This privacy policy was last updated on 06/17/2019.


COMMEMO collects data to operate effectively and to provide our product and service offerings to you. However, we take data privacy seriously and recognize the sensitivity of the information that you share with us while using our website, software and related services (collectively, the “Services”). This privacy policy explains:

  • What personal information (including information that may identify you) that we collect and how we collect it
  • Our purpose and legal basis for processing that information
  • How we store, use, transfer and delete that information
  • With whom we share that information
  • How long we hold that information

Contact Us

Our legal name is GiftWords, Inc., a Delaware corporation doing business as COMMEMO. If you have any questions about this privacy policy or your personal information, please contact us at:


Attn: Amanda Larsen

805 W Acequia Suite 1B

Visalia, CA 93291


Where is your personal information stored?

The Services utilize third-party vendors and hosting partners (like Amazon Web Services) located in the United States for hardware, software, networking, storage, and related technology we need to run the Services. If you are located in a non-U.S. jurisdiction, such as the European Economic Area or the European Union (including the United Kingdom), by providing us with your personal information you consent to the transfer of such personal information to the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws of your home country.

What personal information do we collect?

We may collect the following personal information from you:

  • Contact information, including your name, email address, mailing address and phone number
  • Unique identifiers, including your username and password
  • Payment and billing information, including credit card numbers and billing information
  • Any content or other information you choose to provide to us (such as your digital content and related titles, captions and annotations)
  • If you communicate with us or any other user via the Services, the contents of those communications
  • Information from or about your device, including its internet protocol (IP) address, browser type, web pages that led to you our website, operating system, and date/time stamp.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

How do we collect your personal information?

We collect personal information from what you actively share with us while using the Services.

  • The Services enable users to discover and share information with one another. Therefore, information about its users is an integral part of the COMMEMO experience—but the amount and type of information you share voluntarily, and the decision whether to share any information at all, and with whom to share information within the Services, is always your choice. However, in order to access the Services, we do require certain limited personal information in order to create your account.
  • To personalize your experience on the Services and to otherwise improve our products and services, we may ask you to provide us with information about your personal or professional interests, demographics and experiences with the Services. Providing this additional information is optional. If you elect not to share this information with us, it will not affect your access to the Services.
  • If you invite others to join a project, or if you create administered accounts for other people, you may be asked to submit to us limited personal information about other people. For example, if you want to invite someone to join one of your projects, you will be asked to submit the invitee’s name, email address, and/or phone number. In this circumstance, we only collect your invitee’s name, email address, and phone number.
  • Also, when you share content from any of your projects, we collect the email addresses and/or phone numbers of the recipients. We will not disclose these email addresses and phone numbers to any third parties. Please note, however, that recipients will be able to forward your email and phone number containing the shared content to third parties, if they choose.

We may collect personal information from third parties. If you choose to connect your COMMEMO account with a third-party service (like Twitter, Facebook or Google), we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. At the time access is granted, we will make clear what information we will access and we will never publish through your third-party account without your permission. These third parties have their own privacy and data collection practices and policies for which we are not responsible and will not be liable. You should therefore review their privacy policies carefully before you connect their services to COMMEMO if you have concerns about how they may use your information.

We may collect personal information from cookies. In order to collect your internet protocol (IP) address, browser type, web pages that led to you our website, operating system, and date/time stamp, a “cookie” is set on your computer or device when you use the Services (including visiting our website). Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies or similar technologies. We track only your interactions within the Services (including any domains we host).

We may collect personal information from third-party cookies. Some third-party services that we use to provide the Services may place their own cookies in your browser. These third-parties may then share that information with us, subject to their respective privacy policies. This privacy policy covers use of cookies by COMMEMO only and not the use of cookies by third parties.

Why do we collect and how do we process your personal information?

COMMEMO may collect and use personal information for the following purposes, each of which is a legitimate interest of COMMEMO derived from the relevant and appropriate relationship required in order to take advantage of the Services:

  • Register your account with the Services
  • Allow you to utilize the Services and create and design products for purchase
  • Interact with and advise you of new users and new postings to your projects
  • Provide you with any requested company, product or service information (including sending you promotional communications, targeting advertising, and presenting you with relevant offers)
  • Provide you with marketing information about our company, products and services
  • Respond to customer service requests or other questions or concerns
  • Administer your account and any orders you place with us
  • Improve, optimize and personalize the Services and your experience using the Services

The foregoing purposes are based on COMMEMO’s legitimate interest in creating functional products and services that reflect our business purposes. In addition, any content you upload in connection with any project or otherwise voluntarily deliver to us will also be processed based on your explicit consent (which consent will be required every time you upload content to the Services).

We may also share your personal information with third party processors in some circumstances, including: (i) with your consent; (ii) to a contractor, service provider or partner who meets our data protection standards pursuant to the terms of a written agreement; (iii) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; or (iv) when we have a good faith belief that doing so will help prevent imminent harm to someone.

In addition, we use information (including personal information) derived from cookies to generate aggregate, non-identifying information for system administration purposes and to understand our users’ browsing actions and patterns. This information helps us:

  • Evaluate how users use the Services
  • Perform data analysis
  • Carry out internal research on how our website is used
  • Perform audits (including security audits)
  • Improve and develop new products and services
  • Identify usage trends
  • Determine the effectiveness of promotional campaigns

Cookies and similar technologies also recognize you when you return to the Services. This allows us to further optimize your experience by doing things like automatically logging you in to your account, remembering your preferences, evaluating email effectiveness, and personalizing content and other information.

