1. Introduction

1.1 This Privacy Policy explains how Memorii Ltd (“Memorii”, “we”, “us” or “our”) collects, uses, shares and protects personal data when you use the website at www.amemorii.com and our related services.

1.2 Memorii provides personalised digital eCards and digital memory books created from content supplied by users, including content added by invited contributors.

1.3 We are committed to protecting your personal data and handling it in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable law.

1.4 Please read this Policy together with our Terms and Conditions and our Cookie Policy.

2. Who We Are and How to Contact Us

2.1 Memorii is the data controller responsible for your personal data, except where we act as a processor as described in Section 8.

2.2 If you have any questions about this Policy or wish to exercise your rights, you can contact us at [Legal/Privacy Contact Email] or by post at [Registered Address].

2.3 [If applicable: We have appointed a data protection point of contact who can be reached at the details above.]

3. Scope of This Policy

3.1 This Policy applies to personal data we process about: customers who create or purchase products; contributors invited to add content; visitors to our website; and third parties whose personal data is contained in content uploaded by users.

3.2 Where you upload content featuring other people, please see Section 7, which explains the shared responsibility for that data.

4. Personal Data We Collect

4.1 We collect and process the following categories of personal data:

Account and identity data: name, email address, and account credentials;
Content data: messages, stories, photographs, images and other content you upload, which may contain personal data about you and about others;
Contributor data: the name, email address or other details of contributors invited to add content, and the content they submit;
Transaction data: records of purchases and orders (we do not collect or store full card details, which are handled by our payment provider);
Communications data: correspondence with us, including support requests;
Technical and usage data: IP address, device and browser information, and information about how you use the website, collected via cookies and analytics as described in our Cookie Policy;
Marketing data: your preferences in receiving marketing from us.

5. How We Collect Your Personal Data

5.1 We collect personal data: directly from you when you create an account, upload content, make a purchase or contact us; from contributors when they add content; automatically through cookies and similar technologies when you use the website; and from third-party providers such as our payment and analytics providers.

6. How We Handle Uploaded Messages, Photos and Content

6.1 Content you upload, including messages, stories and photographs, is stored and processed so that we can create, format, store and deliver your personalised product and provide the service.

6.2 This content may contain personal data, including images of identifiable individuals and information about them. We process this content on your behalf to provide the service, and to keep your completed products available while your account remains active.

6.3 We do not use the content of your messages, stories or photographs for advertising, and we do not sell it.

7. Personal Data of Third Parties in Your Content

7.1 Where content you upload contains personal data about other people, including contributors and individuals featured in photographs, you are responsible for ensuring you have a lawful basis and any necessary consent to share that data with us for the purposes of the service.

7.2 In respect of such content, we generally act as a processor acting on your instructions, while you act as controller. We process that data only to provide the service, as described in this Policy and our Terms.

7.3 If you are an individual whose personal data has been uploaded by another user and you wish to exercise your rights, please contact us and we will assist and, where appropriate, direct your request to the relevant user.

8. Legal Bases for Processing

8.1 We rely on the following legal bases under Article 6 of the UK GDPR:

Performance of a contract: to create and deliver your product, manage your account and process orders;
Legitimate interests: to operate, secure, maintain and improve the service, prevent fraud and misuse, and communicate with you about the service, provided our interests are not overridden by your rights;
Consent: for marketing communications and for non-essential cookies and analytics, and for any special category data where required;
Legal obligation: to comply with our legal and regulatory obligations, including record-keeping and responding to lawful requests.
8.2 Where content may contain special category data (for example data revealing health or beliefs shown in a memory), we rely on your explicit consent or another applicable condition, and you are responsible for ensuring a lawful basis for third-party data you upload.

9. How We Use Your Personal Data

9.1 We use personal data to: create and deliver personalised products; operate and secure the service and your account; process payments through our payment provider; provide customer support; send service-related communications; send marketing where you have consented; understand and improve how the service is used; detect and prevent fraud, abuse and unlawful content; and comply with legal obligations.

10. Marketing Communications

10.1 We will only send you marketing emails where you have given consent or where otherwise permitted by law. You can withdraw consent or unsubscribe at any time using the link in any marketing email or by contacting us.

10.2 Withdrawing consent to marketing does not affect service-related communications necessary to provide the service, such as order confirmations.

