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Privacy Policy — Dear Moment

Last Updated: 01.07.2026

Until Dear Moment Ltd is formally incorporated in England and Wales, all references to "Dear Moment Ltd" refer to its founders operating on behalf of the company in formation.

Our Privacy Promise

• You own your memories. Always.
• We never sell your data or your children's data.
• We never show you ads within the app.
• You control who sees your memories. Sharing is always opt-in.
• You can request deletion of all your data at any time.

1. Who We Are and How to Contact Us

Dear Moment ("we," "us," "our") is operated by Dear Moment Ltd (in formation), being incorporated in England and Wales. We are the data controller for personal data processed through the Service.

Privacy contact: dearmomentapp@gmail.com

We are in the process of registering with the UK Information Commissioner's Office (ICO). Our ICO registration number will be published here upon completion. You have the right to lodge a complaint with the ICO at ico.org.uk if you are unhappy with how we handle your data.

2. What Data We Collect

2.1 Data You Provide — Account

• Email address
• Password (stored encrypted; we never see your plain-text password)
• First name or display name

If you sign up via Google OAuth, we receive your name and email address from Google. We do not receive your Google password.

2.2 Data You Provide — Family Members

When you add children, a co-parent, or other family members to your account, you provide their names, dates of birth (required for children; optional for adults and pets), and relationship type.

This data is used to personalise your family timeline and memory capture experience. We never use data about children for marketing or advertising. Any marketing or advertising activities are based only on your own account holder information, and only where you have given consent, as described in Section 3.

2.3 Memory Content

When you capture a memory, we collect and process:

• Voice recordings — raw audio captured in the App. Voice recordings may, in certain jurisdictions, be considered sensitive personal data. We process them to provide transcription and AI summary features.
• Transcriptions — generated automatically from your voice recordings
• AI-generated summaries — a cleaned-up version of the transcription
• Photos and videos you upload
• Text notes you write
• Date, time, and which family members are tagged in the memory

2.4 Invited Family Viewers

When a parent invites a family member (e.g. a grandparent) to view memories, we collect the invited person's email address, which is entered by the parent in the App.

We use this email address to send the invitation and, if accepted, to send family memory digest emails. The invited person's email is not used for any other purpose.

Legal basis: Legitimate interest in facilitating the family sharing feature the parent has requested, balanced against the privacy interests of the invited person.

Invited viewers must accept the invitation via a confirmation page where they agree to these Terms and this Privacy Policy before any content is shared with them. We record the timestamp and IP address of acceptance as evidence of consent.

When the inviting account is deleted, the invited viewer's email address is deleted as part of that account deletion, and their digest link stops working.

2.5 Technical and Usage Data

We automatically collect technical and usage data when you use the Service. This may include:

• Device type, model, and operating system
• App version
• IP address and approximate location derived from IP
• Unique device identifiers
• Browser type and settings
• Pages and features viewed, and how you interact with them (clickstream data)
• Session duration and frequency of use
• Crash reports and error logs
• Referring URLs

This data is collected directly and through third-party analytics providers. Some of this data may, depending on jurisdiction, constitute personal data. We use it to operate, maintain, and improve the Service, to understand how users interact with the App, and for marketing analytics. Third-party analytics providers may collect this data through the Service using their own technologies, subject to their own privacy policies. We ensure such providers are bound by appropriate data processing agreements.

2.6 Data We Do NOT Collect

• We do not collect precise GPS location data.
• We do not collect data from your contacts list without your explicit action.
• We do not collect payment card information directly — all payments are handled by Apple App Store or Google Play Store.

3. How We Use Your Data

We use your personal data for the following purposes on the following legal bases under UK GDPR:

We do not sell your personal data to third parties for their own independent use.

4. Data About Family Members (Including Children)

Dear Moment is a family memory journal. The people who appear in your memories may include children, co-parents, grandparents, and other relatives. All data about family members is entered by the account holder — we do not collect data directly from any family member who is not the registered user.

Data about family members is used to provide and improve the Service and to personalise your experience, as described in Section 3. We do not use data about children for marketing or advertising. Our marketing and advertising activities are based on your own account holder data, not on data about the family members you add.

