1. Acceptance of terms

By accessing and using this website, owned and operated by DEVCLOAK S.R.L. (the "Operator"), having its registered office at [Oradea Municipality, Liszt Ferenc Street, no. 24, Block PB59, 4th floor, apartment 16, Bihor County, registered with the Trade Register Office attached to the Bihor Tribunal under no. J5/1034/2022, VAT ID (CUI) 45993982], you agree to be bound by this version of the Terms and Conditions of Use, as well as any subsequent amendments published on this page. If you do not agree with the terms and conditions set out below, please do not use the website.

2. Purpose of the website

This website https://crowdofmemories.com (hereinafter referred to as the "Website") is intended for uploading files to the platform during events involving multiple participants (weddings, baptisms, parties, etc.).

The materials uploaded on our platform are captured by users and/or participants of the respective event, as well as by the event organizers. Participants uploading materials to our platform, together with the event organizer, are solely responsible for the processing of personal data (photographs, video and/or audio recordings, etc.), and provide their consent in this regard by scanning and agreeing to the QR code during participation in the event.

The information presented on the Website is intended for general informational purposes only. No text or material published on the Website shall be construed as personalized professional advice or as a guarantee of any specific result.

3. Intellectual property rights

Crowd of Memories and Devcloak S.R.L. do not hold any rights over the materials uploaded on the platform. All responsibility and all rights belong to the event organizer and to the persons uploading the materials on the platform.

4. Limitation of liability

Crowd of Memories and Devcloak S.R.L. cannot be held liable and assume no responsibility for personal data processed in connection with the creation, capture and/or uploading of materials on the platform by users and/or organizers.

Furthermore, the Operator shall not be liable for any direct, indirect, incidental, special or consequential damages that may result from accessing or using the Website, or from downloading and/or publishing materials.

To the extent permitted by law, we exclude any liability for any direct, indirect or consequential losses or damages arising from the use of, or inability to use, our website or its materials.

The Operator cannot be held liable at any time for the manner in which clients or users apply the services, content, or information obtained through accessing the website or purchasing services. Likewise, Crowd of Memories and Devcloak S.R.L. cannot be held liable in any form for the way the platform is used by users and organizers.

Important:

• No guarantee regarding information leakage: Although we do not sell or rent personal data stored on our platform, there is a possibility that such data may be downloaded, processed, accessed, or published by platform users. Accordingly, Crowd of Memories and Devcloak S.R.L. shall not be held liable for any leakage of any kind of information and/or materials from our platform, whether in a private and/or public environment.
• Accuracy of information: Although we make reasonable efforts to keep information up to date and accurate, we provide no warranties of any kind regarding the completeness, accuracy, reliability, or availability of the information on the website.
• Use of the platform: Any material uploaded on our platform is the responsibility of the user and/or the event organizer. We shall not be held liable for any loss or damage, whether direct or indirect, resulting from the use of or reliance on the information provided on the website.

5. Personal data

Use of the Website is also subject to the Privacy Policy, which governs how your personal data is collected, processed, and protected, in accordance with Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC (ePrivacy), transposed into national law by Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector. Please refer to the Privacy Policy and the Personal Data section for detailed information regarding your rights and the manner in which data is processed.

Through these terms, we clarify that we protect users and not the individuals appearing in the materials recorded and uploaded on our platform.

6. Links to third-party websites

The Website may contain links to other websites or resources that are not under the control of the Operator. The Operator assumes no responsibility for the content, privacy policies, or security practices of such third-party websites. Accessing these links is at the user's own risk.

7. Amendments to the terms and conditions

The Operator reserves the right to modify these Terms and Conditions at any time, without prior notice. The updated version of the Terms and Conditions will be published on this page, and continued use of the Website after the publication of any amendments shall constitute your express acceptance of the new terms.

8. Governing law and jurisdiction

This website and all terms of use are governed by Romanian law. Any dispute arising in connection with the interpretation, performance, or validity of these Terms and Conditions shall be settled by the competent courts in Romania, within whose jurisdiction the Operator has its registered office and/or domicile.

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Personal data

Introduction

The confidentiality and security of your personal data are of utmost importance to us. All information presented on this website is of a purely informational nature and does not constitute a guarantee of achieving any intended result.

