Privacy Policy

1. Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Application refers to Memora 3D, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to the independent developer of Memora 3D, reachable at the address given in the "Contact Us" section. For the purposes of the GDPR, the Company is the Data Controller.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service, such as a cell phone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• GDPR refers to the EU General Data Protection Regulation.
• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, an online identifier, or one or more factors specific to Your identity.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on behalf of the Company, or to perform services related to the Service. For the purposes of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• You means the individual accessing or using the Service. Under GDPR, You can be referred to as the Data Subject or as the User.

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

Creating stickers does not require an account. If You choose to sign in — which is needed for 3D generation, purchases, and higher collection limits — We collect certain personally identifiable information that can be used to contact or identify You. This information may include:

• Email address, as provided by the sign-in provider You choose (Sign in with Apple or Google).
• A display name, taken from the name Your sign-in provider shares or otherwise derived from the part of Your email address before the "@".
• An account identifier, Your plan tier and its expiry date, account timestamps, and a record of credits granted and spent.
• Purchase records, as described in the "Purchases" part of this section.

Two notes worth knowing. If You use Apple's Hide My Email feature, We receive the private relay address Apple generates rather than Your personal email address. Accounts are matched by verified email address, so if Your Apple ID and Your Google account use different addresses, signing in with each will create two separate Accounts with separate credit balances.

Usage Data

The Application contains no analytics software and does not profile how You use it. However, when the Application communicates with our servers — to sign in, to generate a 3D model, or to verify a purchase — our hosting Service Provider records standard server logs, which may include Your Device's Internet Protocol address (e.g. IP address) and the date and time of the request. These logs are used for security monitoring, abuse prevention, and troubleshooting.

To keep the Service available to everyone, We also count how many 3D generations an Account has requested within a rolling period so We can apply fair-use limits.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from Your Device's camera and photo library. Camera access is used to photograph objects and turn them into stickers. Photo library access is add-only: it is used to save the stickers, exports, and AR photos that You explicitly choose to save. Importing an existing photo uses the system photo picker, which runs outside the Application and hands over only the image You select.

Images processed into stickers are handled entirely on Your Device and are stored on Your Device. An image is transmitted to Us only when You explicitly request a 3D model, as described in the "AI Processing" section. You can enable or disable access to this information at any time, through Your Device settings.

The Application does not request or collect location information.

Purchases

Subscriptions and credit packs are sold through the App Store. Payment is processed by Apple; We never receive or store Your payment card or bank details. To credit Your Account reliably and to prevent duplicate or fraudulent grants, We verify each purchase and store the transaction identifier, the product purchased, whether it was a subscription or a one-time purchase, the credits granted, the store environment, and the decoded receipt data provided by Apple or by our purchase-verification Service Provider. That receipt data may include purchase dates, price and currency, and the storefront country.

3. Data That Stays on Your Device

The core of Memora 3D works without an Account and without a network connection. The following data is created and stored locally, and We have no access to it:

• Stickers. Photos You capture or select are processed into stickers on Your iPhone using Apple's on-device frameworks. The resulting sticker images are stored in the Application's private storage.
• Suggested names. The name proposed for a sticker comes from an on-device classifier. No image leaves Your Device for this.
• Collections. Your boards and sticker layouts are stored in a local database on Your Device.
• 3D models. Generated models are downloaded to Your Device and kept there.
• Widgets and iMessage stickers. If You add a sticker to the iMessage keyboard or use the widgets, the Application copies the images into a shared container on Your Device that only the Application, its widget, and its iMessage extension can read. Neither the widget nor the iMessage extension makes any network request.

This data remains on Your Device — and in Your normal device backups — until You delete it or remove the Application.

4. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service for reliability and abuse prevention.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• To authenticate You and secure Your account: to verify Your identity and protect the security and integrity of the Service.
• To deliver the features You request: in particular, to generate a 3D model from an image You submit, and to grant, spend, and refund the credits associated with that request.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products or services You have purchased through the Service, including granting entitlements and honouring refunds.
• To contact You: to respond to You by email regarding support requests, or to send communications necessary or reasonable for the implementation of the Service, including security notices.
• To manage Your requests: to attend and manage Your requests to Us.
• To comply with legal obligations, and to establish, exercise, or defend legal claims.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us about our Service users is among the assets transferred.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to operate, secure, and deliver the Service — specifically for application hosting and databases, authentication, purchase verification, and the AI processing described below. Service Providers act on Our behalf and under contract, and are not permitted to use Your Personal Data for their own purposes.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

We do not sell Your Personal Data, and We do not share it with third parties for their own direct marketing purposes. The Service has no public areas and no social feed, so nothing You create is shared with other users unless You export it and share it Yourself.

5. AI Processing

Memora 3D uses automated and AI-powered systems to turn an image You have chosen into a three-dimensional model, and to suggest a name for a sticker.

Name suggestion runs entirely on Your Device. 3D generation does not: it requires computing power beyond a phone, and it happens only when You tap Generate and confirm the request. The Application tells You before You confirm that the image will be uploaded for processing, and it states the cost in credits.

To provide this feature, We process the image You selected — and the outline mask derived from it — using systems operated by Service Providers acting on Our behalf. When You confirm a generation:

• The image is transmitted to our server function, which passes it to the AI Service Provider in memory in order to fulfil Your request.
• We do not store Your image. It is not written to our database and not saved to any storage location under our control; there is no user-content storage in our infrastructure.
• Our database records only the generation task itself: Your account identifier, a task reference, the tier requested, the status of the task, and timestamps.
• The finished 3D model is downloaded to Your Device. If a generation fails, the credit is refunded automatically.

