Effective Date: August 1, 2011

The Memoriams™ Network is owned and operated by Adpay, Inc. ® (the "Company")

Collection of Personal Information

Company collects information in several ways from customers and visitors in a variety of ways. Protecting consumer privacy is very important to us. Our Online Privacy Statement is available to inform you about our collection and use of personal information so that you can make informed choices about how your own information is collected and used. Currently, the Online Privacy Statement is only applicable to customers and visitors in the United States who visit the Company’s websites. This Online Privacy Statement reflects Company’s policies covering personal information collected aforementioned websites on or after the effective date shown above.

Company gathers personal information in many ways

• When you register with us on our websites or through one of our partners websites
• Directly from applications, questionnaires and other materials submitted to us by customers
• From transactions in which Company and consumers are involved
• From a variety of third-party sources, such as our business customers, government repositories, consumer reporting agencies and other financial institutions

The more information you provide, the better we are able to customize your experience. Once you register with us directly or indirectly, you are no longer anonymous to Company.

In addition to registration, we may ask you for personal information at other times, for example when you enter a promotion, sweepstakes or contest sponsored by Company and/or one of our partners; when you make a purchase; when you post a classified listing on one of our web sites; when you submit a listing for a web site; or when you report a problem with one of our sites or services. Company also occasionally asks users to complete surveys that we use for research purposes.

Use of Cookies

We occasionally might use cookies to collect personal information. A "cookie" is a small text file placed on your hard drive by a web server. This website uses cookies to tell our servers who you are when you return to our website and to gather other information that we may use or permit others to use from time to time as otherwise provided in this Online Privacy Statement. You can usually set parameters on your computer that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also usually delete cookies from your hard drive. Instructions on how to accept cookies, on how to be notified that a cookie is being offered and on how to delete cookies are available through your Internet Browser.

Use of Information

As a general rule, Company will not disclose any of your personal information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below.

Company may disclose your personal information to business partners or sponsors, but only after we tell you about the data collection or transfer of data. Details of shared use may be found in specific service agreements you may have with Company or in sweepstakes or promotion rules. Some or all data collected during a Company promotion may be shared with a sponsor. If we share personally identifying data about you, we will tell you before we collect or transfer the data.

In promotions, we often provide you the option of requesting information from sponsors. By requesting more information, you give Company permission to transfer your personal information to the sponsor so they may fulfill your request. In many instances, only your e-mail address will be shared. If we share additional information about you with a sponsor, you will be notified prior to the transfer of that information.

Company may also disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating Company's policies or service terms or who may be causing injury to or interfering with Company's, other user's or someone else's rights or property. Company may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain service or improve our products and services.

There are some disclosures to third parties that are not subject to the opt-out, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud. Company may disclose information about former customers to third parties and companies with which Company is affiliated, as well as unaffiliated third parties. Those disclosures may consist of the following:

• Identification information, such as name and address data
• Transaction information, such as account activity, debit activity or credit activity
• Other information relating to financial matters with respects to Company

The data we collect is used in the aggregate to give us demographic information about the entire Company audience in order to improve our services to our customers, to perform statistical analysis of the collective characteristics and behavior of our customers and visitors, to measure overall patron demographics and interests regarding specific areas of the Company domain and to analyze how and where to use our resources.

We also track information such as the domain name from which you contact us, the pages you request, the products you buy, the referring site, and the time that you spend on the site. For all who visit Company, we log IP addresses, the type of operating system that your computer uses, and the type of browser software you use. From the IP address, we can determine the Internet Service Provider and the geographic location of your point of connectivity.

Protection of Information

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, we make our best efforts to ensure its security on our systems.

Company uses reasonable precautions to keep the personal information disclosed to us secure and to disclose any information only to third parties who we believe will treat the information responsibly. However, we are not responsible for any case of abuse, breach of security or actions of any third parties, which receive the information. Company also links to a wide variety of other sites. We are not responsible for their privacy policies or how they treat information about their users.

Company limits access to personal information to those employees of Company and its affiliates who need it to fulfill their business responsibilities. Our employees must adhere to Company privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive personal information is safeguarded.

At Company, security is a priority. We employ appropriate measures to protect consumer information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. Company continually reviews and enhances its security systems, as necessary.

Company employs appropriate measures to assure the quality of information we collect directly from consumers. Where information is collected by Company directly from consumers or sources other than our business customers, we permit them, if possible, to dispute or correct any erroneous or out-of-date personally identifiable information Of course, this correction would not be possible if the information is proprietary to one of our business customers, reflects historical transaction information or if correction would violate the privacy or legal rights of a third party. Where applicable, we abide by laws related to such information. You can access your registration information by clicking on "My Account". You can correct factual errors in your personally identifiable information by: (1) Personally making online changes to your account information; or (2) By sending us a written request that credibly shows error. You can e-mail this request to us at [email protected]. We reserve the right to independently verify claims made. To protect your privacy and security, we also will take reasonable steps to verify your identity before making corrections. We reserve the right to assess a service charge for providing you with any information in connection with your request.

You may request to have your name put on our not-to-be-released list by sending an e-mail to us at [email protected] or by writing us at:

• Memoriams
• 391 Inverness Parkway Suite 100
• Englewood, CO 80112

Please be aware that Company does not control the acts of its customers or visitors. All customers and visitors should be aware that when they disclose personal information such as their actual name, store's name, e-mail address, etc. to third parties, the information may be collected and used by others to send that person unsolicited e-mail from other parties.

Our website is not directed at children under the age of 18 and Company does not collect or maintain information at our website from those we actually know are under the age of 18. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you're online.

If you have any questions or comments about Online Privacy Statement or for some reason believe we have not adhered to our statement, please contact us at [email protected].

As stated above, this Online Privacy Statement is currently only applicable to our website customers and visitors in the United States. As we develop websites for international audiences, we may adopt additional rules and practices consistent with this statement to conform to the policies or requirements of those countries. We may alter this statement as needed for certain products and services and to abide by local laws or regulations around the world. Company reserves the right to amend or modify this statement from time to time. We urge you to review this statement whenever you visit in order to obtain the most current statement. You may change your choices at any time.