Privacy
Last updated: 13 October 2026
1. Controller
PLACEHOLDER: Company name PLACEHOLDER: Legal formPLACEHOLDER: Street address
PLACEHOLDER: Postal code PLACEHOLDER: City
PLACEHOLDER: Country
Email: PLACEHOLDER: Email
Data protection contact: PLACEHOLDER: Data protection contact
2. What data we process and why
We only process the data required to design, produce, pay for and ship your MerryMory bauble.
- Design data (draft): occasion, recipient, your story notes, music style, language, photos, and generated lyrics and songs. Legal basis: Art. 6(1)(b) GDPR (pre-contractual steps and performance of contract).
- Order data: name, shipping and billing address, email address, order contents, payment status. Legal basis: Art. 6(1)(b) and (c) GDPR (contract, tax and commercial law obligations).
- Contact requests: name, email, topic, message, optional order number. Legal basis: Art. 6(1)(b) or (f) GDPR.
- Newsletter: email address, language, time of consent and confirmation (double opt-in). Legal basis: Art. 6(1)(a) GDPR. You can withdraw consent at any time via the unsubscribe link.
- Optional customer account: after your purchase you can voluntarily create an account. Sign-in (email address, optionally Google sign-in, session) is handled by our provider Clerk; we store nothing about your account ourselves and match orders only via your verified email address. Clerk is loaded only on the account page. You can delete your account at any time in the account settings. Legal basis: Art. 6(1)(a) and (b) GDPR.
- Technical data: to prevent abuse (e.g. rate limiting) we store IP addresses only as a truncated, salted hash. Legal basis: Art. 6(1)(f) GDPR.
- Usage statistics: we anonymously count how often steps in the designer are completed. No names, stories or photos are recorded and no profiles are built.
3. Photos
Photos you upload are stored privately in non-public storage and can only be accessed through short-lived signed links. On upload we remove metadata such as GPS coordinates (EXIF).
Photos are never sent to AI providers. They are only used for your preview and to load your bauble.
4. AI generation of lyrics and music
To generate lyrics we send your story notes, occasion, recipient description, language and music style to OpenAI (OpenAI Ireland Ltd. or OpenAI, L.L.C.). To generate music we send the lyrics and music style to ElevenLabs (Eleven Labs Inc. or its EU entity). Legal basis: Art. 6(1)(b) GDPR.
Please only include information you are happy to share and no sensitive data (e.g. health data). Inputs are automatically checked for prohibited content before generation.
For transfers to third countries (in particular the USA) we rely on adequacy decisions (EU-US Data Privacy Framework) where the provider is certified, or on EU Standard Contractual Clauses.
5. Recipients and processors
- Stripe Payments Europe Ltd. (payment processing). You enter payment details such as card numbers directly with Stripe; we never receive them.
- Resend (sending emails such as order confirmations and newsletters).
- OpenAI and ElevenLabs (see section 4).
- Clerk, Inc. (USA) for the optional customer account, only if you create one or use the account page. Transfers based on the EU-US Data Privacy Framework or EU Standard Contractual Clauses.
- Hosting and storage provider: PLACEHOLDER: Hosting location
- Shipping carrier: name and delivery address for delivery.
- Optional, if enabled: Cloudflare Turnstile to protect forms against automated requests.
6. Cookies
We only use strictly necessary cookies: one that recognises your draft (up to 30 days), a security cookie protecting forms (CSRF), one for your chosen language, a login cookie only in the admin area and, only if you sign in to the optional customer account, Clerk's session cookies. There are no advertising or tracking cookies and no third-party pixels. Legal basis: § 25(2) no. 2 TDDDG, Art. 6(1)(b) or (f) GDPR.
7. Retention
- Drafts that were not ordered, including photos and songs: deleted 30 days after the last edit.
- Photos, stories and songs belonging to orders: deleted 90 days after delivery unless you ask us to delete them earlier.
- Order and invoice data: statutory retention periods (up to 10 years under § 147 AO, § 257 HGB).
- Contact requests: 12 months after completion.
- Newsletter: until you withdraw consent.
8. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21), and the right to withdraw consent at any time with effect for the future (Art. 7(3)).
You also have the right to lodge a complaint with a data protection supervisory authority, e.g. the authority responsible for our registered office: PLACEHOLDER SUPERVISORY AUTHORITY
9. Request deletion
You can request deletion of your data at any time here: Delete my data