Privacy Policy

This Privacy Policy is designed to explain how Antlers Technologies Limited collects, uses, and protects your personal information when you use our mobile-first, AI-powered family tree application and related services. We are committed to safeguarding your privacy and ensuring you understand how your data is handled as you digitally preserve your family heritage, connect with loved ones, and access our integrated fintech, gifting, and event services. This privacy policy outlines your rights and how you can exercise them, as well as the measures we take to keep your information secure.

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Meet Antlers

Antlers App is a mobile-first, AI-powered family tree application developed by Antlers Technologies Limited. Our platform empowers users—particularly families and diaspora communities—to digitally preserve their family heritage, nurture meaningful relationships, and celebrate cherished life milestones. Beyond its genealogy features, Antlers App integrates fintech and gifting services, enabling users to securely send money, schedule legacy messages, and access curated event-related solutions such as cakes, photography, and decorations through our trusted Vendor Marketplace.

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Information We Collect and Why?

Antlers App collects the personal information that you have consented to provide to us in order to enable, deliver, and continuously improve the wide range of services we offer. Our platform is designed to empower families and diaspora communities to digitally preserve their family heritage, foster meaningful relationships, and celebrate important life milestones in a secure and meaningful way. Specifically, we gather and use your data to:

• Build and maintain your personalized family tree and related genealogy features.
• Provide integrated fintech services, including the secure sending and receiving of money.
• Facilitate the scheduling of legacy messages, allowing you to convey special communications to loved ones at designated future times.
• Connect you with trusted vendors through our curated Vendor Marketplace, offering event-related services such as cakes, photography, decorations, and other celebration essentials.
• Ensure the ongoing security, reliability, and performance of our application to protect your data and privacy.

By collecting this information, we are able to deliver a seamless, personalized, and secure experience that meets the diverse needs of our users.

If you choose not to provide certain personal information that we require, or if you withdraw consent for its use, we may be unable to offer you particular features or services. This may include, but is not limited to:

• Inability to create or update your family tree or related genealogical data.
• Restrictions on accessing integrated fintech features such as sending money or scheduling legacy messages.
• Loss of access to our Vendor Marketplace for event planning and related services.
• A less personalized app experience, which may affect the relevance of content, offers, and notifications you receive.
• Potential limitations in customer support and communications specific to your account.

We encourage you to provide accurate and complete information to fully benefit from all the functionalities and protections that Antlers offers.

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Categories of Information We Collect?

To use our products and services you need to create an account by signing up, which requires you to provide certain personal information. This information enables us to deliver and personalize your experience with our platform. Likewise, if you use our paid products and services, we cannot provide them to you without getting payment information. Basically, certain information is necessary if you want to use many of our products and services. Consequently, we require the below information to deliver our Services in accordance with our Antlers App Terms and Conditions, and without this we will not be able to provide our Services to you.

Collecting this information is essential for us to provide you with a secure, personalized, and fully functional service. You have control over this information and can update or delete what you provide through your account settings or by contacting us directly.

[We’re to confirm categories of information to be collected above, and provide any category not covered.]

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How Does Antlers Use Your Information?

At Antlers, we use your information to provide, maintain, and improve our platform, enhance your experience, and ensure the security and integrity of our services. Specifically, we use your information for the following purposes:

1. To Create and Manage Your Account:
   We use your personal details to establish and maintain your user account, authenticate your identity, and communicate with you regarding your account status and service updates.
2. To Deliver Family Tree and Genealogy Services:
   Your family heritage data, including names, dates, photos, and relationships, enable us to build, animate, and personalize your family tree experience. We use AI technologies to generate insights, suggest connections, and enhance genealogical accuracy based on the data you provide.
3. To Facilitate Fintech and Payment Services:
   ‍Financial and payment information you provide is used to securely process transactions such as money transfers, gift payments, and purchases through our Vendor Marketplace. We ensure these processes comply with applicable financial regulations and secure transaction standards.

4. To Provide Legacy Messaging and Event Services:
   We use content you create, such as legacy messages and event-related data, to store, schedule, and deliver messages as per your instructions. Additionally, we facilitate your interactions with vendors for event services including but not limited to cakes, photography, and decorations.

5. To Communicate with You:
   ‍We send you important communications including service notifications, updates about features, promotional offers, and customer support responses. We tailor some communications based on your preferences and interaction history.

