Last updated: 29/7-2025

We welcome you to MemoChat, our website at www.memochat.net and/or our iOS and Android Mobile application (collectively our "Platform"). In the below Privacy Policy, we inform you about the scope of the processing of your Personal Data. MemoChat proceeds with all data processing procedures (e.g., collection, processing, and transmission) in accordance with Estonia's Personal Data Protection Act and the EU's General Data Protection Regulation ("GDPR").

Responsible for data processing
Responsible for data processing in accordance with the provisions of Estonian law and GDPR is:

AnimaTech OÜ
Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145, Estonia

Web: www.memochat.net
E-Mail: info@memochat.net

The Supervisory Authority
The competent data protection authority in Estonia is:
Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Tatari 39, 10134 Tallinn, Estonia
Web: https://www.aki.ee

In the course of our business and platform operations, we process data, and this data is generally transferred to our Amazon Web Services (AWS) server and we also use AWS for the provision of our website.

All Personal Data that we obtain from you via the platform will only be processed for the purposes described in more detail below. This is done within the framework of the respective legal regulations mentioned or only with your consent. In particular, Estonian law and GDPR specify when data processing is permitted. MemoChat collects Personal Data if:

You have given your consent,
The data is necessary for the fulfillment of a contract / pre-contractual measures,
The data is necessary for the fulfillment of a legal obligation or
The data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

MemoChat processes and stores your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular Estonian commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

a) Collection of access data and log files
We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.

b) Use of cookies
To improve the services provided on the website, we use cookies that collect information about your usage behavior. Cookies are files that your web browser stores on your hard drive when you visit a website. Cookies may, under certain circumstances, personally identify you either directly (for example, with an e-mail address) or indirectly (for example, with a unique identification code of a cookie, an IP address or the identification code of a device). The data stored may include the pages you visit, the date and time of your visit, and other tracking information. For more information, please refer to our Cookie Policy.

c) Downloading the APP
The APP can be downloaded from the "Google Playstore" a service offered by Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service "App Store" a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

d) Installing the APP
As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which Personal Data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

e) Device information
Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

f) Firebase
We use the Google Firebase developer platform and related features and services provided by Google LLC and Google Ireland Limited for push notifications and analytics. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase developer platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy
Firebase logs are retained for 90 days and include anonymized device identifiers, Firebase tokens, and user engagement data (e.g., message read and delivery status).

a) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations (Art. 6 para. 1 lit. b GDPR) and/or our overriding legitimate interest in processing your request (Art. 6 para. 1 lit. f GDPR).

b) Profile and account
If you create a user account, you will receive a unique ID from us and you are required to provide a username, nickname, and public ID. You may optionally add a profile photo. This allows us to identify you as a user and gives you the opportunity to manage your account, use our services. Within your profile you are able to delete your account at any time. Your data will be processed on the basis of contractual necessity (Art. 6 para. 1 lit. b GDPR) and your consent (Art. 6 para. 1 lit. a GDPR).

c) When using our services
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. The required information is identified as such in the context of the information required for the provision of services.

Of course, in the course of operating the Services, we also process your chats with other users and the content you transmit.

Our Security Model:

Text Messages: Encrypted using AES-256-CBC with salt on our servers (server-side encryption). Messages are encrypted when stored and decrypted when retrieved by users.

Files and Audio Messages: Encrypted on your device before upload using unique per-chat encryption keys. We cannot decrypt these files as the encryption occurs client-side before reaching our servers.
Data in Transit: All communications are secured using HTTPS/TLS encryption.

Some of the Personal Data you provide may be considered "special" or "sensitive". This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

You have choices about the Personal Data you upload and share. You don't have to provide Personal Data; however, Personal Data helps you to get more from our Services. It's your choice whether to include special category data and to make that special category data public. Please do not upload or add data that you would not want to be available.

The legal basis for the processing of your personal and special category data is the establishment and implementation of the user contract for the use of the service as well as your consent. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.

You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing to info@memochat.net.

The legal basis for the data processing is the fulfillment of our contractual obligations (Art. 6 para. 1 lit. b GDPR) and, in individual cases, the fulfillment of our legal obligations (Art. 6 para. 1 lit. c GDPR) as well as your Consent (Art. 6 para. 1 lit. a GDPR).

We only store Personal Data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.

Specific retention periods:
Account Data: Retained until you delete your account, at which point personal data is anonymized
Message Data: Retained based on user settings, with options for 24-hour deletion, 1-week deletion, 1-month deletion, or longer retention for active accounts. All message data is deleted upon account deletion
Log and Usage Data: Retained for up to 12 months to aid performance and troubleshoot issues
Push Notification Tokens: Expire with the session or upon logout

You are not obliged to provide us with Personal Data. However, depending on the individual case as described above, the provision of certain Personal Data may be necessary for the provision of the services. If you do not provide us with this Personal Data, we may not be able to provide the requested service.

