Privacy Policy

1. Who we are

Memorias the Service is operated by Malenko Rostyslav, registered sole proprietor (ФОП) in Ukraine, tax ID 2604802573, registered address Dniprovs'ka naberezhna 19v, Kyiv 02081, Ukraine.

Contact for privacy questions, account deletion, and data subject access requests: supportme@memorias.io.

For the purposes of EU and UK GDPR we are the data controller for the personal data you provide directly to us (account, purchase, and support data) and the processor or joint controller for the memoir content you upload (see §4).

We are not required to designate a Data Protection Officer under GDPR Art. 37, but supportme@memorias.io is the single point of contact for all data protection matters.

2. What this policy covers

This policy describes:

• What personal data we collect;
• Why we collect it and what we do with it;
• Who we share it with (our sub-processors);
• How long we keep it;
• What rights you have over it and how to exercise them.

It applies to everyone who uses Memorias — website visitors, registered users, and people mentioned in other users' memoirs. If you are a person who has been written about in someone else's memoir and wants to know or change how we handle data about you, jump to §10.

3. Data we collect

Data you provide directly. Your email address and an internal account identifier. If you sign in with Google, we receive your name, email address, and profile picture. If you choose to fill in profile fields: a display name, locale, and timezone.

Payment data. Handled entirely by our payment partner (see §6). We receive only a purchase reference and credit-quantity metadata; we never see your full card number, expiry, or CVC.

Content you upload. Audio recordings of your voice describing your memories, and the photographs you add to your book. We store photographs at a size of up to 4096 pixels on the longer side, which is enough to print the book. If your file is larger, we reduce it and do not keep the original file; reducing removes the embedded data about where and when the photo was taken. If a file already fits within this size, it is kept exactly as you uploaded it, together with its embedded data.

Content you create. Transcripts, extracted story atoms, chronologies, questions and answers, and book drafts — all derived from the audio you upload.

Support correspondence. Emails and messages you send us.

Technical and usage data. IP address, browser type and version, operating system, device type, timestamps of requests, and which features you used or which errors occurred. Retained for up to 90 days for security and debugging.

Cookies and local storage. Strictly necessary session cookies for authentication and your language preference. We do not use advertising cookies or any cookie that profiles you across other sites.

Website analytics (Matomo). We use Matomo, an analytics tool we host ourselves on our own server in Germany (EU); no data goes to a third-party analytics company. On our public pages (home, legal, contact, accessibility, sign-in and sign-up) it records page visits; inside your account it records only three events — account created, payment completed (with its amount), and book assembly started — without the address of the page you were on. Before storage the last two bytes of your IP address are removed, so your full IP address is never stored. Raw visit data is deleted after 30 days; only aggregated statistics are kept. We do not link visits to your Memorias account and do not build a profile of you across other websites. Analytics cookies are set only if you allow them in the cookie banner (see §13); without that, Matomo works without cookies.

Your memoir will usually mention other people — family members, friends, colleagues, strangers. These people are data subjects in their own right. When you upload that audio we process personal data about them. See §8 of our Terms of Service (your obligations) and §10 below (their rights).

Memorias recordings often contain information classed as "special category" personal data under GDPR Art. 9 — for example health events, religious beliefs, political opinions, or information about family relationships. We process this data only because you explicitly choose to upload it and give us explicit consent to process it for the purpose of producing your memoir. This consent is the sole legal basis for this processing; you may withdraw it at any time by deleting the affected content or your account (§11).

4. Why we process your data (legal bases)

Under the GDPR and UK GDPR our processing rests on the following lawful bases:

• Creating and maintaining your account — Contract (Art. 6(1)(b));
• Transcribing your recordings and editing them into your memoir — Contract (Art. 6(1)(b)) and explicit consent for special category data (Art. 9(2)(a));
• Processing purchases of Memorias Credits — Contract and legal obligation (tax, accounting), payment data processed by our payment partner;
• Fighting abuse, fraud, and keeping the Service secure — Legitimate interest (Art. 6(1)(f));
• Responding to your support messages — Contract and legitimate interest;
• Complying with legal obligations — Legal obligation (Art. 6(1)(c));
• Understanding how visitors use our public pages, through self-hosted, non-profiling website analytics (Matomo, see §3) — Legitimate interest (Art. 6(1)(f)).

