This document has been translated automatically. Only the French version is the original and legally binding — this translation is provided to make it easier to understand.

Data Protection Policy

Last updated: June 1, 2026

Preamble

The Memorable website, accessible at memorable.me or any other address operated by Memorable Day (the “Site”), is operated by MEMORABLE DAY, a simplified joint-stock company (société par actions simplifiée), operating under the trade name Memorable, SIREN 105 295 034, SIRET 105 295 034 00018, whose registered office is located at 60 rue François Ier, 75008 Paris, France (“Memorable Day” or the “Data Controller”).

This Data Protection Policy (the “Policy”) aims to inform Users of the Site about how their personal data is collected, used, shared, protected and, where applicable, made visible in connection with the use of Memorable Money Pots.

Memorable Day attaches particular importance to the protection of personal data and undertakes to process data in accordance with the General Data Protection Regulation (GDPR), the French Data Protection Act (Loi Informatique et Libertés) and the recommendations of the CNIL.

Any question relating to this Policy may be sent to: [email protected].

Article 1 – Definitions

The terms used in this Policy have the meaning given to them by the GDPR, including:

  • “Personal data”: any information relating to an identified or identifiable natural person;
  • “Processing”: any operation performed on personal data, including collection, recording, storage, consultation, use, transmission or deletion;
  • “Data Controller”: the person who determines the purposes and means of the processing;
  • “Processor”: the person who processes personal data on behalf of the Data Controller;
  • “Consent”: a freely given, specific, informed and unambiguous indication of a person’s wishes by which they agree to the processing of their data.

The following terms also have the meanings set out below:

  • “Money Pot”: a page created by an Organizer to collect Donations without consideration;
  • “Organizer”: a private individual who creates a Money Pot, is its beneficiary and may make withdrawals to their own bank account;
  • “Participant”: a person who makes a Donation to a Money Pot;
  • “User”: any person using the Site, including Organizers and Participants.

Article 2 – Data Controller

The Data Controller is:

MEMORABLE DAY

SAS, simplified joint-stock company

SIREN: 105 295 034

SIRET: 105 295 034 00018

Registered office: 60 rue François Ier, 75008 Paris, France

Email: [email protected]

The data protection / GDPR contact is Georges Vernier, who can be reached at [email protected].

Article 3 – Data Collected

3.1 Data relating to Organizers

In connection with the creation and management of a Money Pot, Memorable Day may collect the following data:

  • last name and first name;
  • email address;
  • login and access information relating to the account or secure links;
  • information relating to the Money Pots created: title, description, image, amount collected, settings, activity history;
  • information necessary for assistance, support, fraud prevention and compliance with legal obligations.

Stripe also collects, for payment, identity verification and withdrawal purposes, certain data relating to the Organizer, including:

  • full identity;
  • date of birth;
  • address;
  • identity document;
  • bank details, including bank details / IBAN;
  • information necessary to verify the Stripe Connect account.

This data is processed by Stripe in accordance with its own terms and privacy policy, where Stripe acts as a data controller or payment provider.

3.2 Data relating to Participants

When a Participant makes a participation, Memorable Day may collect the following data:

  • first name;
  • last name;
  • email address;
  • participation amount;
  • message;
  • photo, where added;
  • visibility settings selected for each item of information;
  • technical information relating to the participation and the confirmation email.

Stripe also collects the data necessary for payment, including information relating to the payment method, payment authentication and, where applicable, certain billing information.

3.3 Browsing data and cookies

When browsing the Site, Memorable Day may collect technical and browsing data, including:

  • IP address;
  • cookie identifiers;
  • pages viewed;
  • browsing events;
  • information relating to the device, browser and operating system;
  • information relating to advertising campaigns or acquisition sources.

This data may be collected by means of cookies or similar technologies, according to the choices expressed by the User.

Article 4 – Purposes and Legal Bases

Memorable Day processes personal data for the following purposes:

4.1 Creation and management of Money Pots

Organizers’ data is used to enable the creation, administration, modification, suspension, closure and tracking of Money Pots.

The legal basis is the performance of the contract between Memorable Day and the Organizer.

