Privacy

‍Last updated: January 2025

In this Privacy Policy, we will explain what information we collect about you, how we use it, when we share it, and the controls we provide you to manage the information you share with us.

If you are a minor and are not sure you understand everything in this Policy, please make sure to speak with a trusted adult before using Memo. Please also remember that Memo is not meant to be used if you are under 13. If you are over 13 but under 16 years old, your parent or guardian must approve your use of the app.

1. Information we process about you

Memo (the ‘App’) collects information that you provide directly to us through your use of our App and your visit to our website.

1.1 Data that you provide to us

Account Creation Data: when you create an account on our App, we will ask you for the following information. Without it, we cannot provide you access to the App:

Your full name, email address, phone number, date of birth, gender, and username.

The email address of a parent or guardian, for users under 16 years old.

During (or after) account creation there is also some additional information you can decide to share with us:

A biography, your location (as precise as you want), and a profile picture.

Content Data: when you use the App, you can decide to share the following data:

Photos and videos that you take (“Content”) using the app or photos that you share from your library. You can create an account without allowing us to access and collect data from your device’s camera or photo library.

Your GPS location: You can choose to attach your GPS location to photos and videos when you upload Content to our App. By default, this location is stored privately and is only visible to you. If you decide to share Content with others, the attached location may also be shared, depending on the Content’s share settings. If location sharing is enabled, by default, your precise location – street level – is shared but you can switch it to your approximate location – city level. If location sharing is disabled, the location attached to the Content remains private and visible only to you. If you are a child, your approximate location is shared by default and only if you choose to share it.

Communications with Memo: When you report a concern with our App, respond to a survey, request assistance, we collect the following data:

Your email address,

Content of communication with us,

Photos you may decide to share with us,

Copies of government issued identification (only when strictly required to identify you with certainty),

Identifiers (e.g., phone numbers or email address),

Any other information you may decide to share with us.

1.2 Data we collect when you use our App or visit our website

‍Like all internet based services, as you use our App or visit our website, we automatically receive information about you from your device and your usage of our App and your visit of our website. Most information is collected through trackers:

Through the use of our website:

Connection and Technical Data such as IP address, account creation date, last login, terminal equipment and port, operating system, system configuration data, device type, operating system version, browser, language preference, and applications.

Through your use of the App:

Connection and Technical Data such as:

IP address, account creation date, last login, terminal equipment and port, operating system, system configuration data, device type, operating system version, browser, language preference, and applications.

user_id (unique identifier generated at account creation), device_id (unique identifier generated when connecting on new device) and Amplitude ID.

Mobile advertising IDs and device identifiers:

‍We collect technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings:

Mobile advertising IDs (e.g., Apple IDFA if you use iOS or Google AAID if you use Android).

Device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices).

Interaction Data:

Friend (number of friends, friend invitations, the friends with whom you interact the most).

Usage Data: actions performed on the App or our website, time of taking or uploading photos and videos, number of photos and videos uploaded, Content viewed, Content interactions, the fact that you deleted Content, or that you blocked users, when you take a screenshot in our App, application crashes, pages visited and event logs.

‍Geolocation Data: when you use our app, we infer your country, city, region based on your IP address.

‍Address Book Data: You can decide to allow Memo to access your address book to identify the friends in your Address Book who may already be on Memo. We do not access your Address Book without your permission. If you decide to find your friends by giving us access to your Address Book, we hash the phone numbers in your Address Book (we don’t look at anything else), securely send those hashed phone numbers to our systems, compare those hashed numbers to the list of hashed phone numbers for other Memo users, and return the username to you as a friend suggestion. Bear in mind that even if you don’t agree to share your Address Book with us, we can still make personalized friends’ suggestions to you based on your hashed phone number that we received from your friends who use our app (see below).

‍Integrations with partners: When you decide to connect a partner application (for example Spotify) to use a specific integration on Memo, we receive information that allows us to bring that feature to you. This will include all necessary device data, and other optional data that you may choose to share as part of the integration.

1.3 Information about you provided by third parties

We may receive information about you from other users of our app. For instance, if other users know you and choose to use contact importing, they may share your phone number with us, just as you may share theirs. Where friends of yours use contact importing, we may suggest you as a friend to them, and them as a friend to you.

We will also receive the information about where you came from to download the App (for example, if you clicked on an ad on another social media) from our partners.

