Privacy Policy

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Mnemova, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to https://mnemova.com/.
  For the purposes of the GDPR, the Company is the Data Controller.

• Cookies are small files placed on Your device by a website, containing details of Your browsing history among its many uses.

• Country refers to: Brandenburg, Germany

• Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• GDPR refers to EU General Data Protection Regulation.

• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

• Service refers to the Application or the Website or both.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. For the purposes of the GDPR, Service Providers are considered Data Processors.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

• Website refers to https://mnemova.com/.

• You means the individual accessing or using the Service. Under GDPR, You can be referred to as the Data Subject or as the User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information, including but not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically when using the Service and may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Where required by law, we use non-essential cookies (such as advertising cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool or through Your browser settings.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies — Administered by: Us
  Purpose: Essential to provide You with services available through the Website and to authenticate users.

• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies — Administered by: Us
  Purpose: Identify if users have accepted the use of cookies on the Website.

• Targeting and Advertising Cookies
  Type: Persistent Cookies — Administered by: Third Parties
  Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These are only placed after You have given Your consent.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products or services You have purchased.
• To contact You: by email regarding updates or informative communications related to the functionalities, products or contracted services.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, or other sale or transfer of some or all of Our assets.

We may share Your Personal Data in the following situations:

• With Service Providers: to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, and for payment processing.
• For business transfers: in connection with any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We apply different retention periods based on the purpose of processing:

• Account Information: retained for the duration of your account relationship plus up to 24 months after account closure.
• Usage Data: up to 24 months from the date of collection.
• Financial and Transaction Data: up to 10 years to comply with tax laws and financial regulations.

When retention periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period and are not restored except for security, disaster recovery, or legal compliance purposes.

Transfer of Your Personal Data

Your information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ. Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards such as the European Commission's Standard Contractual Clauses.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You may update, amend, or delete Your information at any time by signing in to Your Account and visiting the account settings section. Please note that We may need to retain certain information when we have a legal obligation to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing, or protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

• Google AdSense & DoubleClick Cookie
  Google, as a third party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
  You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

• AdMob by Google
  AdMob by Google is provided by Google Inc. and is used to serve ads within our mobile application.
  You can opt-out from AdMob by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
  For more information on how Google uses the collected information, please visit: https://policies.google.com/technologies/partner-sites

Payments

We may provide paid products and/or services within the Service. We use third-party services for payment processing. We will not store or collect Your payment card details — that information is provided directly to Our third-party payment processors.

• Stripe — https://stripe.com/privacy

• Apple Store In-App Payments — https://www.apple.com/legal/privacy/en-ww/

• Google Play In-App Payments — https://policies.google.com/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries outside the European Economic Area ("EEA"). Where we transfer Personal Data outside the EEA to a country without adequate protection, We rely on the European Commission's Standard Contractual Clauses ("SCCs") and supplementary measures such as encryption in transit and at rest.

Your Rights under the GDPR

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data — access, update or request deletion of the information We have on You.
• Request restriction of processing — ask Us to restrict processing of Your Personal Data in certain circumstances.
• Request correction of Your Personal Data — have any incomplete or inaccurate information corrected.
• Object to processing of Your Personal Data — where We are relying on a legitimate interest as the legal basis for Our processing.
• Request erasure of Your Personal Data — ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data — receive Your Personal Data in a structured, commonly used, machine-readable format.
• Withdraw Your consent — at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

You may exercise Your rights by contacting Us. We generally respond within one month. You also have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us and We will take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We will let You know via email and/or a prominent notice on Our Service prior to the change becoming effective.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: https://mnemova.com/contact