Privacy policy.

1.Who We Are

RMEMBER LTD ("rMembr", "we", "us", "our") is a company registered in England and Wales (Company Number: 16355328). Registered address available on request.

We operate the rMembr platform — a digital legacy service that allows users to record memories, store personal and practical information, and have that content shared with designated contacts upon their death.

We are the data controller for the personal data we process under this Privacy Policy. RMEMBER LTD is in the process of registering with the Information Commissioner's Office (ICO). The registration number will be published in this Privacy Policy on completion. If you have any questions, you can contact us at: admin@rmembr.me

2.What Data We Collect

We collect the following categories of personal data:

2.1 Account Data

• Full name
• Email address
• Date of birth
• Profile photograph (optional)
• Password (encrypted — we cannot access this)

2.2 Identity Verification Data

• Government-issued photo ID (e.g. passport, driving licence) — uploaded voluntarily at sign-up or required upon death verification

2.3 Content Data (Your Memories and Legacy)

• Video messages
• Audio recordings and voice notes
• Photographs and images
• Written posts, letters and notes
• Songs and files you upload

2.4 Life Admin Data

• Bank account details and financial information
• Insurance policy details
• Subscription information
• Will information and funeral wishes
• Any other personal or sensitive information you choose to store

2.5 Contact Data

• Names and email addresses of your designated contacts — the people who will receive your memories and content upon your death
• Key contacts — a list of names and details you choose to store (for example, your employer, landlord, or other people your designated contacts may wish to notify). rMembr does not contact or interact with key contacts directly. This information is stored solely for the benefit of your designated contacts following your death.

2.6 Technical and Usage Data

• IP address and device information
• App usage data and interaction logs
• Subscription and payment status (processed via Apple — see Section 5)

2.7 Death Verification Data

• Death certificates submitted by designated contacts
• Communications relating to the verification process
• Any additional evidence requested by rMembr to verify a death

3.How We Use Your Data

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

3.1 To provide the rMembr service

Legal basis: Contract performance — this processing is necessary to deliver the service you have signed up for. This includes storing your memories and life admin content, managing your account, maintaining your contact list, and releasing your content to designated contacts upon verified death.

3.2 To verify your identity and verify deaths

Legal basis: Contract performance and legitimate interests. We process identity and death verification data to ensure that your content is only released to the correct people, and only upon genuine confirmation of your death. We will not release any content until we are satisfied that the verification is genuine. We reserve the right to request additional evidence.

3.3 To manage your subscription and payments

Legal basis: Contract performance. Subscription payments are processed by Apple. We receive confirmation of payment status but do not process or store payment card details ourselves.

3.4 To communicate with you

Legal basis: Contract performance and legitimate interests. We will contact you about your account, subscription renewals, upcoming data deletion (where applicable), and service updates.

3.5 To comply with legal obligations

Legal basis: Legal obligation. We may be required to retain or disclose data in response to a lawful request from a court or regulatory body.

4.Special Category Data

Some of the data you store within rMembr may constitute special category data under UK GDPR — for example, information about your health, finances, or other sensitive personal matters stored within your Life Admin section.

You provide this data voluntarily. By storing special category data on rMembr, you are giving your explicit consent for us to store it securely on your behalf and release it in accordance with your instructions and this Privacy Policy.

We strongly recommend that you only store information you genuinely wish your designated contacts to receive.

5.Third Parties and Data Sharing

5.1 Apple

Subscription payments are processed by Apple via the Apple App Store. Apple's own privacy policy governs the processing of payment data. We receive confirmation of subscription status from Apple but do not receive or store your payment card details.

5.2 AWS (Amazon Web Services)

All rMembr data is stored on secure servers provided by Amazon Web Services (AWS). AWS acts as a data processor on our behalf and is contractually required to process data only in accordance with our instructions and applicable data protection law.

5.3 Designated Contacts

Upon verified confirmation of your death, your content and life admin information will be released to the contacts you have designated. Nothing is shared with your contacts prior to this point.

5.4 Legal Requests

We may disclose your data if required to do so by law, court order, or other legal process.

5.5 No Sale of Data

We do not sell, rent or trade your personal data to any third party for marketing or commercial purposes. Ever.

6.Data Retention

6.1 Active Accounts

We retain your data for as long as your account is active or as needed to provide the service. The free rMembr Core plan retains your core memory content permanently, even if you stop a paid subscription.

6.2 Cancelled or Lapsed Subscriptions

If your subscription lapses or is cancelled, your account will revert to the free Core plan. Your full content will be retained for 13 months from the date of your last successful payment. During this period, you will receive notifications and the opportunity to download your data. After 13 months, content beyond the Core plan allowance will be permanently deleted.

This extended retention period exists to protect users who may be unable to manage their account due to long-term illness or other circumstances — ensuring that if you pass away during this period, your content can still be released to your contacts.

6.3 Deletion Requests

If you wish to permanently delete your account and all associated data, you must submit a written deletion request by email to admin@rmembr.me from your registered email address. Where we have reasonable doubt about the identity of the person making the request, we may require you to provide a copy of your photo ID before we action it.

We require ID verification in such cases to protect our users — we will not action a deletion request from a third party, and we will not delete an account without confirming the request is genuine.

Upon receipt of a valid deletion request, your data will be permanently deleted within 90 days. This 90-day window exists to allow reactivation if a request is made in error.

6.4 Data Following Release

Content released to designated contacts remains stored on rMembr's secure servers and rMembr continues to hold responsibility for that data in accordance with this Privacy Policy for as long as it remains on our systems.

Designated contacts may download their received content at any time via the app or secure web link. Where a contact chooses to download a copy of released content, responsibility for that downloaded copy passes to the contact. rMembr accepts no liability for how downloaded copies are stored, shared or used once they have left our systems.

6.5 Post-Release Account Retention

Following the successful release of your content to your designated contacts, your rMembr account will be retained by us for a period of 6 years from the date of release, for record-keeping and audit purposes. After 6 years, the account and any associated administrative records will be permanently deleted, save for anonymised statistical information that cannot be used to identify any individual. Death-verification documents (including death certificates and ID copies submitted by designated contacts) will be retained on the same 6-year basis. This does not affect the data ownership position set out in Section 6.4 above.

7.Data Security

We take the security of your data seriously. rMembr uses advanced encryption and security measures to ensure your data is kept safe and private. Your data is stored on AWS servers and access is strictly controlled.

No system is completely infallible. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Information Commissioner's Office (ICO) as required by law.

8.Your Rights

Under UK GDPR, you have the following rights:

• Right of access — you can request a copy of the personal data we hold about you
• Right to rectification — you can ask us to correct inaccurate data
• Right to erasure — you can request deletion of your data (subject to the process set out in Section 6.3)
• Right to restrict processing — you can ask us to limit how we use your data
• Right to data portability — you can download your data at any time via the app
• Right to object — you can object to certain types of processing
• Right to withdraw consent — where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, contact us at admin@rmembr.me. We will respond within one month.

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9.Cookies

Our website (rmembr.me) uses cookies. Please refer to our separate Cookie Policy for full details.

10.Children

rMembr is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at admin@rmembr.me and we will delete it promptly.

11.Changes to This Policy

We may update this Privacy Policy from time to time. Where we make material changes, we will notify you by email or via the app. The date at the top of this document will always reflect the most recent version. Continued use of rMembr following notification of changes constitutes acceptance of the updated policy.

12.Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

RMEMBER LTD
Registered Address: Available on request
Email: admin@rmembr.me