Privacy Policy

PRIVACY POLICY

Last Updated: December 4th, 2024

This privacy notice for Memory Squared (“we“, “us“, or “our“) describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

  • Download and use our mobile application (Memory Squared), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at MemorySquaredLtd@outlook.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below.

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
  • Do we process any sensitive personal information? We do not process sensitive personal information.
  • Do we receive any information from third parties? We do not receive any information from third parties.
  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
  • In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
  • How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information.
  • What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
  • How do you exercise your rights? The easiest way to exercise your rights is by contacting us at MemorySquaredLtd@outlook.com. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. HOW LONG DO WE KEEP YOUR INFORMATION?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO RESIDENTS OF SPECIFIC REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
  1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The personal information we collect may include:

  • Identifiers: Name, email address, phone number, user ID, and username.
  • Contact Information: Mailing address (if provided), contact preferences.
  • Professional Information: Job title, education information (if provided).
  • Interests: Information about your interests (if provided).
  • Social Media Usage: Information about which social media platforms you use most (we do not collect usernames, profile information, or friend lists).
  • Login Credentials: Passwords and similar security information for authentication and account access.
  • Transaction Information: Records of virtual gold coin purchases within the app (we do not collect payment instrument details).

Sensitive Information. We do not process sensitive personal information.

Payment Data. We use third-party payment processors (Stripe, PayPal, and Apple In-App Purchases) to assist in securely processing your payment information. All transactions are processed by these third parties, and we do not store payment instrument details such as credit card numbers or bank account information.

Application Data. If you use our application(s), we may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device to provide certain location-based services. You can enable or disable location services when you use our Services at any time through your device settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your device’s storage. You can change our access or permissions in your device’s settings.
  • Push Notifications. We may send you push notifications regarding your account or certain features of the app. You can opt out via your device settings.

Information automatically collected

In Short: Some information is collected automatically when you use our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include:

  • Usage and Log Data. IP address, device information, browser type, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services.
  • Device Data. Information about your computer, phone, tablet, or other devices you use to access the Services.

We may use cookies and similar tracking technologies to collect and store information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

  1. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, and for other purposes with your consent.

We use personal information collected via our Services for a variety of business purposes, including:

  • To facilitate account creation and authentication.
  • To send administrative information to you. We may use your personal information to send you product, service, and new feature information, as well as important notices, such as changes to our terms, conditions, and policies.
  • To send marketing and promotional communications. We may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
  • To respond to user inquiries and offer support.
  • To improve our Services. We may use your information to understand how our users interact with the app, to improve user experience, and to develop new features and services.
  • For other business purposes. We may use your information for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
  1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we have a valid legal reason to do so under applicable law.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, this section applies to you.

We may process your personal information if:

  • Consent: You have given us permission to do so. You can withdraw your consent at any time.
  • Contractual Necessity: The processing is necessary to fulfill a contract with you or to take steps at your request prior to entering into a contract.
  • Legal Obligations: The processing is necessary for compliance with our legal obligations.
  • Vital Interests: The processing is necessary to protect your vital interests or those of another person.
  • Legitimate Interests: The processing is necessary for our legitimate interests and does not override your data protection interests or fundamental rights and freedoms.

If you are located in Brazil, this section applies to you.

We process your personal information in accordance with the Lei Geral de Proteção de Dados (LGPD). Legal bases include:

  • Consent: You have given us your consent.
  • Contractual Obligations: Processing is necessary for the performance of a contract.
  • Legal or Regulatory Obligations: Compliance with legal obligations.
  • Legitimate Interests: Processing is necessary for our legitimate interests, provided that your fundamental rights and freedoms do not override such interests.

If you are located in India, this section applies to you.

We comply with the Digital Personal Data Protection Act 2023 (DPDP Act). We process your personal data based on:

  • Consent: You have given us your consent.
  • Contractual Necessity: Processing is necessary for the performance of a contract.
  • Legal Obligations: Compliance with legal obligations.
  • Legitimate Interests: Processing is necessary for our legitimate interests.

If you are located in other regions with specific data protection laws, including but not limited to Australia, New Zealand, South Africa, and Canada, we will process your personal information in compliance with the applicable data protection laws in your region.

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include:
    • Payment Processing: Stripe, PayPal, and Apple In-App Purchases.
    • Data Hosting and Storage: GoDaddy.
    • Email Delivery: Services used for sending emails and newsletters.
    • Customer Support: Services used to provide customer support.

These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  • Business Transfers. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
  • Legal Obligations. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal processes.

We do not sell, rent, or trade any of your information with third parties for their promotional purposes.

  1. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services.

Our Services may link to third-party websites, online services, or mobile applications and may contain advertisements from third parties. We do not control, and are not responsible for, the content or privacy practices of such third parties. We encourage you to review their privacy policies.

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and similar tracking technologies to collect and store your information.

We may use cookies, web beacons, pixels, and other tracking technologies to help customize the Services and improve your experience. You can control cookies through your browser settings and other tools.

  1. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: Our Services do not currently support social media login authentication.

