Website Privacy Policy

1. Data Controller

Bernstein Holding UG (haftungsbeschränkt)
Eschenlohmühle 2
86862 Lamerdingen, Germany
Email: help@thememo.am

2. Overview

The Memo processes personal data only where necessary to provide the website and subscription service, deliver the content and features included in a subscription, administer referral benefits, operate the website securely, process payments, respond to support requests, measure the website in a privacy-conscious way, and protect subscription content from unauthorised redistribution. The iOS app is covered by our App Privacy Policy on this page.

3. Data Collection

The following personal data may be processed:

• Name and email address — for account management, delivery of subscription content and features, and essential subscription communications
• Payment and invoice data — processed primarily by our payment provider Stripe. We do not store credit card or bank account details.
• Referral data — referral and attribution codes, referring and referred subscriber records, subscription and reward status, qualification dates, applied and queued rewards, and related billing references. The subscriber Referral Center does not reveal another subscriber's identity.
• Subscription access and feature data — subscription tier and capabilities, edition and archive access, PDF download records and watermark identifiers, and feature-use records needed to provide and protect the subscribed service
• Executive request data — questions, instructions, correspondence, attachments, companies or people named in a request, request status, delivered material, and feedback when you use Agent Conversations, Concierge, or Company and People Intelligence
• Private Experience data — invitations, responses, attendance status, guest details, and preferences you choose to provide when an experience is offered
• Technical access data — such as IP address, access time, browser information, and request metadata in server logs and security systems
• Consent and delivery-preference data — cookie consent choices, double-opt-in confirmation, and whether you have enabled edition delivery by email
• Website measurement data — as described in sections 9 to 12 below
• Communication data — when you contact us by email or support request

4. Legal Basis

Processing is based on Art. 6(1)(b) GDPR where it is necessary to provide the subscription service, Art. 6(1)(c) GDPR where we must comply with legal obligations such as tax and accounting retention rules, and Art. 6(1)(f) GDPR where we have a legitimate interest in operating a secure, reliable, privacy-conscious, and high-quality service and in measuring basic aggregate website reach through the minimized process described in sections 10 to 12.

Optional analytics and marketing cookies, related storage, full Google Analytics measurement, Google Signals, and advertising-related measurement are used only on the basis of your consent under Art. 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. Technically necessary cookies or similar storage, including storage of your consent choice, are used where required for the service you request or for secure operation of the website, including under § 25(2) TDDDG where applicable.

Where processing is based on consent, you may withdraw that consent at any time with effect for the future. Where processing is based on legitimate interests, you may object as described in section 19.

5. Payment Processing

Where you purchase a subscription through our website, payment processing is handled by Stripe, Inc. (510 Townsend Street, San Francisco, CA 94103, USA) and its sub-processors. During such a purchase, you are redirected to Stripe's checkout page. Stripe's privacy policy applies: stripe.com/privacy

6. Subscription and Email Delivery

Depending on the subscription, content and service communications may be delivered by email. We use your email address to provide the content and features included in your subscription according to the applicable delivery schedule, and to send account-related messages, payment or subscription notices, and essential service communications. The applicable content, features, and delivery schedule are described on our website or at checkout.

You can turn edition delivery by email on or off in your account settings. Turning it off does not cancel your paid subscription or change access through the app, and essential account or payment messages may still be sent. If your email address has not yet completed double opt-in, enabling delivery sends a confirmation email. Once confirmed, pausing and later resuming edition delivery does not by itself require another confirmation.

Where content or service communications are sent by email, technical delivery is handled via Resend, Inc. and its sub-processors, a US-based email service provider operating under EU Standard Contractual Clauses. Resend's privacy policy applies: resend.com/legal/privacy-policy

If your subscription ends, delivery of the content and access to the features tied to that subscription will stop as provided by the applicable subscription terms. Any separate account functionality may remain available. We may retain minimal suppression or account records where necessary to document cancellation, prevent accidental reactivation, comply with legal obligations, or defend legal claims.

6A. Referral Program

When you open an invitation link, we use a technically necessary, signed referral-claim cookie for up to 30 days to remember the referring subscriber during signup. Referral identifiers are excluded from website analytics and the dedicated invitation route is excluded from the normal website access log.

If a subscription is attributed to a referral, we connect the subscriptions in our internal records and exchange the necessary subscription, invoice, discount and reward status with Stripe. We use these records to grant the referred subscriber's lifetime discount, calculate the referrer's conditional reward, enforce the minimum subscription price, restore eligibility after resubscription, reconcile billing events and prevent self-referral, duplicate attribution and fraud. Processing is necessary to perform the referral terms under Art. 6(1)(b) GDPR and, for security, audit and fraud prevention, based on Art. 6(1)(f) GDPR.

