Privacy Policy

For any matter relating to personal data protection you can write to the address above. We have not formally appointed a Data Protection Officer (DPO) at this time because, based on our internal assessment, the circumstances of article 37.1 GDPR that would require it do not apply: the main processing is the provision of a service requested by the user and the profiling is instrumental to that provision. This assessment is reviewed periodically; if it changes, a DPO will be appointed and this section updated.

LiveMemoriesAI relies on external legal advice in data protection, at least every six months, to review compliance and update the measures when needed.

We do not process special-category data (art. 9 GDPR) as a purpose of the service. When the materials incidentally contain them, the minimisation measures described in §7 of the Terms apply. Those a person chooses to share about themselves in their self-replica follow the regime of §25.

The channel set up for these requests is the Opposition channel, available at /opposition. The platform processes the precautionary suspension and, where appropriate, the removal without undue delay, except for records strictly necessary to evidence the request and the decision taken.

The interlocutor may request access, rectification or deletion of their data and may order the deletion of their account from the memorial by sending /borrarme to the bot or writing to contact@livememoriesai.com.

We do not process interlocutor data for advertising or for commercial profiling.

We do not use memorial conversations, materials or memories to build advertising profiles, to train external AI models, to sell data or to build engagement rankings. Optional web measurement is limited to the sections visited and to usage events with closed values and no content under §19 and requires your separate prior consent.

Under art. 22 GDPR, automated decisions that produce legal effects on you or significantly affect you generally require human intervention, the ability to contest the decision or your explicit consent. Here, no automated decision of the service produces legal effects on the user outside the strictly contractual scope. Memory, photo and style proposals are always subject to custodian approval (HITL), and conversational responses do not replace professional advice.

Optional web measurement uses Google Tag Manager and Google Analytics 4, services provided by Google (Google Ireland Limited for the European Economic Area and Google LLC, in the United States, as the parent company). They are only used if you accept measurement and are governed by Google’s terms applicable to those services. Their scope, data and controls are explained in §12 and §19.

The current named list of providers with their regions and transfer mechanisms is published and maintained in the technical documentation of the service. Any material change is notified to registered users at least 15 days in advance, per §16 of the Terms.

If you accept web measurement, your browser connects to Google. Google may process technical connection and measurement data outside the EEA, including the United States. Those transfers rely on the mechanisms of this section provided for in Google’s terms, such as the EU-US Data Privacy Framework, in which Google LLC participates, or the Standard Contractual Clauses (https://policies.google.com/privacy). This option does not authorise sending memorial content to Google.

In particular, voice synthesis (MiniMax), processing by some large models and the delivery of certain transactional emails may rely on services outside the EEA. In all these cases the contractual agreement includes the SCCs and, when the provider participates in the EU-US DPF, it is considered covered by adequacy decision.

When a paid plan is contracted, Stripe may process billing data outside the EEA (for example, in the United States) under the SCCs and, where applicable, the EU-US DPF. Card data never reach LiveMemoriesAI’s servers.

The category, country and specific mechanism of each transfer are documented and updated when providers or regions change.

The general cookie notice offers Accept and Reject. Both choices let you keep using the service. Accept enables the optional analytics described here. We do not connect to Google Tag Manager before acceptance or if you reject. We use Google consent mode with measurement and advertising denied by default. Accepting only grants measurement (analytics_storage); advertising permissions (ad_storage, ad_user_data and ad_personalization) remain denied.

You can change or withdraw your choice through Cookie preferences on this page or in your account Settings. Withdrawing active consent reloads the page to stop loaded tags; you can remove previous measurement cookies in your browser. Necessary cookies continue working and do not depend on accepting measurement.

To configure cookies in your browser, please consult its help section. Blocking strictly necessary cookies may prevent the service from working.

Materials uploaded by the family and the conversations are not used to train external AI models. The platform uses the models as processors and applies the safeguards of §8 and §9.

When a model is invoked from regions outside the EEA, the mechanisms of §9 apply and calls are anonymised and pseudonymised where possible (avoiding unnecessary identifiers of the custodian or interlocutors in the prompt sent to the AI).

Generated audio carries machine-readable marking under art. 50.2 of the AI Act; the synthetic nature of the voice is additionally communicated audibly and in text.

To exercise them, write to contact@livememoriesai.com, use the controls in your account (settings, export, deletion) or use the Opposition channel (/opposition) if you do not have an account. Telegram interlocutors can use the /identidad and /borrarme commands. We will respond within a maximum of one month (art. 12.3 GDPR), extendable to two months when the request is complex, with prior notice.

We may ask for proportionate identity or relationship verification to avoid disclosing information to the wrong person. This verification is strictly the minimum necessary and is documented.

If you reside in another EEA country, you may complain to the supervisory authority of your country of habitual residence. In cross-border consumer disputes the European Commission ODR platform can facilitate out-of-court resolution (https://ec.europa.eu/consumers/odr).

Before complaining to an authority, we invite you to write to us so we can try to resolve the issue. Most incidents are resolved without administrative intervention.

Accepting the terms or privacy policy does not authorise measurement: a separate choice is requested in the cookie notice. You can reject or withdraw it without losing access to the service through Cookie preferences, on this page or in Settings › Preferences (§12). Your choice is remembered for 180 days; our own technical logs retain the periods in §10.

After your death, your data fall outside the scope of the GDPR (Recital 27) and move to the regime of §3: the people legitimised under art. 3 LOPDGDD may exercise the corresponding rights and request deletion (art. 96 LOPDGDD), unless you expressly forbade it in accordance with the law. The service does not offer posthumous activation or the designation of heirs within the platform. If a collaborator records your death in the memorial, it starts speaking of you in the past and keeps saying that you created it in life; the change is registered with the declaration of whoever makes it (Terms §4 and §27).

Memorial of another living person (Terms §6): their data are processed with their consent (art. 6.1.a GDPR), which the creator of the memorial declares to have obtained and which the person may withdraw at any time, also through the Opposition channel and without an account. After the withdrawal we suspend the memorial and remove it without undue delay. That person keeps every right of §14; if they die, their data move to the regime of §3.