Privacy Policy – Memory Pebbles
Version: 2026-11 · Effective from 11 November 2026
Memory Pebbles (in Hungarian: Élménymorzsák) is a journal in which a parent keeps what a shared moment with their child felt like, and which they can hand over to the child on a day they choose. This policy explains what data we handle, why, for how long, who can access it, and what your rights are.
1. Who handles your data?
Controller: Szabolcs Niedling, sole trader (egyéni vállalkozó)
Address: Rózsa u. 61., 7361 Kaposszekcső, Hungary
Tax number: 58655070-1-37
Email: admin@sabster.hu
We have not appointed a data protection officer, as the size and activity of the business do not require one. Please send any data protection question to the email address above.
2. In short
- We only handle the data the journal needs to work.
- No ads, no analytics, no tracking, and we never sell your data.
- All data (database, photos, voice notes, videos) is stored in the European Union, is only reachable over an encrypted connection, and files open only through short-lived signed links.
- Before a photo is uploaded, all metadata (such as its location) is removed.
- You can download your whole journal at any time, and delete your account with all your data at any time, in the app.
- Who sees what in a journal is enforced by the database rules, not just by the app's screens.
3. What data we handle, why, and for how long
3.1. Your account
| Data | Purpose | Legal basis | Kept until |
|---|---|---|---|
| Email address, password (stored only as a one-way hash), display name, language | Signing in, running your account, notifications in your language | Performance of a contract (GDPR Art. 6(1)(b)) | Your account is deleted |
| Your acceptance of the Terms and this Policy (version, time), your statement that you are over 18 | Proof of what you accepted | Legal obligation and legitimate interest (Art. 6(1)(c) and (f)) | Your account is deleted |
| When you last used the app | The trusted contact feature (see 3.4) | Performance of a contract | Your account is deleted |
3.2. What is in the journal
| Data | Purpose | Legal basis | Kept until |
|---|---|---|---|
| The child's name, date of birth or due date, when access opens, and optionally the child's email address | Running the journal and handing it over to the child | Performance of a contract; for the child's data, the decision of the parent (legal guardian) | The journal or the account is deleted |
| Memories: date, title, text, feeling tags, place, "what they said" quote, visibility; sealed letters; welcome message | Providing the journal | Performance of a contract | The entry, the journal or the account is deleted |
| Photos (one 2000-pixel version and a thumbnail, without metadata), voice notes, videos (one version of at most 720p and a preview image; the original upload is deleted after conversion) | Providing the journal | Performance of a contract | The entry, the journal or the account is deleted |
Special categories of data. You can write anything in the journal, so it may come to contain health information or other special categories of data (for example an illness). We do not ask for such data, and we do not analyse or use it; we only store it and show it to those who may see the journal. If you write such data in the journal, we store it on the basis of your explicit consent (GDPR Art. 9(2)(a)), which you can withdraw at any time by deleting the entry.
Content about the child. The journal is written by the parent about their child. The parent, as legal guardian, decides about the child's data and is responsible for the journal serving the child's interests. We do not read or analyse the content, and we only show it to those entitled to it under the visibility rules (see section 5).
3.3. The child's own account
When the journal opens, the child creates their own account with an invite code (email address, password, name, language). This account is handled like the account in 3.1, and the child can delete it the same way.
If the journal opens before the child's 16th birthday, the parent's consent is required. We store the fact, version and time of this consent, and record it in the audit log (GDPR Art. 8).
3.4. Co-parent and trusted contacts
| Data | Purpose | Legal basis | Kept until |
|---|---|---|---|
| The invited co-parent's name and email address, the invite (the code is stored only as a one-way hash) | Sending the invite and joining | Performance of a contract; for the invitee, legitimate interest | The invite expires (30 days) or is used; then as the co-parent's own account |
| The trusted contact's name, email address, language and the state of the request | Making sure the journal is not lost if the parent is away for a long time | Performance of a contract; for the contact, legitimate interest | The parent removes the contact, or the account is deleted |
| Inactivity tracking (last activity, when warnings were sent) | The trusted contact process (warnings, then access) | Performance of a contract | The account is deleted |
The trusted contact is named by the parent. The contact receives an email about the request and can accept or decline it in the app. They only get access to the journal if the parent has not used the app for the set period and did not respond to the warnings. Access ends as soon as the parent comes back.
3.5. Notifications
| Data | Purpose | Legal basis | Kept until |
|---|---|---|---|
| Your device's push token (Firebase) | Notifying you, for example, that a journal or a letter has opened | Performance of a contract | You sign out or delete your account |
| The notification to be sent (recipient, type, the data the message needs, such as the child's name or an invite code) | Sending the email and push | Performance of a contract | It has been sent (a few minutes), at most a few days |
Push notifications are generic: they contain no names and no journal content. Question and quick-note reminders are scheduled by your phone; no data is sent anywhere for them.