General data protection regulation (GDPR)

Regulation (EU) 2016/679 of the European Parliament and of the Council, known as the General Data Protection Regulation (GDPR), was adopted on 27 April 2016 and entered into force on 25 May 2018. This Regulation was adopted by the European Parliament and the Council of the European Union and establishes the legal framework for the protection of personal data of natural persons within the European Union.

ePrivacy Directive (2002/58/EC) and Law no. 506/2004

The "ePrivacy" Directive has been transposed into Romanian legislation through Law no. 506/2004. The legal provisions require data controllers to take all necessary measures to ensure that users are protected, and that electronic communications remain confidential, protected against interception, and processed based on consent or another lawful basis.

Key definitions

• Personal Data: Any information relating to an identified or identifiable natural person ("data subject"). This may include name, surname, address, email address, phone number, location data, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• Data Subject: The natural person whose personal data is processed.
• Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processor: The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
• Processing: Any operation or set of operations performed on personal data, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Uploaded Materials: Any type of material, video and/or audio recordings, photographic materials, recordings captured by event participants or by event organizers. Such materials are stored for a maximum period of 3 months from the date of the event.
• Platform: https://crowdofmemories.com. Our platform operates as follows: each event organizer (e.g., the contracting party for the event) purchases Credits. One credit = one event. During the event, each participant may scan a QR code and upload materials captured during the event (and not only). Each person accessing the QR code is directly responsible for the processing of personal data of individuals appearing in the uploaded materials.
• User: may be any person registered on our platform; any person uploading materials after scanning the QR code; any person attending the event, etc.
• Organizer: the person organizing the event (parent, groom, godparent, bride, celebrant, etc.). The only person entitled to create the event. The only person who may define the access rights of persons attempting to access the platform and the respective event.
• Credit: the creation of an event is carried out through the purchase of a credit. One credit = one event. The event is created exclusively by the organizer.
• Event: the party or gathering of persons during which personal data is processed by users and participants, which is subsequently uploaded to the platform.

What personal data we collect through the website

In the context of using our website, we may collect various categories of personal data, as indicated in the previous sections.

Data subject rights

In accordance with the legal provisions mentioned above, you have the following rights in relation to your personal data:

• Right of access: You have the right to obtain confirmation as to whether or not we process your personal data and, if so, access to such data and information regarding how it is processed.
• Right to rectification: You may request the correction or completion of inaccurate or incomplete personal data.
• Right to erasure ("right to be forgotten"): You have the right to request the deletion of personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to restriction of processing: You may request the restriction of processing of personal data in certain situations, for example where you contest the accuracy of the data.
• Right to data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller.
• Right to object: You may object at any time, on grounds relating to your particular situation, to the processing of your personal data where such processing is based on our legitimate interests or on the performance of a task carried out in the public interest.
• Rights related to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw it at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: If you consider that your rights have been infringed, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) or to address the competent courts.
• All these rights shall be addressed to the event organizer; Crowd of Memories and Devcloak S.R.L. cannot be held liable in this regard.

Our website ("the Controller / Operator") processes data in a manner that ensures an adequate level of security of personal data, including protection against unauthorised or unlawful processing, as well as against accidental loss, destruction or alteration, through the implementation of appropriate technical and organisational security measures.

In general, the personal data we collect (not necessarily within our website, but also in the context of our direct relationship with you) are information relating to a living individual, such as:

• Full name (or the name associated with a Google account)
• Telephone number
• Email address
• Photograph or video and/or audio recording
• Biometric data for the purpose of uniquely identifying a natural person

Only information that is relevant and necessary is collected (and such personal data have been indicated above, by way of example). CROWDOFMEMORIES.COM shall clearly state the purpose for which such information is requested and the manner in which it will be used, information which is included in the Minimum Data Set.

Where personal data are obtained directly from the data subject, the Controller shall be obliged, prior to any collection, to inform the data subject regarding the intended data processing activities.

Principles regarding the processing of personal data

All personal data processing activities shall be carried out in compliance with the data protection principles ("the Principles"), as set out under the GDPR.

