Updated on May 5, 2026
Privacy policy
A life leaves traces. We exist to keep them safe. This page explains, plainly and precisely, how we do that.
Who we are
The e-memory platform (the “Service”) is operated by Sole Proprietor (ФОП) Maryna Repekh, registered in Ukraine under tax ID (РНОКПП) 3418408086, with registered address at Keletska St. 51-A, apt. 101, Vinnytsia, Ukraine (м. Вінниця, вул. Келецька 51-а, кв. 101). For the purposes of the EU General Data Protection Regulation (GDPR) and the Ukrainian Law on Personal Data Protection, we are the data controller for the personal data we process about you.
You can reach us at team@e-memory.app for any privacy question.
What we collect
We collect the following categories of personal data:
Account data — your name, email address, hashed password, and account preferences.
Memorial content — photos, videos, audio, music, text tributes, and other material you upload to a Memorial Page. This typically includes personal data about the deceased Subject and may include personal data about living people depicted in the content.
Subscription and payment data — your plan, billing status, and transaction history. We do not see or store your payment-card details; these are handled directly by our Merchant of Record (see Section 5).
Communications — messages you send us at team@e-memory.app or through in-app channels, including support tickets and family-objection notices.
Technical data — IP address, device type, browser, operating system, language, approximate location (city-level, derived from IP), the pages and features you use within the Service, and the times you use them. Collected primarily through cookies and similar technologies — see Section 9 and our Cookie Policy.
Successor designations and verification documents — if you nominate a Successor, we store the Successor's name and contact; if a Successor activates access, we retain the documents you supply (death certificate, ID, proof of authority) for the period required by law.
Why we use it, and on what legal basis
Under GDPR Article 6, we rely on the following legal bases:
Performance of a contract (Art. 6(1)(b)) — to provide the Service to you, host your Memorial Pages, handle subscriptions and renewals, deliver Successor access, and respond to support requests.
Legitimate interests (Art. 6(1)(f)) — to keep the Service secure, prevent fraud and abuse, improve our product through aggregated analytics, enforce our Terms, and communicate operational updates. You can object to processing on this basis at any time.
Consent (Art. 6(1)(a)) — for any optional features that require it (such as non-essential cookies or marketing emails). You can withdraw consent at any time, with no effect on processing done before withdrawal.
Legal obligation (Art. 6(1)(c)) — to comply with Ukrainian, EU, or other applicable law, including tax and accounting obligations and lawful requests from authorities.
A note about memorial content
The GDPR does not, on its face, protect personal data of deceased persons. Ukrainian law and the law of several EU Member States do offer post-mortem dignity and personality-rights protection. Living people depicted in memorial content (for example, a family group photograph) remain fully protected under data-protection law.
When you upload content to a Memorial Page, you are responsible for ensuring you have a lawful basis to do so, including any consent required from living persons depicted. We treat all memorial content with discretion and only process it to provide the Service.
We do not use memorial content to train artificial-intelligence models, for advertising, or to enrich third-party data products. AI-assisted features inside the Service (for example, photo restoration) process content only on your instruction and do not retain it for any model-training purpose.
Who we share data with
We share personal data only with a small set of trusted parties, each of which acts under contract and with appropriate safeguards:
Merchant of Record — Lemon Squeezy LLC handles all payment processing, sales-tax collection, and refunds. They are an independent controller of payment data and operate under their own privacy policy.
Hosting and infrastructure — hosting provider, e.g. Amazon Web Services processes data on our behalf to operate the Service.
Email and transactional messaging — email provider, e.g. Postmark delivers account, billing, and notification emails on our behalf.
Analytics — we use [analytics provider, e.g. Plausible / privacy-preserving analytics] to understand aggregate product usage. We do not use Google Analytics or other ad-tech-linked analytics for memorial content.
Customer support tools — if applicable, [help-desk provider].
Law enforcement and authorities — only where we are legally required, and where possible we notify you first.
