This privacy policy (“Privacy Policy” or “Policy”) applies to www.memoraprivacy.com, the Memora App, and Gollum AI LLC (“Company”, “we”, “us”, “our”), and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to the Company, app, site, website, or Company website mean www.memoraprivacy.com, the Memora App, and Gollum AI LLC. By using the Company website, you consent to the data practices described in this Privacy Policy.

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Collection of your Personal Information

In order to better provide you with the services offered, Company may collect personally identifiable information, which falls into categories such as identifiers and customer records information. These include: (i) first and last name, (ii) mailing address, (iii) billing address, (iv) e-mail address, (v) phone number; (vi) voice recordings, and (vii) information from documents you choose to upload such as resumes and other personal documents.

Except as otherwise stated in this Policy, Company does not collect any personal information about you unless you voluntarily provide it to Company. However, you may be required to provide certain personal information to Company when you elect to use certain services. Company also may gather additional personal or non-personal information about you from third parties including, but not limited to, publicly available sources, third-party data providers, and business partners. Any information Company obtains from third parties will be treated in accordance with this Privacy Policy.

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Use of your Personal Information

Company collects and uses your personal information to operate and deliver the services you have requested. This includes using your contact information for account management and billing purposes, processing your voice recordings to provide transcription and speaker identification services, and utilizing uploaded documents to personalize your experience and enhance service accuracy. Company may also use your personal information for communicating with you in relation to services you have requested from Company, inform you of other services available from Company, and for marketing communications.

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Personal Information in Transcribed Content

Company’s services involve transcribing audio conversations which may incidentally contain personal information spoken by users. This incidentally captured information is not collected or used by Company as personal information and is only processed as part of delivering our transcription services.

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Sharing Information with Third Parties

Company does not sell, rent, or lease your data to third parties. However, Company shares your personal information with third parties to deliver targeted advertisements, further detailed in the Third-Party Advertising Technologies Section of this Policy. This includes using tracking technologies such as cookies to collect data about your interactions and browsing behavior for advertising purposes. You have the right to direct us to stop sharing your personal information for targeted advertising at any time. To exercise this right, please follow the procedure outlined in the Privacy Rights Section of this Policy. Company may also share personal information and non-personal data with trusted service providers and partners who assist in operating our website, conducting our business, or providing services to you. This includes our website hosting provider, email service provider, form collection services, analytics services, customer support platforms, cloud storage services, artificial intelligence and machine learning service providers for generating content summaries, as well as other third parties who perform services on Company’s behalf, business partners, and affiliates. The use of your data by such third parties will be subject to their privacy policy.

Company may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with legal process served on Company, (ii) protect and defend the rights or property of Company, and/or (iii) act under exigent circumstances to protect the personal safety of Company, or the public.

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Calendar Integration

The Google Calendar integration API is used to retrieve upcoming meeting information and automatically record meetings from the user’s Google Calendar. Memora fully complies with the Google API Services User Data Policy, including the Limited Use requirements. Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

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Automatically Collected Information

Information about your computer hardware and software may be automatically collected by Company. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the website, to maintain quality of the website, and to provide general statistics regarding use of the Company website.

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Use of Cookies

The Company website uses “cookies” to enhance and personalize your online experience. A cookie is a text file placed on your hard disk by a web page server. Cookies cannot run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. Company uses three main types of cookies:

  • Essential/Functional Cookies: These are necessary for the website to function properly. They enable basic functions like page navigation, secure access to protected areas, and remembering your preferences. For example, these cookies allow Company to recall your specific information on subsequent visits, simplifying the process of recording personal information like billing and shipping addresses.
  • Analytics Cookies: These help Company understand how visitors interact with Company website by collecting and reporting information anonymously. They assist Company in improving our website and enhancing user experience.
  • Third-Party Advertising Cookies: These are used by our advertising partners to deliver targeted advertisements.

You have the ability to accept or decline cookies through your browser settings. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline them if you prefer. However, if you choose to decline cookies, especially essential ones, you may not be able to fully experience the interactive features of the Company website.

