App Privacy Policy

1. Introduction

This App Privacy Policy explains how we collect, use, share, retain, and protect personal data when you use The Memo iOS app (the “App”) and the authenticated subscriber services connected to it. We are committed to handling personal data transparently and in accordance with applicable data-protection law, including the General Data Protection Regulation (“GDPR”).

This policy applies to App authentication, subscription and entitlement checks, edition and archive access, delivery settings, referrals, notifications, subscriber inquiries, PDF Export, and request-based Executive features. The public website, website checkout, cookies, and website analytics are covered by our separate Website Privacy Policy. If the two policies differ regarding processing through the App, this App Privacy Policy applies.

2. Data Controller

The data controller responsible for the processing described in this policy is:

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

3. Definitions

Personal Data: Any information relating to an identified or identifiable natural person.

Processing: Any operation performed on personal data, including collection, recording, organisation, storage, use, disclosure, restriction, erasure, or destruction.

Data Subject: The identified or identifiable person whose personal data is processed.

Controller: The person or organisation that determines why and how personal data is processed.

Processor: A person or organisation that processes personal data on behalf of a controller.

4. Categories of Personal Data Collected

Depending on the features you use, we may process the following categories of personal data:

Account, subscription, delivery-preference, and referral data: Your name when provided during signup, email address, subscription and payment status, subscription tier and capabilities, double-opt-in status, edition email-delivery preference, referral code, referral relationship, reward status, and expected billing amounts. Referral activity shown in the App does not identify the other subscriber.

Authentication and security data: Login-code records, an opaque session token, IP address, user-agent information, access times, request URLs, referrer information, and related request metadata. Login codes and server-side session tokens are stored as cryptographic hashes.

Usage and feature data: Edition identifiers, access and download times, feature-use records, rate-limit records, and technical information needed to provide, protect, and troubleshoot the App. The native iOS app contains no advertising, no analytics SDK and no cross-app tracking.

Notification data: If you allow notifications, we process an Apple Push Notification service device token linked to your subscriber account, together with the notification title and body needed to deliver edition announcements or other requested service notifications.

Inquiry content: If you use subscriber inquiries, we process your questions, generated answers, relevant conversation history, referenced story and editorial context, citations, answer-image links, and any feedback you submit. This content is linked to your subscriber account so you can reopen a conversation.

Selected images: If you attach an image to an inquiry, the selected image is transmitted with that request for analysis. The image bytes are not added to the stored conversation record on our server, but the inquiry provider processes them to answer the request.

Voice transcription: If you choose voice input, the App uses the iOS Speech framework to transcribe microphone audio. The resulting text is treated like a typed inquiry when you send it. We do not receive or retain the microphone recording itself.

Inquiry feedback: If you rate an answer or send feedback, we may process the rating, category, comments, associated conversation context, IP address, and user-agent information for service quality, security, and troubleshooting.

Executive request data: If you use Concierge, Company Intelligence, People Intelligence, or Private Experience requests, we process the request type, subject, details, status, subscriber-facing messages, delivered material, and related operational records needed to provide the requested feature.

PDF and content-protection data: When you use PDF Export or another protected feature, we may process the subscriber identifier, edition date, source filename, download time, watermark identifier, and related security records.

Communication data: Information you provide when you contact us, including your email address, message, and related correspondence.

Data stored on your device: The App stores the session token in the iOS Keychain. Your email address, subscription tier, notification token, and reading state may be stored in app preferences, and recent editions may be cached in Application Support for offline access. Deleting the App removes its locally stored preferences and cached content.

5. Purpose and Legal Basis of Processing

Performance of a contract (Art. 6(1)(b) GDPR): We process personal data to verify your subscription, authenticate the App, provide the editions and features included in your plan, apply your delivery settings, administer agreed referral benefits, send requested notifications, answer subscriber inquiries, and provide requested Executive features.

