitor the use of the Service and follow up on contact moments and support requests.
• Financial administration: to process payments, manage subscriptions and comply with administrative, accounting and tax obligations.
• Improvement and optimisation of the Service: to analyse, improve and optimise the operation of the Service and the underlying AI systems based on usage, interactions and feedback.
• Security and business operations: to ensure the proper technical functioning of the Service, prevent misuse and fraud and protect systems, infrastructure and data.

Back2Us processes personal data on the basis of one or more of the following legal grounds:

• Performance of a contract: where processing is necessary for the provision and delivery of the Service and the performance of the agreed functionalities.
• Compliance with a legal obligation: where processing is necessary to comply with applicable legal or regulatory obligations, including accounting, administrative and tax obligations.
• Legitimate interests: where processing is necessary for purposes such as relationship management, communication, system security, fraud prevention and the improvement of the Service. In such cases, Back2Us carefully balances its legitimate interests against the rights and freedoms of the data subjects concerned.
• Consent: where required under applicable law, including in relation to the processing of personal data relating to third parties uploaded by Users or specific functionalities for which consent is legally required.

Back2Us does not process more personal data than is necessary for the purposes described above and does not retain such data for longer than necessary, unless a longer retention period is required or permitted under applicable law.

The provision of certain personal data, including account information, payment details and content required for the generation of AI personas, is necessary for the conclusion and performance of the agreement between the User and Back2Us. If such data is not provided, Back2Us may be unable to provide the Service, in whole or in part.

Withdrawal of consent

Where the processing of personal data is based on consent, you have the right to withdraw such consent at any time by contacting Back2Us via back2us.contact@gmail.com.

The withdrawal of consent shall not affect the lawfulness of any processing carried out prior to such withdrawal.

Upon receipt of your request, Back2Us will remove the relevant personal data as soon as reasonably possible, unless retention of such data is required or permitted under applicable law, including for administrative, accounting or legal purposes.

Recipients of personal data

Back2Us shares personal data with third parties only to the extent necessary for the performance of the agreement, the provision and use of the Service, the functioning of the underlying technologies or compliance with applicable legal obligations. In all cases, only the personal data necessary for the relevant purpose will be shared.

Where a User invites other individuals to access a memorial, AI persona or related functionality, Back2Us may process personal data such as names, email addresses and usage data for the purpose of facilitating and managing such access.

Personal data may be shared with, among others:

• Hosting and infrastructure providers: for the technical management, hosting, storage and security of the Service and the underlying systems
• Providers of AI and technology solutions: for the processing of audio, visual and text-based materials and the generation of AI personas and related Output
• Payment service providers: for the processing of payments via payment methods such as iDEAL, Apple Pay, credit card or other supported payment solutions
• Communication and email service providers: for the sending of service-related communications, notifications and user support messages
• Government authorities, regulators or supervisory bodies: where Back2Us is legally required to disclose personal data under applicable laws or regulations.

To the extent that third parties process personal data on behalf of Back2Us, such parties shall act as data processors within the meaning of the GDPR. Where required by applicable law, Back2Us enters into appropriate data processing agreements with such parties, ensuring that they implement adequate technical and organisational measures to protect personal data and process such data solely on documented instructions from Back2Us.

Personal data may be processed outside the European Economic Area (“EEA”), including in the United Kingdom and other jurisdictions where service providers or technology partners operate. Back2Us ensures that any such international transfers take place in accordance with applicable data protection laws, including through adequacy decisions, Standard Contractual Clauses or other appropriate safeguards recognised under the GDPR.

Sharing of personal data with third parties

Back2Us shares personal data with third parties only where such disclosure is necessary for the performance of the agreement with the User, the provision of the Service or compliance with a legal or regulatory obligation, as further described in this Privacy Policy.

Retention period

Back2Us does not retain personal data for longer than is necessary for the purposes for which such data is processed, unless a longer retention period is required or permitted under applicable law or pursuant to a statutory retention obligation.

The following retention periods generally apply:

• Account and usage data: personal data and content relating to the use of the Service will be retained for as long as the relevant Account remains active. Following deletion of the Account, such data will in principle be deleted or anonymised, unless retention is required under applicable law or necessary for the establishment, exercise or defence of legal claims.
• Content and AI-related data: content uploaded or otherwise provided by the User, including audio recordings, visual materials, text files and related Output generated through the Service, will be retained for as long as necessary for the functioning, maintenance and improvement of the Service and for as long as the relevant Account remains active.
• Administrative and financial data: personal data required for compliance with legal, accounting, tax and administrative obligations, including invoice and transaction records, will be retained for the statutory retention period of seven (7) years or such longer period as may be required under applicable law.
• Other data: other categories of personal data will not be retained for longer than necessary for the purposes for which they were collected, unless a longer retention period is legally required or otherwise permitted under applicable law.

