Privacy Policy
PRIVACY
NOTICE
Last
updated
October
13,
2022
This
privacy
notice
for
Memento
Languages
LLC
(doing
business
as
Memento
Japanese)
("Memento
Japanese,"
"we,"
"us,"
or
"our"),
describes
how
and
why
we
might
collect,
store,
use,
and/or
share
("process")
your
information
when
you
use
our
services
("Services"),
such
as
when
you:
Download
and
use
our
mobile
application
(Memento
Japanese),
or
any
other
application
of
ours
that
links
to
this
privacy
notice
Engage
with
us
in
other
related
ways,
including
any
sales,
marketing,
or
events
Questions
or
concerns?
Reading
this
privacy
notice
will
help
you
understand
your
privacy
rights
and
choices.
If
you
do
not
agree
with
our
policies
and
practices,
please
do
not
use
our
Services.
If
you
still
have
any
questions
or
concerns,
please
contact
us
at
Info@mementolanguages.com.
SUMMARY
OF
KEY
POINTS
This
summary
provides
key
points
from
our
privacy
notice,
but
you
can
find
out
more
details
about
any
of
these
topics
by
clicking
the
link
following
each
key
point
or
by
using
our
table
of
contents
below
to
find
the
section
you
are
looking
for.
You
can
also
click
here
to
go
directly
to
our
table
of
contents.
What
personal
information
do
we
process?
When
you
visit,
use,
or
navigate
our
Services,
we
may
process
personal
information
depending
on
how
you
interact
with
Memento
Japanese
and
the
Services,
the
choices
you
make,
and
the
products
and
features
you
use.
Click
here
to
learn
more.
Do
we
process
any
sensitive
personal
information?
We
do
not
process
sensitive
personal
information.
Do
we
receive
any
information
from
third
parties?
We
do
not
receive
any
information
from
third
parties.
How
do
we
process
your
information?
We
process
your
information
to
provide,
improve,
and
administer
our
Services,
communicate
with
you,
for
security
and
fraud
prevention,
and
to
comply
with
law.
We
may
also
process
your
information
for
other
purposes
with
your
consent.
We
process
your
information
only
when
we
have
a
valid
legal
reason
to
do
so.
Click
here
to
learn
more.
In
what
situations
and
with
which
types
of
parties
do
we
share
personal
information?
We
may
share
information
in
specific
situations
and
with
specific
categories
of
third
parties.
Click
here
to
learn
more.
How
do
we
keep
your
information
safe?
We
have
organizational
and
technical
processes
and
procedures
in
place
to
protect
your
personal
information.
However,
no
electronic
transmission
over
the
internet
or
information
storage
technology
can
be
guaranteed
to
be
100%
secure,
so
we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or
other
unauthorized
third
parties
will
not
be
able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Click
here
to
learn
more.
What
are
your
rights?
Depending
on
where
you
are
located
geographically,
the
applicable
privacy
law
may
mean
you
have
certain
rights
regarding
your
personal
information.
Click
here
to
learn
more.
How
do
you
exercise
your
rights?
The
easiest
way
to
exercise
your
rights
is
by
filling
out
our
data
subject
request
form
available
here:
info@mementolanguages.com,
or
by
contacting
us.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
Want
to
learn
more
about
what
Memento
Japanese
does
with
any
information
we
collect?
Click
here
to
review
the
notice
in
full.
TABLE
OF
CONTENTS
1.
WHAT
INFORMATION
DO
WE
COLLECT?
2.
HOW
DO
WE
PROCESS
YOUR
INFORMATION?
3.
WHAT
LEGAL
BASES
DO
WE
RELY
ON
TO
PROCESS
YOUR
PERSONAL
INFORMATION?
4.
WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?
5.
WHAT
IS
OUR
STANCE
ON
THIRD-PARTY
WEBSITES?
6.
DO
WE
USE
COOKIES
AND
OTHER
TRACKING
TECHNOLOGIES?
7.
HOW
DO
WE
HANDLE
YOUR
SOCIAL
LOGINS?
8.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
9.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
10.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
11.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
12.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
13.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
1.
WHAT
INFORMATION
DO
WE
COLLECT?
Personal
information
you
disclose
to
us
In
Short:
We
collect
personal
information
that
you
provide
to
us.
