Privacy notice
Draft: to be reviewed with a lawyer before launch. This text precisely describes what the site does today, it is not yet a final legal document.
Last updated: 23 September 2026.
The data controller
The data controller is Industrial Consulting Pro S.r.l.s., registered office at Via Perni 13, 83050 Sorbo Serpico (AV), Italy, VAT number 03246480648, REA AV-314563, PEC industrialconsultingpro@pec.it. 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 and security (IP address, used only to prevent abuse, never for profiling), the messages you write to us, and the tax data needed to calculate VAT when you buy something. If you choose to record voice and face for The Echo, we process that data too — see the dedicated section below. We do not collect data for profiling or advertising, and there is no public visit counter.
Data of people who have never visited the site
Whoever curates a page can also enter data about other people who never gave it to us directly: a relative added to the family tree, the name and email of whoever will receive a letter through time or a sealed word, a person mentioned in a thought in the guestbook. Whoever curates the page declares they have a legitimate standing to do so. If you are one of these people and want to know what data we process about you, correct it, or ask for its removal, write to us from the Contact page: we answer even if you have never had an account with us.
Named by someone else: if your name appears in a showcase you didn't create
Whoever curates a showcase can enter the names of the remembered person's family members: name, family relationship, dates, sometimes a portrait. We don't collect this data from you but from the curator, who enters it under their own responsibility; we have no way to notify you directly, because we don't know your contact details. The basis for this processing is the curator's legitimate interest in reconstructing family memory (GDPR art. 6.1.f). If you're a living person named in a family tree, you still have every right described in this notice: to know what's there, to correct it, to ask to be removed, to object. To exercise them, use the form for family members named in a tree: no account needed, we reply within a month and, if you ask for removal or non-public status, the entry is suspended from public view the same day, while we make a final decision. You may also contact the data protection authority.
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 (rate limits, honeypot fields) or handle internal matters (death attestations, removal requests), and on your consent when it is explicitly required — for the terms of use on first sign-in, and separately and more specifically for the voice and face processed by The Echo.
Data of deceased people
The GDPR does not apply to a deceased person's data, but the Italian Privacy Code (art. 2-terdecies) recognizes the right of whoever has a standing of their own — an heir, a relative — to exercise on their behalf 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. If relatives disagree about a page, write to us from the Contact page: we assess each case individually, we do not yet have an automatic procedure for a disagreement between relatives.
Voice and face for The Echo
The Echo is a living archive, activated with a separate subscription, that keeps your audio and video recordings and reuses them to answer whoever listens — always and only in your own words, never inventing anything new: today we do not generate a synthetic voice or face. Recording voice and face still requires a qualified consent, separate from and more explicit than an ordinary one, revocable at any time: withdrawing it deactivates The Echo immediately, but does not by itself delete the recordings already made, which stay editable and individually deletable by whoever curates the page. If we ever introduce a technology that genuinely generates a new voice or face, we will say so explicitly and collect a specific consent for that, before activating it. Whoever talks with The Echo always does so through a personal link that the page's curator shares with them, never a public address; up to three "trusted people for the Echo", whom you designate yourself alongside this consent, can deactivate it at any time after your passing, even just one of them — deactivation always prevails. This designation is not a will: it grants no right over the estate, it only concerns your own voice and image.
The unspoken words
Your message is stored encrypted: in our archive, no one can read it by simply opening the database. The key that unlocks it is kept separately and used only once, at the moment of delivery, to let the browser of the person you chose open it: the content is decrypted on their own device, not on our servers. No one at Atrahasis reads these messages, by rule and by access log; but we can't tell you it's technically impossible, because whoever holds the key could, and an authority could order it. If you need absolute confidentiality, write the message on paper.
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. A letter through time or a sealed word stays waiting for delivery for however long the chosen condition requires, even many years, if it depends on a distant date or an event that is slow to happen.
Where data is kept
Data is kept on servers within the European Union, in Italy. We do not transfer it outside the European Union, except for a provider offering equivalent guarantees, declared here when applicable.
Security
A death certificate or an exported copy of your showcase are never reachable at a public address: they can only be downloaded through a link of their own, checked on every request. We limit how often certain requests can be made (public forms, sign-in by email) to prevent misuse of your address or of whoever writes to you.
Payments and tax data
If you buy a concession, an unlock, a pavilion, or a subscription to The Echo, we collect the tax data needed to calculate the correct VAT rate (tax code, or company name and VAT number for a business) and process the payment through Stripe, which does not share your card data with us. You will receive a receipt by email; a real tax invoice will be introduced before we start taking real payments.
Deleting memories
We never automatically delete a showcase, a thought from the guestbook, or an object from a showcase: it is a product rule, not a technical limit — see The project. This does not take away your right to the erasure of your own personal data: a genuine request, yours or from whoever has standing to make it, is always assessed case by case, within 30 days, even if it takes a human decision instead of an automatic button. When we delete or anonymize data, the backup copies that held it are overwritten within 14 days and are never used to restore it.
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: we answer even those who have never had an account.
Cookies
We only use technical cookies, never for advertising or tracking: the Cookie page lists them one by one.
Changes to this notice
If we substantially change how we process your data, we will update this page and the date above; for an important change, we will also tell you by email if you have an account.