Cookies and similar technologies

Back2Us does not currently use analytical, advertising or tracking cookies for behavioural advertising or cross-site tracking purposes. This means that no cookies are placed for behavioural analysis, targeted advertising or other forms of user tracking.

The Service likewise does not rely on traditional browser-based cookies commonly used on websites. However, the Service may use comparable technologies, including local storage, software development kits (“SDKs”) and other technical tools necessary for the functioning, security and improvement of the Service.

Such technologies are used exclusively for the following purposes:

• enabling the technical functionalities of the application and Service
• storing user settings and preferences
• maintaining the security, integrity and stability of the systems and infrastructure.

To the extent that these technologies involve the processing of personal data, such processing shall take place in accordance with this Privacy Policy and applicable data protection laws and regulations, including the GDPR. These technologies are not used for advertising, behavioural profiling or analytical tracking purposes.

As Back2Us does not currently use non-essential tracking or analytical technologies, no cookie banner or consent mechanism is displayed.

Should Back2Us introduce non-essential technologies in the future, including analytical, advertising or tracking functionalities, this Privacy Policy will be updated accordingly and, where legally required, prior user consent will be obtained.

Access, correction and deletion of personal data

Under the General Data Protection Regulation (EU) 2016/679 (“GDPR”), you have various rights in relation to your personal data.

You have, among others, the following rights:

• Right of access: you have the right to obtain access to the personal data processed by Back2Us concerning you, including information regarding the manner in which such data is processed.
• Right to rectification: you have the right to request the correction or completion of inaccurate or incomplete personal data.
• Right to restriction of processing: you have the right to request the restriction of the processing of your personal data, for example where you contest the accuracy of the data or object to the processing.
• Right to erasure (“right to be forgotten”): you have the right to request the deletion of your personal data. This right is not absolute and may be limited where continued processing or retention is necessary for contractual, legal or legitimate business purposes.
• Right to data portability: you have the right to receive the personal data you have provided to Back2Us in a structured, commonly used and machine-readable format and, where technically feasible, to transmit such data to another controller.
• Right to object: you have the right to object to the processing of your personal data, including where such processing is based on the legitimate interests pursued by Back2Us.
• Rights relating to automated decision-making: the Service uses automated processes and artificial intelligence technologies for the generation of Output and related functionalities. However, such processes are not intended to produce decisions based solely on automated processing that have legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR. Should this change in the future, you will have the right to object and to request human intervention.

Requests relating to the exercise of your rights may be submitted via back2us.contact@gmail.com. Back2Us will respond to such requests as soon as reasonably possible and, in any event, within the time periods required under applicable law.

To prevent misuse and protect personal data, Back2Us may request additional information to verify your identity before processing a request. Where a copy of an identity document is provided, you are advised to redact your photograph, MRZ (machine readable zone), passport number and national identification number or equivalent government-issued identification number before submission.

Please note that these rights generally apply only to your own personal data. To the extent that you provide personal data relating to third parties through the Service, you remain solely responsible for exercising any rights on behalf of such third parties where permitted under applicable law.

Complaints

If you have a complaint regarding the processing of your personal data by Back2Us, you are encouraged to first contact Back2Us via back2us.contact@gmail.com so that an appropriate solution may be sought.

If you remain dissatisfied, you have the right to lodge a complaint with the competent supervisory authority, including the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Security of personal data

Back2Us takes the protection of personal data seriously and implements appropriate technical and organisational measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unlawful alteration of personal data.

Such measures include, among others:

• the use of encrypted connections and transmission protocols, including TLS/SSL
• access restrictions and authorisation mechanisms
• the use of strong authentication methods
• regular system updates and security patching
• backup and recovery procedures
• system monitoring and the detection of unusual or suspicious activities.

In determining the appropriate level of security, Back2Us takes into account the state of the art, implementation costs, the nature, scope and context of the processing activities, as well as the risks posed to the rights and freedoms of data subjects.

If you suspect that your personal data is not adequately secured or if there are indications of misuse, unauthorised access or security incidents, please contact Back2Us immediately via back2us.contact@gmail.com.

Changes to this Privacy Policy

Back2Us may amend or update this Privacy Policy from time to time. Any updated version of this Privacy Policy will be published on the website and shall become effective upon publication, unless stated otherwise.

Users are encouraged to review this Privacy Policy regularly in order to remain informed of any changes.

Where required under applicable law, Back2Us may notify Users of material changes to this Privacy Policy or request renewed consent prior to the implementation of such changes.

Questions

If you have any questions regarding this Privacy Policy or the processing of your personal data by Back2Us, you may contact Back2Us via back2us.contact@gmail.com. Back2Us will use reasonable efforts to respond to your enquiry as soon as reasonably possible.