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Version 4.4. Effective 3 October 2026 for new users, and 17 October 2026 for existing users. Updated 9 October 2026 to correct where our database and recordings are stored.
This privacy policy explains how Lembray Ltd ("we", "us", "our") collects, uses, stores and protects personal data when you visit our website at lembray.com, contact us, join our waiting list, or use the lembray platform at app.lembray.com (together, "the Service").
lembray helps care providers, and families, record life stories in a person's own voice and keep them as a storybook. Because these stories are personal, some of what is recorded may include special category personal data, such as information about health, religious beliefs or ethnicity. We handle all personal data with the highest standards of care and legal compliance, and we only collect what we need to provide and improve the Service.
This policy forms part of our Terms of Service (lembray.com/terms) and should be read alongside them.
Legal entity: Lembray Ltd
Registered in: England and Wales
Company number: 17193414
Registered office: 31 Manor Road, Manchester, M6 8QN
Contact and privacy enquiries: hello@lembray.com
We aim to respond to all data protection enquiries within 5 working days.
EU Representative: in accordance with Article 27 EU GDPR, our designated EU Representative is João Roso, Rua Alexandre Ferreira, 30 6DT, 1750 Lisboa, Portugal. EU data subjects and supervisory authorities may contact our EU Representative at rosojao@gmail.com on all matters relating to the processing of personal data by Lembray Ltd.
We decide how and why personal data is used, and are the controller, for:
When a care home, home care provider or other organisation ("care provider") uses lembray, the care provider decides how and why the personal data of the people it supports, their families and its own staff is used. The care provider is the controller of that data, and Lembray Ltd acts as its processor, under a written data processing agreement. We only process that data on the care provider's documented instructions.
If you use lembray through a care provider, or your stories are recorded by one, the care provider's own privacy notice also applies to you. You can exercise your data protection rights with the care provider directly, or contact us and we will pass your request to them and help them respond.
When you use the "Book a conversation" form: your name, job title, organisation, type of organisation, approximate number of people supported, email address, phone number (optional) and your message.
When you join the waiting list for lembray for families: your first name, email address, what you are interested in, and a record of your consent to be emailed.
Full name, email address, password (hashed, never stored in plain text), date of birth (optional), city (optional), country (optional).
Profile photo (optional), preferred language.
Audio recorded in the app or uploaded from a device. These are the core content of the Service.
Text transcriptions automatically generated from voice recordings, translations of those transcriptions into a chosen language, and follow-up questions suggested for a future conversation.
Stories, chapter and storybook titles, comments, and any other written content created in the app, including stories written by a family member or carer for the person to read aloud.
Photographs attached to stories, cover images, photographs of the person whose stories are being recorded, and profile photos. Where a photograph or memory is added by a family member or a carer, we also record who added it.
Where lembray is used by a care provider: the organisation's name and logo; the names and work email addresses of office staff and carers; which carers are assigned to which people; records of which family members have been given access, what they can do, who authorised it and when; handover notes (which show chapter names only, never story content); and activity information used for the manager's dashboard and monthly summary.
For existing individual subscriptions only: subscription plan, billing status and payment date. We do not store card numbers or payment details; these are processed entirely by Stripe. We are not currently offering new paid individual subscriptions.
If a printed storybook is ordered: the storybook content needed to print it, and the name and delivery address it is being sent to.
IP address, browser type, device type, operating system, pages visited, session duration and error logs, collected automatically when you use the app.
Emails and messages you send to hello@lembray.com, and records of the emails we send you, including notifications and monthly summaries.
A timestamped record that you accepted our Terms of Service and Privacy Policy, including the version accepted and how.
Email addresses of family members invited to a storybook, and the role or permissions they have been given.
For each activity where we are the controller, we set out the data used, the lawful basis under UK GDPR and EU GDPR, and how long we keep it. Where we act for a care provider, the care provider sets the lawful basis and retention, and we follow its instructions.
Responding to website enquiries
Data: website enquiry details. Lawful basis: legitimate interests (Article 6(1)(f)), in responding to organisations that contact us. Retention: 2 years from last contact.
Emailing you about lembray for families
Data: waiting list details. Lawful basis: consent (Article 6(1)(a)). You can unsubscribe at any time using the link in any email or by contacting us. Retention: until you unsubscribe, or 2 years after you joined, whichever comes first.
Creating and managing your account
Data: account information, consent record. Lawful basis: contract (Article 6(1)(b)). Retention: duration of account plus 90 days.
Providing the core service (recording, transcription, translation, storybook)
Data: voice recordings, transcriptions, stories, photos. Lawful basis: contract (Article 6(1)(b)). Retention: duration of account plus 90 days.
Suggesting follow-up questions
Data: transcriptions. Lawful basis: contract (Article 6(1)(b)). Retention: suggestions are kept with the storyteller's record for as long as their stories are kept.
Letting family members know about new stories
Data: names of invited family members, transcriptions, email addresses. Lawful basis: contract (Article 6(1)(b)). Retention: duration of the family member's access plus 90 days.
