Privacy Policy

1. Who We Are

TearCatch is operated by MILKIES Katarzyna Lew (the "Data Controller"):

• Address: ul. Urocza 16, 71-496 Szczecin, Poland
• NIP: 8512602456 | REGON: 320095458
• Privacy contact: [email protected]

We share your data with the following partner companies within the MILKIES group (see Section 6 for details):

2. What Data We Collect

We collect personal data in three ways: directly from you (account creation and quiz responses), automatically (cookies and tracking technologies), and by inference (our AI generates insights from your responses).

We do not collect health data, clinical psychological assessments, data about your religious or philosophical beliefs, sexual orientation, political opinions, or any other "special category" data as defined under GDPR Article 9.

2.1 Account Data

When you create an account, we collect:

• First name, last name, email address
• Country (to determine applicable law and product availability)

2.2 Quiz Response Data

As you take quizzes over time, we may collect information you voluntarily provide about:

• About you: Gender, birth year, city, spoken languages, ring size
• Breastfeeding and motherhood: Whether you breastfeed or have breastfed, duration, number of children, children's names and birth years, parenting style, keepsake collection habits
• Pets: Types and names of pets, number of pets, relationship with pets
• Loss and memorial: Whether you have lost a loved one or pet, the relationship, year of loss, whether you possess keepsakes (ashes, clothing, fur/hair), whether you seek a tangible connection
• Love and relationships: Relationship status, partner's name, wedding date and style, anniversary, interest in romantic keepsakes
• Life journey: Travel preferences, major life events, attitude toward experiences and milestones
• Wellbeing and self-care: Self-care habits, nature connection, mindfulness practices, personal sense of strength

All quiz questions are optional. You can skip any question you prefer not to answer.

2.3 AI-Generated Insights

Our AI analyzes your quiz responses to generate:

• Psychographic scores: Sentimentality index, need for closure, self-reward tendency, nostalgia level (scored 0-100)
• Identity archetype: One of six archetypes (Memory Keeper, Resilient Guide, Connection Whisperer, Nature Soul, Life Celebrator, Devoted Caregiver)
• Product preference tags: Which MILKIES product lines may interest you

These are generated for entertainment and product recommendation purposes. They are not clinical assessments.

2.4 Tracking and Advertising Data

With your consent (via cookie preferences), we collect:

• Meta (Facebook/Instagram): App User ID, Page User ID, FBP cookie, FBCLID click ID
• Google: Client ID, GCLID click ID
• TikTok: TTCLID click ID
• Pinterest: EPIK cookie
• General: Mobile advertiser ID, UTM source and campaign history, interaction timestamps

This data is used for advertising purposes as described in Section 5.

2.5 Purchase Data

If you purchase MILKIES products (on milkies.com or partner sites), we may link your purchase history to your TearCatch profile, including: total orders, lifetime value, currency, and purchase dates by product category.

3. Why We Collect Your Data (Purposes)

4. Legal Basis for Processing (GDPR)

If you are in the EU/EEA or UK, we rely on the following legal bases:

5. Advertising and Profiling

5.1 How We Use Your Data for Advertising

If you consent to advertising cookies, we use your data to:

• Create audiences on Meta and Google - We may upload hashed email addresses and product preference segments to Meta Custom Audiences and Google Customer Match to show you relevant MILKIES ads.
• Retarget you - If you visit tearcatch.com and consent to cookies, advertising platforms may show you MILKIES ads on their networks.
• Find similar customers - We may use your profile data to create "lookalike" or "similar" audiences on advertising platforms. This means the platforms find other people who are similar to you and show them our ads. Your individual data is not shared with these people.

We only share product preference segments and hashed identifiers with advertising platforms. We never share your quiz responses, children's names, deceased persons' names, or memorial-related details with advertising platforms.

5.2 Your Right to Opt Out of Advertising Profiling

• EU/EEA/UK users: You can withdraw your cookie consent at any time through the cookie settings on our website. We will stop sharing your data with advertising platforms.
• California users: You have the right to opt out of the "sale" or "sharing" of your personal information. Use the "Do Not Sell or Share My Personal Information" link on our website. See Section 9.
• All users: You can opt out of advertising profiling by emailing [email protected]. We will remove your data from all advertising platform audiences within 30 days.

Opting out of advertising does NOT affect your access to TearCatch.

6. Who We Share Your Data With

6.1 MILKIES Group Companies

We share your TearCatch profile (as described in Section 2) with the MILKIES group companies listed in Section 1. These companies use your data to:

• Send you the MILKIES newsletter and seasonal offers
• Recommend products from their specific product lines
• Process orders if you purchase MILKIES products

MILKIES Katarzyna Lew and these partner companies act as joint controllers under GDPR Article 26 for the purposes of newsletter delivery and product recommendations. We have a joint controller arrangement in place that defines our respective responsibilities. You can exercise your data protection rights against any of us, but we recommend contacting [email protected] as your primary point of contact.