6. To Personalize Your Experience:
   ‍Usage data and interaction patterns allow us to customize content, recommendations, and service offerings most relevant to your needs and interests.

7. To Improve Our Services:
   ‍We analyse aggregated usage data, technical diagnostics, and feedback to identify trends, fix issues, develop new features, and enhance overall performance and usability.

8. To Protect Security and Prevent Fraud:
   We monitor for and prevent unauthorized access, fraudulent activities, and other threats to your data and our platform’s integrity.

9. To Comply with Legal and Regulatory Requirements:
   ‍We may process and share your information as required by applicable laws, regulations, legal processes, or in response to government requests.

10. To Enforce Our Terms and Protect Rights:
    ‍Your information helps us enforce our terms of service and protect the rights, property, or safety of AntlersApp, our users, or others.

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You always have control over your information and can update your data, adjust communication preferences, or request deletion in line with our privacy rights provisions.

We may use certain personal information, such as demographic details obtained from third-party sources or data you provide within AntlersApp (including your profile, family trees, and related features), to promote our products and services, as well as offers from our trusted business partners. This marketing may include personalized advertising based on your interests and preferences to enhance your experience.

For marketing communications that you have consented to receive via email or SMS, you retain full control over how we communicate with you. You can opt out or change your preferences at any time by using the unsubscribe link included in every marketing message or by updating your communication settings in your account. Regarding advertising delivered through third-party platforms, we rely on our legitimate interests as the lawful basis for processing such information. We encourage you to manage and control your advertising preferences directly on those third-party platforms to limit or customize the ads you see.

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What is the basis for Use of Your Data?

1. Performance of this Contract: Processing your information is necessary for us to fulfill our contractual obligations to you, such as providing access to our platform, maintaining your family tree, processing payments for services you purchase, and delivering messages or connecting you with vendors as per your requests. Without this processing, we would be unable to provide the core services you subscribe to.

2. Legitimate Interest: We process your information where it is necessary for our legitimate interests or those of a third party. Our legitimate interests include:

Improving and optimizing our services: Analysing usage data helps us understand how our platform is used, so we can continuously develop new features, fix bugs, and enhance overall user experience.

1. Ensuring security and preventing fraud: Monitoring for unauthorized access and fraudulent activities is crucial for maintaining the integrity of our platform and protecting your data
2. Personalization of user experience: Tailoring content and recommendations based on your usage helps us provide a more relevant and engaging service.
3. General Communications: Sending non-marketing operational communications, such as service updates or support responses

3. Consent: We will obtain your explicit consent for specific processing activities, especially for sending you marketing communications via email or SMS. Your family record or information will never be used for marketing or personalized advertising without your separate, explicit consent. Where required by law, we will also seek your consent for the use of certain cookies and tracking technologies. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

4. Compliance with Legal Obligations: We process your information when it is necessary to comply with a legal obligation to which Antlers Technologies Limited is subject. This includes but is not limited to obligations under financial regulations concerning fintech services, tax laws, or responding to lawful requests from governmental or regulatory authorities.  

Your Rights While Using the Antlers App

You have several important rights regarding the personal information we collect and process about you. These rights help you control how your data is handled. They include:

• Right of Access: You can ask us to confirm whether we hold any of your personal information and request a copy of that information.
• Right to Correction: If you believe any of your personal data we hold is incorrect or incomplete, you can ask us to update or correct it.
• Right to Erasure: You can request that we delete your personal data, subject to certain conditions such as legal or contractual obligations.
• Right to Restrict Processing: You may ask us to limit how we process your data in specific situations, such as when you contest the accuracy of your data or object to its processing.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to request that we transfer that data to another organization where technically feasible.
• Right to Object: You can object to our processing of your personal data based on legitimate interests or direct marketing purposes.

Please note that exercising some rights may affect your use of certain features or services within the Antlers app.

Categories of Recipients of Personal Data

We may disclose your personal data to the following categories of recipients, strictly in accordance with applicable data protection laws and only to the extent necessary for the purposes described in this Privacy Policy:

1. Service Providers and Subprocessors:
   Third-party companies and professionals who perform services on our behalf, such as:
   
   • Cloud hosting and IT infrastructure providers
   • Payment processors and financial institutions facilitating transactions
   • Analytics and marketing services
   • Customer support and communication platforms
   • Security and fraud prevention services 

All such providers are bound by confidentiality agreements and are authorized to use personal data only to provide services to Antlers.

