PLEASE READ THIS NOTICE CAREFULLY
IMPORTANT INFORMATION AND WHO WE ARE
Memento Social Ltd, a company registered in England and Wales (Company No. 13023580) whose registered office is at Lincoln Cottage, Pine Grove, Windlesham, England, GU20 6AW and the owner of “Memento” App, (we) are committed to protecting and respecting your privacy.
This notice (together with our Terms of Use and Community Guidelines and any additional terms of use incorporated by reference into these documents) applies to your use of:
“Memento” mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the documentation and services accessible through the App (Services), unless the Terms of Use and Community Guidelines state that a separate privacy notice applies to a particular Service, in which case that privacy notice only applies.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this carefully. If you have any questions about how we process your personal data please contact [email protected].
OUR ROLE
For the purpose of Data Protection Law, we are the Data Controller of personal data collected from your use of the App. Any reference to the Data Protection Law means (while they remain in force and applicable in the UK) the Data Protection Act 2018, the UK General Data Protection Regulation (GDPR), and any other laws and regulations relating to the processing of personal data in the UK.
INFORMATION WE COLLECT FROM YOU AND HOW WE USE IT
We will collect and process the following data about you:
Our legal basis for processing Contact Information and user-generated content is to allow you to use the App and that it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our legal basis for processing information about your gender is legitimate interests as we will aggregate this information across all our users to understand our user profile better, which is in our legitimate interest.
Aggregated Data:
We also collect, use and share Aggregated Data such as statistical or demographic data to inform us and our business partners of subscriber usage which help to underpin our marketing and business strategy. Aggregated Data could be derived from your personal data (and where this happens we rely on legitimate interests as a lawful basis) but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage information, alongside other users, to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We may share anonymised Aggregated Data with third parties who may want to advertise goods or services within the App. .
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties:
If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets. It is likely however that in such circumstance we shall anonymise all personal data as far as possible before disclosing the same to a prospective seller or buyer.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
We use certain suppliers in order to provide our services and they may have access to our data including your personal data in order to do so. This includes hosting providers and IT consultants.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure servers in Virginia, U.S.A., and we rely on the Standard Contractual Clauses to ensure security of your data. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If users use and upload content outside of the UK, then the data will be accessible from that location by other users who may be able to view your uploads.
HOW LONG WE WILL KEEP YOUR DATA FOR
Your data will be held by us indefinitely, unless:
Should your account be deleted, your personal data will be permanently deleted within 30 days.
You can ask us to delete your data: see Your Rights below for further information.
YOUR RIGHTS
You have the following rights:
You can exercise any of these rights at any time by contacting us at [email protected].
THIRD PARTY LINKS
The App will contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
CHANGES TO PRIVACY NOTICE
We keep our Privacy Notice under regular review.
Any changes we may make to our privacy notice in the future will be posted on the App and, where appropriate, notified to you when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App.
CONTACT
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to: [email protected].
Last updated: 16th August 2023
IMPORTANT INFORMATION AND WHO WE ARE
Memento Social Ltd, a company registered in England and Wales (Company No. 13023580) whose registered office is at Lincoln Cottage, Pine Grove, Windlesham, England, GU20 6AW and the owner of “Memento” App, (we) are committed to protecting and respecting your privacy.
This notice (together with our Terms of Use and Community Guidelines and any additional terms of use incorporated by reference into these documents) applies to your use of:
“Memento” mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the documentation and services accessible through the App (Services), unless the Terms of Use and Community Guidelines state that a separate privacy notice applies to a particular Service, in which case that privacy notice only applies.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this carefully. If you have any questions about how we process your personal data please contact [email protected].
OUR ROLE
For the purpose of Data Protection Law, we are the Data Controller of personal data collected from your use of the App. Any reference to the Data Protection Law means (while they remain in force and applicable in the UK) the Data Protection Act 2018, the UK General Data Protection Regulation (GDPR), and any other laws and regulations relating to the processing of personal data in the UK.