4.1 Children's Data — Additional Protections

Where your family includes children, we apply a higher level of protection to their data, consistent with the UK Children's Code (Age Appropriate Design Code) issued by the ICO. Dear Moment is designed to store memories about children, not to collect data from children.

• Children's names, dates of birth, photos, and voice recordings are used solely to provide the family timeline and memory features.
• We do not use children's data for advertising, profiling, or any purpose beyond operating the Service.
• Children's data is never shared with third parties for their own purposes.
• Children's data is accessible only to the parent account and authorised family viewers.

4.2 When a Child Reaches Adulthood

Under UK GDPR, a person who reaches 18 acquires full data subject rights over personal data held about them — including data collected about them since birth. The following is how Dear Moment handles this.

When a family member in your account reaches the age of 18, the following applies:

Notification to the parent account. We will send a notification to the registered parent account when a child member's date of birth indicates they have turned 18, prompting the parent to consider their options:

• Export and share the archive with the now-adult child via the in-app data export feature;
• Delete the data for that family member from the account; or
• Obtain explicit consent from the adult child to continue storing their data within the family account.

The adult child's independent rights. At any point after turning 18, the person about whom memories have been stored may contact us directly at dearmomentapp@gmail.com to:

• Request a copy of all personal data held about them;
• Request correction of any inaccurate data;
• Request deletion of all data held about them.

We will respond to such requests within 30 days and will verify identity before processing. Where a deletion request is received from an adult child, we will action it regardless of the status of the parent account.

This mechanism operates through our existing data subject rights process and does not require any additional technical feature. Tooling within the App to streamline this process may be introduced in a future version.

5. Who We Share Your Data With

5.1 Infrastructure and Service Providers

We use trusted third-party providers who act as data processors on our behalf, bound by data processing agreements. These include providers in the following categories:

• Cloud storage and database services (currently: Supabase)
• AI transcription and language processing services
• Email delivery services
• Analytics and crash reporting services
• Push notification services
• Payment processing (Apple App Store, Google Play Store)

Some of these providers may, as part of their own services, collect data about your use of the App using their own technologies (such as SDKs or cookies). This is standard practice and is subject to their own privacy policies. We select providers carefully and ensure appropriate data processing agreements are in place. We will update this list as our provider stack evolves.

5.2 Apple and Google

If you download the App via the App Store or Google Play, Apple and Google process data in accordance with their own privacy policies. Subscription payments made through the App are handled entirely by Apple or Google — we do not receive your payment card details.

5.3 Family Viewers You Invite

When you invite a family member to view your memories, they will see the content you have shared. You control this and can revoke access at any time.

5.4 Legal Requirements

We may disclose your data if required by law, court order, or regulatory authority.

5.5 Business Transfer

If Dear Moment is acquired or merges with another company, your data may be transferred. We will notify you before your data is transferred and becomes subject to a different privacy policy.

5.6 Advertising Platforms (With Your Consent)

With your consent, given during onboarding, we may share your name and email address with third-party advertising platforms to send you relevant communications and to show relevant ads. Your memories, photos, voice recordings, and other content are never shared with advertising platforms.

You may withdraw your consent at any time by contacting us at dearmomentapp@gmail.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

If you do not consent, your data is not shared with advertising platforms for marketing purposes.

6. International Data Transfers

Dear Moment is operated from the United Kingdom. Some of our third-party providers may process data outside the UK or EEA. Where this occurs, we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or equivalent mechanisms recognised under UK data protection law.

7. Users Outside the United Kingdom

7.1 European Union and EEA Residents

If you are located in the EU or EEA, your personal data is transferred to and processed in the United Kingdom. The UK has been granted an adequacy decision by the European Commission, meaning the UK is considered to provide an equivalent level of data protection to that required under EU GDPR.

As an EU or EEA resident, you have the same rights described in Section 9 of this Policy. These rights are enforceable under EU GDPR. If you are not satisfied with our response to any request, you have the right to lodge a complaint with the data protection authority in your country of residence.

7.2 United States Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal data we collect, the right to delete your data, and the right to opt out of the sale of your personal data. We do not sell personal data as defined under the CCPA. To exercise any rights, contact us at dearmomentapp@gmail.com.