5. How we do not use your data

We want to be specific about things we do not do, because they are common in our industry and users reasonably ask:

• We do not sell your data to anyone.
• We do not share your data with advertisers or data brokers.
• We do not use your content to train artificial intelligence models. Not our own, not third-party. Anthropic, OpenAI and Deepgram contractually or by configuration exclude your content from model training (see §6). DeepSeek does not: its API terms do not commit to excluding customer content from training, and we have no separate agreement with it. DeepSeek is used only on the Standard tier; choose Premium if you do not want your transcript sent to DeepSeek.
• We do not currently train, fine-tune, or condition AI models on user content. If we ever decide to do so, we will notify you at least 30 days in advance by email and require your explicit opt-in before using any of your content. You will always be able to decline without losing access to the Service.
• We do not read your memoir recordings ourselves except in narrow, necessary cases — for example, you ask us for support and provide a specific recording, we must investigate a report of abuse or illegal content, or we are required by valid legal process. Internal access is logged.

6. Who we share data with (sub-processors)

To run the Service we use third-party providers. They process your data on our behalf and are bound by data-processing agreements restricting them to the purposes we specify — except DeepSeek, which is bound only by its published API terms (see §5).

• DeepSeek (China) — language models that edit your transcript into chapters (Standard tier). International transfer notice: DeepSeek is based in the People's Republic of China, which does not have a European Commission adequacy decision. We rely on DeepSeek's commercial API terms, which do not exclude your content from model training (see §5); no data-processing agreement or Standard Contractual Clauses are in place. This is the one sub-processor relationship that involves a transfer outside the EU/UK's adequacy framework; we call it out explicitly rather than bundling it with the others.
• Anthropic (US) — language models (Claude) that edit your transcript into chapters (Premium tier); the automatic fallback when a Standard-tier request cannot be completed by DeepSeek; and the interview assistant ("biographer") on all tiers (on Standard currently as a temporary arrangement). Anthropic can therefore process content from any book, not only Premium-tier ones. Commercial API terms; data not used for training; Standard Contractual Clauses for transfers outside the EEA.
• OpenAI (US) — primary speech-to-text transcription, text-to-speech that reads questions aloud (the question text, up to 5000 characters, is sent), and text embeddings for semantic search over your story atoms. Business API terms; data not used for training; Standard Contractual Clauses.
• Deepgram (US) — fallback speech-to-text transcription, used only when the primary provider is unavailable. We send Deepgram's `mip_opt_out` flag on every request, which excludes your audio from its model-improvement program.
• Amazon Web Services (AWS) — S3 object storage for audio, photographs, transcripts, book files, and data exports. Production storage is in Frankfurt, Germany (eu-central-1). Our development environment, which is not open to the public, uses us-west-2 (US). CloudFront is the content-delivery network for signed download URLs. AWS Customer Agreement and Data Processing Addendum.
• Hetzner Online GmbH — primary application server and database hosting, Germany (EU); encrypted database backups in Hetzner Object Storage, Helsinki, Finland (EU). Data Processing Agreement; GDPR-compliant processor located inside the EU.
• Backblaze, Inc. (United States) — encrypted off-site backup copy of production storage. Data is encrypted on our side before transfer; Backblaze cannot read it. EU-US Data Privacy Framework participant; Data Processing Addendum.
• Cloudflare (US/EU edge) — reverse proxy, DNS and bot protection (Turnstile) in front of the site. Every request to the Service passes through it, so it sees your IP address and request metadata, and the Turnstile token on the sign-up, sign-in and contact forms. Cloudflare Customer Data Processing Addendum; Standard Contractual Clauses.
• Armitage Labs OÜ — Merchant of Record for all purchases; invoicing; VAT and sales tax collection. Creem is the controller for payment data under its own privacy terms (privacy notice).
• Resend (US) — transactional email delivery: account verification and password reset, welcome message, draft-ready and export-ready notices, subscription renewal, cancellation and payment-failure notices, low-balance and credit-expiry warnings, audio-retention and unfinished-book reminders, processing-failure notices, and deletion confirmations. Sending domain memorias.io. Data Processing Addendum with Standard Contractual Clauses.
• Support e-mail (supportme@memorias.io) — received on our own mail server, hosted at Hetzner (EU), not by a third-party mail provider.