Referral relationships, reward history and lifetime eligibility are retained for as long as needed to administer and audit the program, including across cancellation and resubscription, and for any additional period required by accounting law, fraud prevention or legal claims. Full names, email addresses and payment problems of referred subscribers are not shown to referrers.

6B. Executive Features and Requests

When you use an Executive feature, we process the information you submit and the resulting correspondence, status, research, recommendation, response, or document to perform the requested service. Requests may be reviewed by authorised personnel and, where the feature uses automated research or generation, processed by the relevant service provider. Processing is based on Art. 6(1)(b) GDPR where necessary to provide the requested subscription feature and Art. 6(1)(f) GDPR for security, quality control, abuse prevention, and the establishment or defence of legal claims.

Company and People Intelligence, Concierge, and Private Experience requests may necessarily identify other people. Please provide only information that is relevant to the request and that you are entitled to provide. Do not include special-category or other highly sensitive personal data unless it is necessary, lawful, and specifically requested.

7. Contacting Us

If you contact us by email, we process the information you provide in order to respond to your request. This may include your email address, name, message content, and related correspondence. Processing is based on Art. 6(1)(b) GDPR where the request relates to a subscription, and otherwise on Art. 6(1)(f) GDPR.

8. iOS App

Data processing through The Memo iOS app and its subscriber API is described in our App Privacy Policy on this page.

9. Cookies and Tracking

This website uses technically necessary cookies and comparable storage for basic website operation and consent storage. We use Finsweet Cookie Consent to collect and store your cookie preferences. The consent script is loaded via jsDelivr CDN. This loading is used to display and operate the consent mechanism.

The consent banner distinguishes between Essential, Analytics, and Marketing. Essential storage is required for basic operation and for remembering your consent choice. Analytics helps us understand and improve how the website is used through Google Analytics 4. Marketing supports advertising measurement and audience features through the Meta Pixel and Google Signals and requires Analytics under our consent model. No optional category is preselected.

You can accept all optional purposes, reject them, or save a custom choice. You may withdraw or change consent at any time with effect for the future by selecting “Change privacy settings” in the footer of any page. Withdrawing Analytics also disables Marketing. You may alternatively clear your browser site data for this website or contact us.

10. Website Analytics and Advertising Measurement

On this website, we use Google Tag Manager, Google Analytics 4, and Google Consent Mode to understand how the website is used and to improve it. These services are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, including their sub-processors.

If you grant analytics consent, Google Tag Manager and Google Analytics may be loaded. Google Analytics may then process analytics identifiers, page views, referrers, device and browser information, and interaction events. Analytics cookies and similar analytics storage may be set in your browser only after analytics consent has been granted. The legal basis is Art. 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. Google privacy information is available at policies.google.com/privacy.

When you begin subscription checkout with analytics consent granted, the current pseudonymous Google Analytics client and session identifiers, a randomly generated consent reference, your analytics and marketing consent choices, and allowlisted campaign-attribution parameters may be attached to Stripe Checkout metadata. The consent reference is stored by us only as a cryptographic hash so that a later withdrawal can also stop attribution of subscription and payment outcomes. This allows a subscription or payment later confirmed by Stripe to be attributed to the originating website visit. These analytics identifiers and campaign parameters are included only when analytics consent is granted. We do not send your name, email address, Stripe customer ID, or internal subscriber ID to Google Analytics.

We have enabled Google Signals in our Google Analytics 4 property. Google Signals is a Google Analytics advertising feature. If you grant both Analytics and Marketing consent, Google may associate the usage data collected from this website with information from your Google account if you are signed in to that account and have enabled Ads Personalization. This may enable aggregated cross-device reporting and reports about demographic characteristics and interests. Google states that cross-platform reports contain aggregated data and do not expose information about individual Google account users to us.

For Google Signals, Google may use first-party Google Analytics cookies or other first-party identifiers together with Google advertising cookies or other Google advertising identifiers. This processing is based on your prior consent under Art. 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. Google Signals is not used for the minimized denied-consent page views described below. You may withdraw your consent at any time with effect for the future through our cookie settings. You can also manage Ads Personalization in Google My Ad Center, access and delete activity associated with your Google account in Google My Activity, or use the Google Analytics opt-out browser add-on. Further information is available in Google's Google Signals documentation and its policy requirements for Google Analytics advertising features.