As our user base in the United States grows, we will expand this section to address applicable US state privacy laws.

7.3 Other Regions

Dear Moment is intended for a global audience. If you are located outside the UK, EU, EEA, or United States, please be aware that your personal data will be transferred to and processed in the United Kingdom, where data protection laws may differ from those in your country.

By using the Service, you acknowledge this transfer. We take reasonable steps to ensure your data is treated securely and in accordance with this Privacy Policy regardless of where you are located.

Certain countries have specific data localisation or processing requirements (for example, Russia and China). If you are located in a country with such requirements, you should be aware that our Service may not be fully compliant with local law. We recommend consulting local legal advice if this is a concern.

8. Data Retention

While your account is active. We retain your account data and memories for as long as your account is active. Your account is considered active if you have an ongoing subscription, or if you have added a new memory within the previous 12 months. Simply opening the App does not by itself keep an account active — adding a new memory or holding an active subscription does.

After a subscription ends. If your paid subscription ends — whether you cancel or it is not renewed — your account moves to a read-only state. Your memories remain safe and viewable, and you can export them at any time, but new memories cannot be added until you resubscribe. We retain your memories in this read-only state for 12 months from the date your subscription ends.

Inactivity and deletion. If, at the end of that 12-month period, your account still has no active subscription and no new memories have been added, we may permanently delete your account and all Your Content. We will never do this without warning: we will email you several reminders before any deletion takes place, giving you time to return, resubscribe, or export everything. During the current free phase of the Service, the same 12-month inactivity period applies — an account with no new memories added for 12 months may be deleted following the same advance reminders.

On account deletion. When you delete your account — or when an account is deleted following the inactivity process above — your personal data and all Your Content are permanently deleted within 30 days. This includes the email addresses of any family viewers you invited: when your account is deleted, their email addresses and digest access are deleted along with it.

Invited viewer email addresses are retained until: (a) the viewer unsubscribes, (b) you remove them from your sharing list, or (c) your account is deleted — whichever comes first.

Other retention. Anonymised, aggregated data may be retained indefinitely for product improvement purposes. We may retain certain data for longer where required by law or to resolve disputes.

9. Your Rights Under UK GDPR

As a user where UK GDPR applies, you have the following rights:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — ask us to correct inaccurate or incomplete data.
• Right to erasure — ask us to delete your data. You can also do this directly by deleting your account in the App.
• Right to restriction — ask us to restrict processing of your data.
• Right to data portability — request your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interests.
• Right to withdraw consent — where processing is based on consent, withdraw it at any time.

To exercise any of these rights: dearmomentapp@gmail.com

We will respond within 30 days. We may ask you to verify your identity before processing your request.

If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

10. Rights of Invited Family Viewers

If you have been invited to view a family's memories on Dear Moment, you have the right to:

• Unsubscribe from digest emails at any time using the unsubscribe link in any email we send you.
• Request deletion of your email address and associated data by emailing dearmomentapp@gmail.com or using the link provided in our emails.
• Request a copy of the data we hold about you.

Your email address will be deleted within 30 days of an unsubscribe or deletion request.

11. Security

Our security measures include:

• Encryption of data in transit (TLS) and at rest
• Secure authentication via Supabase Auth
• Access controls limiting who can access user data
• Regular review of our security practices

If you believe your account has been compromised, contact us immediately at dearmomentapp@gmail.com. In the event of a data breach likely to affect your rights and freedoms, we will notify you and the ICO as required by law.

12. Cookies and Tracking

The Dear Moment App and web-based Family Viewer use cookies and similar technologies for the following purposes:

• Strictly necessary — to keep you logged in and maintain your session.
• Analytics — to understand how the App and web viewer are used, in order to improve the Service. We use third-party analytics providers for this purpose.
• Advertising — where you have consented, we may use tracking technologies to measure the performance of our advertising campaigns.

You may disable cookies through your device or browser settings, though this may affect the functionality of the Service.

13. Changes to This Policy

We will notify you of material changes by sending a notification via the App and/or an email to your registered address. Your continued use of the Service after the effective date constitutes your acknowledgement of the updated Policy.

14. Contact Us

Dear Moment Ltd (in formation)

General, privacy & data requests: dearmomentapp@gmail.com