Successors and authorised family members — once a Successor request is verified under our Terms, the Successor receives access to the relevant Memorial Pages and account data.
We do not sell your personal data. We do not share memorial content with advertisers or with AI-model training operations.
International transfers
We are based in Ukraine. Depending on the providers we use, your data may be processed in Ukraine, the European Economic Area, the United Kingdom, or the United States. Where we transfer personal data outside your country of residence to a jurisdiction without an adequacy decision, we rely on appropriate safeguards under GDPR Chapter V — typically Standard Contractual Clauses with our providers, supplemented where necessary by additional technical and organisational measures. You can request a summary of the safeguards in place by writing to team@e-memory.app.
How long we keep data
Account data — for as long as your account is active, plus up to 12 months after you close it (in case you re-open or need account-history records), then deleted.
Memorial content — for as long as the relevant Memorial Page exists. If a subscription lapses, content follows the staged retention rules in Section 7 of the Terms of Use (30 days fully accessible, 60 days read-only, 6 months archived, then deleted), subject always to backup rotation in the ordinary course.
Payment data — held by our Merchant of Record under their retention policy; we retain transaction summaries for tax and accounting purposes for the period required by Ukrainian law (currently 3 years from the date of the transaction; longer where another law applies).
Successor-verification documents — retained for as long as the Successor relationship is active, then deleted within 12 months of the relationship ending, unless we are required to retain longer.
Technical logs — typically retained for 30 to 90 days for security and debugging, then deleted or aggregated to anonymous form.
Backups — overwritten in the ordinary course, typically within 90 days of deletion of the underlying record.
Your rights
If GDPR or the Ukrainian Law on Personal Data Protection applies to you, you have the right to:
Access the personal data we hold about you;
Correct data that is inaccurate or incomplete;
Erase data (the “right to be forgotten”), subject to legal exceptions;
Restrict or object to certain processing;
Receive a portable copy of data you provided to us;
Withdraw any consent you previously gave;
Lodge a complaint with a supervisory authority — in Ukraine, the Ukrainian Parliament Commissioner for Human Rights (Ombudsman); in the EU, your local Data Protection Authority.
To exercise any of these rights, write to team@e-memory.app. We will respond within 30 days. We may ask you for identifying information to verify the request — we do this to protect your data from impersonation.
California, Virginia, Colorado, Connecticut, Utah, and other US state residents: where applicable law grants you analogous rights (to know, to delete, to correct, to opt out of sale or sharing, to non-discrimination), you may exercise them by writing to the same address. We do not sell or share personal data within the meaning of these statutes.
Cookies and similar technologies
We use cookies and similar local-storage technologies for authentication, security, basic preferences, and limited privacy-preserving analytics. We ask for your consent before setting non-essential cookies. For details and to manage your preferences, see our Cookie Policy.
Children
The Service is for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has created an account, please write to team@e-memory.app and we will delete it. Memorial content about minors (for example, a young niece in a family photograph) is processed on the lawful basis under which you uploaded it and is subject to the family-objection and takedown procedure described in our Terms.
Security
We apply reasonable technical and organisational measures to protect personal data — encrypted connections (HTTPS/TLS), encrypted storage of memorial content, access controls, separation of payment data with our Merchant of Record, and standard backup practices. No internet service is completely secure; we strongly encourage you to keep your own copies of any irreplaceable memorial content. If a breach affects your personal data and the law requires notification, we will notify you and the relevant supervisory authority without undue delay.
Changes to this policy
We may update this Privacy Policy from time to time. Material changes — for example, a new category of recipient or a new processing purpose — will be notified at least 30 days in advance by email or in-app notification. Non-material changes (corrections, clarifications) take effect when posted. The “Last updated” date at the top of this page always reflects the current version.
Contact
Privacy queries: team@e-memory.app
Sole Proprietor Maryna Repekh
Keletska St. 51-A, apt. 101, Vinnytsia, Ukraine
Tax ID: 3418408086