2. Vendor Marketplace Partners:
   ‍Trusted vendors offering event-related products and services (e.g., cakes, photography, decorations) within our marketplace, to the extent necessary to fulfill your orders or service requests. This includes sharing order details and contact information as needed to coordinate those services.

3. Authorised Family and Community Members:
   Where you choose to share or collaborate on your family tree or legacy messages (e.g., through shared access or invitations), some of your data may be accessible to those individuals with the permissions you grant.

4. Legal and Regulatory Authorities:
   When required by applicable law, regulation, legal process, or government request, we may disclose your personal data to comply with legal obligations, respond to lawful requests, enforce our Terms of Service, or protect rights, property, or safety.

5. Affiliates and Business Partners:
   ‍In cases of mergers, acquisitions, or business transfers involving Antlers Technologies Limited, your data may be transferred to or shared with affiliated entities or new owners, subject to confidentiality and data protection commitments.

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Transfer of data

Your personal data may be transferred to, stored, and processed in countries other than the country in which you reside. This includes countries outside of your home jurisdiction, which may have different data protection laws than those in your country.

1. International Transfers
   As a global service provider, Antlers may transfer your personal data to our service providers, affiliates, and partners located in various countries, including but not limited to countries in Europe, Africa and other regions where we operate or engage third parties. Such transfers are necessary for the provision, maintenance, and improvement of our services.
2. Safeguards for Transfers
   When we transfer your data internationally, we ensure appropriate safeguards are in place to protect your information, in compliance with applicable data protection laws. These safeguards may include:
   
   1. Transfers to countries recognized by relevant authorities as providing an adequate level of protection;
   2. Use of standard contractual clauses required by regulatory authorities;
   3. Binding corporate rules where applicable;
   4. Other legally recognized data transfer mechanisms ensuring an adequate level of protection.
3. Data Transfer in Business Transactions
   In the event of a merger, acquisition, sale, or transfer of all or part of Antlers’ assets or business, your personal data may be transferred as part of such a transaction. We will ensure that any recipient of your personal data is obligated to protect it in accordance with this Privacy Policy and applicable data protection laws.

4. Your Rights Regarding Data Transfers
   ‍Depending on your jurisdiction, you may have rights related to international data transfers, such as the right to request information about the safeguards applied or to object to certain transfers. We encourage you to contact us using the details in the “Contact Us” section if you have any questions or concerns about how your data is transferred and protected.

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If personal info is disclosed or “sold” “shared” to third parties, list the categories of data and recipients for each, and the purpose of such disclosure.

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Data of Minors 

Antlers recognises that under data protection laws, parental or guardian consent is required for processing the personal data of children under the age of 16. We implement reasonable measures to verify that parental consent has been obtained before collecting, using, or sharing data related to minors. When a user declares they are below the age of consent, we will require appropriate parental authorisation prior to processing any personal data.

We limit the collection of personal data from minors to what is necessary for the provision of the Antlers App services and related offerings. We do not engage in profiling or direct marketing based on the personal data of minors without parental consent.

Antlers does not sell, share, or otherwise disclose the personal data of minors under the age of 16 to any third parties for commercial purposes.

In the event that Antlers determines that it is necessary to share or disclose the personal data of a minor under 16 for purposes beyond the operation of its services, Antlers shall first obtain verifiable consent from the minor’s parent or legal guardian before doing so.

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Right to withdraw consent at any time

You have the right to withdraw your consent for us to collect, use, or process your personal information at any time. Please be aware that if you decide to withdraw your consent, some features of the Antlers app or services may no longer be available to you or may not work properly.

If you wish to withdraw your consent or have any questions about your data rights, please contact us at [contact info]. We are committed to responding promptly and helping you with your request.

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Automated decision-making or profiling that produces legal or significant effects

[Antlers to provide information on use of automated decision making.] Antlers may utilize automated decision-making processes, including algorithms and artificial intelligence technologies, to assist in data analysis. These automated processes help improve the efficiency and accuracy of our services by providing initial assessments based on the data collected.

However, any decision or outcome generated through such automated processes does not represent the final determination. All results produced by automated decision-making are subject to thorough review and evaluation by our qualified team. This human oversight ensures that final decisions are carefully considered, appropriate, and tailored to each individual situation.