We
collect
personal
information
that
you
voluntarily
provide
to
us
when
you
register
on
the
Services,
express
an
interest
in
obtaining
information
about
us
or
our
products
and
Services,
when
you
participate
in
activities
on
the
Services,
or
otherwise
when
you
contact
us.
Personal
Information
Provided
by
You.
The
personal
information
that
we
collect
depends
on
the
context
of
your
interactions
with
us
and
the
Services,
the
choices
you
make,
and
the
products
and
features
you
use.
The
personal
information
we
collect
may
include
the
following:
names
email
addresses
usernames
Sensitive
Information.
We
do
not
process
sensitive
information.
Payment
Data.
We
may
collect
data
necessary
to
process
your
payment
if
you
make
purchases,
such
as
your
payment
instrument
number,
and
the
security
code
associated
with
your
payment
instrument.
All
payment
data
is
stored
by
Google
Payments
and
Apple
Pay
.
You
may
find
their
privacy
notice
link(s)
here:
https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice
and
https://www.apple.com/legal/privacy/data/en/apple-pay/.
Social
Media
Login
Data.
We
may
provide
you
with
the
option
to
register
with
us
using
your
existing
social
media
account
details,
like
your
Facebook,
Twitter,
or
other
social
media
account.
If
you
choose
to
register
in
this
way,
we
will
collect
the
information
described
in
the
section
called
"HOW
DO
WE
HANDLE
YOUR
SOCIAL
LOGINS?"
below.
Application
Data.
If
you
use
our
application(s),
we
also
may
collect
the
following
information
if
you
choose
to
provide
us
with
access
or
permission:
Mobile
Device
Access.
We
may
request
access
or
permission
to
certain
features
from
your
mobile
device,
including
your
mobile
device's
storage,
and
other
features.
If
you
wish
to
change
our
access
or
permissions,
you
may
do
so
in
your
device's
settings.
Mobile
Device
Data.
We
automatically
collect
device
information
(such
as
your
mobile
device
ID,
model,
and
manufacturer),
operating
system,
version
information
and
system
configuration
information,
device
and
application
identification
numbers,
browser
type
and
version,
hardware
model
Internet
service
provider
and/or
mobile
carrier,
and
Internet
Protocol
(IP)
address
(or
proxy
server).
If
you
are
using
our
application(s),
we
may
also
collect
information
about
the
phone
network
associated
with
your
mobile
device,
your
mobile
device’s
operating
system
or
platform,
the
type
of
mobile
device
you
use,
your
mobile
device’s
unique
device
ID,
and
information
about
the
features
of
our
application(s)
you
accessed.
Push
Notifications.
We
may
request
to
send
you
push
notifications
regarding
your
account
or
certain
features
of
the
application(s).
If
you
wish
to
opt
out
from
receiving
these
types
of
communications,
you
may
turn
them
off
in
your
device's
settings.
This
information
is
primarily
needed
to
maintain
the
security
and
operation
of
our
application(s),
for
troubleshooting,
and
for
our
internal
analytics
and
reporting
purposes.
All
personal
information
that
you
provide
to
us
must
be
true,
complete,
and
accurate,
and
you
must
notify
us
of
any
changes
to
such
personal
information.
Information
automatically
collected
In
Short:
Some
information
—
such
as
your
Internet
Protocol
(IP)
address
and/or
browser
and
device
characteristics
—
is
collected
automatically
when
you
visit
our
Services.
We
automatically
collect
certain
information
when
you
visit,
use,
or
navigate
the
Services.
This
information
does
not
reveal
your
specific
identity
(like
your
name
or
contact
information)
but
may
include
device
and
usage
information,
such
as
your
IP
address,
browser
and
device
characteristics,
operating
system,
language
preferences,
referring
URLs,
device
name,
country,
location,
information
about
how
and
when
you
use
our
Services,
and
other
technical
information.
This
information
is
primarily
needed
to
maintain
the
security
and
operation
of
our
Services,
and
for
our
internal
analytics
and
reporting
purposes.
Like
many
businesses,
we
also
collect
information
through
cookies
and
similar
technologies.
The
information
we
collect
includes:
Log
and
Usage
Data.
Log
and
usage
data
is
service-related,
diagnostic,
usage,
and
performance
information
our
servers
automatically
collect
when
you
access
or
use
our
Services
and
which
we
record
in
log
files.
