Política de privacidad

Effective date: 5 October 2026

MemorLume is operated by Daniel Martin Jorge, a sole trader (“MemorLume”, “we”, “us” or “our”). Daniel Martin Jorge is the controller of the personal information described in this policy.

This policy explains how we collect, use, disclose and protect personal information when you visit memorlume.com, buy or personalize a product, contact us, or otherwise use our services.

Contact details

  • Controller: Daniel Martin Jorge, trading as MemorLume
  • NIF: 25729315C
  • Address: Calle Moscatel 14, 29631 Benalmádena, Málaga, Spain
  • Email: support@memorlume.com
  • Telephone: +34 640 747 861

Information we collect

Depending on how you use the store, we may collect:

  • identity and contact information, including name, email address and telephone number;
  • billing and delivery information, including postal address;
  • order and transaction information, including products, prices, discounts, delivery status and an order reference;
  • personalization instructions, including selected options, text, symbols, subject/background choices and notes;
  • photographs you upload for a personalized product, which may depict you or other people, including children;
  • customer-service communications and evidence supplied for an order issue, such as photographs or an unedited unboxing video;
  • technical and usage information, including device, browser, IP address, pages and interactions, subject to applicable consent choices;
  • marketing preferences and cookie/privacy choices.

Payment providers process the payment information needed to complete a purchase. MemorLume does not claim to store full payment-card credentials. Do not send card details in a photograph, personalization field, email or support message.

Photographs and other people's information

Only upload a photograph you are entitled to use for the requested personalized product. If it depicts another person, including a child, you must have the authority or permission needed to provide it for this purpose. Do not upload unlawful content or information that is unnecessary for the order.

Uploaded photographs are used to review suitability, prepare and manufacture the personalized product, resolve a photo problem before production, fulfil the order, and address a related customer-service issue. They are not authorized for advertising, public display, supplier portfolios, social media, unrelated reuse or model training.

Our supplier reviews whether a photograph is suitable before production. If an issue is identified, production is paused while we contact the customer and resolve it.

Why we use personal information

We use personal information to:

  • provide the store and perform our contract, including taking payment, reviewing a photograph, manufacturing, delivering and supporting an order;
  • communicate about an order, photo issue, tracking, delivery, return, refund, replacement or complaint;
  • prevent fraud, secure the store and establish, exercise or defend legal claims;
  • maintain tax, accounting and legally required business records;
  • improve and measure the website where permitted and subject to required consent;
  • send marketing only where permitted and according to your choices;
  • comply with legal obligations.

The legal basis will depend on the purpose and applicable law. It is usually performance of a contract or steps requested before a contract, compliance with a legal obligation, our legitimate interests in operating and securing the business and handling claims, or consent for optional cookies/marketing where consent is required. You may withdraw consent at any time without affecting processing already carried out lawfully.

How we disclose information

We disclose only information needed for the relevant service:

  • Shopify: hosts the online store and processes storefront, account, checkout, order and customer-service data for ecommerce operation.
  • Personalization tools: Easify supports the collection and handling of product options and uploaded personalization content.
  • Payment providers: process payments and fraud checks. They receive payment and transaction information under their own applicable terms.
  • Google Workspace: MemorLume uses a business-controlled Google Drive and Google Sheets workspace to share the selected photograph and necessary order instructions with the manufacturer and manage fulfilment. Access is restricted to specifically authorized users; public “Anyone with the link” customer-photo folders are not permitted. Photograph folders and order-management data are separated where useful, and the Sheet excludes information the manufacturer does not need.
  • Manufacturer in China: Zhejiang Shenshi Laser Technology Co., Ltd., registration 91330700794355929N, processes the selected photograph, customization and necessary order information solely to assess photo suitability, manufacture and fulfil the personalized order.
  • Logistics: Yiwu Lianbao International Freight Forwarding Co., Ltd., registration 91330782560975498G, receives necessary delivery information such as recipient name, address, telephone number and shipment reference. It does not receive customer photographs. Other delivery carriers may receive the same limited shipping information where necessary to complete delivery.
  • Alibaba Trade Assurance: it is used for supplier batch purchasing and accounting with batch/internal order references, minimum product/customization specifications, quantities, supplier costs and payment totals. We do not include customer photographs, Drive photo links, telephone numbers, email addresses, customer notes, unnecessary names or unnecessary shipping information in Alibaba. Customer fulfilment data remains in the restricted fulfilment system. If Alibaba technically requires a delivery address or other customer information, we will assess and disclose that processing before using it.
  • Analytics and advertising: subject to applicable consent choices, we use Google Analytics 4 and Microsoft Clarity to understand website use and improve the store, and Shopify's official Meta integration for advertising measurement through browser and server-side events. A limited Shopify custom pixel measures named personalization milestones without sending photographs, filenames, photo links, personalization text or customer/contact data. Klaviyo technologies may support analytics and marketing according to the consent categories you select.
  • Professional advisers and authorities: we may disclose information where reasonably necessary for legal, accounting, security, dispute-resolution or regulatory purposes.