INFORMATION WE COLLECT FROM YOU AND HOW WE USE IT
We will collect and process the following data about you:
- Information you give us to register with the App (Contact Information): This is information you give us about you when registering to use the App or when you fill in a form on the App to report a problem. The information you give us will include your name, e-mail address, date of birth, gender and username. You will also give us your user-generated content when you capture, edit and/or upload these to the App.
Our legal basis for processing Contact Information and user-generated content is to allow you to use the App and that it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our legal basis for processing information about your gender is legitimate interests as we will aggregate this information across all our users to understand our user profile better, which is in our legitimate interest.
- Information we collect about you and your device. Each time you use our Apps we will automatically collect the following information:
- Usage information. Details of your use of our App. Our legal basis for processing Usage information is legitimate interests. It is important for us to understand how our App is being used so we can improve it; and
- Location information. We use GPS technology to determine your current location. This enables us to attach user-generated content, for example photos and posters, to the location in which it was captured. This feature also enables users to view, and/or make use of, location-based advertisements. Our location-enabled Services require your coordinates for the feature to work. If you wish to use the App, your location will be used for this purpose. Where you chose to upload content, other users will be able to view the location of this content, depending on whether you have chosen to have a public or ‘friends and family’ account. Our legal basis for processing Location information is that it is necessary for the performance of a contract to which you are a party. The location-enabled Services are only monitoring your Device location when you are using the App. When the App is closed, or running in the background, we do not collect location information. If you do not want us to process your location, you may not want to use the App.
Aggregated Data:
We also collect, use and share Aggregated Data such as statistical or demographic data to inform us and our business partners of subscriber usage which help to underpin our marketing and business strategy. Aggregated Data could be derived from your personal data (and where this happens we rely on legitimate interests as a lawful basis) but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage information, alongside other users, to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We may share anonymised Aggregated Data with third parties who may want to advertise goods or services within the App. .
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties:
If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets. It is likely however that in such circumstance we shall anonymise all personal data as far as possible before disclosing the same to a prospective seller or buyer.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
- enforce or apply the Terms of Use, Community Guidelines and other agreements you have agreed to with us or to investigate potential breaches; or
- protect the rights, property or safety of Memento Social Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We use certain suppliers in order to provide our services and they may have access to our data including your personal data in order to do so. This includes hosting providers and IT consultants.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure servers in Virginia, U.S.A., and we rely on the Standard Contractual Clauses to ensure security of your data. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If users use and upload content outside of the UK, then the data will be accessible from that location by other users who may be able to view your uploads.
HOW LONG WE WILL KEEP YOUR DATA FOR
Your data will be held by us indefinitely, unless:
- you delete your account through the App or by contacting us at [email protected];
- we delete your account following a breach of the Terms of Use and/or Community Guidelines;
- we delete your account at our discretion.
Should your account be deleted, your personal data will be permanently deleted within 30 days.
You can ask us to delete your data: see Your Rights below for further information.
YOUR RIGHTS
You have the following rights:
- You have the right to lodge a complaint with the Information Commissioners Office (ICO) if you think that we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: https://ico.org.uk/.
- You have the right to access information held about you. You can access your personal data and correct, update or delete it by accessing the App and making any amendments as necessary. Otherwise you can contact [email protected].
- In certain circumstances you have the right to ask us to provide you with your information in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. More information can be found at https://ico.org.uk
- In certain circumstances you have the right to object to us processing your data or ask us to restrict, rectify or erase the data we hold about you. More information can be found at https://ico.org.uk
- Where we are relying on consent to process your personal data, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise any of these rights at any time by contacting us at [email protected].
THIRD PARTY LINKS
The App will contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
CHANGES TO PRIVACY NOTICE
We keep our Privacy Notice under regular review.
Any changes we may make to our privacy notice in the future will be posted on the App and, where appropriate, notified to you when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App.
CONTACT
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to: [email protected].
Last updated: 16th August 2023
