Privacy Policy

1. Introduction

This Privacy Policy explains how Soul Awakened Limited (“EndlessLuv”, “we”, “our”, “us”) collects, uses, shares and protects personal information in connection with the EndlessLuv application, website and related services (the “Services”). It applies to two main groups of people: (a) our account holders and users (“Users”), and (b) people whose details a User gives us so that we can contact them as part of the User’s legacy arrangements (“Recipients”). A separate notice for Recipients appears in Section 11.

EndlessLuv is a digital legacy platform. Because of the nature of the Services, some processing is designed to take place after a User’s death.

2. Who We Are (Data Controller)

Soul Awakened Limited is the data controller responsible for your personal information. We are established at Assikura Buildings, Level 1, Old Railway Track, Santa Venera SVR 9017, Malta.

For any privacy question, or to exercise your rights, contact us at support@endlessluv.com.

We act as controller both for the information Users give us about themselves and their content, and for the Recipient Information Users provide so that we can deliver communications. Users decide who to contact and what their messages say; we decide how that information is stored, secured and transmitted, and we are responsible for handling it lawfully.

3. Information We Collect

3.1 Information you give us (Users)

• Account and identity details (name, email address, password, date of birth, contact details);
• Content you upload, create or schedule (messages, photographs, videos, documents, family tree data and legacy messages);
• Recipient Information you provide about other people (see Section 3.3);
• Nominations of Next of Kin and trusted representatives;
• Payment and subscription information (processed by our payment providers);
• Communications with us, including support requests.

3.2 Information we collect automatically

• Device and technical data (device type, operating system, app version, identifiers);
• Usage data (features used, actions taken, dates and times of access);
• Log and diagnostic data, including IP address;
• Cookies and similar technologies on our website (see Section 9).

3.3 Recipient Information

When a User sets up legacy arrangements, they may give us information about other people — such as name, email address, phone number, relationship to the User, and any role assigned (for example Next of Kin, beneficiary or funeral attendee). We obtain this information from the User, not usually from the Recipient directly.

3.4 Death and verification information

To verify a death and authorise releases, we may collect and process death certificates, executor or funeral director confirmations, court documents, government-issued identification and verification codes. Some of this information may relate to the deceased User and to the person making the request.

3.5 Special category data

Content you choose to store may reveal sensitive information (for example about health, religious beliefs or family relationships). We process such content only to provide the Services at your direction. By uploading such content, you ask us to store and process it for that purpose.

4. How and Why We Use Information

We use personal information to:

• Create and administer accounts and provide the Services;
• Store, encrypt, organise and deliver content and communications you configure;
• Send Next of Kin invitations, verification requests, funeral and memorial notifications, and legacy messages on a User’s instructions;
• Verify deaths and authorise the release of content and access;
• Process payments and manage subscriptions;
• Provide customer support and respond to requests;
• Maintain security, prevent fraud and abuse, and protect our users and platform;
• Comply with legal obligations and enforce our Terms;
• Improve and develop the Services.

5. Legal Bases for Processing

Where the EU or UK GDPR applies, we rely on the following legal bases:

Performance of a contract: to provide the Services to Users under our Terms.

Consent: for certain communications where required by law, for optional cookies, and where you choose to upload special category content for us to store. You may withdraw consent at any time.

Legitimate interests: to operate and secure the platform, deliver legacy and posthumous communications that Users have arranged, prevent fraud, and contact Recipients to give effect to Users’ wishes — balanced against the rights and interests of the individuals concerned.

Legal obligation: to comply with applicable laws, including tax, accounting and lawful requests from authorities.

Vital interests / public interest: in limited cases connected with death verification, where appropriate.

Where we rely on legitimate interests for Recipient Information, we have considered that Recipients may not have a prior relationship with us, and we limit our use to delivering the arrangements a User has made and offer a clear way to opt out.

6. How We Share Information

We do not sell personal information. We share it only as follows:

With Recipients you designate: to deliver the communications and content you have configured.

With service providers (processors): hosting, storage, encryption, email and SMS delivery, payment processing, analytics and customer support providers who act on our instructions under contract.

