PRIVACY POLICY

Last update: 01.12.2025

INTRODUCTION

Welcome to MeMoment (“we,” “us” or “our”). We take your privacy seriously and are committed to protecting it through our compliance with this Privacy Policy ("Policy"). This Policy helps explain how we collect, use, store, and protect your information when you use our services (the “Services”): website (“Website”), mobile application (“App“) and the services and products provided through them. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

We provide our customers (“customers”, “you”, “your”) with a customer personality profile. We are committed to being transparent in our handling and processing of personal Information in accordance with applicable privacy and data protection laws.

By using the Services, you confirm that:

  • You have read it carefully, understand and agree to this Privacy Policy.
  • You are over 18 years of age.

If you do not agree, or are unable to make this confirmation, you must not use the Services. In such case, you must:

  • contact us and request deletion of your data;
  • delete the App from your device or leave the Website and not access or use it;
  • cancel any active subscriptions or trials.

For your convenience, this Policy may be translated from English. In the event of a conflict between the English version and any translation, the English version shall be the authoritative and legally binding text.

We may change this Policy from time to time by updating this page. If we decide to make material changes to this Privacy Policy, you will be notified through our Services or by other available means and will have an opportunity to review the revised Privacy Policy.You should check this page from time to time to ensure that you agree with any changes.

Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Last update at the top of this Policy to ensure you are viewing the most current version.

If you have questions or concerns about the Privacy Policy, please contact us at support@memoment.ai.

PERSONAL DATA CONTROLLER

AppLiks Sp. z O.O., Aleja Jana Pawla II 43A/37B, 01-001 Warsaw, Poland, will be the controller of your personal data.

CATEGORIES OF PERSONAL DATA WE COLLECT

We collect several types of information from you and about users of our Services, including personal Information when you create an account ("Account") or use our Services. Personal information means information that identifies (whether directly or indirectly) a particular individual, such as name, email address, and other personal details ("personal Information, personal data"). We also collect information related to how you use our Services, which helps us improve them.

We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Google). We also collect data automatically (for example, your IP address).

When you provide us with information in connection with a particular activity or otherwise sign up for our products and Services, you agree that such action constitutes establishing a business relationship with us.

Data you give us

If you decide to make a purchase on the Website, we will ask you to provide an email address which will be used to send you the access and/or any details on your payment. We will also ask you several questions about you to tailor our product to your personal needs. You can also provide us with your email when you contact our support team. We do not “sell” Personal information and do not use sensitive data for advertising or share it with third parties for their marketing purposes.

We use automated processing of your test responses to generate a personality profile and tailored recommendations. This profiling does not produce decisions with legal or similarly significant effects. You can object to profiling or request human review at any time.

Data provided by third parties

  • When you use sign in with Apple to register an account in the Services, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen. Find more about sign with Apple in its privacy policy.
  • When you decide to log in using Google, we receive personal data from your Google Account: name, email address, profile picture associated with your Google Account. To know more about how Google processes your data, visit its privacy policy.

Data we collect automatically:

  • Data about how you found us

We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).

  • Browser and Device data

We collect data from or about the devices from which you access the Product, depending on the permissions you’ve granted. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices. Examples of such data include language settings, IP address, location, time zone, type and model of a device, etc.

We also collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

  • Usage data

We record how you interact with our Services. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Services, how long you are on the Services, your purchases.

  • Transaction data

When you make payments through the Services, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

  • Video Game Integration Data

The information about gameplay statistics is collected automatically when connecting third-party games via API to provide integrated gaming experience and to track progress across services.

  • Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Services. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Services. Cookie data will be stored on your device and most of the time only for a limited time period.

  • Third-Party Cookies

The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media links) on the site is not covered by our Privacy Policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies.

  • Google Analytics Cookies

Google Analytics collects information about your Services visits. We use this information only to improve our Services. You can prevent Google Analytics recognition by disabling cookies.

HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Various browsers offer a Do Not Track “DNT” option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser’s preferences.

We currently do not support “Do Not Track” requests because no DNT standard has been adopted, but you can opt out of receiving cookies. Our third-party services may collect information about you and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services honor the “Do Not Track” requests, please read their privacy policies.

FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

  • To provide our Services

This includes enabling you to use the Services in a seamless manner and preventing or addressing Services errors or technical issues.

  • To customize your experience

We process your personal data to adjust the content of the Services and provide content tailored to your personal preferences. For example, we will use the information provided by you during the tests to make the most suitable offer to you.

  • To provide you with customer support

We process your personal data to respond to your requests for technical support, information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Services, security, payment transactions, notices regarding our Terms and Conditions or this Privacy Policy.

  • To communicate with you regarding your use of our Services

We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Services. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Services. To opt out of receiving push notifications, you need to change the settings on your device. To opt-out of receiving emails, you should click the unsubscribe link in the footer of the email. The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.

  • To research and analyze your use of the Services

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Services and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Services based on the results obtained from this processing.

  • To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Services. We may show you advertisements on our Services, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

  • To personalize our ads

We and our partners use your personal data to tailor ads. You can opt out of personalized ads or influence them at any time in the settings on your devices. It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser.

  • To process your payments

We provide paid products and/or services within the Services. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions).

  • To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

LEGAL BASES FOR COLLECTION AND PROCESSING YOUR PERSONAL DATA

In this section, we are letting you know what legal basis we use for each particular purpose of processing. This section applies only to EEA-based users (EEA includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland). We process your personal data under the following legal bases:

  • to perform our contract with you.

    Under this legal basis we:

    • Provide our Services (in accordance with our Terms and Conditions);
    • Customize your experience;
    • Provide you with customer support;
    • Communicate with you regarding your use of our Services;
    • Process your payments.

  • for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

    Our legitimate interests include:

    • Network and Information Security: Detecting and preventing fraud, cyberattacks, and other security incidents to protect our users and Services.
    • Service Improvement and Analytics: Analyzing how our Services are used to improve their performance, functionality, and user experience.
    • Marketing: Conducting direct marketing campaigns about our products and Services to interested users.
    • Administration and Legal Compliance: Enforcing our Terms and Conditions, defending our legal rights, and ensuring the proper administration of our business.

You have the right to object to processing based on our legitimate interests. We will consider your objection and will cease such processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services. We may share some sets of personal data, in particular, for purposes and with parties indicated in this Privacy Policy. The types of third parties we share information with include, in particular:

  • Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions (for payment processing, analytics, hosting, etc).

  • Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

  • Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

YOUR RIGHTS REGARDING YOUR INFORMATION
  • To be in control of your personal data, depending on location you have the following rights:
  • Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Services.
  • Deleting your personal data. You can request erasure of your personal data as permitted by law. When you ask us to delete your personal data, we will process your request promptly. Please note that we are sometimes legally required to retain certain data for a set period. In such cases, we will delete your data as soon as that retention period ends.
  • Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:

We comply with the GDPR. As such, we afforded to all European data subjects their respective data privacy rights to the extent that they are applicable. If you are based in the EEA, you have the following rights in addition to the above:

  • The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
  • The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below. To exercise any of your privacy rights, please send a request to support@memoment.ai.

In order to safeguard your personal Information from unauthorized access, we can ask that you provide sufficient information to identify yourself prior to providing access to your personal Information.

In certain situations, and subject to applicable law, we will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests that are manifestly unfounded or excessive, for example due to their repetitive character. If you have unresolved concerns, you have the right to complain to an EU supervisory authority.

Providing your personal information is generally optional. However, choosing not to provide certain information may impact your experience and our ability to provide you with specific features of the Services. For example:

  • If you do not provide a valid email address, we cannot create an account for you.
  • If you do not provide your complete personal Information, we will not always be able to respond to your request within the timeframes required by applicable law.
  • If you choose not to provide special categories of data (such as psychological information), you will not be able to use features that rely on this data, such as generating your personalized reports, but you will still have access to the core functions of our Services.
CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”) provides additional rights to know, delete and opt-out, and requires us to disclose what personal information we have collected, used, and shared over the last 12 months.

This policy outlines the personal information we collect about you, including the sources of that information and the purposes for its collection. It also details the categories of third parties with whom we share this information.

California Civil Code permits those of our customers who are residents of California to request and obtain from us a list of what personal Information (if any) we have disclosed to third parties for direct-marketing purposes in the preceding calendar year, and the names and addresses of these third parties. To make such a request, please contact us at support@memoment.ai. For all requests, you must put the statement 'Your California privacy rights' in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a resident of California and provide a current address in California for our response. You can submit requests by email. We will verify your identity and respond within the time limit prescribed by law.

California residents are also entitled to know how we respond to DNT browser settings. The Provider does not currently take action to respond to DNT signals because a uniform technological standard has not yet been adopted. We continue to review new technology and may adopt a standard once one is universally accepted.

Under CCPA you as a California resident have the following rights:
  • Right to Know. You have the right to request that we disclose to you the personal information we collect, use, or disclose.
  • Right to Delete. You have the right to request that we delete your personal information that we have collected from you.
  • Right to Opt-Out. Please note that we do not sell personal information.
  • Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights. We will not deny you our Services, charge you different prices, or provide you a lower quality of Services if you exercise your rights under the CCPA.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

To exercise any of your privacy rights, please send a request to support@memoment.ai.

VIRGINIA PRIVACY NOTICE

This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).

  • Disclosures about the use of your personal data

We may collect and use certain information about you, some of which may be personal data (such as your name, email address, IP address, and other information which may be reasonably linked to you), in order to operate the Services and to maximize your experience.
This Policy outlines the personal information we collect about you, including the sources of that information and the purposes for its collection. It also details the categories of third parties with whom we share this information.

  • Data rights

This section of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Services. Before completing your request, we may require some information sufficient to authenticate your identity.

Additionally, VCDPA provides Virginia residents with these data rights:
  • Opt out of the Processing of your personal data for Targeted Advertising.

You may exercise this right at any time by contacting us at support@memoment.ai and specifying that you are a Virginia resident wishing to opt out of targeted advertising. Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

  • Confirm whether your personal data is being processed.

You may confirm whether your personal data is being processed by emailing us at  support@memoment.ai.

  • Appeal a Case with regard to your Request.

In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at  support@memoment.ai to initiate an appeal of this decision.

Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

If your appeal is denied, you may contact the Office of the Virginia Attorney General.

CHILDREN'S PRIVACY

The Services are intended for users 18 and older. We do not knowingly collect personal information from anyone younger than age 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

SECURITY

We implement a variety of physical, technical, and organizational security measures designed to protect your personal information. These measures include, but are not limited to, encryption of data in transit and at rest, access controls to restrict data and regular security reviews of our systems. Please be aware that no method of transmission over the Internet or electronic storage is 100% secure. You play a crucial role in account security by using a strong password and not sharing your login credentials with others.

INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Services set forth in the Terms and Conditions and for purposes indicated in this Privacy Policy. If these countries do not have data protection laws deemed adequate by the European Commission or other relevant authorities, we rely on approved legal mechanisms and we deploy special safeguards to ensure your data receives an adequate level of protection. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to support@memoment.ai.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be reflected in the Effective Date update and you will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Services to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, within the time required or permitted by law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you have an account with us or keep using the Website);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
HOW TO CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@memoment.ai.