Processing payments for existing subscriptions
Data: payment information. Lawful basis: contract (Article 6(1)(b)). Retention: 7 years (UK tax law).
Sending service emails, notifications and monthly summaries
Data: name, email address, activity information. Lawful basis: contract (Article 6(1)(b)). Retention: duration of account plus 90 days.
Printing and delivering storybooks
Data: storybook content, delivery name and address. Lawful basis: contract (Article 6(1)(b)). Retention: delivery details are kept for 12 months after delivery, for queries and reprints.
Maintaining platform security and diagnosing technical issues
Data: device and usage data, IP address. Lawful basis: legitimate interests (Article 6(1)(f)). Retention: 90 days rolling.
Responding to support enquiries
Data: communications data. Lawful basis: legitimate interests (Article 6(1)(f)). Retention: 2 years from last contact.
Demonstrating legal compliance
Data: consent records. Lawful basis: legal obligation (Article 6(1)(c)). Retention: 7 years.
Bot protection (Cloudflare Turnstile)
Data: device and browser signals. Lawful basis: legitimate interests (Article 6(1)(f)). Retention: not retained by us.
We may keep certain data for longer where necessary to establish, exercise or defend legal claims.
Life stories can contain special category personal data as defined in Article 9 UK GDPR and EU GDPR, such as information about health, religious beliefs, ethnicity or political opinions. Some chapters of our conversation library, such as those about faith, wellbeing or wishes for the future, may invite this kind of information.
We handle this carefully. Questions in the library are marked as everyday, gentle or sensitive, sensitive topics are raised only when the person brings them up themselves, and every chapter is optional.
For individual accounts, processing of special category data is based on explicit consent, or on the information having been manifestly made public by the user, or on another lawful condition under Article 9 where one applies. Users are responsible for obtaining any permission needed from the people whose information they share.
For care provider accounts, the care provider, as controller, is responsible for identifying the lawful condition for special category data and for following appropriate consent, mental capacity and best interests processes before any recording takes place.
Voice recordings are the heart of lembray, and we handle them with particular care.
What we do with recordings:
What we do not do:
OpenAI data usage: in accordance with OpenAI's API data usage policies applicable at the time of processing, data submitted via the API is not used by OpenAI to train its models.
Third-party voices: when you record or upload audio that includes another person's voice, you are responsible for making sure that person has given informed consent to be recorded and for the recording to be stored on lembray. In care settings, this responsibility sits with the care provider.
lembray holds personal memories, photographs and recordings that may include information about other people, such as family members and friends.
You are responsible for having the right to upload what you add, for obtaining consent from anyone whose voice, image or personal information you upload, and for not uploading content that infringes anyone's rights.
lembray is private. We never publish stories. A storybook is only visible to the people it has been shared with, and in care provider accounts, every family member's access is authorised by the care provider and can be withdrawn at any time.
Microphone: to record voice stories in the app.
Storage and files: to upload audio files and photos from your device.
Notifications: to send reminders and let you know about new stories. Optional, and can be turned off in Settings.
You can withdraw any permission at any time in your device settings. Withdrawing microphone access stops in-app recording but does not affect existing stories.
To hold your own lembray account you must be at least 13 years old, or the minimum age to consent to digital services in your country, whichever is higher. In some EU member states this is 14, 15 or 16. Account holders under 18 may only use lembray with the knowledge and consent of a parent or guardian, who accepts this policy and our Terms on their behalf.
We do not knowingly collect personal data from anyone below the applicable minimum age. If you believe such a person has created an account, contact us at hello@lembray.com and we will delete the account and its data promptly.
The age requirement applies to account holders, not to the people whose stories are recorded.
We use the following service providers. Where they process personal data on our behalf, we have data processing agreements in place. Some, such as Stripe for payment compliance, may act as independent controllers for certain activities.
Webflow: website hosting and website forms. USA. Appropriate transfer safeguards.
Supabase: database and authentication (SOC 2 compliant). EU (Ireland). Adequacy decision.
Cloudflare R2: storage of voice recordings and media. Western Europe. Adequacy decision.
Cloudflare (CDN and Turnstile): content delivery, DDoS protection and bot protection. Global network, including USA. Appropriate transfer safeguards.
OpenAI: transcription, translation and question suggestions via API. USA. Appropriate transfer safeguards.
Stripe: payment processing for existing subscriptions (PCI-DSS Level 1), independent controller for payment compliance. Global, including USA. Appropriate transfer safeguards.
Brevo: email delivery. France (EU). Adequacy decision.
Sentry: application error monitoring. Receives IP address, browser and device details and the technical context of a fault, never stories, transcriptions, photographs or recordings. EU region, no transfer outside the EU.
Printing partner: printing and delivery of printed storybooks, where ordered. We will name our printing partner here before the first printed storybook is produced.
We do not sell personal data, and we do not share it with advertisers.
Our database (Supabase) is hosted in the EU (Ireland), and voice recordings and media (Cloudflare R2) are stored in Western Europe. Some of our other service providers, such as OpenAI, Webflow, Stripe and Cloudflare's content delivery network, operate in the United States. Transfers of personal data outside the UK rely on appropriate safeguards, including the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, the EU Standard Contractual Clauses, adequacy decisions and other lawful mechanisms where applicable. We have carried out transfer risk assessments for our US providers, and you can request copies of the relevant transfer agreements from hello@lembray.com.