For verification: with executors, funeral directors or others strictly as needed to verify a death and authorise releases.

For legal reasons: where required by law, court order, or to protect rights, safety, or prevent fraud.

Business transfers: in connection with a merger, acquisition or reorganisation, subject to this Policy.

7. International Transfers

We may store and process information in countries outside your own, including outside the EEA or UK. Where we transfer personal information internationally, we use appropriate safeguards required by applicable law, such as European Commission or UK adequacy decisions or Standard Contractual Clauses. You may contact us for more information about these safeguards.

8. Data Retention

We keep personal information only for as long as necessary for the purposes described in this Policy, including the inherently long-term nature of digital legacy storage:

• User account and content: for as long as the account is active and, where legacy delivery is arranged, until those arrangements have been carried out;
• Recipient Information: until the relevant arrangement has been completed or the Recipient asks us to delete it, subject to legal and security requirements;
• Verification and death-related records: for the period needed to evidence that releases were properly authorised;
• Payment and transaction records: as required by tax and accounting law;
• Security and log data: for a limited period proportionate to the purpose.

When information is no longer required, we delete or anonymise it. Specific retention periods are available on request.

9. Cookies and Similar Technologies

Our website uses cookies and similar technologies for essential functionality, security, performance and (with your consent) analytics. You can manage non-essential cookies through our cookie banner or your browser settings. Disabling some cookies may affect how the website works.

10. Your Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Delete your information (“right to be forgotten”);
• Restrict or object to certain processing, including direct contact;
• Data portability;
• Withdraw consent where we rely on it;
• Lodge a complaint with your data protection authority — in Malta, the Office of the Information and Data Protection Commissioner (IDPC).

To exercise any right, contact support@endlessluv.com. We will respond within the timeframes required by applicable law. We may need to verify your identity first. Exercising certain rights (for example deletion or objection) may mean we can no longer carry out some arrangements a User has made.

11. Notice to Recipients

This section is addressed to people we contact on behalf of a User.

Why you are hearing from us. You are receiving a communication from EndlessLuv because a User of our service — typically a family member, friend or someone close to you — asked us to contact you as part of their digital legacy arrangements (for example, as a Next of Kin or beneficiary, or to receive a funeral notification or a legacy message).

Where your data came from. We hold the contact and identifying details the User provided about you (such as your name, email address, phone number, your relationship to the User, and any role they assigned). We obtained this from that User, not from you directly.

How we use it. We use your information solely to deliver the communications and carry out the instructions the User has set up, and to verify identity where needed. We do not use your information for our own marketing and we do not sell it.

Our legal basis. We rely on legitimate interests — enabling individuals to make and give effect to legacy and end-of-life arrangements, and operating the platform that delivers them — balanced against your rights. Where the law requires consent for a particular communication, we rely on consent, which you may withdraw at any time.

How long we keep it. Only as long as needed to carry out the relevant arrangement and meet our legal, security and record-keeping obligations, after which it is deleted or anonymised.

Your rights. You may access, correct, delete, restrict or object to the use of your information, and lodge a complaint with your data protection authority. You can opt out of further messages or ask us to delete your details at any time via support@endlessluv.com or any unsubscribe link provided. Honouring your request may stop some communications the User arranged from reaching you.

12. Children

The Services are not directed to children under 18, and Users must be at least 18 to create an account. We do not knowingly collect personal information from children. If you believe a child has provided us with information, contact us and we will take appropriate steps.

13. Security

We use technical and organisational measures appropriate to the sensitivity of the information, including encryption, access controls and monitoring. No system is completely secure; we cannot guarantee absolute security, but we work to protect your information and to notify you and the relevant authority of a personal data breach where the law requires.

14. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated through the Services, by email or by other reasonable means. The “Last updated” date shows when it was last revised.

15. Contact Us

Soul Awakened Limited
Assikura Buildings, Level 1, Old Railway Track, Santa Venera SVR 9017, Malta
Email: support@endlessluv.com | Website: www.endlessluv.com