Privacy Policy

1. Who we are

In Memoriam Film is operated by SoundCam Productions Kft., 2364 Ócsa, Üllői utca 48., Hungary (company registration number 13-09-211186, Budapest Környéki Törvényszék Cégbírósága; VAT number 13580100-2-13). We are the controller of your personal data under the EU General Data Protection Regulation (GDPR) and the UK GDPR.

Privacy questions and requests: privacy@inmemoriamfilm.com. Everything else: support@inmemoriamfilm.com. We have not appointed a data protection officer because the law does not require one for our activity.

2. What we collect, why, and on what legal basis

We do not need, and ask you not to upload, health records, ID documents or intimate images.

3. The person who has died

The GDPR does not apply to the personal data of people who have died (Recital 27). We still treat their photos and story with the same care as everyone else's. Some national laws give close relatives rights over a deceased person's data or memory — for example, in Hungary a close relative may exercise data rights for five years after death (Infotv. § 25). If you are a close relative and object to a film about someone in your family, contact us and we will look at it promptly and sensitively.

4. Other people in the photos, including children

Family photos show other people: partners, children, grandchildren, friends. They do not deal with us directly, so this page is how we tell them what happens (GDPR Art. 14(5)(b)). Before ordering, the person uploading confirms that they have the right to use the photos and that the people shown agree, or that they are acting for the family.

• Their images are used only to make the film the family asked for.
• The film is delivered privately to the person who ordered it. We never publish it. If the family shares it, it plays on an unlisted page that only people with the link can open and that search engines are told not to index; the family can stop it at any time.
• We never identify anyone, never compare faces with anything outside your own order, and never link faces across orders. Only if the family ticks a separate box do we make face templates to group the photos of the same person within that one order (section 4a).
• We do not use any photo to train AI models.
• Original photos are deleted 30 days after delivery (see section 8).
• Anyone who appears in a film can ask us to remove or blur them: write to privacy@inmemoriamfilm.com.

Photos of children are welcome as part of a family's memories. We apply the same limits, and we refuse uploads that are intimate or sexual, or that show public figures or celebrities.

4a. Finding the same person across your photos (optional)

In the “Who is in the photos?” step you can ask us to find the faces on your photos and put the photos of each person together, so you can say who is who in a few taps (“Mary, his wife”). This needs a face template of each face: a set of numbers that describes the face, which the law treats as biometric data (GDPR Art. 9). We make them only if you tick the separate box for it; the order, the film and the notes work without it.

• The templates are made and kept by Amazon Rekognition, part of Amazon Web Services, in Frankfurt (eu-central-1), in a store that belongs to your order alone. It keeps numbers, not pictures of faces.
• We use them only to group the photos of your own order and to choose the clearest late portrait for the card and the film. We never identify anyone, never search other orders or any other source, never share them and never use them for anything else.
• We switch this on only with the AWS AI services opt-out in place, so Amazon does not use your photos to improve its own services.
• They are deleted as soon as you turn face grouping off, and at the latest 30 days after they were made — every hour we check and delete what is due. The groups and the names you gave them live in your order and go with it.
• The names you give are your words: they are used as you wrote them in the life story, the captions and the film, and nobody is ever named on a photo you did not name them on.
• Anyone shown in the photos can ask us to take their face out of the grouping or to delete it: write to privacy@inmemoriamfilm.com.

5. What we never do

• Train AI models on your photos, videos, documents, voice or stories.
• Sell or “share” your personal data (in the CCPA sense) or use it for targeted advertising.
• Clone anyone's voice or create a talking avatar of the person who died.
• Make the film public, or use it as an example, unless you separately opt in (and you can withdraw that at any time).
• Make automated decisions about you that have legal or similarly significant effects (GDPR Art. 22).
• Use face templates to identify anyone, use them for anything but grouping the photos of your own order, or keep them after the order.

6. Who processes data for us

We use the following service providers (processors) under written data processing agreements (GDPR Art. 28). They may only use your data to provide their service to us.

Some providers keep data briefly for abuse monitoring or caching (for example, Google keeps Gemini API prompts and outputs for up to 55 days for abuse monitoring; Anthropic deletes API data within 30 days; RunPod deletes job results within minutes). We choose zero-retention options where they are available to us.

7. International transfers

Our main systems are in the EU (Frankfurt). Some providers above process data in the United States. Where a provider is certified under the EU-US Data Privacy Framework (and its UK Extension) we rely on that; otherwise we use the European Commission’s Standard Contractual Clauses (2021/914) and, for the UK, the International Data Transfer Addendum. You can ask us for a copy of the relevant safeguards.

8. How long we keep things

You can ask us to delete your photos and film sooner, at any time. A film kept online can be deleted at once from your order page or My films.

9. Your rights

Under the GDPR and UK GDPR you can ask us for access to your data, a copy in a portable format, correction, deletion, restriction, and you can object to processing based on legitimate interests. Where we rely on consent, you can withdraw it at any time. Write to privacy@inmemoriamfilm.com; we reply within one month.

You can complain to a data protection authority: in Hungary, the Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) (naih.hu); in the UK, the Information Commissioner’s Office (ico.org.uk); or the authority where you live or work. We would appreciate the chance to put things right first.

10. If you live in the United States

We do not sell personal information and do not “share” it for cross-context behavioural advertising, as those terms are used in the California Consumer Privacy Act (CCPA). We honor Global Privacy Control signals. Whatever state you live in, you can ask to know, correct or delete the personal information we hold about you, and we will not treat you differently for asking.

11. Cookies

On inmemoriamfilm.com we use only the storage needed for the site to work, unless you agree to more. Details: Cookie Policy.

12. Security

Data is encrypted in transit and at rest. Films and photos are stored privately and shared only through links that are hard to guess and that you control. Our staff and providers access them only when needed to make or support your order.

13. Changes

If we change how we use your data in a way that matters, we will update this page and tell customers with an open order by email. The version and date are at the top.