Privacy
Policy
Introduction
KeepMemoriz FZ-LLC (hereinafter "KeepMemoriz", "we") attaches paramount importance to the protection of your personal data. This privacy policy informs you, transparently, about how we collect, use, store, and protect your data when you use our website www.keepmemoriz.com or our services.
This policy complies with the Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) of the United Arab Emirates, as well as the requirements of Federal Decree-Law No. 14/2023 on e-commerce. For users residing in the European Union, our practices are also aligned with the General Data Protection Regulation (GDPREU Regulation 2016/679).
1. Data controller
Company name: KeepMemoriz FZ-LLC
Address: [Full address], Dubai, UAE
DPO email / Data contact: contact@keepmemoriz.com
Supervisory authority: UAE Data Office (under the PDPL)
For EU users, the competent supervisory authority is that of the Customer's country of residence (e.g., CNIL for France).
2. Data collected
We collect only the data strictly necessary for the operation of our services. Below are the categories of data collected:
| Category | Data collected | Time of collection |
|---|---|---|
| Identification | First name, last name, email address | Order / Account creation |
| Order | Order details, personalizations (event first name, date) | At checkout |
| Payment | Transaction reference (not raw banking data) | At secure payment |
| Browsing | IP address, browser data, pages visited, session duration | Website browsing |
| Communications | Emails exchanged with support | Customer service contact |
| Media (gallery) | Photos and videos shared by guests via the gallery | Service usage |
Sensitive data
KeepMemoriz does not collect sensitive data (health status, political opinions, biometric data, etc.) under the PDPL UAE and GDPR. Photos shared in galleries may contain images of individuals: the Customer is solely responsible for obtaining image rights from the photographed persons.
3. Processing purposes and legal bases
| Purpose | Legal basis (PDPL UAE) | Legal basis (GDPREU customers) |
|---|---|---|
| Order processing and delivery | Performance of contract | Art. 6(1)(b) GDPR |
| Billing and accounting obligations | Legal obligation | Art. 6(1)(c) GDPR |
| Customer service and support | Performance of contract / Legitimate interest | Art. 6(1)(b) and (f) GDPR |
| Website improvement (analytics) | Legitimate interest / Consent | Art. 6(1)(a) or (f) GDPR |
| Marketing emails | Explicit consent | Art. 6(1)(a) GDPR |
| Fraud prevention | Legitimate interest / Legal obligation | Art. 6(1)(c) and (f) GDPR |
4. Cookies and similar technologies
The website www.keepmemoriz.com uses cookies. A cookie is a small text file stored on your device during your browsing.
Types of cookies used
| Type | Usage | Duration | Consent required |
|---|---|---|---|
| Essential | Cart, session, security | Session | No (necessary) |
| Performance | Analytics (Google Analytics) | 13 months | Yes |
| Marketing | Targeted advertising, retargeting | 30 days | Yes |
| Functional | Language/region preferences | 12 months | Yes |
You can manage your cookie preferences via the banner displayed on your first visit or at any time via your browser settings.
5. Data recipients
KeepMemoriz does not sell your personal data to third parties. Your data may be shared with the following service providers, acting as data processors on our behalf:
| Service provider | Purpose | Location |
|---|---|---|
| Shopify Inc. | Store hosting, order processing | Canada (EU servers available) |
| Stripe / PayPal | Secure payment | USA / Luxembourg |
| Google (Analytics / Workspace) | Analytics, emails | USA (with adequate safeguards) |
| Transactional email provider | Sending order emails | Variable |
| Gallery file hosting | Storage of photos and videos shared in galleries | European Union (EU) |
6. International data transfers
KeepMemoriz is based in the United Arab Emirates. Depending on the type of data, processing takes place in various locations:
- Gallery photos and videos, stored and processed exclusively within the European Union, with no transfer to third countries
- Order and payment data, processed by our service providers (Shopify, Stripe/PayPal) with appropriate safeguards (standard contractual clauses, EU adequacy decisions)
- Browsing analytics, Google Analytics with IP anonymization and a GDPR-compliant data processing agreement
For customers residing in the EU, any data transfer to a country outside the EU is governed by appropriate safeguards in accordance with the GDPR: adequacy decision of the European Commission or standard contractual clauses (Art. 46 GDPR).
7. Data retention
| Data category | Retention period | Justification |
|---|---|---|
| Order and billing data | 10 years | Legal accounting obligation (UAE) |
| Customer account data | 3 years after last activity | Business relationship |
| Gallery photos/videos | 6 months after order (automatic deletion) | Duration of subscribed service |
| Browsing logs | 12 months | Security / Fraud prevention |
| Support emails | 3 years | Contractual evidence |
| Marketing data (opt-in) | Until consent withdrawal | Consent |
At the end of these periods, the data is permanently and irreversibly deleted or anonymized.
8. Your rights
In accordance with Federal Decree-Law No. 45/2021 (PDPL) and, for customers residing in the EU, the GDPR, you have the following rights:
- Right of access, obtain a copy of personal data concerning you
- Right to rectification, correct inaccurate or incomplete data
- Right to erasure, request deletion of your data (subject to legal retention obligations)
- Right to data portability, receive your data in a structured, machine-readable format
- Right to object, object to the processing of your data for direct marketing purposes
- Right to restriction, request temporary suspension of processing
- Right to withdraw consent, at any time, without affecting the lawfulness of prior processing
How to exercise your rights
Send an email to contact@keepmemoriz.com with the subject "Data Rights Request". We will respond within 30 days maximum, in accordance with the PDPL and GDPR. If we are unable to verify your identity, we may request additional proof.
If your request is not satisfactorily addressed, you may lodge a complaint with your supervisory authority (UAE Data Office, CNIL, or equivalent authority in your country of residence).
9. Data security
KeepMemoriz implements appropriate technical and organizational measures to protect your data against any unauthorized access, disclosure, alteration, or destruction:
- Encryption of data in transit (SSL/TLS) and at rest
- Data access limited to strictly authorized personnel
- Enhanced authentication for administrator access
- Regular backups and business continuity plan
- PCI-DSS compliance for payment data (via certified providers)
In the event of a data breach likely to affect your rights and freedoms, we will notify the competent authorities within the legal timeframes (72 hours under the GDPR) and inform you if the breach presents a high risk to you.
10. Protection of minors
Our services are intended for adults. We do not knowingly collect personal data from individuals under 18 years of age without the consent of their parents or legal guardians, in accordance with the PDPL UAE and applicable international regulations.
If you believe a minor has provided us with personal data, please contact us immediately at contact@keepmemoriz.com and we will proceed with its deletion as soon as possible.
11. Policy changes
KeepMemoriz reserves the right to modify this privacy policy at any time, in particular to comply with legislative or regulatory developments. The "last updated" date at the top of this document indicates the current version.
In the event of a substantial modification, we will inform you by email or through a visible notification on the website before the changes take effect. Continued use of the site after modification constitutes acceptance of the new policy.
Contact and DPO
For any question regarding your personal data or the exercise of your rights:
Attention: DPO Dubai, UAE
dataoffice.ae