Depending
on
how
you
interact
with
us,
this
log
data
may
include
your
IP
address,
device
information,
browser
type,
and
settings
and
information
about
your
activity
in
the
Services
(such
as
the
date/time
stamps
associated
with
your
usage,
pages
and
files
viewed,
searches,
and
other
actions
you
take
such
as
which
features
you
use),
device
event
information
(such
as
system
activity,
error
reports
(sometimes
called
"crash
dumps"),
and
hardware
settings).
Device
Data.
We
collect
device
data
such
as
information
about
your
computer,
phone,
tablet,
or
other
device
you
use
to
access
the
Services.
Depending
on
the
device
used,
this
device
data
may
include
information
such
as
your
IP
address
(or
proxy
server),
device
and
application
identification
numbers,
location,
browser
type,
hardware
model,
Internet
service
provider
and/or
mobile
carrier,
operating
system,
and
system
configuration
information.
Location
Data.
We
collect
location
data
such
as
information
about
your
device's
location,
which
can
be
either
precise
or
imprecise.
How
much
information
we
collect
depends
on
the
type
and
settings
of
the
device
you
use
to
access
the
Services.
For
example,
we
may
use
GPS
and
other
technologies
to
collect
geolocation
data
that
tells
us
your
current
location
(based
on
your
IP
address).
You
can
opt
out
of
allowing
us
to
collect
this
information
either
by
refusing
access
to
the
information
or
by
disabling
your
Location
setting
on
your
device.
However,
if
you
choose
to
opt
out,
you
may
not
be
able
to
use
certain
aspects
of
the
Services.
2.
HOW
DO
WE
PROCESS
YOUR
INFORMATION?
In
Short:
We
process
your
information
to
provide,
improve,
and
administer
our
Services,
communicate
with
you,
for
security
and
fraud
prevention,
and
to
comply
with
law.
We
may
also
process
your
information
for
other
purposes
with
your
consent.
We
process
your
personal
information
for
a
variety
of
reasons,
depending
on
how
you
interact
with
our
Services,
including:
To
facilitate
account
creation
and
authentication
and
otherwise
manage
user
accounts.
We
may
process
your
information
so
you
can
create
and
log
in
to
your
account,
as
well
as
keep
your
account
in
working
order.
To
request
feedback.
We
may
process
your
information
when
necessary
to
request
feedback
and
to
contact
you
about
your
use
of
our
Services.
To
send
you
marketing
and
promotional
communications.
We
may
process
the
personal
information
you
send
to
us
for
our
marketing
purposes,
if
this
is
in
accordance
with
your
marketing
preferences.
You
can
opt
out
of
our
marketing
emails
at
any
time.
For
more
information,
see
"WHAT
ARE
YOUR
PRIVACY
RIGHTS?"
below).
To
deliver
targeted
advertising
to
you.
We
may
process
your
information
to
develop
and
display
personalized
content
and
advertising
tailored
to
your
interests,
location,
and
more.
To
protect
our
Services.
We
may
process
your
information
as
part
of
our
efforts
to
keep
our
Services
safe
and
secure,
including
fraud
monitoring
and
prevention.
To
identify
usage
trends.
We
may
process
information
about
how
you
use
our
Services
to
better
understand
how
they
are
being
used
so
we
can
improve
them.
To
determine
the
effectiveness
of
our
marketing
and
promotional
campaigns.
We
may
process
your
information
to
better
understand
how
to
provide
marketing
and
promotional
campaigns
that
are
most
relevant
to
you.
To
save
or
protect
an
individual's
vital
interest.
We
may
process
your
information
when
necessary
to
save
or
protect
an
individual’s
vital
interest,
such
as
to
prevent
harm.
3.
WHAT
LEGAL
BASES
DO
WE
RELY
ON
TO
PROCESS
YOUR
INFORMATION?
In
Short:
We
only
process
your
personal
information
when
we
believe
it
is
necessary
and
we
have
a
valid
legal
reason
(i.e.,
legal
basis)
to
do
so
under
applicable
law,
like
with
your
consent,
to
comply
with
laws,
to
provide
you
with
services
to
enter
into
or
fulfill
our
contractual
obligations,
to
protect
your
rights,
or
to
fulfill
our
legitimate
business
interests.