Legitimate interests (Art. 6(1)(f) GDPR): We process personal data where necessary for our legitimate interests in operating a secure and reliable subscription service, preventing abuse and referral fraud, protecting subscription content, troubleshooting errors, enforcing reasonable feature limits, and reviewing voluntary product feedback. We balance these interests against your rights and freedoms.

Compliance with legal obligations (Art. 6(1)(c) GDPR): We process personal data where necessary to comply with tax, accounting, commercial, regulatory, or other legal obligations and lawful requests from authorities.

6. Use of Artificial Intelligence and Related Technologies

Subscriber inquiries use artificial intelligence and automated web-search tools to generate requested answers. Relevant Executive features may also use automated research or generation when that forms part of the requested service. To provide these features, the provider may process your question or instructions, recent conversation history, relevant story and editorial context, any image you attach to an inquiry, and other information you submit for the requested feature. The resulting answer or deliverable may include citations and links to public sources.

When an answer contains a citation, our server may request the cited page to retrieve preview metadata. The publisher receives a request from our server, not your subscriber email address or your device's IP address. If you open a cited source yourself, the source's own privacy policy applies.

Answers may also include images hosted by third parties. If the App loads an image directly from its host, that host may receive your device's IP address, user-agent information, and related request metadata.

AI-generated answers may be incomplete or inaccurate and should be checked before you rely on them. We do not use inquiry content to make decisions about you that produce legal effects or similarly significant effects.

7. Use of Third-Party Services

We use the following providers where necessary to operate the App and connected subscriber services:

STRATO GmbH and its sub-processors: Hosting of the subscriber API and related service data in Germany. Privacy information: strato.de/datenschutz.

Plus Five Five, Inc. (Resend) and its sub-processors: Delivery of one-time sign-in codes, double-opt-in messages, essential account emails, and, when enabled, subscription editions by email. Privacy information: resend.com/legal/privacy-policy.

OpenAI and its sub-processors: Processing of subscriber inquiry questions, relevant conversation and story context, optional image attachments, automated web search, answer generation, and requested automated research or generation used in relevant Executive features. Privacy information: openai.com/policies/privacy-policy.

Apple: Operation of the Apple Push Notification service and, when you choose voice input, the iOS Speech framework. Apple also operates the App Store and the device platform on which the App runs. Privacy information: apple.com/legal/privacy.

Stripe and its sub-processors: Payment processing, subscription management, billing records, and referral-related billing adjustments. Full payment-card and bank-account credentials are handled by Stripe and do not reach the App or our subscriber API. We receive billing identifiers, amounts, status, and limited transaction metadata needed to administer subscriptions. Privacy information: stripe.com/privacy.

Depending on the service and the processing involved, a provider may act as our processor or as a separate controller. Where a provider processes personal data on our behalf, we require appropriate contractual and data-protection safeguards.

8. Data Sharing and Recipients

We share personal data only to the extent necessary with hosting and infrastructure providers, email-delivery providers, OpenAI and its sub-processors for requested AI and web-search processing, Apple for platform services, Stripe for payment and subscription administration, authorised IT or professional advisers where needed, and public authorities where disclosure is legally required.

We do not sell or rent personal data, and we do not use App data to build advertising profiles.

9. International Data Transfers

Some providers may process personal data outside the European Economic Area, including in the United States. Where required, transfers rely on an adequacy decision such as the EU-US Data Privacy Framework, EU Standard Contractual Clauses, or another lawful transfer safeguard.

Data-protection laws outside the EEA may not provide the same level of protection as EEA law and may permit access by public authorities under local law. You may contact us for further information about the safeguards applicable to a particular transfer.