Company website does not currently respond to “Do Not Track” (DNT) signals or other similar mechanisms. You can choose to enable or disable the DNT setting in your web browser, which will communicate your DNT preference to websites you visit. However, please note that enabling DNT may not affect the collection of usage and other data by Company website.

Company has also integrated Google Analytics with Company website to better understand how users interact with Company website and to improve search engine optimization (SEO). Google Analytics uses cookies to collect data such as user demographics, behavior on the site, and other engagement metrics. For more information about how Google uses your data, you can visit https://www.google.com/analytics/terms/us.html. To opt out of Google Analytics tracking, you can visit https://tools.google.com/dlpage/gaoptout/ and download the Google Analytics Opt-out Browser Add-on.

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Third-Party Advertising Technologies

Company uses various third-party advertising technologies to deliver targeted advertisements. These technologies may use cookies and similar tracking mechanisms to collect data about your interactions and browsing behavior. The opt-out instructions and steps may change as our advertising partners update their platforms. While we strive to maintain accurate opt-out instructions, we cannot guarantee their accuracy at all times. Our advertising partners include:

  • Google Ads: We use Google Ads to serve targeted advertisements to users both on our website and across the Google Display Network. If you wish to opt out of personalized advertisements served by Google, you can manage your preferences by visiting Google’s Ad Settings page: https://myadcenter.google.com/personalizationoff.
  • Meta Pixel (Facebook Pixel): We utilize Meta Pixel to gather data for marketing and advertising on both Facebook and Instagram platforms. This tool collects various data points, such as user interactions and browsing behaviors, to deliver targeted advertisements. To manage or opt out of data collection for ad personalization on Facebook, you can: 1) Click on your profile picture in the top right of Facebook; 2) Select “Settings & Privacy”, then click “Settings”; 3) Click “Accounts Center” in the left menu; and 4) Click “Ad Preferences”.
  • TikTok: We utilize TikTok’s advanced advertising technologies, including the TikTok Pixel, to deliver targeted advertisements and optimize ad performance. This involves a comprehensive integration of TikTok Pixel, Events API, Advanced Matching, Shopify APIs, and other up-to-date technologies provided by TikTok. This integration allows for the collection and sharing of extensive customer information to enhance ad targeting and reach. To manage or opt out of this data collection for ad personalization on TikTok, please: 1) Visit your Profile; 2) Tap the three dots in the top right corner to access “Settings and Privacy”; 3) Navigate to “Privacy”, select “Ad Preferences”, and 4) Adjust your ad personalization settings accordingly.
  • Twitter/X: We also use Twitter for advertising and promotional activities. Our website incorporates Twitter functionalities, which may collect certain information such as your interactions and usage metrics. If you wish to opt out of personalized advertisements or data collection through Twitter, you can follow the instructions provided at: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
  • LinkedIn: We use LinkedIn’s advertising tools for professional network advertising. To manage your ad preferences on LinkedIn: 1) Click on your profile icon; 2) Select “Settings & Privacy”; 3) Under “Data privacy”, click on “Manage cookie preferences”; and 4) Adjust your settings for personalized advertising.
  • Reddit: We use Reddit’s advertising platform to reach Reddit users. To opt out of personalized advertising on Reddit: visit https://www.reddit.com/personalization for direct access to ad personalization settings.

This website may contain links to other sites. Please be aware that Company is not responsible for the content or privacy practices of such other sites. Company encourages you to be aware when you leave Company website and to read the privacy statements of any other site that collects personally identifiable information.

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Security of your Personal Information

Company takes industry-standard security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while Company strives to protect your personal information, you acknowledge that: (i) there are security and privacy limitations inherent to the internet which are beyond Company’s control, and (ii) security, integrity, and privacy of any and all information and data exchanged between you and Company through the website cannot be guaranteed. In the event of a data breach that affects your personal information, Company will notify you in accordance with applicable laws.

