Privacy Policy & GDPR

Background:

Memori World PTE. LTD. understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us concerning your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

Account - means an account required to access and/or use certain areas and features of Our Site;

Our Site - means this website, www.memori.world/

We/Us/Our - means Memori World PTE. LTD. headquartered in Singapore.

2. Information About Us

Our Site, memori.world, is owned and operated by Memori world Pte. Ltd. headquartered at
19 KALLANG AVENUE #05-153, Singapore 339410.

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to Our Site (whether We provide those links or whether other users share them). We have no control over how your data is collected, stored, or used by other websites. We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Site for further details, please see Our use of Cookies, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

  • Name
  • Business/company name
  • Contact information such as email addresses
  • Demographic information such as post code
  • Financial information such as credit / debit card numbers
  • IP address (automatically collected)
  • Web browser type and version (automatically collected)
  • Operating system (automatically collected)
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
  • Billing Address
  • VAT No.
  • Social Profile URLs.

5. How Do We Use Your Data?

  • 5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security, see section 6 below.
  • 5.2 We use your data to provide the best possible products and services to you. It includes:
    • 5.2.1 Providing and managing your Account
    • 5.2.2 Providing and managing your access to Our Site
    • 5.2.3 Personalizing and tailoring your experience on Our Site
    • 5.2.4 Supplying Our products and services to you
    • 5.2.5 Personalizing and tailoring Our products and services for you
    • 5.2.6 Responding to communications from you
    • 5.2.7 Supplying you with newsletters, alerts, billing information etc. that you have subscribed to; you may unsubscribe or opt-out at any time changing email preferences on our site or at the bottom of your email
    • 5.2.8 Market research
    • 5.2.9 Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
  • 5.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes, which may include contacting you by email AND/OR telephone with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
  • 5.4 Under GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
    • a) you have given consent to the processing of your personal data for one or more specific purposes;
    • b) processing is necessary for the performance of a contract to which you are a party or to take steps at the request of you prior to entering into a contract;
    • c) processing is necessary for compliance with a legal obligation to which we are subject;
    • d) processing is necessary to protect the vital interests of you or of another natural person;
    • e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
    • f) processing is necessary for the purposes of the legitimate interests pursued by a third party or by us, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data

  • 6.1 We only keep your data for as long as We need to; to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. We will delete your data if we no longer need it as per the terms of our Data Retention Policy.
  • 6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such actions may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
  • 6.3 Data security is of great importance to Us, and to protect your data, We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Site.
  • 6.4 Steps We take to secure and protect your data include
    • 6.4.1 We store user assets like images, videos, etc. in the S3 AWS cloud, and data in the AWS RDS.

7. Do We Share Your Data?

  • 7.1 We may share your data with other companies in Our group. It includes Our subsidiaries AND Our holding company and its subsidiaries.
  • 7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is necessary for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
    • Amazon AWS – N. Virginia
    • PayPal, Inc.
    • Google Analytics/Tag Manager
    • Braintree
    • Facebook, Inc.
    • Google, LLC.
  • 7.3 We may compile statistics about the use of Our Site, including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying information.
  • 7.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

  • 8.1 We may, from time to time, expand or reduce Our business, and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by Users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which we originally collected it.
  • 8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

9. How Can You Control Your Data?

  • When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us, which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details] AND [by managing your Account].

10. How Can You manage or delete your information?

You can access, manage, and delete your account information via the Memori Settings.

  • 10.1 You can cancel your subscription via the Manage Subscription section of the Settings page. You may continue to use Memori until your subscription expires, at which point you will lose access to your account, and all your backed-up content and account data will be deleted, except for data stored for purposes described below.  
  • 10.2 Here are some examples of situations where we’re legally allowed or required to keep some of your personal data: 
    • if there’s an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute.
    • for our legal, tax, audit and accounting obligations.
    • For our legitimate business interests such as to prevent the abuse of our system or fraud prevention.
  • 10.3 To delete your account at any time, please visit the Memori Settings. 

11. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

  • 11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site, you may be required to submit or allow for the collection of certain data.
  • 11.2 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us at [email protected] or from our contact form, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

12. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected] or from our contact form.

13. Memori and the General Data Protection Regulation (GDPR)

In 2016 the European Commission approved and adopted a new framework for European data protection law called the General Data Protection Regulation (GDPR). The GDPR requirements became effective on May 25, 2018 and affect all companies who process the personal data of individuals in the EU.

Here at Memori we embrace the changes being brought in by this new regulation and see it as an opportunity to further improve how we communicate with you, use and share your data and fundamentally, how we place your privacy, security and rights at the forefront of everything that we do.

As both a data controller and processor, we have taken measures to ensure our compliance with the GDPR.

GDPR preparedness checklist

We have been working hard over the recent months to ensure compliance with the GDPR. Below is a high-level overview of the key activities we have performed:

  • Appoint a Data Protection Officer
  • Assess our product and business to determine areas impacted by GDPR
  • Conduct an internal audit to ensure that all third parties and suppliers used by Memori are GDPR compliant
  • Perform necessary changes to the platform (incl. easier to access communication preference controls, explicit acceptance of Terms and Privacy Policies on signup)
  • Update our Privacy Policy
  • Update our Terms & Conditions
  • Create a dedicated page to document our GDPR activities and compliance
  • Create a dedicated page to outline how we secure our customers data
  • Communicate our compliance with our customers

If you have any further questions please don’t hesitate to get in touch with us via our Support Contact form or by emailing us on [email protected]

14. Summary of Your Rights under GDPR

Under the GDPR, you have:

  • 14.1 the right to request access to, deletion of or correction of, your personal data held by Us;
  • 14.2 the right to complain to a supervisory authority;
  • 14.3 be informed of what data processing is taking place;
  • 14.4 the right to restrict processing;
  • 14.5 the right to data portability;
  • 14.6 object to processing of your personal data;
  • 14.7 rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

15.Automated Decision-Making and Profiling

  • 15.1 If We use your personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant) effect on You, then You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their point of view, and obtaining an explanation of the decision from Us.
  • 15.2 The right described in section 14.1 does not apply in the following circumstances:
    • a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
    • b) The decision is authorized by law; or
    • c) You have given you explicit consent.
  • 15.3 Where We use your personal data for profiling purposes, the following shall apply:
    • a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
    • b) Appropriate mathematical or statistical procedures will be used;
    • c) Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
    • d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

16.Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected] or from our contact form.

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

17.Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted immediately on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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