2. How we use information we receive about you

Why we Process your Data

What Personal Data is Processed

Legal Ground for the Processing

So you can create and keep your account and so we can identify you when you log in

Account Creation Data

Performance of the contract between You and Memo

So you can publish, see and react to Content on the Memo App

Content Data, Communications with Memo, Usage Data, Device and Equipment Data

Performance of the contract between You and Memo

So we can process your or other users’ requests, complaints and reports

Content Data, Communications with Memo

Our legitimate interests to provide answers to users regarding our App or the Content displayed

So we can suspend accounts or keep certain users from using the app after violation of applicable law or our Terms of Use

Account Creation Data, Interaction Data

Our legitimate interest to provide a safe and secure environment to our users according to our Terms of Use

So we can connect you with your friends

Address Book Data, Interaction Data, Information provided to us by third parties, Interaction Data

Consent, Our legitimate interest to use the limited data received from your friends to provide you with personalized friends’ suggestions and make your use of our app easier

So we can communicate with you within the App. This can happen when we need to communicate with you about a feature of our App

Account Creation Data, Content Data

Our legitimate interest to communicate with you

To make sure the app or the website is running smoothly for you

Navigation data, Interaction Data

Our legitimate interest to provide a working App or website to you

So we can identify you to your account when you have lost access

Communications with Memo

Our legitimate interest to let you back on the App

So we can recognize you across several devices

Connection and Technical Data

Our legitimate interest to let you back on the App

So we can serve advertising tailored to the preference and interests of our users (i.e.: select the most relevant advertising for you, display advertising on our App, our website or on third parties websites or apps and to measure advertising performance)

Connection and Technical Data, Inferred Data, Mobile advertising IDs and device identifiers

Consent, where required by applicable laws. Legitimate interest, in countries where consent is not required

So we can measure our App’s and website’s effectiveness, the performance of the App (e.g., crashes and causes of crashes) or our website, and its stability, your usage for recommendations of both accounts and Content.

Usage Data, Connection and Technical Data, Device and Equipment Data, Mobile advertising IDs and device identifiers, Geolocation Data, Interaction Data, Inferred information

Our legitimate interest to provide you with a functional app or website that meets your expectations.

So we can carry out surveys and get your feedback for research or product testing purposes

Communications with Memo

Our legitimate interest to make our App better (but you can choose each time if you want to participate in a survey or not)

So we can reach your parents or legal guardian if you are under 16 years old

Account Creation Data

Our legal obligation to obtain parental consent

So we can ensure your and other users safety and security, the security of our App or website, our partners, and compliance with relevant laws and regulations

Content Data, Communications with Memo, Usage Data, Device and Equipment Data

Our legitimate interest to provide a safe and secure environment to our users according to our Terms of Use

So we can answer to requests from national authorities

Account Creation Data, Content Data, Connection and Technical Data, Interaction Data, Device and Equipment Data, Mobile advertising IDs and device identifiers, Geolocation Data

Our legal obligationsIf there is no direct legal obligations, our legitimate interest to cooperate with national authorities

So we can defend and assert our rights before the authorities (civil, criminal or administrative)

All categories of data

Our legitimate interest in asserting and defending our rights

‍3. When we share information about you

3.1 We share information about you with our employees and service providers, who will process it under our control.

Memo Employees: To allow you to use the App to you or provide you support, authorized Memo employees may need to get access to your information. We strictly limit who can access your data.

Service Providers: To bring you our App we work with a small group of partners who provide us services. This includes partners who help with technical and hosting support, sending notifications, publishing, and sharing content, user analytics and satisfaction surveys, management of security incidents or fraudulent activity, etc. In working with those partners, we may share your information with them to bring you our App.

Counsels: For compliance with our statutory obligations, in particular in terms of accounting, auditing and internal control, we wight share your information with our counsels (legal, financial, audit).

3.2 We also share information about you to third parties, who will process it under their own control.

Partner Integrations: Where we partner to bring you a feature we may need to share your information with the partner to integrate the feature into our App.

Legal and Statutory Purposes: From time to time we may receive legal requests for information related to our users, be required to proactively share data with authorities (governmental authorities, courts, and similar third parties) when we learn of certain Content on our App (e.g., Child Sexual Abuse Material or terrorism), address fraud or security concerns, or protect people on our App or elsewhere from harm.

Changes in Ownership: If we’re involved in a reorganisation, merger, acquisition or sale of our assets, your data may be transferred as part of that deal. We’ll notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

4. Children’s data

Memo never knowingly or willingly collects any personal data concerning children under 13 years of age. Depending on where you live, if you are under the age of consent in your country, a parent or guardian may also have to provide consent for you to use our App. If you are under 13, please do not use Memo.