If you grant both Analytics and Marketing consent, we load the Meta Pixel provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland, and Meta Platforms, Inc., 1 Meta Way, Menlo Park, CA 94025, USA. The Pixel records a PageView for this website and may process the page URL, referrer, browser and device information, IP address used for transmission, Meta click identifiers, and identifiers stored by Meta such as _fbp or _fbc. We do not configure the browser Pixel to send names, email addresses, Stripe identifiers, subscriber identifiers, checkout contents, or payment values.

We use the Meta Pixel to measure whether Meta advertisements lead to visits to The Memo, understand aggregate advertising performance, and support Meta audience and delivery features. Processing and access to information on your device are based on your prior consent under Art. 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. Meta may combine Pixel data with information from Facebook, Instagram, and other sources in accordance with its policies. Further information is available in the Meta Privacy Policy and the Meta Business Tools Terms.

If you do not grant Analytics and Marketing consent, the Meta Pixel script is not loaded and no Meta Pixel PageView is sent. If you withdraw either consent after the Pixel has loaded, the website requests that Meta revoke Pixel consent and reloads the page so the tag cannot continue running in the existing document. You can change or withdraw consent at any time through “Change privacy settings”.

If you reject analytics consent, we do not load the Google Tag Manager, Google Analytics, or Meta Pixel browser scripts and do not set optional analytics or advertising cookies through these tools. To maintain a basic aggregate pageview count, the website sends one separate same-origin request to our dedicated minimized pageview endpoint. The request uses no stored analytics identifier and is not used to recognise you on later visits, build a user profile, personalise advertising, or combine the pageview with subscriber account data.

The minimized browser payload contains the event type, a timestamp, the page path, the page title normalised and limited to 150 characters, a non-personalised-processing flag, and random technical identifiers generated in memory for that one event. For links from our controlled daily Instagram advertising workflow, it may also contain the fixed source ig, medium paid, campaign daily_post, and a date-only content value. These values classify the page view at aggregate campaign level. All other URL query parameters are removed. The payload does not contain your name, email address, subscriber ID, referrer, screen resolution, browser language, URL hash, Meta click or advertising identifiers, stored Google Analytics identifiers, or the reason for your consent choice.

Our web server necessarily receives the IP address to establish and answer the HTTPS request, as it does for other page requests. The dedicated endpoint is excluded from the Nginx access log and removes the visitor IP and forwarding headers, original User-Agent, cookies, referrer, and browser client-hint headers before the measurement event reaches the server-side Google Tag Manager container. A conditional allow-list in that container removes all event fields except the event name, sanitised page location, bounded page title, one-event identifiers, non-personalised-processing flag, and technical protocol and destination fields required to transmit the event.

Only this minimized event is forwarded to Google Analytics 4 as a page view for the aggregate pageview count. Because the identifiers are not stored or reused, these page views are not suitable for determining denied-consent visitors, returning users, user paths, reliable sessions, engagement, or conversion attribution. The bounded Instagram values support only an aggregate paid-pageview classification. Google Signals, Meta Pixel, and advertising-related audience functions are not used for these page views. The legal basis for the transient server-side processing and this limited reach measurement is Art. 6(1)(f) GDPR. Our legitimate interest is to understand basic website and campaign reach while respecting the rejection of analytics cookies and visitor-level analytics. You may object to this processing as described in section 19.

11. Hosting and Server Logs

This website is hosted on servers operated by STRATO AG (Otto-Ostrowski-Straße 7, 10249 Berlin, Germany) and its sub-processors. When accessing the site, technically necessary data may be processed in server log files, including IP address, access time, requested page, browser type, operating system, referrer URL, and request status.

Server logs are processed pursuant to Art. 6(1)(f) GDPR for security, troubleshooting, abuse prevention, and reliable operation of the website. Log data is not used to create visitor profiles. Nginx access logs are normally rotated daily and retained for up to 14 days, unless a longer retention period is necessary for security incidents, abuse investigation, legal obligations, or legal claims. Requests to the dedicated minimized pageview endpoint described in section 10 are excluded from the Nginx access log.

12. Server-Side Tagging

Consent-granted analytics requests are routed through our same-origin endpoint at www.thememo.am/metrics before reaching our server-side Google Tag Manager container. The separate denied-consent pageview request uses www.thememo.am/metrics/anonymous/g/collect. Both endpoints are operated on our production VPS. Server-side tagging is used to keep the browser-facing measurement endpoints on our own domain and apply server-side privacy and forwarding controls.