We are committed to maintaining transparency regarding the use of automated decision-making and ensuring that individuals affected by these processes have access to meaningful human intervention, allowing them to seek clarification, provide additional information, or contest decisions where applicable.

If you have questions or concerns about automated decision-making used by Antlers, please contact us at [contact info].

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Retention Policy

Antlers retains your personal data only as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, tax, accounting, or reporting requirements.

When your personal data is no longer needed for the purposes outlined in this Privacy Policy or upon your request, we will securely delete, anonymize, or otherwise dispose of it in a manner that protects your privacy.

In some cases, we may retain certain information for a longer period if required by applicable law or if necessary to protect our legitimate interests, such as resolving disputes, enforcing our agreements, or protecting our legal rights.

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U.S. Residents Additional Privacy Statement 

This U.S. Resident Additional Privacy Statement (“U.S. Statement”) supplements and forms part of our main Privacy Policy. It provides further, detailed information regarding the types of Personal Information we collect, process, use, and share specifically in relation to residents of the United States.

This U.S. Statement is intended to ensure transparency and compliance with relevant U.S. federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and other emerging and existing state privacy regulations.

The categories of personal information which we collect from users are as follows:

1. Identifiers: This includes information such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, and similar identifiers.
2. Personal: Such as your name, signature, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment or employment history, bank account number, credit card or debit card number, and other financial information
3. Commercial Information: Records of products or services you have purchased, obtained, or considered, including purchasing or consuming histories or tendencies. 
4. Internet or Other Electronic Network Activity Information: Information about your interactions with our services or advertisements, browsing history, search history, and other usage data. Information from Third Parties: When you use other online products and services, they may share information about that usage with us.
5. Information from Advertisements: When you view or interact with ads we serve on or off the Antlers App platform or website, we may collect information about those views or interactions (e.g., watching a video ad, clicking on an ad, interacting with reposts of or replies to an ad).
6. Cookies and Similar Technologies: Antlers uses cookies and similar technologies as well as technical integrations with marketing and advertising partners as described in our Cookie Policy which forms a part of this Privacy Statement. Please refer to our Cookie Policy to learn about our practices and the controls we provide you.
7. Other Information: Any additional data voluntarily submitted by you through the app, such as family posts, legacy messages, or memory content.
8. Sensitive Information: While we do not plan to collect sensitive or special categories of data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification, health data, or data concerning a person’s sex life or sexual orientation), we acknowledge that users may voluntarily submit such information through family posts, legacy messages, or memory content. However, users may submit such information voluntarily through family posts, legacy messages, or memory content. Where this is the case, Antlers is committed to handling any sensitive data with the utmost care and in full compliance with the legal requirements.

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Sources of Personal Information

Antlers collects the above categories of personal information from:

1. You, our user/visitor— We collect personal information directly from you based on your interactions with our Services. This includes information you provide when you create or update your account, submit your content (such as family posts, legacy messages, or memories), communicate with us, or otherwise engage with the Antlers App. The specific data collected depends on your use of the Services and the features you choose to utilise.
2. Public records and linked social media accounts — When you link your social media profiles to your Antlers account, we may collect personal information from those profiles, including publicly available data on your social media pages. This allows us to enrich your experience and provide services that integrate with your online presence, subject to your consent and the privacy settings of those platforms.
3. Third parties — We may also receive personal information about you from third-party service providers or partners who assist us in delivering the Services, such as identity verification providers, analytics vendors, or customer support platforms. Additionally, in some cases, third parties might provide information related to you, for example, when you are referred to us or in connection with content or data shared by other users. 

When we collect your personal information, we may disclose it to certain categories of recipients strictly as necessary to provide, maintain, and improve our services and to comply with legal obligations. Such disclosures will be made only under lawful bases consistent with U.S. data privacy laws, including any applicable federal or state regulations. The categories of persons to whom we may disclose your personal information include:

1. Service providers and sub-processors
2. Vendor marketplace partners
3. Authorised family and community members 
4. Regulatory authorities 
5. Affiliates and business partners

We use cookies and similar tracking technologies to disclose information with our service providers and third-party partners for a variety of reasons, including to measure, target, and serve advertisements as further described in this Privacy Statement.

