Privacy Policy of the KEEPMOMENTS Online Store

Last updated: June 15, 2026

www.keepmoments.us

1. Introduction and who we are

This Privacy Policy explains how personal information is collected, used, disclosed, and protected when you visit, create an account with, or place an order through the KEEPMOMENTS online store at www.keepmoments.us (the "Store"). We ask you to read it carefully, because some of the information you share with us, in particular the material you may send to us to be made into a keepsake, is among the most personal information a person ever entrusts to a business, and we treat it accordingly.

The Store is operated by:

KEEP MOMENTS LTD A private company limited by shares, incorporated in England and Wales Company registration number (Companies House): 11909402 Registered office: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom Operational address (order fulfillment, handling of consigned material, dispatch, and returns): Wapienna 4A/2, 71-790 Szczecin, Poland E-mail: [email protected] Phone: +48 731 850 700

In this Policy, "KEEP MOMENTS LTD", "we", "us", and "our" refer to the company named above; "you" and "your" refer to the visitor, customer, or account holder. KEEP MOMENTS LTD is the business responsible for the personal information described here.

KEEPMOMENTS creates bespoke memorial and keepsake jewelry, made to order from material that customers send to us. We make each piece by hand in our workshop in Szczecin, Poland, and ship it internationally.

KEEP MOMENTS LTD is a United Kingdom company. We provide this Privacy Policy for the benefit of our customers in the United States and to describe, in plain terms, how we handle your personal information and the privacy choices available to you. Some United States privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA"), apply only to businesses that meet certain revenue or data-volume thresholds, and we may not meet those thresholds, so the CCPA may not strictly apply to us. We nonetheless provide this notice and honor the consumer privacy choices described in it. This Policy is not a notice under the European Union or United Kingdom General Data Protection Regulation, and it does not import European data-protection concepts; it is a United States privacy notice.

We have not appointed a Data Protection Officer. For any question about this Policy or about how we handle your personal information, contact us at [email protected] or by post at the Szczecin operational address above.

2. One account across our group stores (shared customer database)

KEEPMOMENTS is one of several online stores operated within our corporate group. All of these stores run on one shared technology platform with one shared customer-account database. The practical benefit to you is that a single account lets you sign in and shop across several group stores without creating a separate account for each one.

Because of this shared database, your account information (such as your name, e-mail address, password, saved addresses, and order history) is shared between the two companies that operate the group stores and that are jointly responsible for that shared account information:

KEEP MOMENTS LTD (Companies House registration number 11909402), which operates KEEPMOMENTS; and
MILKIES LTD (Companies House registration number 10195739), a separate company at the same registered office, 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom, which operates other group stores.

These two companies have agreed between themselves how each is responsible for the shared account information, so that your information is handled consistently across the group. We use this shared-account arrangement to provide and maintain your account and to give you a single sign-in across the group stores. Information that is specific to your KEEPMOMENTS order, including any material you send to us, is handled by KEEP MOMENTS LTD as described in this Policy and is not used by the other group company for its own purposes.

You can address any request or question about your account information to a single contact point: [email protected]. You may exercise the privacy choices described in this Policy with respect to your account information against either of the two companies, and a request made to one is treated as made to both. This is the only place in this Policy where MILKIES LTD is mentioned; it is named solely to be transparent about the shared account database.

3. Categories of personal information we collect, and our sources

We collect the following categories of personal information:

Identifiers and contact details that you provide: your first and last name, e-mail address, phone number, delivery address, and billing address. For business customers, we also collect a tax identification number where required for invoicing.
Order and commercial information: the piece you order and its personalization (including any engraving or portrait), the type of material you send to us, your chosen payment method, your delivery address, and your order history. Payment-card details are entered with and processed by our payment provider; we do not store full card numbers on our own systems.
Account information, if you create an account: your password (stored in encrypted, hashed form), your order history, and any saved preferences or addresses.
Information about consigned material that you send to us to be made into a keepsake, which may include sensitive personal information. This is described in Section 4.
Internet and device activity information collected automatically when you use the Store: your IP address, browser type and version, operating system, screen resolution, the pages you view, the time you spend on the site, your clicks, and information collected through cookies and the tracking tools described in Section 8. This information is collected only as described in Section 8 and, for non-essential tools, only with your consent.