3.6. Subscription
Payment goes through Google Play (later also the App Store). We never see or store card details. From the store we only receive and verify the subscription's data: the product, the purchase token, its state and expiry. From this we work out which plan you are entitled to.
- Purpose: providing your plan.
- Legal basis: performance of a contract.
- Kept until: 8 years after the subscription ends, for accounting and settlement obligations; otherwise until your account is deleted.
3.7. Audit log
For security and accountability we record certain events, for example:
- a journal opening for the child;
- the steps of the trusted contact process;
- exports;
- deletions;
- changes to settings.
The audit log holds only identifiers, the time and the type of event – no journal content, names or email addresses. It is kept after an account is deleted, but then only an identifier that can no longer be linked to a person remains.
- Legal basis: legitimate interest and the duty to keep data secure (GDPR Art. 6(1)(f), Art. 32).
- Kept for: 5 years.
3.8. Technical data
Our service providers (see section 4) keep short technical logs to run the service (for example IP address, time, type of request), which are deleted after a few days. We do not collect analytics ourselves, and we write no personal data into our own logs.
3.9. The export
The export is made on your device: we do not store the ZIP file and keep no copy of it. We only record in the audit log that an export was made (without any content).
4. Who helps us process the data (processors)?
| Processor | Task | Where the data is |
|---|---|---|
| Supabase, Inc. (USA) | Database, file storage, sign-in, server functions | European Union (Frankfurt, Germany) |
| Sendinblue SAS (Brevo), France | Sending emails | European Union |
| Google Ireland Ltd. / Google LLC (Firebase Cloud Messaging) | Delivering push notifications | EU; delivery may involve the USA |
| Google Ireland Ltd. / Google Commerce Ltd. (Google Play) | Subscriptions and payment | Under Google's terms |
| HostingBazis Bt. (Mándoki u. 40., 4642 Tornyospálca), Hungary | Website hosting; the server that converts videos | Hungary |
Each provider is bound by a data processing agreement (DPA) or equivalent terms.
Transfers outside the EU. The data is stored in the EU. The US parent companies of Supabase and Google may access it under the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses (SCCs). Push notification texts are generic and contain no names or content.
Brevo – email tracking. Brevo keeps anonymous statistics about the emails it sends (delivery, opens, clicks), and links in the emails go through its redirect server. We do not use this data for anything.
5. Who sees what is in the journal?
- The child sees nothing before access opens. After that, they see the parents' "shared" entries, never the "only mine" ones. Sealed letters reach them only on the chosen day.
- The co-parent sees the other parent's "shared" entries; "only mine" entries and letters only if their author allowed it in their own settings.
- A trusted contact sees content only after the trusted contact process has been activated, and only the content of the parent who named them – by default only "shared" entries, and never letters or the welcome message.
- We (the operator) do not read the content. We access the database only to run it, to fix problems, or to meet a legal obligation, and we keep a record of this.
6. How we protect your data
- Every connection is encrypted (HTTPS/TLS), and storage is encrypted at the provider level.
- Files are kept in private storage and open only through short-lived signed links.
- Access rules are enforced by the database and checked by automated tests.
- Passwords are stored only as one-way hashes, and so are invite codes.
- The server's secret keys never go into the app.
7. Your rights
- Access and portability: download your whole journal in the app (Settings → Download my journal): a readable page and machine-readable data, together with the files.
- Rectification: change your entries and your details in the app.
- Erasure: delete your entries and your account in the app (Settings → Delete account). Deleting your account also deletes your data in the database and your files. Files go within minutes, and from the provider's backups within 30 days at the latest.
- Note: if a journal's owner deletes their account, the journal is deleted too, together with the co-parent's and the child's entries. It is worth exporting it first.
- Restriction and objection: write to us at admin@sabster.hu.
- Withdrawing consent: where your consent is the legal basis, you can withdraw it at any time. This does not affect the lawfulness of processing before the withdrawal.
We answer your request within one month at the latest.
Complaints: if you feel we have violated your rights, you can complain to the Hungarian National Authority for Data Protection and Freedom of Information (NAIH):
- address: Falk Miksa utca 9–11., 1055 Budapest, Hungary;
- postal address: 1363 Budapest, Pf. 9.;
- email: ugyfelszolgalat@naih.hu;
- web: www.naih.hu.
You can also complain to the data protection authority of your own EU country, or go to court. Please write to us first – we may be able to sort it out quickly.
8. Cookies and local storage
The website uses no cookies and does no tracking. On your device, the app only stores what it needs to work, for example your sign-in, your language and the selected journal. The sign-in is removed when you sign out; a finished export is removed from the device when the account changes.
9. Changes
If this policy changes materially, we will tell you in advance in the app and by email. The version of the policy you accepted, and when, is stored with your account.