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Privacy statement Momentio

We take your privacy very seriously and handle all your personal information with the utmost care. We always act in accordance with the General Data Protection Regulation ("GDPR"). This document sets out Momentio's privacy policy for the use of the Momentio Platform and our website. Please read this privacy statement carefully. If you have any questions or need more information about this topic please contact us via the contact form .

The purpose is to ensure the reliability, integrity and security of your data, as well as compliance with applicable laws and regulations regarding privacy.

Momentio is also referred to in this privacy statement as 'we' or 'we'. You as a user of Momentio's services are also referred to as “User”.

2. What is Momentio?

 

Momentio develops and operates an online platform for recording and storing important documents, data, memories and last wishes regarding funerals and inheritances in a digital safe.


By completing Momentio properly, administrative tasks can be handled more efficiently and relatives can concentrate more quickly on the grieving process and the beautiful memories that are left behind.

The platform ("Platform") can be accessed via the website www.momentio.io or directly via https://account.momentio.io/login/nl


No "app" is required for Momentio. You can access the Momentio portal with the most commonly used internet browsers.


In order to offer and deliver our services, we process certain personal data as described in this privacy statement.


The party responsible for the processing of personal data is Momentio, a trade name of Momentio BV, located in Venhuizen ("Momentio").

3. Momentio data

 

Momentio BV

Chamber of Commerce number: 90143302

VAT number: NL865222009B01

Contact Form

4. Which personal data is processed by Momentio, why and on what legal basis?

Create an account

In order to use the Platform, a personal account must be created. When you create an account you must and can enter certain information about yourself:

Minimum personal information to create an account ("Account Information"):

● First name

● Last name

● Email (for verification and notifications)

● Phone number (for verification)

● Country

● Language setting (preferred language for platform)

Personal situation

Additional personal information that you can provide when creating an account ("Personal situation") if you wish:

● Name

● Address

● Postcode

● Place of residence

● Place of birth

● Date of birth

● Marital status

● Donor codicil

● Religion

● Password for executor

''Read-only'' password that we store encrypted with which the executor can log in in combination with the email address of the Momentio user. You must inform the executor yourself and provide the login name and password.

● Yes/no partner/children/parents/guardian/administrators/executor

 

Momentio processes this personal data to create your account and to ensure that you can use the Platform in accordance with your wishes. The processing of your personal data in this context is necessary for the execution of the agreement to which you are a party in connection with the use of the Platform (Article 6(1)(b) GDPR).

 

Contacts

 

Contacts are created for selection in Last Wishes, Memories and Legacy.

 

● Name

● Date of birth

● Email address

● Phone number

● Address

● Postcode

● Place of residence

● Country

5. Other information

Important information

 

Important information that you can provide to contact persons and/or relatives in order to adjust or stop services (“Important information”):

  • Password information

    • We only help you reveal where and how you have stored your passwords. We do not ask you to save passwords.

  • Means of access

    • Information regarding keys, access cards, etc

  • Financial details

    • Information regarding bank accounts, alimony, crypto. We help you gain insight into financial data, but we do not ask for access data.

  • House

    • Information about the house, such as mortgage provider and policy number

  • Insurances

    • Name of insurers, type of insurance and policy number

  • Subscriptions

    • Description of subscriptions and policy number

  • Contracts

    • Type, name, customer number, contract number and additional information

  • Social media accounts

    • Type, username. We do not ask for a password.

 

Files

 

In ''Files'' you can add files that are relevant to arranging your last wishes or estate.

Files can also be used with ''memories'' or ''legacies''.

Last wishes

 

Last wishes that you can provide for the executor to arrange your funeral (“Last wishes”):

  • Information about final wishes (wishes regarding funeral)

  • Contacts

    • who must be informed in the event of death

    • who can be selected as organiser, speaker, carrier

Legacy

 

Inheritance that you can specify for the executor and/or notary to arrange your estate ("Inheritance"):

  • Information about inheritance

  • Assigned inheritance to 1 or more contact persons including the associated message.

The aforementioned documents and information may contain personal data of you and third parties. Storing these documents and information in the Platform is not mandatory and is done at your own initiative. The processing of personal data contained in the documents and information stored by you is necessary for the execution of the agreement to which you are a party in connection with the use of the Platform (Article 6(1)(b) GDPR). Momentio has no access to this information and data. This information and data will only be provided to the executor you specified.

6. Information messages

 

In order to send you information messages (not marketing communications) necessary to provide the Services (such as push notifications, system notifications, email notifications and text messages), we may use your mobile phone number and/or your email address.

Momentio can also send you personalized emails, depending on, among other things, your activity and data entered on the Platform. For example, if certain information is missing, Momentio can advise you by email to supplement the information.

This processing of your personal data in this context is necessary for the performance of an agreement to which you are a party in connection with the use of the Platform (Article 6 (1) (b) GDPR).

Customer satisfaction

 

Momentio may ask you by email to rate its services. We use your email address for this.