If
you
are
located
in
the
EU
or
UK,
this
section
applies
to
you.
The
General
Data
Protection
Regulation
(GDPR)
and
UK
GDPR
require
us
to
explain
the
valid
legal
bases
we
rely
on
in
order
to
process
your
personal
information.
As
such,
we
may
rely
on
the
following
legal
bases
to
process
your
personal
information:
Consent.
We
may
process
your
information
if
you
have
given
us
permission
(i.e.,
consent)
to
use
your
personal
information
for
a
specific
purpose.
You
can
withdraw
your
consent
at
any
time.
Click
here
to
learn
more.
Legitimate
Interests.
We
may
process
your
information
when
we
believe
it
is
reasonably
necessary
to
achieve
our
legitimate
business
interests
and
those
interests
do
not
outweigh
your
interests
and
fundamental
rights
and
freedoms.
For
example,
we
may
process
your
personal
information
for
some
of
the
purposes
described
in
order
to:
Send
users
information
about
special
offers
and
discounts
on
our
products
and
services
Develop
and
display
personalized
and
relevant
advertising
content
for
our
users
Analyze
how
our
Services
are
used
so
we
can
improve
them
to
engage
and
retain
users
Support
our
marketing
activities
Diagnose
problems
and/or
prevent
fraudulent
activities
Understand
how
our
users
use
our
products
and
services
so
we
can
improve
user
experience
Legal
Obligations.
We
may
process
your
information
where
we
believe
it
is
necessary
for
compliance
with
our
legal
obligations,
such
as
to
cooperate
with
a
law
enforcement
body
or
regulatory
agency,
exercise
or
defend
our
legal
rights,
or
disclose
your
information
as
evidence
in
litigation
in
which
we
are
involved.
Vital
Interests.
We
may
process
your
information
where
we
believe
it
is
necessary
to
protect
your
vital
interests
or
the
vital
interests
of
a
third
party,
such
as
situations
involving
potential
threats
to
the
safety
of
any
person.
If
you
are
located
in
Canada,
this
section
applies
to
you.
We
may
process
your
information
if
you
have
given
us
specific
permission
(i.e.,
express
consent)
to
use
your
personal
information
for
a
specific
purpose,
or
in
situations
where
your
permission
can
be
inferred
(i.e.,
implied
consent).
You
can
withdraw
your
consent
at
any
time.
Click
here
to
learn
more.
In
some
exceptional
cases,
we
may
be
legally
permitted
under
applicable
law
to
process
your
information
without
your
consent,
including,
for
example:
If
collection
is
clearly
in
the
interests
of
an
individual
and
consent
cannot
be
obtained
in
a
timely
way
For
investigations
and
fraud
detection
and
prevention
For
business
transactions
provided
certain
conditions
are
met
If
it
is
contained
in
a
witness
statement
and
the
collection
is
necessary
to
assess,
process,
or
settle
an
insurance
claim
For
identifying
injured,
ill,
or
deceased
persons
and
communicating
with
next
of
kin
If
we
have
reasonable
grounds
to
believe
an
individual
has
been,
is,
or
may
be
victim
of
financial
abuse
If
it
is
reasonable
to
expect
collection
and
use
with
consent
would
compromise
the
availability
or
the
accuracy
of
the
information
and
the
collection
is
reasonable
for
purposes
related
to
investigating
a
breach
of
an
agreement
or
a
contravention
of
the
laws
of
Canada
or
a
province
If
disclosure
is
required
to
comply
with
a
subpoena,
warrant,
court
order,
or
rules
of
the
court
relating
to
the
production
of
records
If
it
was
produced
by
an
individual
in
the
course
of
their
employment,
business,
or
profession
and
the
collection
is
consistent
with
the
purposes
for
which
the
information
was
produced
If
the
collection
is
solely
for
journalistic,
artistic,
or
literary
purposes
If
the
information
is
publicly
available
and
is
specified
by
the
regulations
4.
WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?
In
Short:
We
may
share
information
in
specific
situations
described
in
this
section
and/or
with
the
following
categories
of
third
parties.
Vendors,
Consultants,
and
Other
Third-Party
Service
Providers.
We
may
share
your
data
with
third-party
vendors,
service
providers,
contractors,
or
agents
("third
parties")
who
perform
services
for
us
or
on
our
behalf
and
require
access
to
such
information
to
do
that
work.