We do not use Your submitted content to train general-purpose AI models, and We require that Service Providers processing this content on Our behalf do not do so either.

6. No Advertising, Analytics, or Tracking

This section describes things the Service deliberately does not do:

• The Application contains no advertising and no advertising software.
• The Application contains no third-party analytics, attribution, or crash-reporting software.
• We do not track You across other companies' apps or websites, and We do not build advertising profiles or use device fingerprinting. The Application's privacy manifest declares no tracking and no tracking domains.
• We do not sell or rent Personal Data.

For App Store privacy-label purposes, the categories of data the Service can collect — photos or videos You choose to submit for 3D generation, email address, name, user ID, and purchase history — are used for app functionality only, and are linked to Your Account rather than used to track You.

7. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. Where possible, We apply shorter retention periods and reduce identifiability by deleting or anonymizing data.

We apply different retention periods to different categories of Personal Data:

• Account information (identifier, email address, display name, plan tier): retained for the duration of Your Account. It is deleted when You delete Your Account.
• Credit and generation records (credits granted and spent, generation task references and their status): retained for the duration of Your Account, so that balances and refunds remain auditable. They are deleted when You delete Your Account.
• Images submitted for 3D generation: not retained by Us at all. They are processed in transit and never stored in our systems. Handling by the AI Service Provider is governed by our contract with that provider and by its own retention practices.
• Purchase records: retained for the duration of Your Account and, where required, for as long as necessary to meet accounting, tax, and anti-fraud obligations, or to resolve chargebacks and disputes — even after an Account is deleted, where the law requires it.
• Server logs (including IP addresses and request timestamps): retained for a limited period for security monitoring and troubleshooting, in line with our hosting provider's log-retention schedule.

We may retain Personal Data beyond these periods where We are required by law to do so, where the data is necessary to establish, exercise, or defend legal claims, or where residual copies exist in encrypted backups that are scheduled for routine deletion. Backup copies are not restored except where necessary for security, disaster recovery, or legal compliance. You may request information about how long We will retain Your Personal Data by contacting Us.

8. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating location and in any other places where the parties involved in the processing are located. Our primary hosting infrastructure is located in the Asia-Pacific region, and Service Providers involved in authentication, purchase verification, and AI processing may operate in other countries, including the United States. This means Your information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place.

9. Delete Your Personal Data

You have the right to delete, or to request that We assist in deleting, the Personal Data that We have collected about You.

The Service gives You the ability to delete Your Account from within the Application: open the Profile tab and choose Delete Account. Deletion is immediate and permanent. It removes Your Account and its associated server-side records, including Your profile, Your credit history, Your purchase records, and Your generation task records. Any remaining credits are forfeited.

Stickers, 3D models, and collections stored on Your Device are not affected by Account deletion, because they were never held by Us; delete them in the Application or remove the Application to erase them. You can also sign out, or restore previous purchases, from the same screen.

You may also contact Us to request access to, correction of, or deletion of any Personal Data that You have provided to Us. Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

10. Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

11. Security of Your Personal Data

The security of Your Personal Data is important to Us. Data is transmitted over encrypted connections, sign-in credentials are handled by Apple and Google rather than by Us, Your session is stored in the Device keychain, and account records are protected by access rules that only permit an Account to read its own rows. Operations that grant credits or apply purchases run on the server, not in the Application.

Remember, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

12. GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes — for example, when You confirm a 3D generation, or grant camera or photo library access.
• Performance of a contract: provision of Personal Data is necessary for the performance of an agreement with You, such as maintaining Your Account, delivering purchased credits, and honouring subscriptions.
• Legal obligations: processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject, such as retaining transaction records.
• Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by the Company, such as securing the Service, preventing abuse and fraud, and troubleshooting faults.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ.

Where We transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses ("SCCs") and, as applicable, the UK International Data Transfer Agreement or the UK Addendum to the SCCs, together with supplementary measures such as encryption in transit and at rest, access controls, and data minimisation. You may contact Us to request further information about the safeguards We use for international transfers.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data, including a copy of the Personal Data We hold about You.
• Request correction of any incomplete or inaccurate information We hold about You.
• Request erasure of Your Personal Data where there is no good reason for Us to continue processing it. Account deletion is available directly in the Application.
• Request restriction of processing in certain circumstances, for example while We verify accuracy or consider an objection.
• Object to processing where We rely on a legitimate interest and something about Your particular situation makes You want to object.
• Request the transfer of Your Personal Data to You or to a third party in a structured, commonly used, machine-readable format.
• Withdraw Your consent at any time. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area, please contact Your local data protection authority.

13. "Do Not Track" Policy as Required by the California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals, because it does not track Your activity across websites or other companies' applications in the first place.

14. Children's Privacy

Our Service is not directed to children under the age of 13, and We do not knowingly collect Personal Data from children under 13. Creating stickers works without an Account and without sending anything to Us; creating an Account requires You to meet the minimum age set by Your sign-in provider and by the law of Your country.

If You are a parent or guardian and You believe that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from a child under 13 without verified parental consent, We will take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

15. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third party sites or services.

16. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy. Where the change is material, We will provide a more prominent notice before it becomes effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, You can contact us by email: support@memora3d.app.

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