App Privacy Policy
Last updated: 15 July 2026
1. Data Controller
Bernstein Holding UG (haftungsbeschränkt)
Eschenlohmühle 2
86862 Lamerdingen, Germany
Email: help@thememo.am
2. Scope
This policy applies to The Memo iOS app and the subscriber API used by the app at services.thememo.am. The public website is covered by our separate Website Privacy Policy.
3. Data We Process
- Account, subscription, delivery-preference and referral data. We process your email address, subscription status and tier, double-opt-in status, edition email-delivery preference, referral code, referral relationship and reward status, and expected billing amounts to confirm eligibility, send a one-time sign-in code, provide the correct edition and features, manage optional edition delivery by email, and show and administer referral benefits. Referral activity shown in the app does not identify the other subscriber.
- Authentication and security data. We process login-code records, an opaque session token, IP address, user-agent information, access times and request metadata to authenticate the app, prevent abuse and operate the service securely. The session token is stored in the iOS Keychain; our server stores a cryptographic hash rather than the token itself.
- Notification data. If you allow notifications, we process an Apple Push Notification service device token linked to your subscriber account so we can announce new editions.
- Inquiry content. If you use the inquiry feature, we process your questions, generated answers, the referenced story and editorial context, citations, and any feedback you choose to 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 compressed and transmitted with that request for analysis. The image is not added to the stored conversation record on our server, but it is processed by the inquiry provider to answer the request.
- Voice transcription. If you choose voice input, the app captures microphone audio and sends it to Apple through the iOS Speech framework for transcription. 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 process the rating, optional category and comments, and—only when you choose to include it—the associated conversation context. IP address and user-agent information may be recorded with the feedback for security and quality control.
4. Purposes and Legal Bases
Account verification, app access, your edition email-delivery preference, edition delivery, referral-program administration, billing information, notifications and requested inquiries are processed as necessary to provide the service and agreed referral benefits under Art. 6(1)(b) GDPR. Security, referral-fraud prevention, abuse prevention, service reliability and voluntary product feedback are processed under Art. 6(1)(f) GDPR, based on our legitimate interests in operating and improving a secure subscription service. Where iOS asks for permission to use notifications, photos, the microphone or speech recognition, you can decline or later change that permission in iOS Settings.
5. Service Providers
We share data only where necessary to provide app functionality:
- STRATO AG and its sub-processors host the subscriber API and related data in Germany.
- Resend, Inc. and its sub-processors deliver one-time sign-in codes, double-opt-in confirmation emails and, when enabled, subscription editions by email.
- OpenAI and its sub-processors process inquiry questions, relevant conversation and story context, and optional image attachments to generate answers.
- Apple provides push notifications and, when you choose voice input, processes microphone audio through the Speech framework to return a transcription.
- Stripe maintains the subscription and payment records against which app eligibility is checked. Payment-card and bank-account details do not reach the app or our subscriber API.
We require service providers acting on our behalf to process personal data only for the relevant service and to provide protection consistent with this policy and applicable data-protection law.
6. International Transfers
Some service providers may process 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.
7. 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 are stored in app preferences. Recent editions are cached in Application Support so they remain available offline. Signing out removes the session and account details from the app. Deleting the app removes its locally stored preferences and cached content.
8. Retention
- One-time sign-in codes expire after 10 minutes.
- Authentication sessions are removed on sign-out, account deletion or when they are no longer valid.
- Your email-delivery preference and double-opt-in record are retained with the subscription account so the preference can be respected and a previously confirmed address does not need to be confirmed again solely because delivery was paused.
- Push tokens remain registered until they are unregistered on sign-out or account deletion, invalidated by Apple, or otherwise removed when no longer necessary.
- Inquiry conversations and associated feedback are retained for up to 90 days from the conversation's most recent activity, then deleted.
- 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.
- Technical server logs are normally rotated daily and retained for up to 14 days, unless longer retention is necessary for a security incident, legal obligation or legal claim.
9. Account Deletion
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, and it does not remove subscription, payment or referral-program records that remain necessary to administer your contract, honor lifetime eligibility, prevent fraud, meet legal obligations or resolve claims.
10. Analytics, Advertising and Tracking
The native iOS app contains no advertising, no analytics SDK and no cross-app tracking. We do not sell personal data or use app data to build advertising profiles. If you open our public website or a third-party source from the app, that website's own privacy practices apply.
11. Your Rights
Subject to applicable law, you may request access, correction, deletion, restriction or portability of your personal data, and you may object to processing based on legitimate interests. You may also lodge a complaint with a data-protection supervisory authority. To exercise your rights, contact help@thememo.am.
12. Supervisory Authority
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany
www.lda.bayern.de
13. Changes
We may update this policy when the app, its providers or legal requirements change. The current version and update date will always be published on this page.