Privacy Policy

Introduction

Collect Memories (brand of Barracud'Apps, operated by Pierre LAMOTTE) places great importance on protecting your personal data and respecting your privacy.

This Privacy Policy informs you about how we collect, use, store, and protect your personal data, in compliance with the General Data Protection Regulation (GDPR) and applicable Belgian legislation.

1. Data Controller

Controller Identity:

• Trade Name: Collect Memories (brand of Barracud'Apps)
• Operator: Pierre LAMOTTE
• Status: Self-employed primary activity (natural person)
• Address: Rue de la Station 290, 5621 Morialmé, Belgium
• Company Number: BE0786897157
• Email: contact@collect-memories.be
• VAT No.: BE0786897157

Data Protection Officer (DPO):
Currently, no DPO is designated (not mandatory for small structures).
For any questions regarding data protection: contact@collect-memories.be

2. Personal Data Collected

We collect different categories of data depending on your interactions with our services:

2.1 Website Browsing

Automatically collected data:

• IP address
• Browser type and version
• Operating system
• Pages viewed and visit duration
• Origin (referring site)
• Date and time of connection

Legal Basis: Legitimate interest (traffic statistics, website security)

Retention Period: 13 months maximum

2.2 Contact Form / Quote Request

Collected data:

• Last name and first name
• Email
• Phone (optional)
• Message / Project description

Legal Basis: Consent (checkbox) and execution of pre-contractual measures

Retention Period:

• If no order: 3 years from last contact
• If order: see 2.3

2.3 Memory Collection Service Order

2.3.1 Ordering Client Data

Collected data:

• Identity: last name, first name, date of birth
• Contact details: postal address, email, phone
• Payment data: bank details (if transfer), credit card data (via secure third-party platform)
• Billing data: company number, VAT number (if professional)

Legal Basis: Service contract execution

Retention Period:

• During service duration
• 10 years after service completion (Belgian accounting and tax obligations)

2.3.2 Interviewed Person Data

Collected data:

• Identity: last name, first name, date and place of birth
• Contact details: address, email, phone
• Audiovisual recordings: session videos and audios
• Life narrative: memories, journey, experiences
• Potentially sensitive data (depending on narrative):
  • Health data
  • Political, religious, philosophical opinions
  • Ethnic origin
  • Sexual life
  • Biometric data (voice, image)

Legal Basis: Explicit consent of the Interviewed Person (specific signed form)

Retention Period by Collect Memories:

• During service duration (3 to 6 months generally)
• Up to 30 days after file delivery to Client
• Then complete destruction of all recordings and files

Retention Period by Client: Indefinite retention (private family archive)

2.4 Cookies and Trackers

Cookies used:

• Technical cookies (mandatory for website functionality): session, security
• Analytical cookies (anonymous statistics): Google Analytics or privacy-friendly alternative (Matomo, Plausible)

Cookies NOT used:

• Advertising cookies
• Social media cookies (except if you voluntarily share content)

Cookie Management: You can accept or refuse non-essential cookies via the consent banner during your first visit.

You can also manage your preferences at any time via your browser settings.

Retention Period: 13 months maximum

3. Processing Purposes

Your data is collected and used for the following purposes:

We NEVER use your data for third-party advertising purposes or resale.

4. Data Recipients

Your data may be transmitted to the following recipients, strictly within the scope of the service:

4.1 Internal Recipients

• Pierre LAMOTTE (office agent, data controller)
• Collect Memories field agent(s)

4.2 External Service Providers (Processors)

Guarantees:

• All our processors are bound by confidentiality commitments
• Transfers outside the EU (e.g., Anthropic) are governed by Standard Contractual Clauses approved by the European Commission

4.3 Legal Authorities

In case of legal obligation, your data may be transmitted to competent authorities (police, justice, tax administration).

We never sell or rent your data to third parties.

5. Data Security

We implement technical and organizational measures to protect your data:

5.1 Technical Measures

• HTTPS encryption on the website (SSL certificate)
• Offline storage of video/audio recordings (secure external hard drives)
• No cloud or online storage of recordings
• Regular backups on separate media
• Access control: only authorized agents have data access
• Strong passwords and multi-factor authentication

5.2 Organizational Measures

• Agent awareness of data protection
• Confidentiality commitment signed by agents
• Secure data destruction protocols (permanent deletion)
• Data access limited to strict necessity

5.3 In Case of Data Breach

In case of a data breach likely to present a risk to your rights and freedoms, we commit to:

• Notify the Belgian Data Protection Authority within 72 hours
• Inform you directly if the risk is high
• Take all measures to limit consequences

6. Your Rights (GDPR)

In accordance with GDPR, you have the following rights:

6.1 Right of Access (Art. 15 GDPR)

You can request access to all personal data concerning you.

We will provide you with a free copy (first request) in electronic format.

6.2 Right of Rectification (Art. 16 GDPR)

You can request correction of inaccurate or incomplete data.