• Personal data shall be processed lawfully, fairly and in a transparent manner: This means that the Controller must have a lawful basis for collecting and using personal data; must not use the data in ways that have unjustified adverse effects on data subjects; must be transparent regarding how it intends to use the data and provide appropriate fair processing notices to data subjects at the time of data collection; must handle personal data in a manner consistent with the reasonable expectations of the individuals concerned; and must ensure that no unlawful activities are carried out in relation to such data.
• Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes: This means that the Controller must be clear from the outset as to why personal data are being collected and how they will be used; must comply with fair processing requirements, including the obligation to provide clear and transparent notices to data subjects at the time of collection.
• Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed: The Controller shall retain personal data only to the extent necessary for the purpose for which they are processed, without collecting more information than is required. The existence of a minimum data set describes such essential information.
• Personal data shall be accurate and, where necessary, kept up to date: The Controller shall take reasonable steps to ensure the accuracy of the personal data held, verify the source of such data, carefully consider any objections regarding the accuracy of the information, and assess the need for updates.
• Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed: This means that the Controller must periodically review retention periods, assess the purposes for which data are retained, determine whether (and for how long) continued retention is necessary and secure, delete data that are no longer required, and safely update, archive or dispose of outdated information.
• Personal data shall be processed in a manner that ensures appropriate security: The Controller shall implement appropriate technical and organisational measures to prevent unauthorised or unlawful processing, accidental loss, destruction or damage of personal data. The Controller shall ensure the implementation of adequate physical and technical security measures supported by robust policies and procedures, and that staff and collaborators are properly trained and prepared to respond promptly and effectively in the event of a data breach.
• Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection of the rights and freedoms of data subjects with respect to the processing of personal data.

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Cookie policy

To ensure an optimal experience on our website and to personalize content and advertisements, we use both first-party and third-party cookies. Cookies are small text files stored on your device, which help us analyze traffic and provide enhanced functionalities.

In accordance with Regulation (EU) 2016/679 (GDPR), we hereby inform you that:

• Purpose of use: Cookies allow us to collect information about how you use our website, to personalize your experience, and to improve the services provided.
• Consent: By continuing to browse this website, you consent to the use of cookies in accordance with this page. You may choose to accept all cookies or manage your preferences selectively.
• Cookie management: To modify or withdraw your consent, please access your browser's cookie settings or use the cookie configuration panel available on the website.

Your cookie preferences help us understand how you wish your data to be used on our website. You may choose which types of cookies to enable, thereby customizing your browsing experience. Whether it concerns traffic analysis, personalization of functionalities, or the display of relevant advertisements, your preferences allow us to provide a tailored experience adapted to your needs. You may modify these settings at any time within this section.

These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. They allow us to analyze traffic data and improve the website's performance in order to provide a better user experience for our users.

This Cookie Policy has been drafted to inform you about our practices regarding the information we collect from you when you visit our website, through cookies or other tracking technologies, while at the same time ensuring the protection of your personal data.

As of 25 May 2018, Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "Regulation") has been applied in all EU Member States. The main purpose of the Regulation is to harmonize legislation across the European Union, thereby eliminating the need for national implementing measures.

DEVCLOAK is responsible for the administration of our website, https://crowdofmemories.com, and acts as a data controller (strictly with regard to the data of registered individuals), having its registered office in Oradea Municipality, Liszt Ferenc Street, no. 24, Block PB59, 4th floor, apartment 16, Bihor County, registered with the Trade Register Office attached to the Bihor Tribunal under no. J5/1034/2022, and holding VAT identification number (CUI) 45993982.

A cookie is a ".txt" file provided to your browser by a web server, which may be stored on your device's hard drive. Most browsers are configured to accept cookies by default. If you do not wish this, you may modify your browser settings so that you are notified each time you receive a cookie or so that you refuse the acceptance of cookies.

We have designed this platform to process and store the minimum possible number of cookies.

The website https://crowdofmemories.com uses exclusively session cookies, which are data temporarily stored in the user's device memory and contain information relating to the user. These cookies are stored only for the duration of a browsing session and are deleted once the user leaves the website or closes the browser. There are also persistent cookies, which are stored and reused each time the user returns to the website. It is important to note that users may delete such cookies at any time.

