Privacy Policy 52memories

1. Controller

52memories AG
c/o FirstOffice GmbH
Grabenstrasse 15A
6340 Baar, Switzerland
Email: info@52memories.de

2. Scope

This Privacy Policy applies to services provided via www.52memories.ai and governs the processing of personal data under the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (revDSG).

3. Legal Basis

Data processing is based on:

- Art. 6(1)(b) GDPR – contract performance
- Art. 6(1)(a) GDPR – consent
- Art. 6(1)(f) GDPR – legitimate interests (e.g., website security)

Swiss data protection law applies accordingly for Swiss residents.

4. Data for Event Creation

We process:

- Event type, event name, event date
- Package selection and options
- Organizer name(s), recipient name(s)
- Email addresses
- Voucher codes (if provided)

Purpose: delivery of the digital memory experience

Legal basis: Art. 6(1)(b) GDPR

5. Contributors & Uploaded Content

Contributors voluntarily submit:

- Name (optional)
- Email address
- Uploaded content (text, image, or video)
- Time of submission

They receive system emails such as confirmations, reminders, delivery notices, or completion messages.

Legal basis: Art. 6(1)(a) GDPR

6. Payments

Payments are processed by third-party providers (e.g., Stripe, PayPal, Apple Pay, Google Pay). We do not store payment data. We only receive payment confirmations.

7. Communication

We use email addresses to send:

- Order and contract confirmations
- Event-related notifications
- Responses to support inquiries

8. Cookies & Tracking

a) Necessary cookies – required for the operation of the website  
b) Analytics and marketing cookies – used only with prior consent  

Legal basis: Art. 6(1)(a) GDPR  

Consent can be revoked via cookie settings at any time.

9. Tracking Tools

(only if implemented)

- Google Analytics
- Google Ads / Remarketing
- Meta Pixel (Facebook/Instagram)
- Pinterest Tag
- LinkedIn Insight Tag
- TikTok Pixel
- OneTrust Consent Tool

Data transfers to third countries (such as the USA) are based on Standard Contractual Clauses.

Please note: Data transferred to the USA may be subject to access by U.S. authorities. By consenting to the use of such tools, you accept this potential risk in accordance with Art. 49(1)(a) GDPR.

10. Data Sharing

Personal data is only shared:

- for the fulfilment of contractual obligations (e.g., hosting, email delivery)
- with payment providers (only for Organizers)
- where legally required

The data of Contributors is not shared with third parties outside the service context.

11. Data Retention

Personal data is stored for a maximum of five (5) years after the completion of the event, unless legal obligations require longer retention. Data is reviewed periodically and deleted or anonymized when no longer needed.

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12. Rights of Data Subjects

You have the right to:

- access your data
- correct inaccurate data
- request deletion
- restrict or object to processing
- withdraw consent
- data portability

Contact: info@52memories.de

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13. Security

We apply appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, or alteration.

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14. Changes

This Privacy Policy may be updated to reflect legal, technical, or service-related changes. The current version is always available at www.52memories.ai/privacy.