5. International transfers

Some of the partners and service providers referred to in this policy are located outside of the European Union.

In such case, we ensure that:

The personal data is transferred to countries recognized as offering an equivalent level of protection or,

One of the mechanisms offering appropriate guarantees is implemented (for example, the adoption of the standard contractual clauses of the European Commission.

6. How long we keep information about you

We keep your information only for as long as it’s needed to provide our services to you, in line with legal requirements and data protection authorities guidelines.

7. What controls you have over your information in the App

At Memo we have implemented features to ensure that you remain in control of your personal data.

Notification: In the settings of the applications you can choose and control which notifications you receive about our App.

Block or Hide Users: To make sure you have a great experience when using our App, you can block or hide users who you do not want to receive Content from or who you do want to see your Content. If you block or hide a user, at any time you can go into the settings of the App and view who you have blocked or hidden. You can also unblock or unhide them at any time.

Who sees your Content: Note that when you share Content through our App, that Content is available only to whoever you choose to share it with. How other users use your Content is not under our control.

Time Zone: When you create an account we determine your time zone for the purpose of providing you our App. In the settings of the applications you can change your time zone at any time.

Integrations: From time to time we may offer integrations with partners to provide you certain features. If those partners require you to log into your account on their services to avail of the feature, you will be able to control those integrations in the settings of the applications at any time.

Delete your Content: You can find out more about how to delete photos and videos saved on Memo here.

Change or correct personal data: You can manage your account and the content contained in it, as well as edit some of your personal data, through your profile settings page.

Delete Your Account: In the settings of the App, you can choose to delete your account at any time. If you choose to delete your account, your account will be scheduled for deletion. This process takes approximately 15 days. If you log back into your account during that 15 day period, it will stop the deletion request. If you do not log back in, your account and all of your information will be permanently deleted. Note, information will not be deleted where Memo has received a valid legal request requiring us to preserve your information.

Consent: When we rely on your consent, you can withdraw your consent at any time from the “settings” page in our application.

If your account is permanently suspended by us and you choose to delete your account, we will keep Account Creation Data related to your account to prevent permanently suspended users from creating new accounts.

8. What rights do you have over your information

Privacy is a fundamental human right. That means every person that uses our App, irrespective of where they reside, can expect the same things from us. Whether you are in Europe, one of the 50 U.S. States, Latin America, the Middle East, Africa, Japan, Asia Pacific, or anywhere in between, you can:

Right to access and obtain a copy of your data: you may request access to your personal data. If you request such access, we will provide you with all the information required by law, including the purposes of the processing, the categories of data processed, the categories of recipients, the data retention periods and your rights.

Right of rectification: You may also ask us to rectify any personal data concerning you that is inaccurate and to complete any incomplete information.

Right to erasure/deletion: Under certain circumstances, you may request the erasure of your personal data. We may nevertheless need to retain certain limited data in an archived database, in particular if we have a legal obligation to retain such personal data or if it is necessary for the exercise or defense of legal claims.

Right to restrict processing: In certain circumstances, you may request the limitation of the processing of your personal data, in particular when you request the rectification of your personal data.

Right to withdraw your consent: Where the processing of your personal data is based on your consent, you may, at any time, withdraw any consent you have previously provided to us. Such withdrawal does not affect the lawfulness of processing based on consent prior to withdrawal.

Right to object: You may also object at any time to the processing of your Personal Data when it is used for commercial prospecting purposes or for reasons related to your particular situation.

Right to portability: In certain cases, you may also obtain a copy of your personal data, in a commonly used and machine-readable format, to enable you to exercise your right to data portability.

If you are in the European Union, EFTA States or the United Kingdom, and wish to raise a concern about our data processing practices, you have the right to do so with your local supervisory authority.

If you would like to exercise any of these rights, wish to raise a concern or have a question about our data processing practices, please contact us at privacy@yourmemo.app.

Since we don’t necessarily collect your email address, we may request additional information to make sure that the request does come from you.

9. Contact

The data controller for our App is Memo, operated by Gergely Papp.

If you have a question about our privacy practices or Privacy Notice, you can contact us at:

Email: privacy@yourmemo.app

Postal Mail: Demjén, Széchenyi István út 11, 3395, Hungary

10. Update of our Privacy Policy

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

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