We do not sell data to third parties.

We may request permission to store your APP data including your Internet Connection and Network, Camera, Audio, Video, Photos and Gallery of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.

When you use the app, you will receive so-called push messages from us, even if you are not currently using the App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.

We will not disclose or otherwise distribute your Personal Data to third parties unless this:

Is necessary for the performance of our services,
You have consented to the disclosure, or
The disclosure of data is permitted by relevant legal provisions.

However, we are entitled to outsource the processing of your Personal Data in whole or in part to external service providers acting as processors within the framework of Estonian law and GDPR. External service providers support us, for example, in the technical operation and support of the platform, data management, the provision and performance of services, marketing, as well as the implementation and fulfillment of reporting obligations.

Our main third-party partners include:
Firebase (Google LLC) for notifications and user engagement analytics
Amazon Web Services (AWS) for secure server hosting
Synervoz SDK for enhanced communication features

These providers may process data outside the EU. We implement appropriate safeguards, including Standard Contractual Clauses (SCCs), to ensure GDPR compliance.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with Estonian law and the GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place at MemoChat.

Every data subject has:

The right to information according to Art. 15 GDPR,
The right to rectification according to Art. 16 GDPR,
The right to deletion according to Art. 17 GDPR,
The right to restriction of processing pursuant to Art. 18 GDPR, and
The right to data portability under Art. 20 GDPR.

Further, you can revoke consent, in principle with effect for the future.

Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). We would, however, appreciate the chance to deal with your concerns before you approach a data protection supervisory authority.

Finally, you also have a right to object according to Art. 21 GDPR. This applies, on grounds relating to data processing on the basis of my legitimate interest and also to profiling.

If you object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate reasons for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject.

State-of-the-art internet technologies are used to ensure the security of your data. We employ robust measures to protect your data:

Hybrid Encryption Model:
Text Messages: Server-side encryption (SSE) using AES-256-CBC with salt. Each message is encrypted differently using unique salt values.

Files and Audio Messages: Client-side encryption with per-chat keys before S3 upload. We cannot decrypt these files as encryption occurs on your device.

Data in Transit: HTTPS/TLS encryption for all communications.

Data Fragmentation: S3 file encryption and segmentation for enhanced data security.

For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the Personal Data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your account or by contacting us using info@memochat.net.

You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all purposes by submitting your request to us using info@memochat.net.

Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

We kindly ask you to regularly inform yourself about the content of our Privacy Policy. We will amend our Privacy Policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us using info@memochat.net.
 

Last updated: 29/7-2025

These Terms of Service and End User License Agreement (the "Terms") apply to any registered user (the "Registered User") who access and/or use MemoChat ("you") and govern our mutual rights and obligations arising from the using MemoChat and provision of the services. By using MemoChat you enter into an agreement on provision of the services with MemoChat of AnimaTech OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145, Estonia ("MemoChat", "we", "us" or "our") (the "Agreement").

Your access to MemoChat and using our services are conditioned by acceptance of and compliance with these Terms and our Privacy Policy. By accessing or using MemoChat you accept these Terms and agree to be bound by them. If you disagree with any part of the Terms, you may not use MemoChat.

We are constantly trying to improve MemoChat and our services, so these Terms may need to change along with updates and services. We reserve the right to change the Terms at any time, but if we do, we will bring it to your attention by placing a notice on MemoChat. If you don't agree with the new Terms, you are free to reject them; unfortunately, that means you will no longer be able to use MemoChat or our services. If you use MemoChat and our services in any way after a change to the Terms is effective, that means you agree to all of the changes.

AnimaTech OÜ
Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145, Estonia
Email: info@memochat.net

Please note that MemoChat is designed for users 13 years old and over ("Minimum Age"). By using MemoChat, you confirm that you are at least the Minimum Age or have valid parental or legal guardian consent where required by law. If you are located in the European Union, parental consent is required if you are under 16 years old. We take no responsibility if your age confirmation is not true. If you believe that a child under the Minimum Age may have provided us Personal Data, please contact us at info@memochat.net.

MemoChat provides a secure, private and an easy way to stay in touch with your friends and family without the worry of your personal information being shared. MemoChat is accessible via our Android and iOS Mobile Applications.

We reserve the right to modify, terminate or otherwise amend our offered services and any promotional offerings at any time in accordance with these Terms.

Basic version of MemoChat is a free version where no payment is required, and you can access our services once your User Account is activated.

