Privacy policy

Denvo LLC, 1209 Mountain Road Pl NE, Ste N, Albuquerque, NM 87110, United States

Denvo LLC is a Limited Liability Company (LLC) under the law of New Mexico, USA and is established outside the European Union. The GDPR applies all the same, because Memorabley is offered to people in the EU (Art. 3(2) GDPR).

We have not designated a representative in the Union under Art. 27 GDPR.

Email: contact@memorabley.com

We have not designated a data protection officer.

When you create a page, we store what you enter: the recipient's name, the sender, your message and the blocks (notes, photos, videos, voice memos, songs and places). Every page gets an address and a secret edit link. Anyone who knows the address can view the page; anyone who knows the edit link can change it.

You can also protect a page with a password. It then shows its content only after the password has been entered. Of the password we store only a hash that cannot be reversed. The password protects the page itself: photos, videos and voice memos remain reachable at their direct address, and anyone who knows the edit link sees the content without the password and can change or remove it. To guard against guessing we count password attempts per page and per caller; for that we derive a value from the IP address that cannot be reversed.

You can invite people to write along. There is a separate invite link for that. Whoever follows it enters a name; we store this name with the page and show it at the blocks that person adds. People writing along get a personal link with which they can add, change and delete blocks, but nothing else. Of the personal link we store only a hash that cannot be reversed. A new invite link replaces the old one; people who already joined stay. A page is a draft until it is published: only then can it be seen at its address. Drafts nobody has changed for 90 days are deleted together with the files that belong only to them.

Pages are not listed publicly and are marked so that search engines do not index them.

Apart from GIF files and smaller PNG files, we save every photo again before it is uploaded (PNG files from 2.5 MB, or longer than 2000 pixels on their longest side, and for photos in the places block longer than 1600 pixels); this removes embedded metadata such as the location where the photo was taken. GIF files, smaller PNG files, videos and voice memos are uploaded unchanged; videos may contain metadata such as the recording location.

A published page is online for 30 days, counted from the moment the recipient first opens it; we store that moment. After that the page can no longer be reached, we keep it for another 12 months and then delete it. Pages with Premium, with “Keep forever”, from a subscription and pages from before the plans existed stay until they are deleted. You can delete a page in the app on the device you created it on, or by emailing us. When the page goes, the files that belong only to it go with it, on very large pages up to 150 of them at first. Files you take out of the page while editing stay reachable at their address until we remove them.

The legal basis is the performance of our agreement with you (Art. 6(1)(b) GDPR).

A gift page can hold data about you that you did not enter yourself: your name, photos, videos or a voice memo. It comes from the person who created the page.

We do not go through the content and we do not have your contact details, so we cannot notify you ourselves (Art. 14(5)(b) GDPR). We review content when a page is reported.

The legal basis is our legitimate interest in showing a personal gift the way it was meant (Art. 6(1)(f) GDPR). Whether the content may be shown at all is the responsibility of the person who created the page.

If you want something about you gone, write to contact@memorabley.com with the address of the page. We look at it and remove what has to be removed.

The website and its server functions are operated by Vercel Inc. (USA); server functions run in Frankfurt am Main. Uploaded files are kept in Vercel's file storage (Vercel Blob); Vercel decides where those files are stored, and that can be outside the EU. The database is operated by Supabase Inc. (USA).

Vercel and Supabase process this data as processors on the basis of their respective data processing terms. Where those providers are certified under the EU-US Data Privacy Framework, a transfer to the USA relies on the European Commission's adequacy decision, otherwise on the Commission's standard contractual clauses (Implementing Decision (EU) 2021/914). You can request a copy of the safeguards at contact@memorabley.com.

When you visit, the host processes technically necessary data such as your IP address, the time and your browser identifier in order to deliver the page and fend off attacks (Art. 6(1)(f) GDPR).

The controller is a company established in the United States. Server functions and the database run in the EU, which is not necessarily true of the uploaded files; the data can also be accessed from the United States. The United States has no data protection law equivalent to the GDPR, and the remedies against access by authorities are weaker than in the EU.

We count page views and editor steps with our own statistics, without cookies and without storing anything on your device. We do not store your IP address: from your IP address and browser identifier we derive a value that changes daily and cannot be reversed. We store the events themselves (such as which page or editor step was opened, with the time, the order, the active time spent and the scroll depth, and details about the gift such as design, occasion and number of blocks), a random session identifier, the identifier of the gift page that was opened, the entry page and its language, a marker for recognised bots, device type, browser and operating system as rough categories, the window size, the website you came from, and campaign parameters from the link (utm_source, utm_medium, utm_campaign, utm_content). From the host's location data we keep country, region and city for everything that happens in a browser (the app's browser window included), and only the country for events the app sends itself.

The app counts the same way, without storing anything for it on your device: which screens and editor steps you open, whether you share or invite, and how you move through the choice of plans, together with the platform (iOS or Android) and the app version. For a purchase, on the website and in the app, the statistics keep what was bought (plan, kind of purchase, amount, currency, payment channel and whether it was a test purchase), tied to the session in which the purchase began, but without a name, email address or payment details. So that the session survives the trip to the checkout, we pass its random identifier to Stripe; it sits with the payment and tells Stripe nothing about you.

We keep the statistics for 90 days after the last event of a session; after that a daily job deletes the session with all its events.