10. Retention Periods and Account Deletion

We retain personal data only for as long as necessary for the purposes described in this policy, to provide and protect the service, comply with legal obligations, resolve disputes, and establish, exercise, or defend legal claims. In particular:

• One-time sign-in codes can be used for 10 minutes. Records are removed after successful verification or account deletion. If a code is not used, its hashed code, IP address, user-agent information, and timestamps remain until a later code request for the same email replaces the record or the App account is deleted.
• Authentication sessions become unusable when subscription eligibility is lost. Token records are deleted when you sign out, delete your App account, or present a token that is no longer eligible.
• Database rate-limit records are retained for the relevant fixed window and are removed during later inquiry processing after their cleanup threshold has passed.
• Your subscription, double-opt-in proof, and email-delivery preference are retained with the subscription account so we can provide the service, respect your preference, and document the account relationship.
• Push tokens remain registered until they are unregistered through the App, removed through account deletion, invalidated by Apple, or otherwise no longer needed.
• Our database copy of inquiry conversations and associated feedback becomes eligible for deletion after 90 days of inactivity. The retention sweep is scheduled to run daily. Processing and retention by the inquiry provider are governed by our provider configuration and agreement.
• Selected image bytes sent with an inquiry are not stored in the conversation record on our server.
• Executive requests, delivered results, PDF-download and content-protection records are retained while needed to provide and document the requested feature, protect the service, comply with legal obligations, or resolve claims.
• Referral relationships, reward history, and lifetime-discount 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.
• Our rotating backend log files, which may include IP address, request URL, user-agent and referrer information, are configured for retention of up to 60 days. Separate infrastructure access logs are normally retained for up to 14 days. Logs may be retained longer where necessary for a security incident, legal obligation, or legal claim.
• Communication records are retained for as long as needed to respond, document the matter, comply with legal obligations, or resolve claims.

Settings → Delete Account removes your App authentication records, login codes, registered notification devices, inquiry conversations, and associated feedback from our servers. It does not cancel your paid subscription, which must be managed where you purchased it. Subscriber, payment, referral, Executive-request, PDF-download, content-protection, and other records may remain where necessary to administer or document the contract, honour eligibility, prevent fraud, comply with legal obligations, or resolve claims. You may contact us to request deletion of records that are no longer necessary.

11. Data Security Measures

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures include encrypted transmission, access controls, data minimisation, rate limits, and cryptographic hashing of App login codes and server-side session tokens. The session token itself is stored in the iOS Keychain.

No system can be guaranteed to be completely secure. We review and adjust our safeguards as the service, risks, and available security practices evolve.

12. User Rights under the GDPR

Subject to applicable law, you have the right to:

• Request access to your personal data (Art. 15 GDPR)
• Request rectification of inaccurate or incomplete data (Art. 16 GDPR)
• Request erasure of your data (Art. 17 GDPR)
• Request restriction of processing (Art. 18 GDPR)
• Receive data you provided in a structured, commonly used, machine-readable format where the requirements for portability are met (Art. 20 GDPR)
• Object to processing based on legitimate interests for reasons arising from your particular situation (Art. 21 GDPR)
• Withdraw consent at any time with effect for the future where processing is based on consent
• Lodge a complaint with a data-protection supervisory authority

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

13. Obligation to Provide Data and Consequences of Non-Provision

You are generally not legally required to provide personal data to us. However, your email address, authentication information, and subscription data are necessary to verify eligibility and provide App access. Information you submit in an inquiry or Executive request is necessary to perform that specific request.

If you do not provide required data, we may be unable to authenticate you or provide the relevant feature. Where iOS requests permission for an optional feature, you may decline or later change that permission in iOS Settings, but the related feature may then be unavailable.

14. Automated Decision-Making and Profiling

We use automated rule-based checks for subscription entitlement, feature limits, request allowances, security controls, and referral benefits. We do not use AI profiling or solely automated decisions that produce legal effects concerning you or similarly significantly affect you. You may contact us if you believe an automated rule was applied incorrectly. If our use of legally significant automated decision-making changes, we will provide the information and safeguards required by applicable law before the processing begins.

15. Updates to this Privacy Policy

We may update this policy to reflect changes in the App, our providers, our processing practices, or legal requirements. If a change is material, we will provide notice by an appropriate means, such as through the App, by email, or on our website. The current version and update date will always be published on this page.

16. Contact Information

If you have questions about this policy or wish to exercise your data-protection rights, contact:

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

You may also lodge a complaint with your local supervisory authority. The supervisory authority responsible for us is:

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