Website enquiries: 2 years from last contact.
Waiting list: until you unsubscribe, or 2 years after joining, whichever comes first.
Account data, voice recordings, transcriptions and stories (individual accounts): duration of account plus 90 days after closure.
Care provider accounts: as set out in our agreement with the care provider and on its instructions. When a care provider removes someone from lembray, their stories, recordings and photos are permanently deleted, unless the storybook has first been passed to a family member to keep.
Payment records: 7 years from the transaction date (UK tax law).
Device and usage logs, and error reports: 90 days rolling.
Consent records: 7 years from the date of consent.
Support communications: 2 years from last contact.
Collaborator data: duration of access plus 90 days.
After an individual account is closed, we keep data for up to 90 days so it can be recovered if asked. You can ask for immediate deletion at any time, and we will act within 30 days, subject to legal retention requirements.
Individual accounts with no login or new content for more than 24 months may be treated as inactive. We will contact you at least 60 days before taking any action. Our lawful basis for this is legitimate interests (Article 6(1)(f)): keeping accurate records and not keeping data longer than needed.
When retention periods end, data is permanently and securely deleted from our systems and our processors' systems. Deleted data may remain in encrypted backups for a limited period before being overwritten.
In transit: all data is encrypted using TLS 1.3.
At rest: data held by us and our service providers is encrypted at rest.
Voice recordings: stored with private access controls, and never publicly accessible.
Authentication: managed by Supabase Auth. Passwords are hashed using bcrypt.
Access controls: restricted to authorised people on a least-privilege basis. In care provider accounts, carers only see the people assigned to them, and a carer's access ends as soon as the care provider marks them as having left.
Bot protection: forms in the app are protected by Cloudflare Turnstile.
Monitoring: our infrastructure is monitored for unusual activity.
If a personal data breach is likely to result in a risk to people's rights and freedoms, we will notify the Information Commissioner's Office within 72 hours of becoming aware of it, tell affected people without undue delay where required by law, and act at once to contain it. Where we act for a care provider, we will tell the care provider without undue delay so it can meet its own obligations.
To exercise any of these rights, contact hello@lembray.com. If your data is held by a care provider, you can also contact the care provider directly. We respond within one calendar month, which may be extended by two further months for complex requests; we will tell you if so.
Right of access: receive a copy of the personal data we hold about you.
Right to rectification: ask us to correct inaccurate data. Most details can be updated in Settings.
Right to erasure: ask us to delete your personal data. We act within 30 days, except where we must keep it by law.
Right to restriction: ask us to pause processing in certain circumstances.
Right to data portability: receive your personal data in a structured, commonly used, machine-readable format. A storybook can also be downloaded as a PDF from within the app, for convenience.
Right to object: object to processing based on legitimate interests. We will stop unless we have compelling legitimate grounds.
Right to withdraw consent: withdraw consent at any time, including unsubscribing from the waiting list. This does not affect processing before withdrawal.
Right not to be subject to automated decision-making: we do not make automated decisions with legal or similarly significant effects.
Right to complain: see section 21.
Our website and app use only essential cookies, such as those needed to keep you logged in. We do not use advertising or analytics cookies, tracking pixels, Google Analytics or Meta Pixel.
Forms in the app are protected by Cloudflare Turnstile, which runs invisibly in the background and may process some device and browser signals. See cloudflare.com/privacypolicy for details.
lembray does not make decisions about anyone that have legal or similarly significant effects. AI is used only to turn speech into text, to translate, and to suggest questions that a carer or family member may choose to ask.
Because lembray processes voice recordings and personal life stories, we have carried out a Data Protection Impact Assessment under Article 35 UK GDPR, and we keep it under review as the Service changes. A summary is available on request, and we share what care providers need for their own due diligence.
As required by Article 30 UK GDPR, we keep an internal record of our processing activities, available to the ICO on request.
We will email account holders at least 14 days before any material change to this policy takes effect. Small changes, such as correcting a typo, may be made without notice but are always reflected in the version number and effective date. Where the law requires it, we will ask for your consent before a change that needs a new lawful basis.
For privacy questions, data requests or anything about this policy, email hello@lembray.com. We aim to reply within 5 working days, and we would always welcome the chance to resolve a concern directly before you contact a supervisory authority.
UK: Information Commissioner's Office (ICO). Website: ico.org.uk. Phone: 0303 123 1113. Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
EU: if you are based in the European Union, you can complain to the data protection authority in your member state. A full list is available at edpb.europa.eu.
This policy is written to comply with the UK General Data Protection Regulation, the Data Protection Act 2018 and the EU General Data Protection Regulation (Regulation 2016/679).
Lembray Ltd. Company No. 17193414. Version 4.4.
Preserving voices, stories and the people behind them.
hello@lembray.com
From the Portuguese lembrai, remember.
© 2026 Lembray Ltd. Registered in England and Wales, Company No. 17193414.