This helps us improve Memorabley (legitimate interest, Art. 6(1)(f) GDPR). When you look at your own page in the app, we do not count it as a gift opened; the page view itself is counted.

Gift pages can show content from other providers. Your IP address and technical data are then sent to that provider:

• YouTube (Google Ireland Limited) and Vimeo (Vimeo.com, Inc.): your device loads a linked video's still image from the provider as soon as the page opens; the player (for YouTube via youtube-nocookie.com) is only embedded once you tap play.
• Spotify (Spotify AB): your device loads a song's album cover from Spotify's image server when the page opens. When there is no preview clip, Spotify's player is shown there as well.
• Apple (Apple Inc.): when there is a preview clip, your device only loads it from Apple once you tap play; opening the page sends no request to Apple.
• Mapbox (Mapbox, Inc.): map data for the places block.

The legal basis is our legitimate interest in showing the content as it was chosen (Art. 6(1)(f) GDPR).

When you search for a place, your search term goes to Open-Meteo (geocoding-api.open-meteo.com). For a song's preview clip we look up title and artist in Apple's catalogue (iTunes Search); in the browser and in the app this happens directly from your device. We check Spotify links with Spotify through our server. Your device loads a found song's cover directly from Spotify or Apple.

When someone reports a page, they send us its address, a reason and optionally a description and an email address for questions. To detect abuse, we store a value derived from the IP address that changes daily. A daily job deletes the description, the email address and that value 90 days after the review is closed.

The legal basis is our obligations as a hosting provider under Regulation (EU) 2022/2065 (Digital Services Act) (Art. 6(1)(c) GDPR) and our legitimate interest in a safe service (Art. 6(1)(f) GDPR).

You only need an account for the subscription. You sign in with your email address and get a code by email; there is no password. We store your email address, an account id, your sign-ins (a non-reversible hash of the session key, the kind of device, start, end and the day of last use) and which gift pages belong to your account. Sign-in runs on Supabase's authentication service; the email with the code is sent by Resend (Resend, Inc., USA) as a processor.

If you delete your account, we delete the account, your sign-ins and every gift page of the account with the files that belong only to them. Records of purchases remain, without anything that names you. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

On the website you pay through Stripe (Stripe Payments Europe, Limited, Ireland, and Stripe, Inc., USA). You enter payment details such as the card number directly at Stripe; we never see them. Stripe tells us that and what was paid, the amount, the identifiers of the payment and the email address you gave there; we send the order confirmation to it. For a subscription, Stripe keeps you as a customer under the email address of your account.

In the app you buy through Apple's App Store. RevenueCat (RevenueCat, Inc., USA) helps us with that as a processor: RevenueCat receives a customer id (a random id of the app or your account id) and what the store says about your purchases. Neither RevenueCat nor we receive payment details.

For every purchase we store a record: what was bought, when, through which provider, its identifier of the payment, the amount, and which gift page and account the purchase belongs to. We keep records for as long as legal retention duties require, also after a page or an account was deleted, then without anything that names you. Order confirmations and the emails around a subscription are sent by Resend for us.

The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and, for keeping the records, a legal obligation (Art. 6(1)(c) GDPR). For transfers to the United States, what is said under “Hosting and storage” applies.

On the website, your browser keeps an unfinished draft locally (localStorage) so it survives a reload; a technically necessary cookie may be set for your language choice. When you open a password-protected gift page with the right password, your browser remembers that with a technically necessary cookie for 30 days, also in the browser window of the app, so you do not have to enter the password on every visit. Once a page is a draft on our server, your browser remembers its edit link and the recipient's name locally, so you find your way back to it the next time you start creating; the entry expires after 90 days and is deleted when you publish. When you join through an invite link, we store a technically necessary cookie in your browser with your personal link for writing along, for one year; it is named after a non-reversible hash of the invite link. That way the invite link later takes you back to writing along instead of letting you join a second time.

The app keeps the list of your gifts and an unfinished draft on the device, and the edit keys and personal links for writing along in the keychain or keystore. The app only asks for the microphone when you record a voice memo; you choose photos and videos with the system picker, and the app only sees what you select. We do not use advertising IDs, and we do not track you across other apps or websites.

When you sign in on the website, your browser stores a technically necessary cookie with your session key, for 60 days or until you sign out. Next to it sits a second technically necessary cookie without any key, which only records that someone is signed in in this browser, so that the header shows the link “My gifts”; it lasts just as long. When you go to the checkout, your browser remembers with a technically necessary cookie for two hours which order it started, so that only this browser is led back to your page afterwards. So that your own look at your page does not start its time online, your browser remembers locally which pages you created or wrote along on. When you open a gift page someone else sent you, your browser remembers its address locally (50 at most), so you find it again under “Your gifts”; you can remove any entry there. The app keeps the session key of your account in the keychain and remembers on the device which purchases are still on their way.

You have the right to access, rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interests. Write to us at contact@memorabley.com or at the address above.

You can also lodge a complaint with a data protection supervisory authority: the one where you live, where you work or where the alleged infringement took place (Art. 77 GDPR). In Germany these are the state data protection commissioners, in Austria the Datenschutzbehörde (dsb.gv.at), in Spain the Agencia Española de Protección de Datos (aepd.es).