1. Who we are

MyLogacy is operated by Jay Emm Systems. In this policy, "we" and "us" mean Jay Emm Systems, and "you" means the person whose account holds the memories.

TODO(review) Confirm the registered legal name and form of the entity, the country and state it is registered in, its registered address, and whether a data controller or representative needs to be named for visitors outside the United States.

2. What we collect

Information you give us when you sign up

• Your email address, which is how you sign in.
• Your name, if you give one.
• If you sign in with Google, Apple or Facebook, the identifier and email address those services return to us.

The memories you add

• Photographs and video.
• Audio recordings, including voice notes and recorded answers.
• Text you write, such as titles, captions, stories and recipes.
• The names and relationships of the people you add to your network, and the email addresses or phone numbers you use to invite them.
• Which circles a memory belongs to, and any correction you make when the software files something in the wrong place.

Information about how you use the service

TODO(review) Confirm exactly what usage, device and diagnostic data the app and the backend record, whether crash reporting is used, and whether any of it is tied to your account or kept separately. Nothing should be listed here until the engineering answer is written down.

We do not run advertising trackers or third party analytics on this website.

3. Information inside your files

Photos and videos usually carry hidden details recorded by the camera. We read them, because they are what makes the timeline and the map work:

• The date and time the picture was taken.
• The camera or phone that took it.
• The location, if your camera or phone saved coordinates with the file. This is what places a memory on the map.

If you do not want location data in your account, remove it from the files before you upload them, or turn location off in your camera app. TODO(review) Confirm whether the app offers a setting to discard location data on upload, and whether removing a location from a memory also removes it from the stored original file.

4. Face grouping

MyLogacy looks at the faces in your photos and groups the ones that appear to be the same person, so that you can open a person and see every memory they are in. You name those groups yourself, and you can correct or remove a grouping.

TODO(review) This is the highest risk section on the page and needs a lawyer. Face grouping may count as biometric data under Illinois BIPA, Texas CUBI, Washington, Colorado, the EU GDPR and other laws, several of which require written consent before any face template is created, published retention and destruction schedules, and in some cases a ban on selling or profiting from the data. A lawyer needs to decide whether the feature can be on by default, what consent screen is required, and where. Engineering needs to confirm whether face templates are stored, in what form, for how long, and whether they are deleted when the photo is deleted.

5. AI processing

Your files are processed automatically so the product can work. That includes:

• Suggesting which circles a photo, video or recording belongs to.
• Transcribing audio and video so you can search it and read it back.
• Reading handwriting on a scanned recipe card.
• Building the things you ask for, such as a documentary, a podcast episode, a photo book or a reel.
• Answering questions you ask the assistant, using the memories in your own account.

TODO(review) Name the AI providers actually used in production, what is sent to each one, whether any provider retains the content it receives, whether content is ever used to train a model, and where that processing happens. Until that list is confirmed, this page should not promise anything about it.

6. Voice and likeness

MyLogacy can narrate in a voice trained on recordings you provide, and can build an avatar. Training is off unless you turn it on, and each generation that uses a cloned voice asks you to consent at the time.

You can also record whether your voice and avatar may be used after your death, and that setting can only be changed while you are living.

TODO(review) Confirm which third party voice or avatar service holds the trained model, how long it is kept, and how it is destroyed when an account is deleted. Confirm what consent is required from other people whose voices appear in an uploaded recording.

7. Sharing and public links

Nothing in your account is public by default. Memories reach other people in three ways, and all three start with you:

People you invite

An invited person sees the circles you gave them, and nothing else. You can remove their access.

Scan and Watch pages

A printed keepsake carries a QR code that opens a page for one memory. That page is public. Anyone who has the printed object, or the link, can open it.

Tribute pages

A tribute page is not listed anywhere and is not searchable, but anyone who has the link can open it. Treat the link itself as the key.

We also use service providers to run the product, such as hosting, email delivery, payment processing and print fulfilment. A print partner receives what it needs to print and post your order, including the shipping address. TODO(review) List the actual providers in use, the category of data each receives, and confirm there is a written data processing agreement with each one.

We do not sell your memories, and we do not hand them to advertisers. TODO(review) Confirm this statement is one the company is willing to be held to, and check the definition of "sell" and "share" under the California Consumer Privacy Act, which is broader than it sounds.

8. Where your files are kept

Files and account data are stored with Amazon Web Services in the United States. TODO(review) Confirm the region and provider before publishing, and state what applies to visitors and customers outside the United States, including the transfer mechanism relied on for the EU and the UK.

TODO(review) Describe the security measures that actually exist rather than generic assurances. Encryption in transit and at rest, who on the team can access customer files and under what controls, how access is logged, and what happens in the event of a breach, including the notification timeline required by law.

9. Keeping, exporting and deleting

Getting a copy of everything

You can create a portable archive of your account from your settings. It contains your account details, your memory information as JSON and CSV, your circles, and the original files where they are available. The download link is short lived, and the archive is deleted 24 hours after it is prepared.

Deleting your account

When you delete your account, access is revoked immediately and your private files and any connected voice resources are permanently removed. If our automatic cleanup cannot confirm that every external item was removed, the deletion is held open and our support team completes it by hand.

One thing to know before you delete

Keepsake links stay playable for one year after an account is deleted, so that a photo book or an ornament already in someone's hands does not stop working the day the account closes. If you need a keepsake link switched off sooner, ask us.

How long we keep everything else

TODO(review) State real retention periods. How long backups hold deleted content, how long an inactive account is kept before anything happens to it, how long invitation records, logs and support emails are kept, and what a memorialised account retains. Do not publish a number that engineering has not confirmed.

10. Children

MyLogacy is meant to be used by adults. Photographs and video of children are an ordinary part of a family archive, and they are added by the adult who holds the account.

TODO(review) Set and state the minimum age for holding an account, and check the position under COPPA in the United States and the age of digital consent under the GDPR in each EU country where the app is offered. Decide whether a child can be an invited viewer, and what that requires.

11. Your rights

You can see, correct, export and delete your memories from inside the app at any time.

TODO(review) Depending on where you live you may have further rights, and the wording here has to match the law rather than paraphrase it. A lawyer needs to add the specific rights and response deadlines for the jurisdictions the app is sold in, most likely the GDPR, the UK GDPR, the California Consumer Privacy Act and the newer state privacy laws, plus the appeal and complaint routes each of them requires.

12. Changes to this policy

When this policy changes we will post the new version on this page. TODO(review) Decide how account holders are told about a material change, how much notice is given, and whether continued use counts as acceptance. Add a "last updated" date once the first reviewed version exists.

13. How to reach us

Privacy questions and requests go to Jay Emm Systems. TODO(review) Add the real support email address, the postal address for written requests, and the name of whoever handles privacy requests. Do not publish this page with a placeholder address.

See the contact page.