4.2 Completion of participations

Participants’ data is used to record their participation, process their Donation, send a confirmation email, provide access to the secure participation management link and inform the Organizer of a new participation according to the applicable settings.

The legal basis is the performance of the contract and, for certain visibility settings, the Participant’s consent.

4.3 Management of participation visibility

The Participant may configure the visibility of certain information associated with their participation, including their last name, first name, amount, message and photo.

Depending on the choices offered on the Site, certain information may be:

  • visible to anyone with the Money Pot link;
  • visible only to the Organizer;
  • hidden from the public and, for the relevant information, also from the Organizer where the interface allows it.

The Participant’s email address is not transmitted to the Organizer and is not displayed publicly.

The Participant receives a confirmation email containing a secure link allowing them to view and edit their participation, including the information visible publicly or visible to the Organizer. This link is secure and has no planned expiry date.

4.4 Payments, identity verification and withdrawals

The data necessary for payment, identity verification, adding a bank account and withdrawals is processed in order to enable:

  • the collection of Donations by Stripe on behalf of the Organizer;
  • verification of the Organizer’s identity;
  • the addition of one or more bank details / IBANs;
  • the withdrawal of available funds to the Organizer’s bank account;
  • prevention of fraud, disputes and abuse.

The legal basis is performance of the contract, compliance with legal obligations and Memorable Day’s legitimate interest in securing its platform.

4.5 Support, security and fraud prevention

Data may be used to respond to User requests, provide support, process reports, analyze disputes, prevent fraud, suspend a Money Pot, block a withdrawal or make refunds where necessary.

The legal basis is performance of the contract, compliance with legal obligations and Memorable Day’s legitimate interest.

4.6 Statistics, audience measurement and advertising

Memorable Day uses audience measurement, analytics and advertising tools, including Google Analytics, Plausible, DataFast, Google Ads and Google Tag Manager.

These tools may be used to measure Site traffic, understand the use of functionalities, improve the user experience, measure the effectiveness of advertising campaigns and optimize acquisition paths.

Where these tools require the placement of cookies or trackers that are not strictly necessary, their use is based on the User’s consent.

Memorable Day does not send marketing emails to Organizers or Participants, unless the service evolves in the future.

Article 5 – Recipients of the Data

The data collected is intended for the following persons and providers, within the limits of their respective roles:

5.1 Within Memorable Day

Data is accessible to authorized persons within Memorable Day, in particular for service administration, support, compliance, fraud prevention, payment management and security.

5.2 Hosting and infrastructure

The Site is hosted by Heroku, a service operated by Salesforce, and may rely on Amazon Web Services infrastructures. Images and files may be stored and delivered using Amazon S3 and CloudFront.

5.3 Payment and identity verification

Payments, identity verification, management of Stripe Connect accounts and withdrawals are handled by Stripe. Stripe may process personal data as a technical service provider, payment service provider or data controller, depending on the case.

5.4 Transactional email

Transactional emails, including participation confirmations, participation notifications, management links and messages relating to the operation of the service, are sent using SendGrid or Resend.

5.5 Analytics, audience measurement and advertising

Data may be transmitted or made accessible to analytics and advertising tools, including Google Analytics, Google Ads, Google Tag Manager, Plausible and DataFast, depending on the User’s consent choices.

Data may be transmitted to administrative, judicial, tax or regulatory authorities, or to any authorized third party, where Memorable Day is required to do so by law, court decision, regulatory obligation or in order to defend its rights.

Article 6 – Public Visibility of Data

Memorable Money Pots are not intended to be indexed in search engines and are not offered in an internal search engine. They are accessible by direct link.

Anyone with the direct link to a Money Pot may nevertheless access the Money Pot page and view the information made visible according to the settings selected by the Organizer and Participants.

Participation information visible publicly may include, in particular, the Participant’s first name, the first letter of their last name, the amount, the message or the photo, only according to the choices made at the time of participation or subsequently modified via the secure link received by email.

Article 7 – Retention Period

Memorable Day retains personal data for the time necessary for the purposes for which it was collected, extended where applicable by the periods necessary to comply with legal, accounting, tax and regulatory obligations, prevent fraud, manage disputes and defend Memorable Day’s rights.