This processing of these personal data is necessary to promote the legitimate interests of Momentio, Article 6.1 sub f GDPR, namely to ensure an improvement of its services.

Newsletter

 

If you take out a subscription with Momentio you will NOT automatically be added to the newsletters. We do not want to bother you unnecessarily. The confirmation email will contain a link where you can register for the newsletter if desired. You can also simply read the blog post via our website without becoming a member.

Momentio would like to inform you about the development of its Platform and services. If you join the newsletter, Momentio will inform you if the service has changed (e.g. new functionality).

Where required, a double opt-in procedure will be used for registration. After registering on our website, you will receive a confirmation email in which you will be asked to confirm your registration. This entire process is documented and stored by Momentio. This includes the time and confirmation of registration and your IP address.

If you no longer wish to receive newsletters from Momentio at any time, you can unsubscribe yourself via the website. Every email Momentio sends also contains a link to the option to unsubscribe.

To send you newsletters, we use the email address and IP address you provide. The processing of these personal data is necessary for the pursuit of Momentio's legitimate interests (Article 6 (1) (f) GDPR), namely direct marketing.

7. Other processing

Merging and encrypting data

 

To minimize the processing of personal data, Momentio may aggregate or encrypt your personal data to create anonymous data that cannot be traced back to a natural person.

The processing of these personal data is necessary for the pursuit of Momentio's legitimate interests (Article 6(1)(f) GDPR), namely to comply with privacy legislation and to protect your privacy.

Automatically generated data (log files)

 

Momentio collects automatically generated data about use of the website and the Platform. This information consists of your IP address; account activity (such as storage space usage, number of logins); data that has been viewed or clicked on; and other log information (such as browser type, IP address, date and time of access, cookie ID, and HTTP referrer).

Momentio needs this information to ensure that the website and the Platform work optimally (for example to display content correctly and to keep the website and the Platform safe); the processing of these personal data is therefore necessary for the pursuit of Momentio's legitimate interests (Article 6 (1) (f) GDPR).

Comply with legislation

 

To comply with applicable law, Momentio may be required to process personal data for purposes other than those set out in this privacy statement, such as law enforcement and complying with court orders.

The processing of your personal data in this context is necessary to comply with a legal obligation to which Momentio is subject (Article 6 (1) (c) GDPR).

8. In which cases does Momentio disclose my personal data to third parties?

In certain circumstances we may share personal data with third parties:

  • Next of kin: To provide next of kin with the information you have entered and marked to share with the designated next of kin (Executor and shared memories);

  • Service providers: In order to provide the services, Momentio shares your personal data with service providers (processors). These service providers process personal data on behalf of Momentio. A processing agreement applies to the processing by service providers, in which Momentio has stated that the service provider will only process the personal data on the basis of and in accordance with Momentio's instructions. The data you store in the Momentio platform is stored in Europe (Ireland).

We use a contact form for the website, which is completely separate from the data you store in the Momentio platform. In the form we ask for your name, email and telephone number. The respective service provider of the contact form is located outside the European Economic Area (EEA), namely the United States. To comply with EU data protection law for international transfers, Momentio only allows service providers outside the EEA to process your personal data if a contract has been concluded between Momentio and the service provider that includes the standard contractual clauses adopted by the European Commission, which it is ensured that adequate data protection arrangements are in place (Article 46(1)(c) GDPR). Examples of service providers with whom Momentio may share personal data to provide the services are:


AWS: The Momentio Platform is hosted on an AWS environment. Momentio has chosen Ireland as its hosting location. All data is stored encrypted in a database. AWS does not have access to the data.

Amazon Web Services EMEA SARL

Treublaan 7

1097 DP Amsterdam

Chamber of Commerce: 68579780

 

Mollie: Mollie is the payment provider for the Momentio platform.

Mollie

Keizersgracht 126

1015 CW Amsterdam

  • Third-party content: Our website also contains content from third parties (such as YouTube videos, maps from Google Maps, RSS feeds or images from other websites). In order to display this third-party content, we transmit your IP address to the relevant third parties. We have no influence on whether these third parties only use your IP address to display the content or whether your IP address is also used for other purposes. The processing of these personal data is necessary for the pursuit of Momentio's legitimate interests, namely displaying third-party content.

  • Competent authorities: to the extent required by law or strictly necessary for the prevention, detection or prosecution of criminal acts and fraud, Momentio discloses personal data to law enforcement officers and other government authorities. The processing of your personal data in this context is necessary to comply with a legal obligation to which Momentio is subject.

  • Merger and Acquisition: We may transfer your personal data to third parties in the event of a merger, acquisition, reorganization, sale of assets, bankruptcy or insolvency of Momentio. If required by applicable law, we will ensure that your consent is first obtained or that you are informed. In this context, the processing of these personal data is necessary for the representation of Momentio's legitimate interests.

You can contact Momentio via the contact form if you have any questions about forwarding your data to third parties.

