Privacy Policy
How we use and protect your personal data
Last updated: 17 September 2026
1. Data controller
The controller of personal data processed through lifemory.eu is TOP GUIDE S.R.L., tax ID CIF 54815518, trade register no. J2026036188000, registered office at Str. Calea Roșiori nr. 104, Sat Văcărești, Comuna Drăgănești de Vede, jud. Teleorman, 147132, România. For any question about your data, email support@lifemory.eu or call 0779 243 541 (Monday–Friday, 09:00–18:00 Romanian time).
We process data in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Romanian law.
2. What data we process, why and on what legal basis
| Data | Purpose | Legal basis (Art. 6 GDPR) |
|---|---|---|
| Name, email, password (encrypted), login data | creating and managing your account | performance of a contract – Art. 6(1)(b) |
| Name, delivery and billing address, phone, email, products ordered, amount paid | processing, making and delivering your order; invoicing | performance of a contract – Art. 6(1)(b); legal obligation – Art. 6(1)(c) |
| IP address and approximate country/town derived from it, when an order is placed and for unpaid orders (abandoned baskets) | preventing fraud and unauthorised payments; contacting you to complete an order you started | legitimate interests – Art. 6(1)(f) |
| Memorial page content (photos, texts, videos, audio) and details of people invited to contribute | hosting and displaying the memorial page | performance of a contract – Art. 6(1)(b) |
| Messages sent by chat, email or phone; name and email given in the chat; country and an encrypted identifier (hash) of the IP address | answering requests, support, protection against abuse | performance of a contract / pre-contractual steps – Art. 6(1)(b); legitimate interests – Art. 6(1)(f) |
| Text sent to AI features (text correction, voice playback, chat message translation) | providing the feature you requested | performance of a contract – Art. 6(1)(b) |
| Technical data: browser and device type, pages visited, server logs | operating and securing the website | legitimate interests – Art. 6(1)(f) |
| Usage statistics via Google Analytics 4 | audience measurement | consent – Art. 6(1)(a), given in the cookie banner |
We do not sell personal data and do not use it for automated decisions that produce legal effects concerning you.
3. Who we share data with
We use service providers (processors) that handle data only on our instructions and under contract:
| Provider | Purpose | Location / safeguards |
|---|---|---|
| Vercel Inc. | website hosting, technical logs | USA and EU – EU-US Data Privacy Framework, standard contractual clauses |
| Supabase Inc. | database, accounts and authentication | servers in the EU (Frankfurt, Germany) |
| Cloudflare Inc. | DNS, website protection, email forwarding, storage of uploaded files | EU and USA – Data Privacy Framework, standard contractual clauses |
| Stripe Payments Europe Ltd. | card payment processing | Ireland (EU) |
| Resend | sending order emails and notifications | USA – standard contractual clauses |
| OpenAI | AI features (text correction, voice, chat message translation) | USA – standard contractual clauses |
| Courier companies | delivering physical products (name, address, phone) | Romania and the destination country (EU member state) |
| Google Ireland Ltd. (Google Analytics 4) | usage statistics, only with your consent | EU and USA – Data Privacy Framework |
| GeoJS | determining the approximate country/town from the IP address of orders | USA – standard contractual clauses |
We disclose data to public authorities only where the law requires it. Public memorial pages can be seen by anyone who has the link or scans the QR code; private pages are accessible only to the people you give access to.
4. Transfers outside the European Economic Area
Where a provider processes data outside the EEA (for example in the USA), the transfer relies on a European Commission adequacy decision (including the EU-US Data Privacy Framework) or on standard contractual clauses approved by the Commission. You can request a copy of these safeguards at support@lifemory.eu.
5. How long we keep data
- invoices and accounting records: 10 years, as required by Romanian Accounting Law No. 82/1991;
- your account and memorial page: for as long as the account is active; after you ask for deletion, data is deleted within 30 days at the latest (except data we are legally required to keep);
- support messages (chat and email): up to 3 years after the last message;
- unpaid orders (abandoned baskets), including the IP address: up to 30 days;
- technical logs containing IP addresses: up to 12 months;
- Google Analytics data: up to 14 months.
6. Your rights
- the right of access to your data;
- the right to rectification of inaccurate data;
- the right to erasure (“right to be forgotten”);
- the right to restriction of processing;
- the right to data portability;
- the right to object, including to processing based on legitimate interests;
- the right to withdraw your consent at any time, without affecting processing carried out before withdrawal.
To exercise your rights, email support@lifemory.eu. We reply within one month at the latest.
You have the right to lodge a complaint with the Romanian supervisory authority, the National Supervisory Authority for Personal Data Processing (ANSPDCP), 28-30 G-ral. Gheorghe Magheru Blvd., Sector 1, Bucharest – www.dataprotection.ro. If you live in another EU/EEA country, you may also contact the data protection authority in your country of residence (in the United Kingdom: the Information Commissioner’s Office, ico.org.uk).
7. Data about deceased people
The GDPR does not apply to the data of deceased people. However, memorial pages may also contain data about living people (relatives, friends) in photos or texts. Please publish such content only with their agreement. Anyone who appears on a page can ask us at support@lifemory.eu to remove their data.
8. Cookies
Analytics cookies are used only with your consent. Details and the full list are in our Cookie Policy.
9. Data security
We use encrypted connections (HTTPS), access controls and providers that apply recognised security measures. If a personal data breach occurs that poses a risk to you, we notify ANSPDCP and, where required, the people affected, in accordance with Articles 33–34 GDPR.
10. Children
The Services are not intended for people under 16. If we learn that we have collected data from a child under 16 without parental consent, we delete it.
11. Changes
We may update this policy. The current version is published on this page with the date of the last update.
12. Contact
TOP GUIDE S.R.L., Str. Calea Roșiori nr. 104, Sat Văcărești, Comuna Drăgănești de Vede, jud. Teleorman, 147132, România · support@lifemory.eu · 0779 243 541.