Privacy Policy

1. Who we are

The Application is developed and operated by sollnho, acting as the data controller for the personal information described in this policy. If you have any questions or wish to exercise your privacy rights, contact us at concat.sollnho@gmail.com.

2. Information we collect

Information you provide

• Account information (optional). Registration is not required to use core features. If you sign in with Google, we receive the basic profile information associated with your Google Account (such as your email address and display name) through Google Sign‑In, so we can enable account‑based features and backup.
• Content you create. The journal entries, titles, tags, photos and other images, documents you scan, and the stories and ebooks you build. This content is stored on your device by default.
• Communications. Information you provide when you contact us for support.

Information collected automatically

• Device & usage data. Device model and type, unique device or app identifiers, operating system, IP address, and information about how you use the Application.
• Photo metadata. When you attach a photo, its capture time and any location embedded in the photo’s EXIF data may be recorded alongside your entry.
• Analytics & diagnostics. Aggregated usage analytics and crash reports that help us keep the Application stable and improve it.
• Advertising identifier. Your device’s advertising ID, used to serve ads (see Advertising).

3. Location information

With your permission, the Application collects your device’s approximate (coarse) and precise (fine) location to power location‑based features — for example, automatically tagging an entry with where it was written, showing your entries on a map, and finding entries near you. Location is only collected while you use these features and only after you grant the location permission.

You can decline the location permission, or revoke it at any time in your device settings. If you do, the location‑based features simply will not use your location; the rest of the Application continues to work. We do not use your precise location for advertising.

4. AI features

Some features use artificial intelligence — for example, extracting text from a document or photo (OCR) and other AI‑assisted writing tools. When you choose to use one of these features, the specific content you submit (such as the image or text you are processing) is sent over an encrypted connection to our backend and to Google’s Gemini API to generate the result, which is returned to you.

This processing happens only when you actively invoke an AI feature. The content is used solely to provide the requested feature; we do not use it to build advertising or marketing profiles. Google’s handling of API data is governed by the Gemini API Terms. AI output may be inaccurate — please review it before relying on it.

5. Cloud backup (Google Drive)

Backup is off by default. If you enable Google Drive backup, an exported copy of your app data is uploaded to your own Google Drive using the Drive authorization you grant. The Application accesses only the files it creates for backup; it does not read the rest of your Drive. Backups are stored under your Google Account and are subject to Google’s Privacy Policy. You can delete backups at any time from your Google Drive, and you can turn backup off in the Application.

6. How we use information & legal bases

We use the information above to operate and improve the Application. Where the EU/UK General Data Protection Regulation (GDPR) applies, we rely on the following legal bases:

Where we rely on consent, you may withdraw it at any time without affecting processing already carried out.

7. Advertising

Memorial’s free tier is supported by ads served through Google AdMob and, via mediation, Meta Audience Network. In regions that require consent (such as the EEA and the UK), we present Google’s consent form (User Messaging Platform) before serving ads:

• If you consent, we may show personalized ads using your device’s advertising identifier.
• If you decline, you receive non‑personalized ads.

You can reset or delete your advertising identifier, and limit ad tracking, in your device settings, and you can revisit your ad‑consent choices in the Application. Premium (subscription) users may see fewer or no ads depending on the plan.

8. Third‑party services

The Application relies on third‑party services that have their own privacy policies for how they handle data:

• Google Play services
• Google AdMob
• Meta Audience Network (Meta Platforms)
• Google Analytics for Firebase
• Firebase Crashlytics
• Google Gemini API
• Google Drive API

9. Sharing & disclosure

We do not sell your personal information. We may share information only in these limited ways:

• Service providers. Trusted providers (such as the third parties above) that process data on our behalf and are bound to protect it and use it only for the services they provide to us.
• Aggregated / anonymized data. Data that no longer identifies you may be shared to analyze and improve the Application.
• Legal & safety. When required by law (for example, a subpoena or similar legal process), or when we reasonably believe disclosure is necessary to protect rights, safety, investigate fraud, or respond to a lawful government request.

10. International data transfers

Our backend and the third‑party services we use (including Google Cloud / Firebase, primarily in the United States) may process your information in countries other than your own. Where required, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses for transfers outside the EEA/UK.

11. Data retention

We keep content you create for as long as it remains on your device or in your enabled backup, and for a reasonable period thereafter if held by us. Automatically collected information is retained for up to 24 months and thereafter may be kept in aggregate form. Backups stored in your Google Drive remain until you delete them. When you ask us to delete your data, we do so within a reasonable time, except where retention is required by law.

12. Your privacy rights

Depending on where you live, you may have the right to:

• access the personal information we hold about you;
• correct inaccurate information;
• delete your information (“right to be forgotten”);
• restrict or object to certain processing;
• receive your information in a portable format;
• withdraw consent at any time; and
• lodge a complaint with your local data protection authority.

To exercise any of these rights, email us at concat.sollnho@gmail.com. We will respond within the timeframe required by applicable law.

13. California privacy rights

If you are a California resident, the CCPA/CPRA gives you the right to know what personal information we collect, to delete it, to correct it, and to opt out of its “sale” or “sharing”. Over the past 12 months we may have collected these categories: identifiers (e.g. device/advertising IDs, email if you sign in), internet or app activity, approximate/precise geolocation (with consent), your user content, and inferences used to improve the app.

We do not sell your personal information for money. To the extent that showing personalized ads is considered “sharing” under California law, you can opt out by declining ad personalization in the consent prompt or by resetting your advertising identifier in device settings. We do not discriminate against you for exercising your rights.

14. Deleting your account & data

You control your data and can remove it in several ways:

• Individual entries. Delete any entry, photo or story directly in the Application.
• All on‑device data. Clear the app’s storage in your device settings, or uninstall the Application.
• Backups. Delete backup files from your Google Drive and turn backup off.
• Full account & server‑side deletion. To request deletion of your account and any associated data held by us, email concat.sollnho@gmail.com with the subject “Delete my data”. We will verify your request and delete the data within a reasonable time, except where we must retain it for legal reasons.

15. Children’s privacy

The Application is not directed to children. We do not knowingly collect personal information from children under 13 (or under 16 in the EEA, or the minimum age required by your country). If you believe a child has provided us with personal information, contact us at concat.sollnho@gmail.com and we will delete it.

16. Security

We use physical, electronic and procedural safeguards to protect your information, including encryption in transit and access controls, and you can lock the Application with a fingerprint or PIN. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

17. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the “Last updated” date above; for material changes we will provide a more prominent notice where appropriate. Your continued use of the Application after an update means you accept the revised policy.

18. Contact us

If you have questions about this policy or how we handle your information, contact the Service Provider at concat.sollnho@gmail.com.

Memorial is a product of sollnho. This policy is available in English; localized versions may be provided for convenience, with the English version controlling in case of any conflict.