When analytics consent is granted, normal Google Analytics events may be forwarded from the server-side container to Google Analytics 4. If analytics consent is rejected, the dedicated route first removes browser connection metadata and the server container then applies a strict event-data allow-list before the minimized page view described in section 10 is forwarded. Apart from the bounded page title and the strict daily Instagram campaign tuple described above, we do not add user data, advertising identifiers, referrer, screen resolution, browser language, other query data, hash, persistent analytics identifiers, or subscriber identifiers to that event.

We do not use the minimized pageview endpoint to override the visitor's choice about analytics cookies, advertising audience measurement, or visitor-level analytics. Rejected analytics consent means no analytics cookies, no Google Tag Manager, Google Analytics, or Meta Pixel browser script, no persistent analytics identifier, no cross-page recognition, no visitor-level campaign attribution, and no Google Signals or Meta Pixel processing for that pageview.

13. SSL/TLS Encryption

This website uses SSL/TLS encryption. You can recognise an encrypted connection by the “https://” address in your browser. Encryption helps protect data transmitted between your browser and our website.

14. Content Protection and Watermarking

Where subscription content is supplied as a PDF or other downloadable document, it may be individually watermarked or marked with a subscriber-specific identifier derived from your email address. This is necessary to protect our intellectual property and enforce our Terms of Service. Processing is based on Art. 6(1)(f) GDPR (legitimate interest in preventing unauthorised redistribution).

15. Data Sharing

Personal data is shared only where necessary to provide the service, operate the website, process payments, comply with legal obligations, protect our rights, or work with carefully selected service providers.

• Stripe, Inc. and its sub-processors — for payment processing (see section 5)
• Resend, Inc. and its sub-processors — for technical email delivery (US-based, with EU Standard Contractual Clauses)
• OpenAI and its sub-processors — for requested Agent Conversations and automated research or generation used in relevant Executive features
• Google Ireland Limited, Google LLC, and their sub-processors — for Google Tag Manager, Google Analytics 4, and Consent Mode
• Meta Platforms Ireland Limited, Meta Platforms, Inc., and their sub-processors — for consent-based Meta Pixel advertising measurement and audience features
• Finsweet, Inc. and its sub-processors — for the cookie consent functionality
• jsDelivr CDN — for delivery of the cookie consent script
• STRATO AG and its sub-processors — for server hosting in Germany

Where required under Art. 28 GDPR, we have concluded data processing agreements with our processors.

16. International Data Transfers

Through the use of Stripe, Resend, OpenAI, Google, Meta, Finsweet, and jsDelivr, data may be transferred to countries outside the European Economic Area, including the United States. Where applicable, providers rely on the EU-US Data Privacy Framework, EU Standard Contractual Clauses, or comparable transfer safeguards as required by law.

17. Data Retention

Unless a more specific retention period applies, personal data is stored only for as long as necessary for the purpose for which it was collected, or as required by law.

Subscription and account data are stored for as long as needed to provide the relevant subscription or account functionality. After the related subscription and account relationship has ended, your email address and name will be deleted within 30 days unless referral-program administration, lifetime-discount eligibility, statutory retention periods, documentation obligations, suppression requirements, fraud prevention, or legal claims require longer storage.

Executive requests, related correspondence, submitted materials, delivered results, feature-use records, and Private Experience records are retained only while needed to provide the feature, maintain any subscriber-facing history or archive, administer an experience, protect the service, or comply with legal and documentation obligations. They are deleted or anonymised when those purposes no longer apply. More specific retention information for app inquiries is provided in the App Privacy Policy on this page.

Cookie consent choices are stored for the duration configured in the consent banner or until you change or delete the consent data in your browser. Minimized denied-consent page view events forwarded to Google Analytics 4 are retained according to the retention settings configured in Google Analytics, without a persistent identifier that would allow us to recognise the browser on a later page.

Invoice data is retained for 10 years in accordance with German tax law (§ 147 AO, § 257 HGB).

18. Your Rights

You have the right to:

• Access your stored data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure of your data (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)

To exercise your rights, please contact: help@thememo.am

19. Right to Object

You may object at any time to processing based on Art. 6(1)(f) GDPR for reasons arising from your particular situation. We will then stop processing the data unless we can demonstrate compelling legitimate grounds or the processing is necessary for the establishment, exercise, or defence of legal claims.

If personal data is processed for direct marketing, you may object at any time. In that case, your data will no longer be processed for direct marketing purposes.

20. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany
www.lda.bayern.de

21. Changes

We reserve the right to update this privacy policy as needed. The current version is always available on this page.