We review this list whenever we add or remove a sub-processor. Material changes will be notified by email where your content is affected.

You can request copies of our international-transfer safeguards at supportme@memorias.io.

7. How long we keep your data

• Account and profile data — until you close your account; after a 30-day restoration window it is deleted per §11;
• Audio recordings — until you delete them, until account closure, or 12 months after the last activity in the book (a recording or an assembly) if you have not purchased Family Archive (see the Terms of Service §5);
• Transcripts and derived content — same as audio, but survive audio deletion so a book can be reassembled;
• Paid transaction records — while your account is open they are the basis of your credit balance and are kept; after the account is deleted they are kept for up to 3 years from the transaction date, linked only to an internal pseudonymous account number with no name or contact details, and then deleted. Our payment partner separately retains invoices for the period its own tax obligations require;
• Support correspondence — up to 3 years after last contact;
• Application and technical logs — up to 90 days;
• Some records are kept indefinitely without your name or contact details: usage metering (AI and speech-to-text usage records) is fully anonymized; the e-mail delivery log, the deletion audit (which keeps the book title) and QR permalinks to public book pages stay linked to an internal pseudonymous account number;
• Backups that contain deleted content — kept up to 31 days in our encrypted off-site backup, then permanently deleted.

After the retention period we permanently delete or irreversibly anonymize your data from our primary systems.

8. Where your data is stored

• Production audio, transcripts, and your books: AWS S3, Frankfurt, Germany (eu-central-1), delivered via AWS CloudFront. Our non-public development environment uses us-west-2 (US).
• Structured data (database): Hetzner Cloud, Germany; encrypted database backups: Hetzner Object Storage, Helsinki, Finland (EU).
• Encrypted off-site backup of production storage: Backblaze B2, United States; the data is encrypted on our side before transfer.
• AI processing: happens transiently on Anthropic, DeepSeek, OpenAI, and Deepgram infrastructure (DeepSeek in China; the others in the US); your content is sent, processed, and results returned, with no long-term retention beyond what each provider's terms describe. We do not train models on it; of these providers, only DeepSeek does not commit to excluding it from its own training (see §5).
• Authentication: our own application infrastructure on Hetzner Cloud, Germany, plus Google's infrastructure if you sign in with Google.

9. Security

We take reasonable technical and organizational measures to protect your data:

• TLS (HTTPS) in transit for all connections;
• Encryption at rest for object storage;
• Access to production systems is limited to the operator and restricted via SSH keys;
• Credentials and API keys are stored as environment variables, not in source code;
• Automated backups;
• Rate limiting and abuse detection on authentication endpoints.

No service is perfectly secure. If a breach occurs that is likely to result in a high risk to your rights, we will notify you within 72 hours of becoming aware of it — a stricter, self-imposed commitment than GDPR Art. 34 requires (which sets no fixed deadline for notifying individuals, only "without undue delay"; the 72-hour clock in GDPR Art. 33 applies to notifying the supervisory authority).

10. Your rights

If you are in the EU, EEA, UK, or any jurisdiction with comparable privacy law, you have the following rights. We honor these rights for all users globally as a matter of policy, even where local law does not require it.

• Right of access. You can request a copy of the personal data we hold about you.
• Right of rectification. You can request that we correct inaccurate data.
• Right of erasure ("right to be forgotten"). You can request that we delete your data. See §11 for how this works.
• Right to restriction. You can request that we pause processing while a dispute is resolved.
• Right to data portability. You can request a machine-readable export of the data you provided to us.
• Right to object. You can object to processing based on legitimate interest.
• Right to withdraw consent. Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing that happened before withdrawal.
• Right to lodge a complaint. You can complain to the data protection authority in your country (for Ukraine: the Ukrainian Parliament Commissioner for Human Rights; for the EU: your national DPA; for the UK: the ICO).

