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This Privacy Policy describes how Memento (“us” or “we” or “our” or “the Company”) collects, uses, and discloses your Personal Information when you visit www.memento.com and/or use our web or mobile application. We are committed to protecting your privacy and processing your data in a fair and transparent manner.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information, such as your:
Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
We will respect and protect your privacy as set out in this Privacy Policy. We will share your personal data with third parties only in the ways that are described in this Privacy Policy - and do not and will not sell your personal data.
The Company may share your personal data with select third parties, only with your express consent or under another lawful basis for processing under the applicable law.
Third parties with which we may share your personal data include vendors such as host and cloud service providers, marketing and mailing agencies, and sub-contractors involved in the fulfilment of our contractual obligations towards our clients. The legal basis for this processing is Art. 6(1)(f) GDPR.
We use Pipe Video Recording to record, transcode, and store video (with audio) recordings to enable our video greeting card service. For further details, please see Pipe's privacy policy by clicking on this link.
Amazon CloudFront is a web service of Amazon Web Services (“CloudFront”) that speeds up distribution of static and dynamic web content such as .html, .css, .js, and image files, to users. CloudFront delivers content through a worldwide network of data centers called edge locations. When a user requests content that is being served with CloudFront, the user is routed to the edge location that provides the lowest latency (time delay), so that content is delivered with the best possible performance.
CloudFront captures information about each request that includes system logs which captures the following information: IP address, lat/long of the server which served the request, country and date and time. More information about AWS's privacy practices can be found here.
We use the Facebook Pixel product of Facebook Inc. on our website. With its help, we can keep track of what users do after they see or click on a Facebook advertisement. This enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found here. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes.
Please click here if you would like to withdraw your consent
Our website uses Google Analytics, a web analysis service of Google Inc.. Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.
Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.
Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.
Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.
You can find additional information on how to install the browser add-on referenced above here.
For the cases in which personal data is transferred to the US, Google has self-certified pursuant to the EU-US Privacy Shield.
Google Tag Manager (GTM”) is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behaviour: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website to include the following tracking tools (as in described earlier in this policy):
If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM’s privacy practices can be found here and terms of use here.
We use a third party payment processor, Stripe, for all payments. We do not store credit card details and instead rely on Stripe for this.
We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed here.
We may disclose personal information to:
The personal information we collect is stored and processed in the United States and Canada, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.
Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Deletion: You may request that we delete the information we have collected about you at any time by emailing us at privacy@memento.com. Please note that in certain circumstances, we may not be able to completely remove your information from our systems. For example, we may retain your information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law or as retained in our data backup systems or cached or archived pages, or where the burden or expense of accommodating your request would, in our good faith judgment, be disproportionate to the risks to your privacy, or where the rights of others may be violated. All retained personal information will continue to be subject to the terms of the Privacy Policy to which the User has previously agreed.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
At our discretion, we may change our Privacy Policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.
If we make a significant change to this Privacy Policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended Privacy Policy.
We welcome your comments regarding this Privacy Policy. If you believe that the Company has not adhered to this Privacy Policy, please contact our Privacy Team and Data Protection Officer at privacy@memento.com.
This policy is effective as of June 8, 2021.
