Privacy Policy

1. Controller and definitions

The controller of personal data is Sites Reais — Soluções de Internet, Lda., legal person no. 505 349 488, with registered office at Rua Nuno Álvares 311, 4420-516 Valbom, Portugal, which operates the Memorea brand and the memorea.pt website (hereinafter, “Memorea”).

Any questions concerning the protection of personal data, including the exercise of the rights set out in section 10, may be sent to geral@memorea.pt or made by telephone on +351 912 453 297. Memorea is not required to designate a data protection officer under Article 37 GDPR and has not made such a designation.

For the purposes of this policy:

• “Data Subject” means the natural person to whom the personal data relate;
• “Visitor” means anyone who accesses the public pages of the memorea.pt website;
• “Guest” means anyone who uses the application of an event, accessible by QR code or link;
• “Client” means anyone who requests a proposal for, or contracts, the service;
• “Host” means the person or entity organising the event (the couple, a company or an organisation), who may be the same as the Client;
• “Backoffice” means the restricted area, accessible only with authentication, where Memorea and the Hosts manage the events.

2. General principles

• The website contains no advertising and no social media plug-ins. Audience measurement, through Google Analytics, is carried out exclusively on the public pages and only with consent; never on the pages of events.
• Without consent, neither the public pages nor the event application set cookies or communicate with Google. The event application stores on the Guest’s device only the entries needed for it to work, described in section 4 and in the Cookie Policy.
• Memorea does not sell, rent or transfer photographs or contact details to third parties, nor does it use them to train artificial intelligence models.
• Memorea does not carry out facial recognition or any other processing of biometric data.
• Event photographs are deleted from Memorea’s servers 90 days after the date of the event, without prejudice to the Data Subject’s right to request their earlier deletion.

3. Visitors to the memorea.pt website

Viewing the home page, using the price calculator and reading the legal pages do not involve the disclosure of data to third parties, unless the Visitor consents to audience measurement. The website does not include social media plug-ins, and fonts are served from Memorea’s servers, so the browser does not contact Google or any other entity to obtain them. The price calculator’s calculations are carried out locally, on the Visitor’s device, and the values entered are not transmitted.

As is inherent to its operation, the server that delivers the pages records the IP address, the date and time and the request made, in order to ensure that the service works and to detect abusive use. The legal basis is Memorea’s legitimate interest in the availability and security of the service (Article 6(1)(f) GDPR). These records are deleted after 14 days.

Audience measurement, subject to consent. On the home page and the legal pages, a notice is shown, until the Visitor responds, with two equally prominent options: “Decline” and “Accept”. If there is no response, or if consent is declined, no measurement takes place and the browser does not contact Google. If consent is given, Google Analytics is used on those pages:

• Entity processing the data: Google Ireland Limited, acting as Memorea’s processor, which may transfer the data to Google LLC, in the United States of America. The applicable safeguard is set out in section 8.
• IP address: according to information from Google, Google Analytics does not log or store the IP address, using it only to determine the approximate location, after which it is discarded.
• No advertising purposes: the data are not used for advertising purposes. Google Signals and ad personalisation are disabled, and Google’s advertising signals are always sent as declined.
• Event pages excluded: measurement never takes place on the pages of an event — the Guest application, the gallery or the projector mode —, even if consent was given on the home page. The referring address is sent without the part after the “?” character and, where it is another website or an event page, limited to the domain, so the name of an event is never disclosed to Google.
• Retention: a maximum of 14 months in Google Analytics (section 7). The two cookies remain in the browser for 13 months, as described in the Cookie Policy.
• Withdrawal of consent: may be made at any time, without giving reasons, through the “Cookie preferences” option in the footer or through the Cookie Policy. Transmission stops immediately and the Google Analytics cookies are deleted from the browser. Withdrawing consent does not affect the lawfulness of processing carried out beforehand, the data from which are kept until the end of the period indicated above.

Apart from audience measurement, where consented to, the only means of collecting data on the website is the contact form, and only when the Visitor fills it in and selects “Send request”. The data thus transmitted are processed under section 5.