We
have
contracts
in
place
with
our
third
parties,
which
are
designed
to
help
safeguard
your
personal
information.
This
means
that
they
cannot
do
anything
with
your
personal
information
unless
we
have
instructed
them
to
do
it.
They
will
also
not
share
your
personal
information
with
any
organization
apart
from
us.
They
also
commit
to
protect
the
data
they
hold
on
our
behalf
and
to
retain
it
for
the
period
we
instruct.
The
categories
of
third
parties
we
may
share
personal
information
with
are
as
follows:
Ad
Networks
Cloud
Computing
Services
Data
Analytics
Services
Data
Storage
Service
Providers
Product
Engineering
&
Design
Tools
Sales
&
Marketing
Tools
Social
Networks
User
Account
Registration
&
Authentication
Services
Testing
Tools
We
also
may
need
to
share
your
personal
information
in
the
following
situations:
Business
Transfers.
We
may
share
or
transfer
your
information
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.
Affiliates.
We
may
share
your
information
with
our
affiliates,
in
which
case
we
will
require
those
affiliates
to
honor
this
privacy
notice.
Affiliates
include
our
parent
company
and
any
subsidiaries,
joint
venture
partners,
or
other
companies
that
we
control
or
that
are
under
common
control
with
us.
Business
Partners.
We
may
share
your
information
with
our
business
partners
to
offer
you
certain
products,
services,
or
promotions.
5.
WHAT
IS
OUR
STANCE
ON
THIRD-PARTY
WEBSITES?
In
Short:
We
are
not
responsible
for
the
safety
of
any
information
that
you
share
with
third
parties
that
we
may
link
to
or
who
advertise
on
our
Services,
but
are
not
affiliated
with,
our
Services.
The
Services
may
link
to
third-party
websites,
online
services,
or
mobile
applications
and/or
contain
advertisements
from
third
parties
that
are
not
affiliated
with
us
and
which
may
link
to
other
websites,
services,
or
applications.
Accordingly,
we
do
not
make
any
guarantee
regarding
any
such
third
parties,
and
we
will
not
be
liable
for
any
loss
or
damage
caused
by
the
use
of
such
third-party
websites,
services,
or
applications.
The
inclusion
of
a
link
towards
a
third-party
website,
service,
or
application
does
not
imply
an
endorsement
by
us.
We
cannot
guarantee
the
safety
and
privacy
of
data
you
provide
to
any
third
parties.
Any
data
collected
by
third
parties
is
not
covered
by
this
privacy
notice.
We
are
not
responsible
for
the
content
or
privacy
and
security
practices
and
policies
of
any
third
parties,
including
other
websites,
services,
or
applications
that
may
be
linked
to
or
from
the
Services.
You
should
review
the
policies
of
such
third
parties
and
contact
them
directly
to
respond
to
your
questions.
6.
DO
WE
USE
COOKIES
AND
OTHER
TRACKING
TECHNOLOGIES?
In
Short:
We
may
use
cookies
and
other
tracking
technologies
to
collect
and
store
your
information.
We
may
use
cookies
and
similar
tracking
technologies
(like
web
beacons
and
pixels)
to
access
or
store
information.
Specific
information
about
how
we
use
such
technologies
and
how
you
can
refuse
certain
cookies
is
set
out
in
our
Cookie
Notice.
7.
HOW
DO
WE
HANDLE
YOUR
SOCIAL
LOGINS?
In
Short:
If
you
choose
to
register
or
log
in
to
our
Services
using
a
social
media
account,
we
may
have
access
to
certain
information
about
you.
Our
Services
offer
you
the
ability
to
register
and
log
in
using
your
third-party
social
media
account
details
(like
your
Facebook
or
Twitter
logins).
Where
you
choose
to
do
this,
we
will
receive
certain
profile
information
about
you
from
your
social
media
provider.
The
profile
information
we
receive
may
vary
depending
on
the
social
media
provider
concerned,
but
will
often
include
your
name,
email
address,
friends
list,
and
profile
picture,
as
well
as
other
information
you
choose
to
make
public
on
such
a
social
media
platform.
We
will
use
the
information
we
receive
only
for
the
purposes
that
are
described
in
this
privacy
notice
or
that
are
otherwise
made
clear
to
you
on
the
relevant
Services.