The use of these cookie files represents an advantage for visitors, as it allows the saving of certain browsing preferences, such as the website display language or the type of filters applied on specific pages. Refusing a cookie does not mean that the user will be denied the possibility to browse the website or view its content.

Through cookies, website owners may monitor and categorize users' interests in relation to certain sections of the website, which subsequently allows them to improve the browsing experience and provide relevant content.

The website and the company do not have access to, nor can they control, cookies set by other websites. It is your responsibility to consult the privacy and cookie policies of such websites. For example, cookies set by Google Analytics are used for statistical purposes.

These cookies cannot be used to identify you. Of course, you may access and browse our website even without cookies.

If you do not wish for your device to be recognized, you may prevent the storage of cookies by disabling the cookie storage option directly in your browser settings. If you do not wish to receive information collected through cookies, most browsers provide a simple method that allows you to refuse or accept cookie functionalities. However, please note that certain cookies may be necessary in order to provide specific features of our online services.

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google") (www.google.com/analytics), to help us analyze how our website is used, user interactions, and visitors' search behavior, while anonymizing the data being analyzed.

Google Analytics is not used to identify you.

Google Analytics uses so-called "cookies". The data collected through these cookies regarding your use of this website is generally transmitted to a Google server located outside the European Union and stored there. When the IP anonymization ("IP anonymization") function is enabled on this website, your IP address will first be truncated by Google within Member States of the European Union or other parties to the Agreement on the European Economic Area (so-called IP masking). Only in exceptional cases is the full IP address transmitted to a Google server outside the EU and subsequently truncated before further processing.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website and internet usage when accessing https://crowdofmemories.com. Google will not combine the IP address transmitted by your browser within the framework of Google Analytics with other data.

It is also possible that other personal data may be processed upon direct registration through the Google platform – Gmail.

One of the most important aspects of our website is that the platform is designed in such a way as to store the smallest possible number of cookie files (towards the absolute minimum), in order to ensure that each user experiences a secure, protective environment and ecosystem that is non-intrusive with respect to personal data.

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Contact, other information, and exercise of rights

CROWDOFMEMORIES.COM, respectively DEVCLOAK S.R.L., through its legal representative, ensures that any processing of data is carried out in compliance with the principles guaranteed by Regulation (EU) No. 679/2016 and Law No. 506/2004, and that personal data are processed in a manner ensuring an adequate level of protection, including protection against unauthorised or unlawful processing, as well as against accidental loss, destruction or damage, through the implementation of appropriate technical and organisational measures and the application of adequate internal data protection policies.

Crowdofmemories.com does not provide refunds for amounts collected for services sold or rendered, nor for goods sold through the website https://crowdofmemories.com.

Crowd of Memories and Devcloak S.R.L. cannot be held liable for any damages or losses caused or suffered by any third party as a result of the processing of personal data by the organiser, user, or participant of the event.

This policy should be read in conjunction with the following policies, procedures and guidelines (sections of this dedicated page):

• Privacy Policy;
• Cookie Policy;
• Terms and Conditions of Use of our Website;
• Information regarding the protection of personal data.

Each user understands that they may withdraw their consent to the processing of their personal data by deleting their account. The deletion of the user account does not remove the possibility of holding the user liable for any damages and/or losses caused to third parties affected by materials uploaded by the user on the platform.

For any information, concerns, or issues, or in order to give effect to your rights and to benefit from the rights of natural persons as established under Regulation (EU) No. 679/2016 on the Protection of Personal Data (GDPR) and Law No. 506/2004, please contact our company:

• Email: [email protected]
• Telephone: +40 775 372 408
• Registered office: Oradea Municipality, 24 Liszt Ferenc Street, PB59 Building, 4th Floor, Apartment 16, Bihor County, registered with the Trade Register Office attached to the Bihor Tribunal under No. J5/1034/2022 and holding CUI 45993982, Romania
• Unique registration code: RO 45993982
• Trade Register number with the Trade Register Office attached to the Bihor Tribunal: J5/1034/2022

Version and last amendment (or update) of the text: v. 1.0 dated 30.04.2026.