Privacy Policy
Last updated 20 October 2026
Memorials hold some of the most personal things people share. This policy explains what data we collect, why, who we share it with, and the choices and rights you have.
1. Who is responsible for your data
The data controller is Pavla S.A., 5 Metsovou str., 10682 Athens, Greece (TIN 998279795, GEMI 007944701000), which operates Memorram. For anything about your personal data, contact info@memorram.com.
2. What we collect
When you create an account
- Your name, email address and password (stored only in encrypted, hashed form).
When you create a memorial
- What you choose to add: the name and dates of the person or pet remembered, their story, photos, videos, audio recordings and captions, and the memorial's visibility setting.
- Memorial content may include information about other people (for example family members shown in photos). Please only share what you have the right to share.
When you pay
- Your plan, billing period, amounts paid and invoice details. Card details are entered directly with Stripe; we only receive a reference to the payment and, where Stripe provides it, the card brand and last four digits.
When you contribute to a memorial as a visitor
- The name you enter, your message, and any photos, videos or audio you upload. These are shared with the memorial owner, who decides whether to publish them.
When you contact us
- Your name, email address and the content of your message.
When you browse the site
- Technical data needed to run the site securely, such as your IP address, browser type and the pages requested, recorded in server logs.
- Only if you agree: analytics and marketing data collected through cookies and similar technologies (see Cookie Policy).
3. Why we use it, and on what legal basis
| Purpose | Legal basis (GDPR art. 6) |
|---|---|
| Creating your account and memorials, hosting and showing your content, processing visitor contributions for your approval | Performance of our contract with you |
| Taking payments, renewing plans, sending receipts, renewal reminders and other service emails | Performance of contract |
| Keeping invoices and accounting records | Legal obligation (Greek tax law) |
| Keeping the service secure, preventing abuse and fraud, handling reports about content | Our legitimate interests |
| Answering your messages | Our legitimate interests / steps at your request before a contract |
| Analytics to understand and improve the site (Google Analytics) | Your consent |
| Measuring and personalising our advertising (Google Ads, Meta Pixel) | Your consent |
You can withdraw consent at any time through Cookie settings. This does not affect processing before the withdrawal. We do not sell your personal data, and we never use the content of memorials for advertising.
4. Who we share it with
We use trusted providers who process data on our behalf, under contracts that require them to protect it:
| Provider | What for | Location |
|---|---|---|
| Hetzner Online GmbH | Website hosting and file storage | EU (Finland) |
| Stripe Payments Europe Ltd. | Payment processing, invoices and the billing portal | EU (Ireland), with transfers to Stripe, Inc. (USA) |
| Twilio SendGrid | Sending service emails | USA |
| Google Ireland Ltd. | Google Analytics, Google Tag Manager and Google Ads — only with your consent | EU / USA |
| Meta Platforms Ireland Ltd. | Meta Pixel advertising measurement — only with your consent | EU / USA |
We may also disclose data where required by law or to protect our rights, and to professional advisers bound by confidentiality.
5. Transfers outside the EU
Some providers are based in, or use sub-processors in, the USA. In those cases transfers are covered by the EU–US Data Privacy Framework where the provider is certified, and/or by the European Commission's Standard Contractual Clauses.
6. How long we keep it
- Account data: while your account is open. When you ask us to close it, we delete it, except what we must keep by law.
- Memorials: while the memorial exists. When a plan ends, the memorial is kept offline for at least 12 months so you can reactivate it, then may be deleted after at least 30 days' email notice. Deleting a memorial removes its content immediately from the site.
- Visitor contributions: as long as the memorial they belong to, unless the owner or the contributor removes them earlier.
- Billing records: for as long as Greek tax law requires.
- Messages to us: up to 24 months after the conversation ends.
- Cookies: for the periods listed in the Cookie Policy.
7. Your rights
You can download a complete copy of any memorial you own at any time from your account (“Download everything”). You also have the right to access your data, have it corrected or deleted, restrict or object to its processing, receive it in a portable format, and withdraw consent at any time. To use any of these rights, email info@memorram.com; we will reply within one month. You also have the right to lodge a complaint with the Hellenic Data Protection Authority (dpa.gr) or the authority in your EU country.
8. Public and private memorials
- Private memorials can only be seen by their owner while signed in. They are never listed in our directory and are blocked from search engines.
- Public memorials can be seen by anyone with the link, may appear in our public memorial directory and can be found by search engines.
- Memorials whose plan has ended are taken offline for visitors.
- The link for contributing to a memorial is not indexed by search engines; anyone you send it to can leave a tribute for your approval.
9. Children
Accounts are for adults (18+). Visitors under 15 may only contribute to a memorial with a parent's or guardian's permission. If you believe a child has given us personal data without permission, contact us and we will delete it.
10. Security
We protect your data with encrypted connections (HTTPS), hashed passwords, access controls and providers that meet recognised security standards. No system is perfectly secure, so please use a strong, unique password.
11. Cookies
Essential cookies keep you signed in and protect forms. Analytics and marketing cookies are only used if you agree. Details are in our Cookie Policy, and you can change your choice at any time in Cookie settings.
12. Changes to this policy
We will update this page when our practices change and email account holders about significant changes.