Privacy Policy

1. Data controller

The controller of personal data is ELITSON LIMITED, company number 2832922 (Hong Kong). Data-protection contact: [email protected].

The person responsible for organising the processing of personal data is the Seller’s principal; enquiries go to [email protected]. The Seller applies reasonable technical and organisational safeguards: encryption in transit (TLS), restricted access to data, and regular backups.

2. Purposes of processing

• creating and maintaining a remembrance page or a life-story page ordered by the user;
• transcribing voice recordings and preparing text drafts using AI technologies — at the user’s request;
• user registration, authentication and account support;
• accepting and processing payments, fulfilling plaque and printed-book orders, and delivery;
• sending service messages (confirmations, order notifications) by email;
• responding to enquiries and providing support;
• securing the service and preventing abuse;
• sending marketing messages — only with separate consent.

3. Categories of data

• name and contact details (phone, email);
• remembrance-page content: the deceased’s name and details, biography, photos, video and audio, burial location;
• life-story content about a living person: voice recordings of answers, transcripts, chapter texts, photos;
• family-tree data about relatives (names, years of life, family relationships);
• order and delivery data (plaque or book delivery address);
• sign-in data from Google, Apple or Telegram, if you choose to sign in that way: your name, your email address (Apple may give a forwarding address) and your account identifier at that provider. We receive nothing else from them and never gain access to your account there;
• technical data: IP address, device identifiers, cookies.

4. Voice recordings and AI technologies

Voice recordings the user makes to create a biography or life story are sent to a third-party AI technology provider solely for transcription and preparation of a text draft. The service does not store the audio after processing — only the text the user has accepted is kept. Under the terms of the API used, the provider does not use the transmitted data to train its models.

5. Data about third parties and the deceased

A user who posts data about other people (living relatives, a gift recipient, the subjects of a story) confirms they are entitled to do so and, where required, have obtained those people’s consent. A living person whose data has been posted on the service may request its removal by contacting the controller.

Regarding a deceased person’s data, their close relatives or heirs may contact the controller.

6. Legal bases

Processing rests on the performance of the contract with the user (Art. 6(1)(b) GDPR), on the user’s consent (Art. 6(1)(a)), on the Seller’s legal obligations (Art. 6(1)(c)) and on the Seller’s legitimate interests in securing the service and preventing abuse (Art. 6(1)(f)). Consent is recorded with its date and may be withdrawn at any time by contacting the controller; withdrawal does not affect processing carried out before it.

7. Retention

Remembrance-page and life-story-page data is kept while the user’s order is active and no deletion request has been made. Account data is kept for the life of the account. On the subject’s request, data is exported or deleted, except records the controller must retain by law (for example, payment records, for the period set by tax law).

8. Data-subject rights

A data subject may access their data and obtain a copy of it, have it corrected or deleted, restrict or object to its processing, receive it in a portable format, withdraw consent, and lodge a complaint with the data-protection authority of their country of residence. Requests are answered within 30 (thirty) days. To exercise these rights, use the contact below.

9. Subprocessors and data transfer

Third-party processors are engaged to deliver the service. The service’s servers and database are located in the European Union; some processors are located outside the European Economic Area and the United Kingdom, in particular in the United States. Transfers to those processors rest on the European Commission’s standard contractual clauses (with the UK addendum where applicable), included in the processors’ data-processing terms, or on an adequacy decision. The subprocessors are:

• a hosting provider — server and database hosting (European Union);
• a cloud media-storage and delivery (CDN) provider — photos, video and audio (EU/USA);
• an AI technology provider — transcription of voice recordings and preparation of text drafts (servers in the EU/USA);
• an email service provider — sending service emails (USA);
• a print contractor — printing ordered books (receives the book layout and delivery data only when a printed book is ordered);
• a payment provider — processing bank-card payments (EU/USA);
• an SMS/OTP provider — phone-number verification, where a phone number is used to sign in;
• an advertising and analytics provider — measuring advertising effectiveness: receives a hashed phone number and email address, IP address, browser data and advertising click identifier (EU/USA).

For users in Kazakhstan and Uzbekistan: by using the service, you consent to the processing and cross-border transfer of your personal data to the subprocessors above in accordance with this Policy. Consent may be withdrawn by contacting the controller; withdrawal may make further provision of the service impossible.

10. Cookies

The service uses cookies necessary for the site to work and for authentication, as well as advertising and analytics cookies that help measure the effectiveness of advertising. You can manage cookies in your browser settings; declining advertising cookies does not affect how the service works.

On the pages of the site we collect visit statistics: which pages you opened and in what order, where you arrived from, your device and browser type, your approximate city from your IP address, and how you moved through the page: what you tapped and how far you read. This is so we can see what is unclear on the site. Your name, your phone number and whatever you type into a form field are not sent into these statistics. On a memorial page and on story pages nothing is collected at all.

11. Contact

For any personal-data question, email [email protected].