6.3 Right to Erasure / Right to be Forgotten (Art. 17 GDPR)

You can request deletion of your data in the following cases:

• Withdrawal of your consent
• Data not necessary for the purposes
• Legitimate objection to processing
• Unlawful processing

Exceptions: Legal retention obligations (invoices: 10 years)

6.4 Right to Restriction of Processing (Art. 18 GDPR)

You can request temporary freezing of data processing, particularly during verification of data accuracy or examination of your objection.

6.5 Right to Object (Art. 21 GDPR)

You can object at any time to processing of your data for reasons relating to your particular situation (when processing is based on legitimate interest).

Marketing objection: You can object at any time to use of your data for marketing purposes (newsletter) via the unsubscribe link in emails.

6.6 Right to Data Portability (Art. 20 GDPR)

You can receive your data in a structured, commonly used, and machine-readable format, and transmit it to another controller.

6.7 Right to Withdraw Consent (Art. 7 GDPR)

When processing is based on your consent, you can withdraw it at any time.

⚠️ For the Interviewed Person: Consent withdrawal results in project cessation and destruction of all recordings.

6.8 Right to Define Post-Mortem Directives (Art. 85 Belgian GDPR)

You can define instructions regarding retention, erasure, or communication of your data after your death.

7. How to Exercise Your Rights?

7.1 Request by Email or Mail

Email: contact@collect-memories.be (preferred)

Postal Mail:
Collect Memories - Barracud'Apps
Attention: Pierre LAMOTTE
Rue de la Station 290
5621 Morialmé, Belgium

7.2 Information to Provide

To process your request, please specify:

• Your identity (last name, first name, email used)
• The right you wish to exercise
• A copy of an identity document (to prevent identity theft)

7.3 Response Time

We commit to responding within 30 days from receipt of your request.

This period may be extended by 2 months for complex requests (you will be informed).

7.4 Free of Charge

Exercising your rights is free (first request).

For manifestly unfounded or excessive requests, we may charge reasonable fees or refuse to comply.

8. Right to Lodge a Complaint

If you believe your rights are not respected, you can lodge a complaint with the Belgian supervisory authority:

Data Protection Authority (DPA)

• Address: Rue de la Presse, 35 - 1000 Brussels, Belgium
• Website: https://www.autoriteprotectiondonnees.be
• Email: contact@apd-gba.be
• Phone: +32 2 274 48 00

You can also contact the supervisory authority of your country of residence (if outside Belgium).

9. Data Transfers Outside the EU

Some of our providers may be located outside the European Union (e.g., Anthropic for AI, based in the USA).

9.1 Guarantees

Transfers outside the EU are governed by:

• Standard Contractual Clauses from the European Commission
• Verification of adequate level of protection in the third country
• Additional technical security measures (encryption, pseudonymization)

9.2 Transparency

We inform you beforehand of any transfer outside the EU within the scope of the service.

10. Retention Periods

11. Minors

Our services are intended for adults (18 years and older).

If we discover that we have inadvertently collected data from a minor without parental consent, we will delete it immediately.

Exception: If a minor (>13 years) is the Interviewed Person, consent from their legal representative is mandatory.

12. Privacy Policy Modifications

We reserve the right to modify this Privacy Policy at any time, particularly to:

• Comply with new legal obligations
• Improve our data protection practices
• Reflect changes in our services

Notification of Modifications:

• The "Last Updated" date at the top of this document will be modified
• Significant modifications will be notified to you by email (if we have your address)
• The old version will be archived and available upon request

You are invited to regularly consult this page.

13. Cookies - Detailed Information

13.1 Strictly Necessary Cookies (exempt from consent)

These cookies cannot be disabled without compromising website functionality.

13.2 Analytical Cookies (subject to consent)

These cookies allow us to:

• Measure website traffic
• Understand visitor journeys
• Improve content and navigation

Anonymization: IP addresses are anonymized.

Opt-out: You can refuse these cookies via the banner or your browser settings.

13.3 Cookie Management

Accept/Refuse during your visit:
A banner allows you to choose during your first visit.

Modify your preferences:
You can modify them at any time via [link "Cookie Management" in footer].

Deletion via your browser:

• Chrome: Settings > Privacy and security > Cookies
• Firefox: Settings > Privacy and security > Cookies
• Safari: Preferences > Privacy > Manage website data

14. Links to Third-Party Websites

Our website may contain links to third-party websites (e.g., social media, partners).

We are not responsible for the privacy practices of these third-party websites.

We encourage you to read their own privacy policies.

15. Questions and Contact

For any questions regarding this Privacy Policy or the processing of your personal data:

Email: contact@collect-memories.be

Postal Mail:
Collect Memories - Barracud'Apps
Pierre LAMOTTE
Rue de la Station 290
5621 Morialmé, Belgium

We commit to responding promptly.

16. GDPR Glossary

• Personal data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation on data (collection, recording, storage, modification, consultation, use, transmission, erasure, etc.).
• Data controller: Entity that determines the purposes and means of processing (Collect Memories).
• Processor: Entity that processes data on behalf of the controller (e.g., host, AI).
• Consent: Free, specific, informed, and unambiguous manifestation of will.
• Sensitive data: Data revealing ethnic origin, political/religious opinions, health, sexual life, biometric data, etc. (require explicit consent).