Certain data may be retained for longer where necessary to prove a transaction, comply with a legal obligation, fight fraud, manage payments, withdrawals, refunds or disputes.

Data processed by Stripe is retained according to Stripe’s own rules and the obligations applicable to payment, identity verification and compliance services.

Article 8 – Security

Memorable Day implements reasonable technical and organizational measures to protect personal data against destruction, loss, alteration, unauthorized disclosure or unauthorized access.

These measures may include, in particular, the use of secure links, unique tokens, access restrictions, technical logs, encryption measures where relevant, specialized providers and internal security procedures.

However, no method of electronic transmission or storage can guarantee absolute security. In the event of a personal data breach presenting a risk to the persons concerned, Memorable Day will comply with the notification obligations provided for by the applicable regulations.

Article 9 – Transfers Outside the European Union

Certain providers used by Memorable Day may process data outside the European Union or the European Economic Area. In such cases, Memorable Day ensures that appropriate safeguards are implemented in accordance with applicable regulations, including standard contractual clauses, adequacy decisions or additional measures where necessary.

Article 10 – Rights of Individuals

In accordance with applicable regulations, Users have the following rights:

  • right of access;
  • right to rectification;
  • right to erasure;
  • right to restriction of processing;
  • right to object;
  • right to data portability;
  • right to withdraw consent where processing is based on consent;
  • right to define instructions regarding the fate of their data after death;
  • right not to be subject to a decision based solely on automated processing producing legal effects or significantly affecting them.

Article 11 – Exercising Rights

To exercise their rights, the User may send a request to Memorable Day:

  • by email to [email protected];
  • or by post to Memorable Day’s registered office: 60 rue François Ier, 75008 Paris, France.

The request must specify the right being exercised and contain the information necessary to identify the person concerned. Memorable Day may request proof of identity where necessary to protect data against a fraudulent request.

Memorable Day will respond within the time limits provided for by applicable regulations.

If the User considers that their rights are not being respected, they may lodge a complaint with the CNIL.

Article 12 – Cookies and Trackers

A cookie is a small file placed on the User’s device when they visit the Site. It may in particular enable the Site to function, remember preferences, measure audience, improve the user experience or measure advertising campaigns.

Memorable Day may use:

  • cookies strictly necessary for the operation of the Site;
  • audience measurement cookies;
  • product analytics cookies;
  • advertising cookies, in particular related to Google Ads;
  • trackers used through Google Tag Manager.

Cookies that are not strictly necessary are placed only with the User’s consent, where such consent is required. The User may accept, refuse or configure cookies using the mechanisms made available on the Site.

Article 13 – Tools Used

As of the date of this Policy, Memorable Day may use, in particular, the following tools:

{% table %}

  • Tool
  • Purpose

* Nature

  • Heroku / Salesforce
  • Hosting of the Site

* Infrastructure

  • Amazon Web Services / S3 / CloudFront
  • Hosting, storage and delivery of files and images

* Infrastructure

  • Stripe
  • Payment, Stripe Connect, Stripe Checkout, Stripe Identity, identity verification, withdrawal

* Payment / compliance

  • SendGrid, Resend
  • Sending transactional emails

* Email

  • Google Analytics
  • Audience measurement and browsing analytics

* Statistics

  • Plausible
  • Audience measurement

* Statistics

  • DataFast
  • Audience measurement

* Statistics

  • Google Ads
  • Advertising measurement and optimization

* Advertising

  • Google Tag Manager
  • Management of tags and trackers
  • Technical / measurement {% /table %}

Article 14 – Changes to the Policy

Memorable Day reserves the right to amend this Policy at any time in order to reflect changes to the Site, the services, the tools used or the applicable regulations.

The new version will be published on the Site. Where required by regulations, Memorable Day will inform Users or request their consent.

Article 15 – Acceptance

By using the Site, the User acknowledges that they have read this Policy. Where certain processing operations are based on consent, the User may accept or refuse such processing according to the mechanisms made available to them.