Version: 1.0
Last updated: 2026-08-12
This policy explains how Memora processes personal data as part of its service connecting customers who wish to have a personalized artwork created with independent artists.
The sale is concluded directly between the customer and the Artist identified before the order is confirmed.
1. Data controller
For processing carried out in connection with the website, the initial form, the configurator, and the Memora intermediation service, the data controller is:
Memora
Operator of the Memora project
Hereinafter “Memora”.
2. Role of Memora
Memora provides a service enabling, in particular:
- collection of a creation request;
- access to the configurator;
- collection of the desired characteristics of the artwork;
- receipt of the reference photograph;
- connection of the customer with an Artist;
- transmission to that Artist of the elements necessary to prepare and perform the order;
- facilitation of certain communications relating to that order.
The Artist is an independent professional.
When processing data necessary for their own sale, creation, delivery, or accounting and legal obligations, the Artist may act as a separate data controller.
3. Data processed by Memora
Depending on use of the service, Memora may process:
Identification and contact details
- first name;
- last name;
- email address;
- where necessary, a phone number.
Project information
- type of subject;
- dimensions;
- medium;
- options;
- preferences;
- instructions sent to the Artist;
- information relating to the artistic project.
Reference photograph
Memora may receive and temporarily store the photograph submitted by the customer in order to:
- prepare the project;
- enable configuration of the artwork;
- transmit it to the relevant Artist;
- enable the Artist to create the artwork.
Matching information
Memora may also record:
- the Artist associated with the project;
- the date of the different stages;
- the status of the project;
- the order reference where it is provided;
- communications relating to operation of the service.
Technical data
To ensure operation and security of the service, Memora may process certain technical data, including:
- IP address;
- date and time;
- browser or device information;
- technical logs;
- session or project identifiers.
4. Purposes and legal bases
Preparing and providing the Memora service
Memora processes the information necessary to:
- receive your request;
- create your access to the configurator;
- record your choices;
- prepare your connection with an Artist;
- transmit your project to the Artist.
Legal basis: performance of the intermediation service requested from Memora and pre-contractual measures taken at your request.
Transmission to the Artist
The information necessary for the project, including the reference photograph, may be transmitted to the Artist who will create and sell the artwork.
This transmission is necessary for operation of the requested service.
Only the information necessary is transmitted.
Persons other than the customer appearing in the photograph
A photograph may depict persons other than the person placing the order.
Memora does not process these images in order to identify, analyze, or profile the persons depicted.
Processing is limited to what is necessary to enable the private creation requested by the customer.
For these persons, where applicable, Memora relies on its legitimate interest and that of the parties in enabling performance of a private artistic commission, subject to the rights and freedoms of the persons concerned and the safeguards set out in this policy.
Memora may refuse or delete content where there is a particular risk to a person's rights.
Service security
Certain technical data may be used to:
- secure the website;
- detect errors;
- prevent abuse;
- protect accounts and projects.
Legal basis: Memora's legitimate interest in ensuring the security of its service.
Managing requests and disputes
Certain information may be retained where necessary to:
- respond to a request;
- establish how the service operated;
- manage a dispute;
- establish, exercise, or defend Memora's rights.
Legal basis: Memora's legitimate interest.
5. The photograph is not intended for publication
The photograph provided in the configurator is used to enable creation of the artwork.
Uploading it does not constitute any authorization for publication.
On the sole basis of the upload, Memora may not:
- publish the photograph;
- publish a photograph / artwork comparison;
- use it on social media;
- use it in advertising;
- include it in its public portfolio.
6. Authorization for publication that may be offered after the order
After the order or completion of the artwork, Memora may send the customer a message enabling them to:
- rate their experience with Memora;
- optionally leave a testimonial;
- and, if they wish, access a separate form allowing certain publications to be authorized.
This invitation does not itself constitute authorization.
Any potential publication is based on separate and optional choices concerning, in particular:
- the original photograph;
- the completed artwork;
- the photograph / artwork comparison;
- social media;
- advertising communications.
