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Privacy Policy and Data Protection Notice
Last updated: 27 August 2026
1. Data Controller
Under Turkish Personal Data Protection Law No. 6698 ("KVKK"), the data controller is:
[Full Name / Company Name], [Address]. Contact:
support@comemorys.com.
2. Personal Data We Process
| Data category |
Content |
How it is collected |
| Identity and contact |
Username, email address |
Registration form |
| Transaction security |
Irreversible hash of your password, IP address, registration time, session cookie |
Automatically |
| User content |
Names of the people you add, voice recordings, the transcribed text of those
recordings, photos you upload |
Directly from you |
3. Purposes and Legal Basis
- Providing the service (creating your account, storing your memories and
showing them back to you) — KVKK art. 5/2-c: necessary for the performance of a contract.
- Security (recording IP addresses to prevent abuse and automated
registrations) — KVKK art. 5/2-f: legitimate interest.
- Password reset emails — KVKK art. 5/2-c.
- Content that may qualify as special category data, such as voice recordings and
photos — KVKK art. 6: your explicit consent. The consent you give during
registration covers this and you may withdraw it at any time.
Important notice about other people's data
When you add another person's voice, photo or name to Comemorys, you are processing that
person's personal data. It is your responsibility to make sure that the person concerned (or
their relatives, if they have passed away) is aware of this and consents to it before you
upload such content.
4. Data Retention and Security
- Passwords are never stored in plain text; only an irreversible hash is kept.
- Audio and photo files are stored on the server under unguessable random names.
- Site traffic is encrypted with HTTPS; the session cookie is protected with the
HttpOnly, Secure and SameSite attributes.
- Data is retained for as long as your account exists. When you delete your account, all your
person records, audio files and photos are permanently deleted from the server.
5. Cookies
Comemorys uses strictly necessary cookies only: the
COMEMORYS_SID cookie that keeps you signed in. No advertising, tracking or
analytics cookies are used, and your data is never shared with third parties for advertising.
Your language preference is kept in your browser's local storage (localStorage) and is never
sent to the server.
6. International Transfers and Third Parties
- Hosting: Data is stored on [hosting provider name and server
country].
- Email: Password reset emails are sent through the SMTP server belonging to
the comemorys.com domain.
- Fonts: Page fonts are loaded from Google Fonts, during which your
browser's IP address is transmitted to Google.
- Speech-to-text: This is performed by your browser's own speech recognition
feature. In some browsers, such as Chrome, this feature may send the audio to the browser
vendor's servers; that is governed by your browser's own privacy policy.
7. Your Rights (KVKK art. 11)
In relation to your personal data you have the right to learn whether it is being processed, to
request information about it, to request its correction, deletion or destruction, to object to
the processing, and to claim compensation for any damage suffered.
- Deletion: You can delete all of your data instantly and permanently from
within the app via Account Settings → Delete My Account.
- For any other request, write to
support@comemorys.com. Requests are answered
within 30 days at the latest.
8. Children's Privacy
Comemorys is not designed for people under 18. If an account belonging to a user under 18 is
identified, the related data will be deleted.
9. Changes
Updates to this text are published on this page; for significant changes we also notify your
registered email address.
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