Your use of MemoChat requires that you have hardware, software and an internet connection fulfilling certain recommended requirements. If the recommended requirements are not met, you may potentially still use our service, but normally with a lower quality or performance. Such reduced quality or performance will not give you the right to claim any compensation from MemoChat.

MemoChat may not be always accessible due to the planned maintenance and updates of our software. If possible, we will inform you about such maintenance in advance, on our website or via MemoChat interface.

The following terms apply when you use our APP obtained from either the Apple's, or Google's store (each an "App Distributor") to access our APP:

The License granted to you for our APP is limited to a non-transferable License to use our APP on a device that utilizes the Apple iOS or Google operating systems, as applicable, and in accordance with the usage rules set forth in the applicable App Distributor's terms of service;
We are responsible for providing any maintenance and support services with respect to the APP as specified in the terms and conditions of this License or as otherwise required under applicable law, and you acknowledge that each App Distributor has no obligation whatsoever to furnish any maintenance and support services with respect to the APP;
You must comply with applicable third-party terms of agreement when using the APP;
You acknowledge and agree that the App Distributors are third-party beneficiaries of the terms and conditions in this License, and that each App Distributor will have the right (and will be deemed to have accepted the right) to enforce the terms and conditions in this License against you as a third-party beneficiary thereof.

To use certain parts of our service, you will need to create the MemoChat Account. You may register MemoChat account by following the instructions in our APP or other instructions prompted to you. You are responsible for safeguarding your account information. We will not be liable for any loss or damage arising from your failure to comply with the above requirements.

Your MemoChat Account is strictly personal and shall not be used by any other person without your supervision. Neither shall you assign your account to any other person. You are in any event solely responsible for the use of MemoChat and our service through your MemoChat Account.

We may change, terminate, or restrict access to any aspect of MemoChat, our service or your MemoChat Account, at any time, without notice. We reserve the right to impose limitations of use based on what we consider fair or legitimate usage,

You acknowledge that your MemoChat Account can be inaccessible for a limited period of time due to the necessary hardware and/or software maintenance of the server or in cases of temporary server shutdown.

You are responsible for your use of MemoChat, including the lawfulness of any content displayed, shared, uploaded or otherwise made available by you while using MemoChat (the "User Content"). User Content includes, for example, chat names. You are responsible for ensuring that your chat names do not include Prohibited User Content (as listed below).

Any use or reliance on any User Content or materials posted via MemoChat or obtained by you through MemoChat is at your own risk. We do not endorse, support, represent or guarantee the completeness, truthfulness, accuracy, or reliability of any User Content or communications posted via MemoChat or endorse any opinions expressed via MemoChat. You understand that by using MemoChat and our service, you may be exposed to User Content that might be offensive, harmful, inaccurate or otherwise inappropriate, or in some cases, User Content that has been mislabeled or is otherwise deceptive. Under no circumstances will we be liable in any way for any User Content, including, but not limited to, any errors or omissions in any User Content, or any loss or damage of any kind incurred as a result of the use of any User Content generated or made available via MemoChat.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public.

We reserve the right to report any illegal or suspicious activity to applicable local authorities.

Prohibited User Content includes, without limitation, a content which:

We reserve the right to edit or remove any User Content uploaded or posted through MemoChat if, in our opinion, such User Content does not comply with these Terms.

 

Intellectual property rights associated with MemoChat, and its contents are our sole property or our affiliates. We reserve all rights to our intellectual property rights which are contained in, published at and/or provided through MemoChat. We are the exclusive and unlimited owner of all the economic and, to the maximum extent possible and permitted by respective laws, moral rights to MemoChat. The APP is protected by copyright.

MemoChat is not, in any case, transferred, assigned, sold or leased to you, and we retain ownership of MemoChat even after installation on your personal devices.

You may not copy, reproduce, modify, lease, loan, sell, create derivative works from, upload, transmit, or distribute the intellectual property rights to MemoChat in any way.

All our trademarks, business names, logos, domain names, and any other our features and brand are our sole property. We do not grant you any rights to use any of our brands whether for commercial or non-commercial use.

We grant you limited, non-exclusive, revocable right to use MemoChat in the extent of the functionalities of the respective MemoChat version you have been registered for (the "License"). You are not entitled to grant any sublicence or assign this License to any third person. The License shall remain in effect until the termination of the Agreement and provision of our services.

Any graphics, data, articles, photos, images, illustrations, texts and other content displayed or available on or through MemoChat are protected by copyright and/or other intellectual property laws. You must abide by all copyright notices, trademark rules, information, and restrictions contained in any content you access through MemoChat, and you won't use, copy, reproduce, modify, translate, publish, broadcast, transmit, distribute, perform, upload, display, license, sell or otherwise exploit for any purpose any content not owned by you, without the prior consent of the owner of that content or another authorization.