We collect this information from the following sources:

directly from you, when you browse the Store, create an account, place an order, send us material, contact us, or sign up for our e-mails;
automatically, through cookies and similar technologies, as described in Section 8; and
from third-party login providers, if you choose to sign in or register using Google or Facebook, as described in Section 9.

Providing personal information is voluntary. However, the information needed to fulfill an order (such as your name, delivery address, and the material for your keepsake) is required to place and complete that order, and an order cannot be processed without it.

4. Sensitive personal information (consigned material)

Each KEEPMOMENTS piece is made to order from material that you send to us. That material may include:

cremation ashes (of a person or of a pet),
hair or fur,
breast milk,
flowers or a piece of fabric (for example, a piece of a wedding dress), or
umbilical cord.

Because of the nature of this material, and because of the context that surrounds many of these orders (for example, the loss of a loved one, the loss of a child, or material from a living person), the information we hold in connection with your order may constitute or reveal sensitive personal information, including information that can relate to health. We are aware of how personal this is.

We collect and use sensitive personal information only with your consent and only for the limited purpose of making the piece you have ordered. We do not use it to infer characteristics about you, we do not use it for advertising, and we do not disclose it to anyone other than the service providers strictly necessary to fulfill your order (for example, our shipping carrier for the physical return of any unused material). You may withdraw your consent to our handling of this material at any time by contacting us at [email protected]; withdrawing consent does not affect anything we lawfully did before you withdrew it, and it may make it impossible for us to complete your order.

Throughout this Policy and in our communications with you, we use the respectful term "ashes". We describe breast milk neutrally, as one of the materials we may work with.

5. How we handle and return consigned material

We handle the material you send to us with corresponding care. Specifically:

the material is stored securely, and access is restricted to the authorized workshop staff directly involved in making your piece;
it is used solely to make the piece you have ordered;
it is identified throughout by your order code, so that it is never confused with another order;
once your piece is complete, any unused material is returned to you by default, or, only if you instruct us to do so, securely destroyed; and
you may ask us to return or destroy the material at any time by contacting us at [email protected].

We recognize that ashes and other biological material are irreplaceable, and we handle them accordingly. We carry consigned material with insured DHL Express transport for the journey to and from our workshop.

6. How and why we use your information

We use the personal information described above for the following purposes:

to process and fulfill your order, including making your piece, arranging delivery, returning any unused material to you, communicating with you about your order, and handling complaints and returns;
to create and maintain your account and to provide a single sign-in across our group stores, as described in Section 2;
to send you transactional messages relating to your order or account (for example, order confirmations and shipping notifications);
to send you newsletters and marketing e-mails, where you have signed up to receive them; you can unsubscribe at any time using the link in each e-mail or by contacting us;
to operate, secure, and improve the Store, including analytics and advertising measurement through the tools described in Section 8, which we use only with your consent;
to make the piece you have ordered from the material you consign to us, which we do only with your consent, as described in Section 4;
to comply with our legal, tax, and accounting obligations; and
to establish, exercise, or defend legal claims, and to detect and prevent fraud and misuse of the Store.

We do not make decisions about you that produce legal or similarly significant effects through solely automated means.

7. How we disclose your information (recipients)

We do not sell your personal information, and we do not share it for cross-context behavioral advertising in exchange for value. We disclose personal information only to the categories of service providers listed below, only to the extent needed for them to perform services for us, and each of them is bound by a contract that limits how it may use the information:

Service provider category	Purpose	Location
Hosting and database provider (our own server running Medusa and PostgreSQL)	Operating the Store, accounts, and orders	European Union
Content management system (Directus)	Managing site content and media	European Union
Content delivery and media storage (Cloudflare R2 and Cloudflare CDN)	Storing and delivering media and pages	European Union, with global edge delivery
Payment provider (Stripe)	Processing card and local payment methods	European Union and United States
E-mail provider (Mailchimp and its transactional service Mandrill)	Sending transactional and marketing e-mail	United States
Shipping carrier (DHL Express)	Delivering your order and returning unused material	Per destination country
Error monitoring (Sentry)	Detecting and diagnosing technical errors	European Union
Google (Google Analytics 4, Google Tag Manager, Google Ads, and Google sign-in)	Analytics, advertising, and login	United States
Meta (Meta Pixel, Conversions API, and Facebook sign-in)	Advertising and login	United States
TikTok (TikTok Pixel and Events API)	Advertising	Transfers outside the European Economic Area
Microsoft (Microsoft Clarity)	Session recording and heatmaps	United States

Our own infrastructure, namely the servers running Medusa, PostgreSQL, and Directus, and our Cloudflare R2 storage, is hosted within the European Union. Several of our advertising, analytics, and e-mail providers are based in the United States or transfer data internationally; where these providers handle information that originates in the European Economic Area or the United Kingdom, they do so under the EU-US Data Privacy Framework where they are certified, or otherwise under European Standard Contractual Clauses or the equivalent United Kingdom transfer mechanisms. You may request more information about these safeguards by contacting us at [email protected].

We may also disclose personal information where we are required to do so by law, to respond to a lawful request from a public authority, or to protect our rights, your safety, or the safety of others.

8. Cookies and tracking technologies

The Store uses cookies and similar technologies. Cookies are small text files stored on your device while you use the Store.

Consent banner and consent control. When you first visit the Store, we show you a consent banner built on Google Consent Mode v2. The banner lets you make a granular choice between categories of cookies and tracking, which we group as necessary, analytics, and marketing. Until you make a choice, all non-essential tools are blocked: Consent Mode v2 defaults to "denied", so analytics and marketing tools do not run until you choose to allow them. Rejecting non-essential tools is as easy as accepting them. You can change or withdraw your consent at any time through the persistent link in the footer of every page, which also links to our Cookie Policy. We keep a record of the consent you give as proof of your choice. We do not use an IAB Transparency and Consent Framework banner; our consent control is the banner described here.

Essential cookies are necessary for the Store to function, for example to operate the shopping cart, the sign-in process, and your session. These do not require your consent, and disabling them may stop parts of the Store from working.

Non-essential tools run only after you allow the relevant category through the banner. The Store uses the following, and only the following, non-essential tracking tools:

Google Analytics 4 and Google Tag Manager - to understand how the Store is used and to measure site traffic (analytics).
Meta Pixel and the Meta Conversions API - to measure and support advertising, both in your browser and server-side (marketing).
TikTok Pixel and the TikTok Events API - to measure and support advertising, both in your browser and server-side (marketing).
Google Ads - for remarketing and conversion measurement (marketing).
Microsoft Clarity - a tool that records interactions with the Store, including session replays and heatmaps, to help us see where the Store is confusing or difficult to use. Given the nature of our Store, Clarity is configured to mask sensitive fields, so that the content of forms, personal data, engraving text, and uploads is hidden from the recording. Clarity runs only with your consent.

Server-side measurement. For Meta and TikTok, some conversion information is also sent directly from our servers to Meta and to TikTok (through the Meta Conversions API and the TikTok Events API). This server-side measurement is gated by your consent in the same way as the in-browser tools, and identifying information is hashed before it is sent.

Managing cookies in your browser. Independently of the banner, you can manage or delete cookies through your browser settings. In Google Chrome: Settings, then Privacy and security, then Cookies. In Mozilla Firefox: Settings, then Privacy and Security, then Cookies and Site Data. In Safari: Settings, then Privacy. In Microsoft Edge: Settings, then Cookies and site permissions. Blocking essential cookies may prevent parts of the Store, such as the shopping cart, from working.

We do not sell or share your personal information, including the information collected through these tools.

9. Signing in with Google or Facebook

You can create an account or sign in using Google or Facebook. If you choose to do so, we receive from the chosen provider a limited set of information, namely your e-mail address, your name, and an identifier that lets us link the login to your account. We use this information solely to create and operate your account and to sign you in. When you use this option, the login process is also governed by the privacy policy of Google or of Meta (Facebook), as applicable, and we encourage you to review their policies. You can always choose to register with an e-mail address and password instead.