11. Cookies and Analytics

11.1 We use cookies and similar technologies, including Google Analytics, to understand how the website is used and to improve the service. Non-essential cookies are only set with your consent.

11.2 Full details of the cookies we use, their purposes and how to manage them are set out in our Cookie Policy.

12. Who We Share Your Data With

12.1 We share personal data with trusted third parties who process it on our behalf or provide services to us, including:

Stripe, our payment provider, to process payments securely;
Google, in connection with analytics services;
hosting, infrastructure, email and IT service providers who support the operation of the service;
professional advisers, and regulators or authorities where required by law.
12.2 We require our processors to protect personal data and to process it only on our instructions and in accordance with applicable law.
12.3 We may disclose personal data where required to comply with a legal obligation, enforce our Terms, protect our rights or the safety of others, or in connection with a business reorganisation, merger or sale.

13. International Data Transfers

13.1 Some of our providers, including our payment and analytics providers, may process personal data outside the United Kingdom.

13.2 Where we transfer personal data outside the UK, we ensure an appropriate safeguard is in place, such as transfer to a country subject to UK adequacy regulations, or the use of the UK International Data Transfer Agreement or the Addendum to the EU Standard Contractual Clauses.

13.3 You can contact us for more information about the safeguards we use for a particular transfer.

14. How Long We Keep Your Data

14.1 We retain your account data, content and created products for as long as your account remains active, so that you can access and re-access your memories.

14.2 When you close your account, or when you make a valid deletion request, we will delete or anonymise your personal data and content within a reasonable period, except where we are required to retain certain data to comply with legal obligations, resolve disputes or enforce our agreements.

14.3 Residual copies may remain in secure back-ups for a limited period before being overwritten in the ordinary course.

15. How We Protect Your Data

15.1 We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration.

15.2 No method of transmission or storage is completely secure, and while we take reasonable steps to protect your data, we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

16. Your Rights Under UK GDPR

16.1 Subject to conditions and exceptions in law, you have the right to:

be informed about how your data is used;
access the personal data we hold about you;
request correction of inaccurate or incomplete data;
request erasure of your data (the right to be forgotten);
restrict or object to processing, including processing based on legitimate interests and processing for direct marketing;
data portability, to receive your data in a structured, commonly used, machine-readable format;
withdraw consent at any time where we rely on consent; and
not be subject to solely automated decision-making with legal or similarly significant effects.

17. How to Exercise Your Rights

17.1 To exercise any of your rights, including a request to delete your data, contact us at [Legal/Privacy Contact Email]. We may need to verify your identity before responding.

17.2 We will respond to valid requests without undue delay and within one month, which may be extended by up to two further months for complex or numerous requests, in which case we will let you know.

17.3 Exercising your rights is normally free of charge, but we may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive.

18. Deletion of Content and Memories

18.1 You may request deletion of specific content or of your account and all associated content at any time. We will action valid deletion requests as described in Section 14.

18.2 Please note that once content or a product is deleted it cannot be recovered. We recommend you download any product or content you wish to keep before requesting deletion or closing your account.

19. Children's Privacy

19.1 The service is intended for users aged 18 and over. We do not knowingly collect personal data from children in the course of account registration.

19.2 Content uploaded by users may feature children; where it does, the uploading user is responsible for having the consent of a person with parental responsibility, as set out in our Terms. If you believe we hold data about a child that should be removed, please contact us.

20. Automated Decision-Making and Profiling

20.1 We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. If this changes, we will update this Policy and, where required, obtain your consent.

21. Personal Data Breaches

21.1 We maintain procedures to detect, report and investigate personal data breaches. Where a breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office and, where required, affected individuals, in accordance with our legal obligations.

22. Third-Party Websites and Services

22.1 The service may link to or rely on third-party websites and services with their own privacy practices. We are not responsible for the privacy practices of those third parties, and we encourage you to review their policies.

23. Changes to This Policy

23.1 We may update this Policy from time to time. The current version will always be available on the website with the date it was last updated.

23.2 Where changes are material, we will take reasonable steps to notify you.

24. Complaints and the ICO

24.1 If you have a concern about how we handle your personal data, please contact us first so we can try to resolve it.

24.2 You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at ico.org.uk, or by calling their helpline.

25. Contact Us

25.1 For any questions about this Policy or your personal data, contact us at [Legal/Privacy Contact Email] or by post at [Registered Address], quoting “Privacy Enquiry”.

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