We do not authorize the manufacturer or carrier to use personal information for their own advertising or unrelated purposes.

Cookies and similar technologies

The store uses technologies needed to operate the site and optional technologies for personalization, analytics and marketing. Shopify's Cookie Preferences control is available in the footer. Where consent is required, you can accept, decline or choose categories, and you can return to Cookie Preferences to change your selection.

Shopify's privacy controls transmit those choices to integrated services. Optional Google Analytics, Microsoft Clarity, Meta browser tracking and the personalization-measurement pixel are configured to follow the applicable consent choices. You can withdraw or change your choices through Cookie Preferences. Withdrawal does not affect processing already carried out lawfully and may require a reload before all optional technologies stop.

International transfers

MemorLume is established in Spain, while some service providers process information in other countries.

Personalization and required order information are transferred to Zhejiang Shenshi in China so it can manufacture and fulfil the product. MemorLume and Zhejiang Shenshi have signed the European Commission's 2021 Standard Contractual Clauses, Module Two (controller to processor). We also require purpose limitation, named access, password protection, limited carrier disclosure, deletion after production and confirmed receipt, and immediate incident reporting. The signed contract is held privately and is not published.

Other providers, including Shopify, Google, Meta and Microsoft, may process information internationally according to their service terms and transfer safeguards. We use applicable contractual safeguards and provider data-processing terms where required. A transfer safeguard does not remove the need to minimize the information shared.

Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including order performance, delivery, support, disputes, security, tax/accounting and other legal obligations. The applicable period depends on the record and the status of the order; we do not state an invented universal number of days.

For the manufacturer, customer photographs and order data are to be deleted after both production is complete and the customer has received the completed crystal, including remaining supplier copies/backups. Open delivery, defect or replacement cases may require a narrowly documented hold until the issue is resolved. MemorLume must also remove access and handle copies held in its own tools; deletion from the manufacturer does not automatically delete information held by Shopify or another provider under its own applicable retention requirements.

Security and incidents

We use administrative, technical and organizational measures appropriate to the nature and risk of the information. No system can be guaranteed completely secure. The manufacturer has confirmed that its processing computer is password protected and that photograph access is limited to identified authorized people. It must notify MemorLume without undue delay of a loss, unauthorized access, disclosure or other personal-data incident.

Your choices and rights

Depending on where you live, you may have rights to ask for access, correction, deletion, restriction, portability or objection, to withdraw consent, and to opt out of certain targeted-advertising or sale/sharing activities where applicable. These rights can be subject to lawful exceptions, including records that must be kept for tax, fraud prevention, dispute or other legal purposes.

To make a request, contact support@memorlume.com. We may need to verify your identity and authority. If you are acting for another person, we may request evidence of authorization.

You may complain to the Spanish Data Protection Agency (AEPD) at aepd.es or to another competent supervisory authority. Contacting us first may allow us to address the issue promptly, but it does not limit your right to complain.

Children

The store is not directed to children as purchasers. A customer photograph may nevertheless depict a child. The purchaser must have the authority or permission needed to provide that image for manufacture. We process it only for the order and related support; it must not be reused for advertising or public display without a separate valid basis and authorization.

External links

The website may link to third-party sites. Their privacy practices are governed by their own notices. Review those notices before providing information directly to them.

Changes to this policy

We may update this policy when the store, providers, data flows or legal requirements change. The current version and effective date will be posted on this page. Material changes will be communicated where required.