10. How long we keep your information

We keep personal information only for as long as we need it, according to the following periods:

Order and contract information is kept for the duration of the contract and then for the period in which a legal claim could be made, which is up to 6 years under the law of England and Wales; comparable limitation periods under United States state law may be shorter.
Tax and accounting records are kept for the period required by the applicable tax and accounting law, which is generally up to 6 years.
Account information is kept for as long as your account exists. After you delete your account, we keep only what we are legally required to keep, or what we need until any related legal claims are time-barred.
Newsletter and marketing-consent information is kept until you withdraw your consent or unsubscribe.
Consent records (proof of the cookie and marketing choices you make) are kept as evidence for the applicable limitation period, up to 6 years after the consent ends.
Server logs are kept for no longer than 12 months.
Cookies and tracking technologies are kept for the durations set out in our Cookie Policy.
Consigned material is kept only for as long as we need it to fulfill your order; any unused material is then returned to you, or destroyed only if you instruct us to do so.

11. Your privacy rights and how to exercise them; security; children; and changes

Your State Privacy Rights

Depending on where you live, your state's privacy law may give you certain rights over your personal information. United States state privacy laws that may apply include the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA, California), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act (CTDPA), among others. Regardless of whether any of these laws strictly applies to us, we honor the following choices for our customers:

The right to know and access: you may ask us to confirm whether we hold personal information about you and to provide you with a copy of it.
The right to delete: you may ask us to delete personal information we hold about you, subject to the records we are required to keep by law or that we need to handle a legal claim.
The right to correct: you may ask us to correct inaccurate personal information about you.
The right to opt out of the sale or sharing of your personal information: we do not sell or share your personal information, so there is nothing to opt out of, and we do not provide a "Do Not Sell or Share My Personal Information" link because we do not engage in either activity.
The right to limit the use of sensitive personal information: we use sensitive personal information only with your consent and only to fulfill your order, as described in Section 4, and you may withdraw that consent at any time.
The right to non-discrimination: we will not deny you service, charge you a different price, or provide you a different level of service because you exercise any of these rights.

To exercise any of these rights, contact us at [email protected] or by post at KEEP MOMENTS LTD, Wapienna 4A/2, 71-790 Szczecin, Poland. So that we can respond safely, we may need to verify your identity by confirming information we already hold about you; we use any information you provide for verification only for that purpose. You may use an authorized agent to submit a request on your behalf, in which case we may ask for proof of the agent's authority and may still verify your own identity. We will respond to your request within the time required by the applicable law. If we decline a request, we will explain why.

If you have a concern about how we handle your personal information, please contact us first at [email protected] so that we can address it. We will acknowledge your concern, look into it, and tell you the outcome.

Security

We use appropriate technical and organizational measures to protect your personal information against loss, misuse, and unauthorized access, including encryption of data in transit using TLS, access controls that limit personal information to authorized staff, regular backups, and server hardening with firewalls and intrusion detection. No method of transmission or storage is completely secure, but we work to protect your information and to keep our measures current. If a security incident affecting your personal information occurs, we will handle it and notify affected individuals and authorities as required by the applicable law.

Children

The Store is not directed to children, and we do not knowingly collect personal information from children under 13 years of age. If we learn that we have collected personal information from a child under 13 without appropriate parental consent, we will delete it without undue delay. If you believe a child has provided us with personal information, please contact us at [email protected].

Changes to this Policy

We may update this Policy from time to time, for example to reflect changes in the law, in technology, or in how we handle personal information. We will publish any updated version on the Store's website and, where the change is material and we have your e-mail address, we will also let you know by e-mail. Where we rely on your consent and a change affects that consent, we will ask for your consent again. The date of the most recent update is shown at the top and bottom of this Policy.

12. Contact and seller information

This Privacy Policy supplements the Terms and Conditions of the KEEPMOMENTS online store. If you have any question about this Policy or about how we handle your personal information, please contact us.

Last updated: June 15, 2026