Privacy notice
Draft: to be reviewed with a lawyer before launch. This text describes the intent, it is not yet a final legal document.
Last updated: 11 September 2026.
The data controller
The data controller is Atrahasis (legal entity to be defined once incorporated — see The project). For any request about your data, write to us from the Contact page.
What data we collect
The data you choose to give us to create or manage a memorial page (name, dates, places, biography, photographs, uploaded objects), your account data (email, preferences), the technical data needed for access (IP address, for security and antispam) and the messages you write to us. We do not collect data for profiling or advertising.
Legal bases
We process your data to perform the contract when you create a showcase or buy a concession, on a legitimate interest when we prevent abuse (antispam, rate limits), and on your consent when it is explicitly required (for example, the consent to voice and image for whoever creates their own page while alive).
Data of deceased people
The Italian Privacy Code (art. 2-terdecies) recognizes heirs' right to exercise, on behalf of the deceased, the rights this notice describes: access, rectification, removal of the page through the Removal procedure. Whoever creates a page for a loved one declares, when creating it, to have the standing to do so.
Biometric data (The Echo)
Voice and face processed for The Echo (a feature not yet active) are biometric data, a special category of data: they will require an explicit, revocable consent, collected separately from this notice, and a mandate stating who decides after a passing. This section will be completed before the feature is activated.
Retention
A showcase's data is kept for the whole duration of the concession, and for the five years of dormant mode that follow: no automatic deletion, ever (see Terms and concessions). An account's data with no active showcase is kept for as long as the account stays open.
Where data is kept
Data is kept on servers within the European Union. We do not transfer it outside the European Union, except for a provider offering equivalent guarantees, declared here when applicable.
Your rights
You can ask at any time for access, rectification, removal (through the Removal procedure) or a copy of your data (through "Download a copy", from your showcase), and withdraw a consent given earlier. Write to us from the Contact page to exercise any of these rights.