Privacy Policy Memorians App

Updated on April 11, 2026

This Privacy Policy applies to your use of the Memorians app and the digital memorial service that accompanies it. The policy explains which personal data we process, why we do so, with whom we share data, how long we retain data, and what rights you have.

1. Who We Are

Data Controller

Memorians B.V.

Molenstraat 125-B

5701KB Helmond

The Netherlands

Chamber of Commerce number: 97458910

For privacy questions or requests, you can contact us at: ln.snairomemobfsctd-965ed0@ycavirp

2. No Traditional User Account

The Memorians app does not require a traditional user account with username and password.

To enable the Service to function, we may process data linked to a device, app instance, memorial, product activation, scan moment, shared memorial page, or support request.

Even when this data does not directly identify you by name, it may still qualify as personal data if it can be linked to an individual or household.

Therefore, we do not describe the Service as fully anonymous. Where possible, we limit the use of personal data and work with technical or pseudonymized identifiers.

3. Which Personal Data We Process

Depending on how the Service is used, we may process the following categories of personal data:

Memorial Content: photos, videos, audio files, written memories, names, dates, relationship indicators, tributes, and other content provided to create, display, or manage a memorial.
Device and App Usage Data: app instance identifiers, device type, operating system, app version, language, timestamps, scan moments, activation status, and limited technical or diagnostic data needed to operate and secure the Service.
Support and Communication Data: when you contact us, we may process your name, email address, order or memorial reference, device information, and the content of your message.
Transaction or Fulfillment-Related Data: where relevant, we may process order references, reseller references, activation data, product-related support information, and limited purchase-related data.
Shared or Public Memorial Content: if the Service allows sharing a memorial or tribute via a link or making it visible to others, we process the content and metadata needed to enable that sharing.

4. Why We Process Personal Data and on What Basis

We only process personal data when there is a valid legal basis for doing so.

Performance of a Contract: for providing the Service you requested, including storing and displaying memorial content, linking content to a physical product or activation flow, enabling access to a memorial, and offering core app functionality.
Legitimate Interest: for limited technical, diagnostic, support, and security-related processing necessary to operate, secure, improve, troubleshoot, and defend the Service, provided your interests and rights do not outweigh these interests.
Consent: where legally required, for optional features such as optional marketing communications or optional notifications that are not necessary to provide the Service.
Legal Obligation: when we must process or retain data to comply with applicable legislation, tax rules, administrative obligations, fraud prevention, or requests from competent authorities.

5. Processing Purposes

We use personal data for the following purposes:

providing and operating the Service;
storing, organizing, displaying, and managing memorial content;
activating or supporting the use of a Memorians product or memorial experience;
ensuring security, preventing abuse, resolving errors, and improving reliability;
responding to support requests and privacy requests;
complying with legal obligations and conducting or defending legal claims;
sending optional communications when a user has validly opted in.

6. Private and Shared Content

Some memorial content is private by default. Other content may be deliberately shared by a user via a specific link, memorial page, or other sharing functionality.

Users may only upload or share content they are authorized to share. If uploaded materials contain images, audio, video, or personal data of living persons, the user is responsible for lawfully sharing them.

We advise users not to share sensitive or private information publicly unless they clearly intend to do so.

7. Sensitive Content

Memorial content may contain deeply personal or sensitive information, such as information about grief, health, religion, family relationships, or other private matters.

Users are responsible for ensuring they have the right to provide content to the Service. If we become aware of unlawful, infringing, or clearly inappropriate content, we may restrict access to or remove the content in accordance with our Terms of Service and applicable law.

8. With Whom We Share Personal Data

We do not sell personal data.

We may only share personal data where necessary with the following categories of recipients:

service providers who help us operate the Service, such as hosting, storage, infrastructure, diagnostics, communications, or support providers;
business partners or resellers, but only where relevant for fulfillment, activation, or customer support;
professional advisors, such as legal, administrative, or compliance advisors;
government authorities or other parties when disclosure is legally required or necessary for establishing, exercising, or defending legal claims.

When third parties process personal data on our behalf, we strive to implement appropriate contractual and security measures.

9. International Transfers

Some service providers may process personal data outside the European Economic Area.

When personal data is transferred outside the European Economic Area, we use, where necessary, a valid transfer mechanism under applicable law, such as an adequacy decision, Standard Contractual Clauses, or another appropriate safeguard.

10. Retention Periods

We do not retain personal data longer than necessary for the purposes described in this Privacy Policy, unless a longer retention period is legally required or permitted.

In general terms:

Memorial Content is retained as long as the relevant memorial remains active within the Service, unless it is deleted earlier following a valid request or based on an internal retention policy.
Technical and Diagnostic Data is only retained as long as reasonably necessary for security, troubleshooting, analytics, and Service integrity.
Support Correspondence is retained as long as reasonably necessary to handle the request and maintain a record of the resolution.
Legal, Tax, Administrative, and Dispute-Related Data may be retained for the period required by law or reasonably necessary to substantiate or defend legal claims.

Backups may continue to exist for a limited period before being overwritten in the normal course of business.

11. Security

We take appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

No method of transmission or storage is completely secure. While we take appropriate measures to protect personal data, we cannot guarantee absolute security.

12. Your Rights

Subject to applicable law, data subjects may have the following rights:

access to their personal data;
correction of inaccurate personal data;
deletion of personal data;
restriction of processing;
objection to certain processing;
data portability where applicable;
withdrawal of consent, where processing is based on consent.

Data subjects may also have the right to lodge a complaint with a competent supervisory authority.

13. How to Exercise Your Rights

Because the Service does not use a traditional account with username and password, we may need additional information to identify the relevant memorial, product, device, app instance, or support history before we can process a request.

You can exercise your rights via: ln.snairomemobfsctd-2c0f21@ycavirp

Where possible, please provide:

your name and contact details;
the memorial, product, or order reference;
the email address used in previous contact with us;
the details of your request;
other information that can help us identify the relevant record.

We may reasonably request additional information to verify your identity and prevent unauthorized disclosure, deletion, or modification of memorial content.

14. Children

The Service is not intended for children under 16 years of age without the involvement of a parent or legal guardian.

If we learn that personal data has been unlawfully provided by a child in a situation where consent was required, we will take reasonable steps to delete that data.

15. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. If we make material changes, we will publish the updated version and adjust the “Updated on” date. Where legally required, we will provide additional notice.

16. Contact

For questions, concerns, or privacy requests, you can contact: