Introduction
MemoriaCall Inc. is committed to protecting your privacy and ensuring you have a positive experience on our website and while using our products and services (collectively, “Products”). This policy applies to the Memoria Inc. website, mobile applications, and desktop clients worldwide. Scope and Consent
This policy outlines our practices for collecting and using your Personal Data during online and offline interactions with us. "Personal Data" means any information that can identify an individual, including name, email address, postal or physical address, credit or debit card number, title, and other personally identifiable information.
If you reside in the European Union (EU), United Kingdom, Liechtenstein, Norway, Iceland, or Switzerland, you may have additional rights regarding your Personal Data, as further outlined below, including rights under the EU's General Data Protection Regulation (GDPR).
Data Controller and Processor
MemoriaCall Inc. will be the Controller of your Personal Data provided, collected, and/or processed under this Privacy Policy for responding to information or service requests, concluding business transactions, and other business purposes. MemoriaCall Inc. will be a Processor of data entered into the service when a Customer uses the Services (see “User-Generated Information” below). If you have questions about whether any of the foregoing applies to you, please contact us using the information in the “Contact Us” section below.
Policy Updates

This policy may be updated periodically for operational practices or regulatory changes. We recommend reviewing our Privacy Policy regularly. If we propose any material changes, we will notify you by posting a notice on this page before the changes take effect. We encourage you to periodically review this page for the latest information on our privacy practices.

Collection of Personal Data

We may collect the following categories of Personal Data when you use or interact with our Service:

• Name
• Title
  
• Email address
  
• Home/work/mobile telephone number
  
• Postal or other physical address
  
• Credit/debit card information
  
• Facebook profile information (if you use Facebook to log in or create an account)
  
• IP addresses and other information collected passively (see “Passive Collection” below)
  
• Device identifiers (see “Mobile Application” below)
  
• Host Information: Automatically recorded information when you use the Service, including your IP address, operating system type and version, client version, IP addresses along the network path, and MAC address of your internet connection.
  
• Usage Information: Information about your usage of the Service, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, messages, contacts, content shared, calls, use of video and screen sharing, meetings, cloud recording, and other feature usage.
  
• User-Generated Information: Information you upload, provide, or create while using the Service (see “User-Generated Information” below).
  

User-Generated Information We collect and retain, generally as a Processor, Personal Data and other information you upload, provide, or create while using the Service, including information related to:

• Meetings: Meeting title, invitation content, participants, meeting link, date, time, and duration, along with activity recorded during the meeting, such as joining or leaving, third-party integrations, and audio and video content (not stored unless cloud recording is used).
  
• Messages: Message content, sender and recipients, date, time, and read receipts. Content shared, such as files and file names, sizes, and types.
  
• Status: Information about your activity status, such as active, out of office, or busy. You can choose whether or not to share status information with other users.
  

If you share a meeting link with another user who is not already in the meeting, that user will be able to see the list of other users in the meeting and other invitees joining the meeting.
Passive Collection
MemoriaCall Inc. and our third-party service providers automatically collect some information about you when you use our Products using methods such as cookies and tracking technologies. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and clickstream data to analyze trends and administer the website and/or Products.
Mobile Application
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We send push notifications to update you about events or promotions. If you no longer wish to receive these communications, you can turn them off at the device level. We collect certain information about your device to ensure proper notifications.
rocessing of Personal Data
We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data, you can request deactivation of your account by contacting us as specified in the “Contact Us” section.
We will only process your Personal Data if we have a lawful basis for doing so, such as consent, contractual necessity, or legitimate interests.
We process Personal Data for purposes such as:

• Account configuration and maintenance
  
• Enabling meetings and webinars
  
• Hosting and storing personal data from meetings and webinars
  
• Personalizing, improving, or operating our Service and business
  
• Fulfilling service-related requests
  
• Protecting against fraudulent, harmful, unauthorized, or illegal activity
  
• Providing reports and support based on service usage
  
• Processing orders and delivering services
  
• Complying with contractual and legal obligations
  
• Resolving disputes and enforcing agreements
  

Data Subject Rights
You have certain rights with respect to your Personal Data, including:

• Access: Request more information or a copy of the Personal Data we hold about you.
• Rectification: Request correction or supplementation of inaccurate or incomplete data.
• Objection: Object to the collection or use of your Personal Data for certain purposes.
• estriction of Processing: Ask us to restrict further processing of your Personal Data.
• Portability: Request a copy of your Personal Data in a machine-readable format.
• Withdrawal of Consent: Withdraw consent for processing your Personal Data.
• Right to File Complaint: Lodge a complaint with the supervisory authority in your country or EU Member State.

Data Retention
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.Cookies and Tracking Technologies
MemoriaCall Inc. and our partners use cookies and similar technologies to analyze trends, administer the website, track users’ movements, and gather information about our user base. Users can control the use of cookies at the individual browser level. For more information, please review our Cookie Policy.
Interest-Based Advertisements
We partner with third parties to display advertising on our website or manage our advertising on other sites. Some of our partners use cookies and other technologies to gather information about your activities to provide interest-based ads. More information about the OBA Principles can be found at the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance (EDAA) websites.
Geolocation
We collect information about your location when using our Products to optimize your connection, support compliance, and suggest customizations.Sharing of Personal Data
We do not sell or rent your Personal Data to third parties for any purposes, including marketing. We share Personal Data with business partners, service vendors, and authorized third-party agents to provide requested Products or transactions.
In certain cases, we may transfer user information as part of business transactions such as mergers or acquisitions. We may also disclose Personal Data to comply with legal obligations or to establish or exercise our legal rights.
Security of Personal Data
Memoria Inc. is committed to protecting your Personal Data. We use industry-standard security technologies, procedures, and organizational measures to protect your Personal Data from unauthorized access, use, or disclosure.
Linked Websites and Third-Party Services
Our websites and services may link to third-party websites and services outside our control. We encourage you to review the privacy policies of these sites and services.Newsgroups/Forums
Information provided in memoriaCall Inc. chat rooms or forums will be made broadly available to others. Participants' opinions are their own and do not reflect the opinion of memoriaCall Inc.
Meeting Recordings
If you use a feature that allows for recordings, we collect information related to such recordings, including Personal Data if provided.

• For Hosts: You are responsible for notifying and obtaining consent from meeting participants for recordings.
• For Attendees: Be aware that meetings or webinars may be recorded. If you do not want to be recorded, you can leave the meeting or webinar.

Transfer and Storage of Personal Data
Our Products are hosted in the U.S. We may transfer your Personal Data to the U.S. or other locations for processing or storage. By using our Products, you consent to the transfer and storage of your Personal Data.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
MemoriaCall Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield. We commit to handling Personal Data from the EU, Switzerland, and the UK according to the Privacy Shield Principles.
Standard Contractual Clauses
In some cases, MemoriaCall Inc. will transfer Personal Data from the EU under the European Commission-approved Standard Contractual Clauses. A copy can be obtained from the European Commission’s website.
Contact Us
If you have any questions about this Privacy Policy, please contact our Privacy Team at MemoriaCall Inc.
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