6.2 Advertising Platforms

With your consent, we share data with:

• Meta Platforms Ireland Ltd (Facebook, Instagram) - for Custom Audiences and ad delivery
• Google Ireland Ltd - for Customer Match and ad delivery
• TikTok Technology Ltd - for ad delivery
• Pinterest Europe Ltd - for ad delivery

These platforms act as independent data controllers for the data they receive. Their own privacy policies apply.

6.3 Service Providers

We use service providers (data processors) for:

• Hosting and infrastructure (EU-based servers)
• Email delivery (newsletter service provider)
• AI model hosting (quiz content generation)
• Analytics

All processors are bound by data processing agreements under GDPR Article 28.

6.4 No Other Sharing

We do not sell your personal data. We do not share your data with anyone other than those listed above, unless required by law.

7. International Data Transfers

Your data is stored on servers in the European Union.

When we share data with our UK-based partner companies (Keep Moments Ltd and MILKIES Ltd), this is covered by the EU adequacy decision for the United Kingdom.

When we share data with advertising platforms, some processing may occur outside the EU/EEA. These transfers are protected by:

• The EU-US Data Privacy Framework (for US-based platforms that are certified), or
• Standard Contractual Clauses (SCCs) adopted by the European Commission

You can request a copy of the applicable transfer safeguards by contacting [email protected].

8. How Long We Keep Your Data

After account deletion, we delete all your personal data within 30 days, except where we are required by law to retain it (e.g., tax/accounting records).

9. Your Rights

9.1 Rights for EU/EEA/UK Residents (GDPR)

You have the right to:

• Access - Request a copy of all personal data we hold about you.
• Rectification - Correct inaccurate or incomplete data.
• Erasure ("right to be forgotten") - Request deletion of your data. This will result in account closure.
• Restriction - Request that we stop processing your data in certain circumstances.
• Data portability - Receive your data in a structured, machine-readable format (JSON).
• Object - Object to processing based on legitimate interest (product recommendations, partner offers). We will stop unless we have compelling legitimate grounds.
• Withdraw consent - For advertising cookies, at any time. Withdrawal does not affect prior lawful processing.
• Not be subject to automated decisions - Our product recommendations are generated by AI, but they do not produce legal effects or similarly significantly affect you. If you believe otherwise, contact us and we will provide human review.

How to exercise your rights: Email [email protected]. We will respond within 30 days (extendable by 60 days for complex requests). We may verify your identity before processing your request.

Right to complain: You may lodge a complaint with your local data protection authority. In Poland, this is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, www.uodo.gov.pl.

9.2 Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know - Request disclosure of the categories and specific pieces of personal information we have collected, the sources, the purposes, and the third parties we share with.
• Delete - Request deletion of your personal information.
• Correct - Request correction of inaccurate personal information.
• Opt out of sale/sharing - We share personal information with advertising platforms for cross-context behavioral advertising. You can opt out using the "Do Not Sell or Share My Personal Information" link on tearcatch.com, or by emailing [email protected].
• Non-discrimination - We will not discriminate against you for exercising your rights.

How to exercise your rights: Email [email protected] or use the links on tearcatch.com. We will respond within 45 days (extendable by 45 days with notice).

Categories of personal information we collect (CCPA disclosure):

• Identifiers (name, email, phone)
• Personal information categories listed in Cal. Civ. Code 1798.80(e) (name, address, phone)
• Characteristics of protected classifications (gender)
• Commercial information (purchase history, product preferences)
• Internet or other electronic network activity (tracking IDs, interaction timestamps, cookies)
• Geolocation data (country, city)
• Inferences drawn from the above (psychographic scores, identity archetype, product preference tags)

9.3 Rights for Residents of Other US States

If you reside in Virginia, Colorado, Connecticut, Texas, Oregon, Montana, or another US state with a comprehensive privacy law, you generally have similar rights to access, delete, correct, and opt out of targeted advertising. Contact [email protected] to exercise your rights.

10. Children

TearCatch is not intended for anyone under 16 years of age. We do not knowingly collect data from children under 16. If we discover that we have collected data from a child under 16, we will delete it promptly. If you believe a child under 16 has provided us with personal data, please contact [email protected].

11. AI Transparency Disclosure

In accordance with the EU Artificial Intelligence Act:

• TearCatch uses artificial intelligence to generate personalized quiz content and product recommendations.
• The AI processes your quiz responses to create creative outputs (e.g., a "letter from your puppy") and to assign product preference tags.
• Quiz results are generated for entertainment and self-reflection. They are not clinical psychological assessments, medical advice, or professional counseling.
• Your interactions with the AI-generated content influence which MILKIES product lines are recommended to you.
• The AI system is not classified as high-risk under the EU AI Act. A formal assessment under Article 6(3) has been documented and is available upon request to relevant authorities.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes - particularly to the types of data we collect, the purposes of processing, or the parties we share with - we will notify you by email at least 14 days before the changes take effect.

The "last updated" date at the top of this page reflects the most recent revision.

13. Contact Us

Data Controller: MILKIES Katarzyna Lew ul. Urocza 16, 71-496 Szczecin, Poland NIP: 8512602456

Privacy inquiries: [email protected]

For complaints, you may also contact your local data protection authority.

This Privacy Policy is effective as of April 2026.