We provide you with our services and MemoChat "as is". You acknowledge that MemoChat and our services are not error-free. You use it at your own risk and discretion. That means MemoChat and our services don't come with any warranty. We make no warranties, expressed or implied, with respect to the availability, merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, performance and quality of MemoChat or our service.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

Use of, or inability to use MemoChat;
Use of or reliance on any User Content displayed on MemoChat;
The correctness and completeness of the information provided by you to any other MemoChat user;
The User Content provided and/or published by the users through MemoChat and for the possible breach of the third party right by using, providing and/or publishing the User Content through MemoChat;
Any malfunction and non-accessibility of MemoChat caused by the force majeure, e.g. third-party acting, hacker-attacks, software or hardware failure;
Any claims between the users.

If you are a business entity or entrepreneur, please note that in particular, we will not be liable for:

Loss of profits, sales, business, or revenue;
Business interruption;
Loss of anticipated savings;
Loss of business opportunity, goodwill or reputation; or
Any indirect or consequential loss or damage.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your device, computer equipment, computer programs, data or other proprietary material due to your use of MemoChat or to your downloading of any content on it, or on any website linked to it.

To the fullest extent allowed by applicable law, you agree to indemnify and hold us, our affiliates, officers, agents, employees, and partners harmless from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys' fees) arising from or in any way related to any third party claims relating to (i) your use of MemoChat and our service (including any actions taken by a third party using your MemoChat Account), and (ii) your violation of these Terms.

In case there is a technical issue or you have a complaint regarding any part of our services you must notify us about such issue or complaint and we will consequently investigate circumstances of described problem and inform you about the result of it and about the steps we will take.

You may notify us through e-mail address: info@memochat.net. We will do our best to respond to your complaint within 30 days after we receive such a complaint. You are not entitled to be reimbursed for any costs related to the complaint.

You are responsible for all data-related charges that you may incur for using our APP, including, without limitation, mobile, text-messaging, and data charges. You should understand or ask your service provider what charges you may incur before using the APP.

You take into account that we process your personal data for the purpose of providing you with our services and access to MemoChat under the applicable laws related to processing and protection of personal data. Further details regarding processing of Personal Data can be found in our Privacy Policy, which is available at https://memochat.net/privacy/.

Agreement is entered into for an indefinite period of time.

You are free to terminate the Agreement at any time, by contacting us at info@memochat.net; please refer to our Privacy Policy, as well as the licenses above, to understand how we treat information you provide to us after you have stopped using our services.

We are also free to terminate (or suspend access to) your use of MemoChat and our services or your MemoChat Account, for any reason in our discretion, including your breach of these Terms. We have the sole right to decide whether you are in violation of any of the restrictions set forth in these Terms.

MemoChat Account termination may result in destruction of any User Content associated with your MemoChat Account, so keep that in mind before you decide to terminate your MemoChat Account. We will try to provide you with an advance notice prior to our terminating your MemoChat Account so that you are able to retrieve any important User Content you may have stored in your MemoChat Account (to the extent allowed by law and these Terms), but we may not do so if we determine it would be impractical, illegal, not in the interest of someone's safety or security, or otherwise harmful to our rights or property.

If you have deleted your MemoChat Account by mistake, contact us immediately at info@memochat.net – we will try to help, but unfortunately, we can't promise that we can recover or restore anything.

Provisions that, by their nature, should survive termination of these Terms shall survive the termination. By way of example, all of the following will survive termination: any obligation you have to pay us or indemnify us, any limitations on our liability, any terms regarding our ownership or intellectual property rights, and terms regarding disputes between us.

In the event that any party to these Terms fails to exercise any right or remedy contained herein, this shall not be construed as a waiver of that right or remedy.

Previous Terms and Conditions
In the event of any conflict between these Terms and any prior versions thereof, the provisions of these Terms shall prevail unless it is expressly stated otherwise.

Every effort has been made to ensure that these Terms adhere strictly with the relevant provisions of applicable consumer protection legislation. However, in the event that any of these terms are found to be unlawful, invalid or otherwise unenforceable, that term is to be deemed severed from these Terms and shall not affect the validity and enforceability of the remaining terms and conditions.

In the event of a dispute arising under these Terms, the parties agree to attempt resolution through good faith negotiation or mediation before pursuing formal legal action. This does not prevent either party from seeking urgent interim relief from a court of competent jurisdiction when necessary.

These Terms and the relationship between you and MemoChat shall be governed by and construed in accordance with the Law of Estonia and MemoChat and you agree to submit to the exclusive jurisdiction of the Courts of Tallinn.