However, we may provide features that allow you to share content from our app to social media platforms. When you choose to share content, your device will prompt you to select the social media platform, and you may be subject to that platform’s privacy policy.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

  • Data Storage. Your data is stored on secure servers provided by GoDaddy, located in secure data centers.
  • Access Controls. Only authorized personnel have access to personal data, and they are required to maintain the confidentiality of such information.
  • Security Measures. We employ security measures such as encryption (SSL/TLS), firewalls, and access controls.

Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it, or, if this is not possible, securely store your personal information and isolate it from any further processing until deletion is possible.

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Account Information

If you would like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.

Data Subject Rights

Depending on your location, you may have certain rights under applicable data protection laws, including:

  • Access: You may request access to your personal information.
  • Correction: You may request correction of any inaccurate or incomplete personal data we hold about you.
  • Deletion: You may request deletion of your personal information.
  • Objection: You may object to the processing of your personal information.
  • Restriction: You may request that we restrict the processing of your personal information.
  • Data Portability: You may request to receive your personal information in a structured, commonly used, and machine-readable format.

To exercise these rights, please contact us at MemorySquaredLtd@outlook.com.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

Opting Out of Marketing Communications

You can unsubscribe from our marketing emails by clicking the unsubscribe link in the emails or by contacting us.

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. Currently, no uniform technology standard for recognizing DNT signals has been finalized. As such, we do not respond to DNT signals.

  1. DO RESIDENTS OF SPECIFIC REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of certain regions, you are granted specific rights regarding access to your personal information.

European Economic Area (EEA), United Kingdom (UK), and Switzerland

If you are located in the EEA, UK, or Switzerland, you have the rights outlined in Section 10 above. Additionally, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Brazil (LGPD)

If you are located in Brazil, you have the following rights under the LGPD:

  • Confirmation of Processing: Right to confirm the existence of processing.
  • Access to Data: Right to access your personal data.
  • Correction: Right to request correction of incomplete, inaccurate, or outdated data.
  • Anonymization, Blocking, or Deletion: Right to request anonymization, blocking, or deletion of unnecessary or excessive data.
  • Data Portability: Right to data portability to another service or product provider.
  • Deletion of Personal Data: Right to request deletion of personal data processed with your consent.
  • Information about Sharing: Right to information about public and private entities with which we have shared data.
  • Information about Consent: Right to information about the possibility of denying consent and the consequences.
  • Revocation of Consent: Right to revoke consent.

To exercise your rights, please contact us at MemorySquaredLtd@outlook.com.

India (DPDP Act)

If you are located in India, you have rights under the DPDP Act, including:

  • Right to Access: Request access to your personal data.
  • Right to Correction and Erasure: Request correction or erasure of your personal data.
  • Right to Data Portability: Receive your personal data in a structured format.
  • Right to Withdraw Consent: Withdraw your consent at any time.

To exercise your rights, please contact us at MemorySquaredLtd@outlook.com.

United States (California, Colorado, Connecticut, Utah, Virginia)

Residents of these states have specific privacy rights under state laws such as the California Consumer Privacy Act (CCPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA), and Virginia Consumer Data Protection Act (VCDPA). These rights may include:

  • Right to Know: The categories and specific pieces of personal information we have collected.
  • Right to Delete: Request deletion of your personal information.
  • Right to Opt-Out: Opt-out of the sale of personal information (we do not sell personal information).
  • Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights.

To exercise your rights, please contact us at MemorySquaredLtd@outlook.com.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. You have the right to access and correct your personal information. To exercise your rights, please contact us at MemorySquaredLtd@outlook.com.

South Africa

We comply with the Protection of Personal Information Act (POPIA). You have the right to access, correct, and delete your personal information. To exercise your rights, please contact us at MemorySquaredLtd@outlook.com.

Other Regions

Residents of other regions may have additional rights under applicable data protection laws. Please contact us at MemorySquaredLtd@outlook.com to exercise your rights.

  1. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last Updated” date and will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at:

Email: MemorySquaredLtd@outlook.com

Address:

Memory Squared
23 Wayte Street
Swindon, Wiltshire SN2 2BF
United Kingdom

  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

To request to review, update, or delete your personal information, please contact us at MemorySquaredLtd@outlook.com. We will respond to your request in accordance with applicable data protection laws.

INTERNATIONAL DATA TRANSFERS

We may transfer your personal data to countries other than the one in which you reside. These countries may have data protection laws that are different from the laws of your country.

When we transfer your personal information internationally, we will take appropriate measures to protect your personal information in accordance with this privacy notice and applicable law.

Standard Contractual Clauses (SCCs). We may use Standard Contractual Clauses approved by relevant authorities to ensure that your personal data receives an adequate level of protection.

CHILDREN’S PRIVACY

Our Services are intended for users aged 9 and above. We comply with the Children’s Online Privacy Protection Act (COPPA) and similar regulations worldwide.

  • Children Under 13: We do not knowingly collect personal information from children under 13 years of age without verifiable parental consent. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete such information.
  • Parental Control: If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at MemorySquaredLtd@outlook.com.

YOUR CONSENT

By using our Services, you consent to this privacy notice.

DISCLAIMER

This privacy notice is intended to comply with global data protection laws and to provide comprehensive information about how we collect, use, and protect your personal information. However, it is not a substitute for legal advice. We recommend consulting with a legal professional to ensure compliance with all applicable laws and regulations.

Thank you for trusting Memory Squared with your personal information.