How to exercise your rights. You can delete your account and download an export of your data yourself in your account settings (the "Data & privacy" section). For these and all other requests you can also email supportme@memorias.io with your request and the email address associated with your account; we handle those requests directly and respond within 30 days (extendable by a further 60 days for complex requests, in which case we will tell you). We may ask you to verify your identity before acting on a request.

If you are mentioned in someone else's memoir, you can request that we delete or restrict processing of data about you even if you are not the account holder who uploaded it. Email supportme@memorias.io with your name and any other identifying information the memoir might use, a description of the content you believe contains your data, and any context that helps us locate it. We will investigate, notify the account holder, and — where the legal balance weighs in favor of erasure — remove or redact the relevant portions. Certain limited exceptions may apply (for example, journalistic or literary expression protected under GDPR Art. 85).

11. Deletion

You can delete your account and download an export of your data yourself in your account settings (the "Data & privacy" section), or request either by emailing supportme@memorias.io from your account address; we handle email requests directly and complete verified deletion requests within 30 days. If you delete the account in the app, it is closed immediately; for 30 days we can restore it if you ask, after which your data is erased permanently.

When your account is deleted:

• All story atoms, transcripts, Biographical record entries, questions, sessions, and draft books are deleted from our primary database;
• Your audio recordings, transcript files, and book files (EPUB, PDF, DOCX) are deleted from storage;
• Any pending AI processing tasks in our queue are canceled.

Certain records are retained after deletion in pseudonymized form — linked to an internal account number, with no name, e-mail or other contact details — because law requires it or because they support refund and chargeback investigations: transaction records are kept for up to 3 years from the transaction date and then deleted; paid invoices are held by Creem (our Merchant of Record) for the period its own tax obligations require — Creem is the controller for this data, contact them directly via its privacy notice for requests relating to those records.

Backups containing your data are overwritten in the normal course of backup rotation; the encrypted off-site copy is kept up to 31 days, then permanently deleted. We do not manually scrub backups — this is industry-standard practice.

12. Children

Memorias is not intended for users under 16. We do not knowingly collect data from anyone under 16. If you believe a child under 16 has created an account, please contact supportme@memorias.io and we will delete the account and associated data.

13. Cookies and local storage

Today we set two kinds of cookies. Strictly necessary cookies: a cookie that marks that you are signed in, a cookie that remembers your language preference, and a cookie that records your cookie choice itself (so we don't ask again on every visit). All three are required for the Service to work and are exempt from consent under the EU ePrivacy rules (Directive 2002/58/EC, Art. 5(3)).

Analytics cookies (Matomo) are set only if you accept them in the cookie banner shown on your first visit — see §3 for exactly what Matomo records. If you decline, or close the banner without choosing, Matomo keeps working without ever setting a cookie. We keep your choice for 182 days (about 6 months), after which we ask again — a period we follow as a recommended good practice from France’s data protection authority (CNIL). You can change your mind at any time: click "Cookie settings" in the footer of any page to reopen the banner and accept, decline, or fine-tune analytics cookies.

We do not use advertising cookies, tracking pixels, or third-party analytics that profile you across sites.

14. California residents (CCPA / CPRA)

If you are a California resident you have additional rights under the California Consumer Privacy Act, as amended by the CPRA:

• The right to know what personal information we have collected;
• The right to delete your personal information;
• The right to correct inaccurate personal information;
• The right to opt out of the sale or sharing of personal information — we do not sell or share personal information as those terms are defined in the CCPA;
• The right to limit the use of sensitive personal information.

To exercise these rights, email supportme@memorias.io. We will not discriminate against you for exercising them. The categories of personal information we collect are listed in §3 of this policy.

15. Changes to this policy

We may update this policy. Material changes will be announced by email to the address on your account at least 30 days before they take effect. Non-material changes (typos, clarifications, sub-processor list additions) take effect on publication and are tracked in the version history at the top of this document.

16. Contact

Privacy questions or requests: supportme@memorias.io.

Operator: Malenko Rostyslav, registered sole proprietor (ФОП) in Ukraine, tax ID 2604802573, registered address Dniprovs'ka naberezhna 19v, Kyiv 02081, Ukraine.

If you are in the EU and believe your rights have been violated, you can also complain to your local data protection authority. A directory is maintained at https://edpb.europa.eu/about-edpb/about-edpb/members_en.