Under the laws in some U.S. jurisdictions, you have the right to opt out of our sharing of your personal information for online targeted advertising. Antlers does not sell or share your personal information for any purpose except as expressly stated in this Privacy Policy. You can learn more about our practices and the controls we provide you or opt out of certain types of such sharing by visiting our Cookie Policy. To change your preferences around targeted advertising, please visit our Do Not Sell or Share my Personal Information/Opt Out of Targeted Advertising page. 

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Exercising Your Rights

Right to Know - You may have the right to request that we disclose what personal Information we collect, use, disclose, or share. This includes the right to request the categories of personal information we have collected about you, the categories of sources of personal information, the business purpose for collecting, disclosing, or sharing personal information, the categories of third parties with whom we disclose or share categories of personal information, and the specific pieces of personal information we have collected about you.

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Right to Delete. You may have the right to request that we delete your Personal Information. You may submit a request to delete your own information either online or by email. To delete your Personal Information, you must delete your account and, once an account deletion request is completed, this process is irreversible. Your information (including family trees, records, photos, and DNA Data) will be permanently deleted.

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Authorised Agents. In applicable jurisdictions, U.S. residents can use authorised agents to make requests to know and requests for deletion. Even if you choose to use an authorised agent for a request, you may still need to work directly with us to provide:

• Signed permission allowing the authorised agent to act on your behalf.
• Verification of your identity (e.g., a copy of your government-issued ID, which will be used solely to verify your identity and address).
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Right to Appeal. Depending on where you live, if your request to know or delete your data is denied, you may have the right to appeal. You can do so by contacting us at [*]. Please incorporate the phrase “request for appeal” in the subject line and clearly state the specific reasons for your appeal. Your request will then be reviewed, and you will be informed of our decision.

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Right to Correct. You have the right to correct inaccurate personal information that we maintain about you. You can do so by visiting Account Settings or contacting us at [*].

If you are a California resident, California Civil Code Section 1798.83 provides you with the right to request, once per calendar year, certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes.

Specifically, upon receiving a verifiable written or electronic request from you, we will provide, free of charge, the following information covering the immediately preceding calendar year:

• The categories of personal information about you that we disclosed to third parties for their direct marketing purposes; and
• The names and addresses of those third parties.

If the nature of the third parties’ business is not reasonably clear from their name, we will provide examples of the types of products or services they market to give you a reasonable understanding of their business.

To make a request under this section, please contact us at:

• [Designated email address]
• [Designated mailing address]
• [Designated toll-free telephone number or fax number]

We will respond to your request within 30 days of receipt. Please note this right applies only to information disclosed for the third parties' direct marketing purposes and does not cover disclosures for other purposes, such as service providers who process information on our behalf but do not use it for their own direct marketing.

We do not disclose personal information to third parties for their direct marketing purposes unless you have affirmatively consented to such disclosure or exercised an option to prevent such disclosure, in accordance with applicable law.

Antlers undertakes to recognise, respect, and honour Global Privacy Control (GPC) browser signals that express a user’s preference to opt out of the sale or sharing of their personal data for targeted advertising or similar purposes. Antlers commits to processing such signals in full compliance with applicable laws, ensuring that user choices conveyed via GPC are implemented promptly and effectively. This includes refraining from any sale or sharing of Personal Data where a valid GPC signal has been received, unless otherwise permitted or required by law, and maintaining appropriate technical and organisational measures to uphold these user privacy preferences.

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Changes to this Privacy Policy

Antlers may update or modify this Privacy Policy at any time to reflect changes in legal requirements, business practices, or technological advancements. When significant changes are made, Antlers will provide notice to users by appropriate means, such as through the Antlers App, email, or other communication channels.

Continued use of the Antlers App or related services after such changes constitutes your acceptance of the updated Privacy Policy. We encourage users to review this Privacy Policy periodically to stay informed about how we protect and use personal data.

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Contact Information

Various federal, state, and local laws may protect your personal information. Residents of all states who believe that their personal information was used improperly may file a complaint with their attorney general or applicable regulatory body.

In every other case, if you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact us at:

• Email: dpo@antlersapp.com 
• Mailing Address: [insert physical mailing address]
• Phone: [insert telephone number]

We are committed to responding to your inquiries promptly and addressing your privacy-related concerns in accordance with applicable laws.

This Privacy Policy was last updated on [September 22, 2025]

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