9. What are my rights?

 

Under the GDPR you have a number of rights with regard to your personal data and its processing:

  • You have the right to be informed by us whether or not your personal data is being processed and, if that is the case, to obtain access to your personal data and to additional information about the processing of your personal data;

  • You have the right to request that we correct incorrect personal data;

  • In some cases you have the right to request us to delete your personal data (the right to be forgotten);

  • In some cases you have the right to have us restrict the processing of your personal data, for example when you have contested the accuracy of your personal data;

  • You have the right, at your request, to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and you have the right to have this data transmitted to another controller;

  • You have the right to object to the processing of personal data that is based on Momentio's legitimate interests. In that case, we will no longer process the personal data unless we can demonstrate that there are compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms or it is related to the establishment, exercise or defense of legal claims;

  • When personal data is processed for direct marketing, you have the right to object at any time to the processing of your personal data for such marketing. In that case, Momentio no longer processes your personal data for those purposes;

  • Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent until it is withdrawn.

You can submit your request to us via the contact form . Momentio will respond to your request as quickly as possible, but in any case within 30 days of receiving the request. This period may be extended by two months if necessary, depending on the complexity of the requests and their number. Momentio will inform you within 30 days of receipt of the request if such an extension will take place, stating the reason for the delay.

If Momentio does not take action on your request, we will inform you as soon as possible, but in any case no later than 30 days after receipt of the request, of the reasons for not taking action. In that case, you also have the right to file a complaint with the supervisory authority and to appeal to the courts.

10. How can I unsubscribe from Momentio and what happens to my personal data if I do so?

 

You can unsubscribe as a user of Momentio's services via the contact form , indicating that you wish to cancel. We will process these requests as soon as possible, no later than 4 weeks after receipt, or as otherwise required by applicable law.

Your personal data will be retained as long as you use the Platform. As soon as your agreement with Momentio has been terminated, the retention periods as stated in paragraph 6 below begin to run. This means, for example, that your account data will be deleted no later than 4 weeks after termination of the agreement or after a GDPR request. This is an automated process. Some personal data is retained longer after deregistration or death, for example your payment history, as stated below in the data retention table.

11. How long does Momentio store my personal data?

 

Types of personal data

Retention period

Account information Additional account informationAccount information

Up to a maximum of 4 weeks after termination of the agreement or after GDPR request to delete data. This process is fully automated.

General payment information Payment history

Purchase remains in the database, but is anonymously related to an account number that can no longer be linked to a person in our platform after deletion of data.

Mollie, our payment service, will not store your personal data for longer than the mandatory legal period prescribes or, if such a legal period does not apply, no longer than is strictly necessary to achieve the purposes for which your personal data was collected. As a financial institution, Mollie is in many cases legally obliged to retain personal data for a number of years, such as the personal data that Mollie receives with regard to the assessment of your application as a customer, the preparation and execution of the agreement and the processing of payments.

Up to date details can be found in the Mollie privacy statement .

Communication data

1 year after termination of agreement

Marketing data

1 year after termination of agreement

Technical user data (IP address, browser type, click behavior)

Up to a maximum of 4 weeks after termination of the agreement or after GDPR request to delete data. This process is fully automated.

 

Please note: you can request the deletion of your personal data at any time, as described in paragraph 4. Momentio will assess this request and accept it if the request is justified. Momentio may reject a request for certain reasons, for example due to a legal (fiscal) retention obligation.

Momentio may retain the collected data in an aggregated and anonymous form after the retention period has expired, to conduct analyzes and research, for market research and/or to prevent fraud.

12. How does Momentio protect my personal information?

 

The protection of your Personal Data is extremely important to us. Momentio therefore uses reasonable administrative, technical and physical security measures to protect your personal data against unauthorized access, destruction or modification of information. Furthermore, we regularly check our systems using external specialists and/or software to determine whether our security measures are still adequate.

13. Can this privacy statement be changed?

 

It is possible that the privacy statement will be changed in the future. It is therefore recommended to regularly visit the section of the website where the privacy statement can be read. As a user of the Platform, you will receive a notification when logging in to the Platform or an email if there are important changes to the privacy statement.

14. What are cookies and how are they used by Momentio?

When you use the website, various cookies are stored on your computer, mobile device and/or tablet ("Devices"). Cookies are small pieces of information (in the form of text) that a server sends to the browser (such as Internet Explorer, Chrome, Safari) with the intention that the browser sends this information back to the server the next time a user visits the website. Cookies cannot damage your Devices or files stored in them. For more information about how on which Momentio uses cookies.

15. Where can I file my complaint?

If you suspect that a breach of data protection law has occurred and we cannot resolve the matter amicably, you have the right to lodge a complaint with a supervisory authority.

 

Final adjustment

This privacy statement was last updated on June 12, 2023.

You can find and read all legal documents on our website .

If you have any questions or would like more information about the above and/or this topic, please do not hesitate to contact us via the contact form .

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