Refusal does not affect the order or the service received.
7. Minors
In the current version of Memora, content depicting a minor is not intended for public use by Memora.
The presence of a minor in a photograph does not necessarily prevent its private use as a reference for a commissioned artwork where the customer is authorized to submit that photograph.
Memora nevertheless applies enhanced protective measures and may request additional information or refuse certain content.
8. Data transmitted to the Artist
To enable creation of the artwork, Memora may transmit to the Artist:
- your first and last name where necessary;
- your contact details necessary to perform the order;
- your reference photograph;
- your configuration choices;
- your instructions;
- your project reference.
The Artist receives only the information useful for the sale and creation of the artwork.
The Artist's identity is presented to the customer before the sale is concluded.
9. Use of the photograph by the Artist
The photograph is transmitted to the Artist to enable preparation and performance of the order.
It is not transmitted so that the Artist may freely publish it or reuse it for their own promotional activities.
The obligations applicable to the Artist regarding the photograph are defined in their relationship with Memora and under their own legal obligations.
Any separate public use requires the corresponding rights and permissions.
10. Technical service providers
Memora may use service providers to provide the service, including:
Hosting
Laravel Cloud
Storage of files and photographs
Email delivery
Infrastructure / security
Other service providers
These providers access data only to the extent necessary to provide their services and in accordance with the applicable contractual obligations.
11. Payment
In this version of Memora, the Artist is the seller of the artwork.
Memora does not process payment data in its capacity as seller.
Where a payment provider is technically accessible within the journey, banking information is processed by the relevant payment provider in accordance with its own terms and the configuration of the sale with the Artist.
Memora does not store full payment card numbers.
12. Retention periods
Requests that did not result in an order
Project information is retained for:
6 months
from the last communication, and is then deleted or anonymized unless there is a specific need to retain it.
Reference photograph
The original photograph is retained by Memora for the period necessary to prepare and follow up the project.
It is removed from the active environment no later than:
120 days after delivery
after delivery or closure of the project, unless there is a specific need related to a complaint or dispute.
Copies contained in technical backups may be progressively deleted according to a maximum cycle of:
up to an additional 120 days
Service-related data
Information necessary to evidence operation of the service or manage potential disputes may be archived with restricted access for:
5 years where necessary
where such retention is necessary and justified.
13. Transfers outside the European Economic Area
Certain technical service providers may process data from countries outside the European Economic Area.
Where applicable, Memora uses the mechanisms provided for by applicable regulations, including:
- an adequacy decision;
- or standard contractual clauses accompanied, where necessary, by additional safeguards.
To obtain information about transfers actually carried out:
14. Security
Given the private nature that submitted photographs may have, Memora implements measures intended in particular to:
- limit access to photographs;
- protect their transmission;
- limit their retention;
- restrict access to the relevant persons and Artists;
- protect accounts and technical systems.
Memora does not use reference photographs to train artificial intelligence models.
Memora does not perform facial recognition using these photographs.
15. Your rights
Depending on the legal basis and the conditions provided for by the GDPR, you may in particular have:
- a right of access;
- a right to rectification;
- a right to erasure;
- a right to restriction;
- a right to data portability for certain processing activities;
- a right to object to processing based on legitimate interests.
To exercise your rights:
Memora may request information reasonably necessary to verify your identity.
16. Persons depicted in a photograph
If you are depicted in a photograph submitted by another person and wish to exercise a right concerning your data, you may contact:
Memora will assess the request taking into account:
- your circumstances;
- the private purpose of the order;
- the progress of the creation;
- the rights of the different persons concerned.
17. Complaint
You may lodge a complaint with the competent data protection authority.
Where Memora is established in France:
Commission nationale de l'informatique et des libertés — CNIL
18. Changes to this policy
Memora may amend this policy to reflect changes in its service, its providers, or applicable regulations.
The version applicable at the time data is collected may be retained in order to document the information provided to users.