4. Guests at an event

When the Guest accesses the page of an event (by QR code or link) and chooses to take part, the following data are processed:

Optional participation. The Guest may attend the event without using the application. Use of the application requires acceptance of the Terms and Conditions and giving a name or, at restricted-access events, signing in with the e-mail address in the list or with the personal link received in the invitation. Taking and sending photographs, including them in the gallery (which may be switched off through the “Add to the event Gallery” option before sending), answering the forms that the Host does not make mandatory and receiving notifications are optional. Consent is given through the act of sending and may be withdrawn at any time, without giving reasons and free of charge, by writing to geral@memorea.pt. Withdrawing consent does not affect the lawfulness of processing carried out beforehand, nor does it cover photographs already printed on paper, which remain in the possession of whoever received them.

Restricted-access events. Where the Host so decides, only the people in the list of participants provided by the Host can access the application. These data are not collected from the Guest but from the Host, who is responsible for informing the participants and for the lawfulness of the list. Memorea uses them solely for the purposes indicated above and sends the Host’s messages from Memorea’s mailbox, each with the personal link to access the event.

Notifications. Event announcements are only sent to the device after the Guest has authorised them on the device itself, an authorisation that may be withdrawn at any time in the browser or system settings. Delivery is carried out by the notification service of the maker of the Guest’s browser (namely Apple, Google or Mozilla), which receives the message encrypted and has no access to its content.

Storage on the device. The application keeps in the browser’s local storage only what it needs to work: the random identifier referred to above (which does not allow the Guest to be identified), the name given, the access session for restricted-access events, the language and appearance chosen, the announcements already read and the acceptance of the Terms and Conditions at each event. They are not cookies: they are not automatically sent with each request and are deleted when browsing data are cleared. Each entry is described in the Cookie Policy.

No audience measurement. Google Analytics is not loaded on event pages, even if consent was given on the home page, and the event application does not set cookies. No information about the use of the event application is disclosed to Google.

People shown in other people’s photographs. Anyone who appears in a photograph sent by another Guest may request its removal from the gallery, without giving reasons and without having to identify themselves, simply by indicating the photograph concerned.

5. Clients and requests for proposals

In connection with a request for a proposal or the contracting of the service, the name, e-mail address, telephone number, type and date of the event are processed, together with any other information provided by the Client, in order to respond to the request and prepare the service. The legal basis is the taking of steps prior to entering into a contract and, subsequently, the performance of the contract (Article 6(1)(b) GDPR). If the request does not lead to a contract, the contact details are deleted after 24 months.

Requests submitted through the form are stored on Memorea’s server, located in Germany, and consulted in the Backoffice; a copy is also kept, in the form of an e-mail message, in Memorea’s mailbox, hosted by Amen in the European Union. These data are not transferred outside the European Union or disclosed to other recipients.

Where there is a contract, billing data are kept for 10 years, in compliance with legal tax obligations (Article 6(1)(c) GDPR), and cannot be deleted at the Data Subject’s request during that period.

To manage the event, the Client is given access to the Backoffice, for which the name, e-mail address, encrypted password (never stored in readable form) and the date of last access are processed, for as long as the account remains active.

6. Processing of photographs

A photograph is personal data of every person identifiable in it and may reveal information beyond the image itself. Accordingly, Memorea follows these rules:

• Removal of metadata. The photograph shown in the gallery is recompressed by Memorea, losing the original EXIF metadata in the process — including GPS location, if the device recorded it. Of the EXIF metadata, only the time the photograph was taken is kept, for ordering purposes.
• Private nature of the gallery. Each event’s gallery is available at its own address, accessible by QR code or link, and search engines are asked not to index it. Memorea does not publicise it, and the gallery does not include Google Analytics or any other third-party tool.
• Copy delivered to the Host. If the Guest authorises sharing, the original file — without a frame and with whatever metadata it contains — is delivered to the computer connected to the printer, owned by the Host, for the Host’s use.
• Projector mode. During the event, the gallery may be shown on a screen visible to the Guests.
• Excluded processing. Memorea does not carry out facial recognition, emotion detection, profiling, advertising, sale or transfer to third parties, nor does it use the photographs to train artificial intelligence systems. Photographs are not used in Memorea’s promotional materials without written authorisation, given specifically for that purpose.

7. Retention periods

Backups. Deleting a photograph at the Data Subject’s request takes immediate effect in the gallery and on the server; the photograph may, however, remain in a backup already made until the end of the respective period, a maximum of 14 days. Backups are only accessed in order to restore the service in the event of a failure.

