Privacy Policy

1.Who we are and our role in the data

Memora ("Memora", "we", "the Service") is a SaaS platform that enables event photographers and organizers to share photos from events (weddings, corporate events, parties and more) so that each guest automatically receives only their own photos via WhatsApp, SMS or email. Matching each guest to their photos is performed using AI-based face-recognition technology.

The Service is operated by [full legal/business name], licensed dealer (Osek Murshe) no. [dealer no.], of [address], Israel ("the Operator").

2.Who this policy covers

• Business customers — photographers, studios and event organizers using Memora.
• Event guests — people photographed at an event who receive their photos through the Service, and who may upload a selfie for matching.
• Site visitors — visitors to the Memora marketing site.

3.Information we collect

4.Face & biometric data — the core of the Service

This is the most sensitive and important part of this policy, and we commit to full transparency about it.

What we create and store

• To match a guest to their photos, the system analyzes faces in the photos and in the selfie and produces a "face embedding" — a numerical vector describing facial features. This is a mathematical representation, not a photo, and the original facial features cannot be reconstructed from it.
• We store face embeddings, not "biometric profiles" for general identification of a person. The embeddings are used solely for matching within the specific event.
• The selfie is used only for matching — finding the photos in which the guest appears. It is not retained as a permanent identification profile and is not used to identify the guest in any other dataset.

Legal status of the data

Face data may constitute a "special category" of personal data (biometric data) under Article 9 GDPR, and "sensitive information" under the Israeli Protection of Privacy Law, 5741-1981 and its regulations. Accordingly we apply heightened safeguards, an explicit-consent legal basis, and short retention/deletion policies (§§6–8). [final classification pending counsel]

5.Purposes and legal basis

6.Guest consent and selfies

• Use of face recognition is the guest's choice (opt-in): matching occurs only after the guest actively chooses to take a selfie or approve its use.
• Before uploading the selfie, the guest is shown a clear notice explaining that the selfie is used solely to find their photos and that they may decline and still receive a general gallery / contact the photographer. [product flow pending confirmation]
• Consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out beforehand.
• The photographer/organizer is responsible for informing event guests about the photography and the use of the Service, per their agreement with Memora.

7.Retention periods

We keep information only as long as needed for the purpose for which it was collected:

• Face embeddings and matching selfie: deleted automatically once matching is complete / when the event gallery ends, and no later than [X days] after the event. [set exact number — suggested default 30 days]
• Event photos: kept for the gallery period set by the photographer/organizer, then deleted/returned per the agreement.
• Contact & delivery data: [period].
• Account & billing data: for the engagement term + the period required by law (accounting/tax).

8.Right to deletion and removal

Every guest may request deletion of their face data and photos at any time, for any reason. Requests should be sent to support@memora-ai.cloud and will be handled within [X days]. Upon deletion we remove the embeddings, the selfie and the photos associated with the guest (subject to third-party rights and legal retention duties).

Where the photographer/organizer is the Controller, we forward relevant deletion requests to them and assist in fulfilling them.

9.Sub-processors and data sharing

We rely on trusted sub-processors to provide the Service. We do not sell personal data. Main providers:

Each sub-processor is bound by a data processing agreement and confidentiality and security obligations. [final list pending confirmation]

10.Transfers and EU storage

Storage of guest data and face data takes place on servers in the European Union (EU). To the extent any transfer occurs outside the EU/EEA, it will rely on a lawful transfer mechanism (such as Standard Contractual Clauses) with appropriate safeguards. As an Israeli operator, we also comply with the Israeli Protection of Privacy Law. [final storage architecture pending confirmation]

11.Your rights

Subject to the GDPR and the Israeli Protection of Privacy Law, you have the following rights:

• Right of access to information collected about you.
• Right to rectify inaccurate information.
• Right to erasure ("right to be forgotten").
• Right to restrict and object to processing.
• Right to data portability.
• Right to withdraw consent at any time.
• Right to lodge a complaint with a supervisory authority (the Israeli Privacy Protection Authority, or an EU data protection authority).

To exercise rights, contact support@memora-ai.cloud.

12.Security

We apply technical and organizational security measures, including encryption in transit and at rest, access controls, environment separation, and data minimization. Face data is handled under heightened safeguards. [measures pending engineering & legal confirmation]

13.Children

The Service is not intended for the proactive collection of information from minors. Where minors appear at an event, responsibility for notice and obtaining parental/guardian consent rests with the photographer/organizer and event host. We will prioritize any deletion request concerning a minor. [age policy pending counsel]

14.Cookies and marketing

The site uses essential cookies and marketing/analytics cookies subject to your consent via the cookie banner. You can change preferences at any time. Marketing communications are sent only after opt-in and can be unsubscribed at any time.

15.Changes to this policy

We may update this policy from time to time. Material changes will be posted on the site and may also be sent directly. The update date appears at the top of this document.