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Data Storage and Retention

Company retains your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. As a United States-based company located in Delaware, Company stores your data either locally on your device or in secure cloud infrastructure located within the United States. For users outside the United States, using our services involves transferring data to the U.S. where it will be processed and stored. We implement appropriate safeguards including encryption of data in transit and at rest, access controls, security monitoring, and staff training. Access to production data is strictly controlled and limited only to authorized personnel who require access for essential business purposes, such as development and support. You have control over your data and can delete it at any time through the app interface. To determine the appropriate retention period for personal information, Company considers the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which Company processes your personal information, and whether those purposes can be achieved through other means, as well as applicable legal requirements. After this period, your personal information will be securely deleted or anonymized so that it can no longer be associated with you, unless the law allows or requires Company to preserve certain information, including in the context of an ongoing or anticipated legal proceeding.

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Right to Deletion

Subject to certain exceptions (some of which are set out below), on receipt of a verifiable request from you, Company will: (i) delete your personal information from Company records, and (ii) direct any service providers to delete your personal information from their records.

Please note that Company may not be able to comply with requests to delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of Company’s ongoing business relationship with you, or otherwise perform a contract between you and Company, (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity, (iii) debug to identify and repair errors that impair existing intended functionality, or (iv) comply with an existing legal obligation.

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Sensitive Personal Information

Company does not intentionally collect sensitive personal information through its website. However, due to the nature of our audio recording and transcription services, sensitive personal information may be incidentally captured in recorded conversations. Users should exercise caution when recording conversations containing sensitive information such as health data, government identifiers, or other confidential details. Any such incidentally captured information is processed solely to provide our transcription services and can be managed through the app’s retention and deletion controls. If Company’s practices regarding sensitive information change, this Privacy Policy will be updated accordingly.

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Children’s Privacy

Our services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from anyone under 13 years of age. If you are under 13, please do not attempt to register for or otherwise use our services or send any personal information about yourself to us.

If we learn that we have collected personal information from someone under 13 years of age, we will take steps to delete that information as quickly as possible. Parents or legal guardians who believe that a minor under 13 may have provided us with personal information should contact us immediately per the information provided in the Contact Information Section at the end of this Policy.

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Your Privacy Rights

Depending on your location, you may be entitled to certain rights regarding your personal information. These may include:

  • Right to Know: You may have the right to request information about the personal information we collect, use, disclose, or sell.
  • Right to Access: You may have the right to request access to your personal information in a portable format.
  • Right to Delete: You may have the right to request deletion of your personal information, subject to certain exceptions.
  • Right to Correct: You may have the right to request correction of inaccurate personal information.
  • Right to Limit the Use of Sensitive Personal Information: Under applicable laws, you may have the right to limit the use and disclosure of your sensitive personal information. This includes data like financial account details, precise geolocation, and other sensitive categories defined by law. You may request that we limit the use of this information to the purposes necessary to provide the services you have requested. Currently, we do not collect sensitive personal information through our website.
  • Right to Opt-Out: You may have the right to opt-out of the sale or sharing of your personal information.
  • Right to Opt-Out of Automated Decision-Making: You may have the right to opt-out of decisions based solely on automated processing of your personal information, including profiling, which could significantly affect you.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, you or your authorized agent can submit a verifiable consumer request by contacting us via the information provided in the Contact Information Section at the end of this Policy. We will respond to verifiable requests within 30 days, unless we notify you that we require additional time. If we deny your request, you have the right to appeal our decision. To submit an appeal, please contact us using the same method you used for your initial request, clearly stating that you wish to appeal our decision. We will respond to your appeal within 30 days. Please note that these rights are not absolute and may be subject to limitations or exceptions under applicable law.

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Changes to this Privacy Policy

Company reserves the right to change this Privacy Policy from time to time. Company will notify you about changes in the way Company treats personal information by updating this Privacy Policy on the website and by making reasonable efforts to notify you based on the significance of the scope and impact of the change. Your continued use of the website and/or services available after such modifications will constitute your acknowledgment of the modified privacy policy and your agreement to abide and be bound by that policy.

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Contact Information

Company welcomes your questions or comments regarding this Privacy Policy. Please contact Company at:

Gollum AI LLC

1111B S Governors Ave STE 26713, Dover, DE 19904

legal@memoraprivacy.com

Last updated: January 18, 2025