8. Recipients and international transfers

The recipients of personal data are exclusively those indicated in the following table. The service providers identified in it act as processors, processing the data on Memorea’s behalf, under a contract entered into for that purpose, and may not use them for their own purposes. The Host receives the data relating to the respective event, thereby becoming the controller for any processing it carries out with them.

Transfers outside the European Union: on the website and in the event application, Memorea makes a single transfer, and only with consent to audience measurement. The platform — website, application, database, photographs and backups — is hosted on a server located in Germany, and e-mail is hosted by Amen in the European Union. The exception is Google Analytics: Google Ireland Limited may transfer audience measurement data to Google LLC, in the United States of America. The transfer is covered by the EU-U.S. Data Privacy Framework, to which Google LLC has adhered and in respect of which the European Commission adopted an adequacy decision on 10 July 2023. Without consent no transfer takes place, as the browser does not even contact Google. Data relating to events (photographs, names and questions) are not disclosed to Google. Notifications, where authorised by the Guest, are delivered by the notification service of the maker of the Guest’s browser, which may be located outside the European Union and receives the message encrypted, with no access to its content (section 4). Any change to this arrangement will be reflected in this section, with an indication of the applicable safeguard, before it takes effect.

The data may also be disclosed to public authorities, where required by law, and to legal representatives or courts, for the establishment, exercise or defence of a right in legal proceedings. Apart from these cases, there is no other disclosure.

9. Security measures

Memorea applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, under Article 32 GDPR, in particular:

• Encryption of all communications (HTTPS) between the user’s device, Memorea’s server and the event printer;
• Storage of Backoffice passwords as a cryptographic hash, which does not allow them to be read, not even by Memorea itself;
• Personal access to the Backoffice, with sessions that expire after 7 days;
• Hosting of the server in a data centre in the European Union, with daily backups;
• Isolation of each event’s gallery and exclusion of its indexing by search engines.

In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, Memorea notifies the CNPD within 72 hours of becoming aware of it and, where the risk is high, also communicates it to the affected data subjects, under Articles 33 and 34 GDPR.

10. Rights of data subjects

Under Articles 15 to 22 GDPR, the Data Subject has, at any time, the right to:

• Access: obtain confirmation that their data are being processed and a copy of them;
• Rectification: obtain the correction of inaccurate or incomplete data;
• Erasure: obtain the deletion of their data, including photographs and name;
• Restriction and objection: obtain the restriction of processing or object to processing based on legitimate interest;
• Portability: receive the data they provided in a structured, commonly used and machine-readable format, or request that they be transmitted to another controller;
• Withdrawal of consent: withdraw the consent given, without affecting the lawfulness of processing carried out beforehand.

Requests should be sent to geral@memorea.pt. Memorea responds within one month of receipt of the request, free of charge. Additional information necessary to confirm the identity of the requester may be requested, for the sole purpose of preventing the disclosure of data to unauthorised third parties.

If the request is not granted, Memorea informs the Data Subject of the reasons. The Data Subject also has the right to lodge a complaint with the supervisory authority:

CNPD — Comissão Nacional de Proteção de Dados (the Portuguese Data Protection Authority)
Av. D. Carlos I, 134, 1.º — 1200-651 Lisboa
+351 213 928 400 · geral@cnpd.pt · cnpd.pt

11. Minors

Under Article 16 of Law No. 58/2019 of 8 August, minors may give consent to the processing of their personal data in relation to the direct offer of information society services from the age of 13. Below that age, consent is given by the holders of parental responsibility.

Since events may be attended by minors, who may appear in photographs, and since Memorea is unable to verify the age of Guests, the Host is informed that it is responsible for obtaining the agreement of the holders of parental responsibility. In addition, any request to remove a photograph of a minor, made by whoever exercises parental responsibility, is granted without the need for reasons and regardless of any time limit, by writing to geral@memorea.pt.

12. Changes to this policy

This policy may be amended to reflect changes to the service, and the date shown at the top will be updated accordingly. Where the change is relevant to the data of account holders or of their events — in particular the introduction of a new recipient, a new purpose or a longer retention period —, the affected data subjects are informed by e-mail before it applies. Memorea keeps previous versions and makes available, on request, the version in force on a given date.

This policy should be read together with the Terms and Conditions and the Cookie Policy.