How do we use your personal financial information?

We offer products and services for sale through our online store (“Paid Offerings”). To facilitate payment for Paid Offerings, we will require certain personal financial information from you. When you purchase or subscribe to any Paid Offering, we will collect your name, billing and shipping address, phone number, and credit/debit card number and other relevant payment information.

We will not share this financial information with any third party other than contracted payment processors and the financial institutions involved in processing your payment and we will otherwise comply with applicable consumer credit laws.

Be aware, however, that if you click away from our website to visit the site of any third party (including, without limitation, sites of payment processors, advertisers or sponsors), you may be asked for your payment or other personal information in order to purchase or use products and services offered. These companies have their own privacy and data collection practices and policies for which we are not responsible and will not be liable. You should therefore review their privacy policies carefully if you have concerns about how your information may be used.

How long do we keep your personal information?

As a result of the nature of the Services, we intend to keep your personal information for as long as we need to in connection with COMMEMO’s legitimate interests. Generally, that means we will keep your personal information for the later of the following:

  • For as long as you have a registered account with the Services and for up to one (1) year after your account is terminated
  • If you purchase any products through the Services, for seven (7) years from the date of purchase or longer if required by applicable law
  • We may keep your personal information longer if we cannot delete it for legal, regulatory or technical reasons
  • We may also keep it in a permanently nonidentifiable form for research or statistical purposes

We reserve the right to remove any personal information (or anything else) submitted to COMMEMO for any reason. Without limiting the foregoing, we generally only do this if we believe, in our judgment, that information you provide to us:

  • Infringes, misappropriates or violates a third party’s patent, copyright, trademark, trade secret, moral rights or other intellectual property rights, or rights of publicity or privacy
  • Violates, or encourages any conduct that would violate, any applicable law or regulation or would give rise to civil liability
  • Is fraudulent, false, misleading or deceptive
  • Is defamatory, obscene, pornographic, vulgar or offensive
  • Promotes discrimination, bigotry, racism, hatred, harassment or harm against any individual or group
  • Is violent or threatening or promotes violence or actions that are threatening to any other person
  • Promotes illegal or harmful activities or substances
  • Simply is not appropriate for a family audience

How do we keep your personal information secure?

Regardless of how long we have access to or process your personal information, we place great importance on the security of all personal information associated with our users. We have commercially reasonable security measures in place to attempt to protect against the loss, misuse or alteration of user information in our possession or under our control. For example, our security and privacy practices are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal information. We use secure server software to encrypt financial information you input before it is sent to us. Understand, however, that we cannot guarantee that loss, misuse or alteration of data will not occur, although we use commercially reasonable efforts to prevent this.

What are your rights around your personal information?

If you have an account, you can access, modify or delete your personal information or account via your account profile. Where we hold your personal information (whether or not you have an account), you can also make a “subject access request” to use and we will provide you with:

  • A description of your personal information that we have possession or control of
  • An explanation of why we have that personal information
  • Information about who that personal information may be disclosed to
  • A copy of the personal information in a readable form (unless there is a legitimate reason why we cannot provide you with a copy)

You can send a “subject access request” or other requests related to your personal information (including a request to delete, restrict, rectify, transfer or complain about the use of your personal information) to us at or in writing at the address provided above. When you submit a request, we will review it and get back to you as soon as possible—in most cases within 72 hours. Note that certain requests may take up to a month to complete and, in some cases, we may not be able to comply with a request (but we will provide an explanation of why we were unable to do so and what steps we have taken to comply in good faith).

In the event you delete your account or other personal information, know that we may maintain residual copies of your personal information for a brief time (to protect information from accidental or malicious destruction). After that time, your personal information and any content you provide to us will be unrecoverable.

How can you manage emails and other notifications from COMMEMO?

If you opt-in when you create your account, we will send you email notifications when another user:

  • Creates a new post
  • Comments on a submission you created or previously posted
  • Sends you a message via the COMMEMO platform
  • Invites you to connect or accepts your invitation to connect

Email notifications may vary depending on the product or service you are using. After you opt-in, you can opt-out of some or all of these notifications either by following the “unsubscribe” links at the bottom of the email, or if you are a registered user, managing your “Email Notifications” within the “Settings” page of your account profile. You can subsequently opt-in to these notifications in the same way.

Sometimes we will also send you emails about your account, service changes or new policies. You cannot opt out of this type of “transactional” email (unless you delete your account).

Note that when you interact with an email sent from us (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction from cookies and similar technologies.

What will happen if this privacy policy changes?

If we decide to change this privacy policy, we will issue an updated version with an updated date legend (and/or notify you via e-mail or by other appropriate means) so that you will be aware of what changes are being made to our collection, processing, storage and maintenance of your personal information. We will also use commercially reasonable efforts to identify and summarize any material changes to our privacy policy. If you do not consent to any changes to our privacy policy and as a result you would like us not to process or hold your personal information in accordance with the revised privacy policy, you can opt out of any such new policy by deleting your account and other personal information (or making an appropriate request relating to your personal information) before the effective date of the revised privacy policy.

If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your personal information would be transferred or become subject to a different privacy policy, we will notify you in advance so you can opt out of any such new policy by deleting your account and other personal information before such transfer.