Please
note
that
we
do
not
control,
and
are
not
responsible
for,
other
uses
of
your
personal
information
by
your
third-party
social
media
provider.
We
recommend
that
you
review
their
privacy
notice
to
understand
how
they
collect,
use,
and
share
your
personal
information,
and
how
you
can
set
your
privacy
preferences
on
their
sites
and
apps.
8.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short:
We
keep
your
information
for
as
long
as
necessary
to
fulfill
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We
will
only
keep
your
personal
information
for
as
long
as
it
is
necessary
for
the
purposes
set
out
in
this
privacy
notice,
unless
a
longer
retention
period
is
required
or
permitted
by
law
(such
as
tax,
accounting,
or
other
legal
requirements).
No
purpose
in
this
notice
will
require
us
keeping
your
personal
information
for
longer
than
the
period
of
time
in
which
users
have
an
account
with
us.
When
we
have
no
ongoing
legitimate
business
need
to
process
your
personal
information,
we
will
either
delete
or
anonymize
such
information,
or,
if
this
is
not
possible
(for
example,
because
your
personal
information
has
been
stored
in
backup
archives),
then
we
will
securely
store
your
personal
information
and
isolate
it
from
any
further
processing
until
deletion
is
possible.
9.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
In
Short:
We
aim
to
protect
your
personal
information
through
a
system
of
organizational
and
technical
security
measures.
We
have
implemented
appropriate
and
reasonable
technical
and
organizational
security
measures
designed
to
protect
the
security
of
any
personal
information
we
process.
However,
despite
our
safeguards
and
efforts
to
secure
your
information,
no
electronic
transmission
over
the
Internet
or
information
storage
technology
can
be
guaranteed
to
be
100%
secure,
so
we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or
other
unauthorized
third
parties
will
not
be
able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Although
we
will
do
our
best
to
protect
your
personal
information,
transmission
of
personal
information
to
and
from
our
Services
is
at
your
own
risk.
You
should
only
access
the
Services
within
a
secure
environment.
10.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
In
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
and
Canada,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at
any
time.
In
some
regions
(like
the
EEA,
UK,
and
Canada),
you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i)
to
request
access
and
obtain
a
copy
of
your
personal
information,
(ii)
to
request
rectification
or
erasure;
(iii)
to
restrict
the
processing
of
your
personal
information;
and
(iv)
if
applicable,
to
data
portability.
In
certain
circumstances,
you
may
also
have
the
right
to
object
to
the
processing
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?"
below.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
If
you
are
located
in
the
EEA
or
UK
and
you
believe
we
are
unlawfully
processing
your
personal
information,
you
also
have
the
right
to
complain
to
your
local
data
protection
supervisory
authority.
You
can
find
their
contact
details
here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If
you
are
located
in
Switzerland,
the
contact
details
for
the
data
protection
authorities
are
available
here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your
consent:
If
we
are
relying
on
your
consent
to
process
your
personal
information,
which
may
be
express
and/or
implied
consent
depending
on
the
applicable
law,
you
have
the
right
to
withdraw
your
consent
at
any
time.
You
can
withdraw
your
consent
at
any
time
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?"
below.
However,
please
note
that
this
will
not
affect
the
lawfulness
of
the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will
it
affect
the
processing
of
your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
Opting
out
of
marketing
and
promotional
communications:
You
can
unsubscribe
from
our
marketing
and
promotional
communications
at
any
time
by
clicking
on
the
unsubscribe
link
in
the
emails
that
we
send,
or
by
contacting
us
using
the
details
provided
in
the
section
"HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?"
below.
You
will
then
be
removed
from
the
marketing
lists.
However,
we
may
still
communicate
with
you
—
for
example,
to
send
you
service-related
messages
that
are
necessary
for
the
administration
and
use
of
your
account,
to
respond
to
service
requests,
or
for
other
non-marketing
purposes.
Account
Information
If
you
would
at
any
time
like
to
review
or
change
the
information
in
your
account
or
terminate
your
account,
you
can:
Log
in
to
your
account
settings
and
update
your
user
account.
Upon
your
request
to
terminate
your
account,
we
will
deactivate
or
delete
your
account
and
information
from
our
active
databases.
However,
we
may
retain
some
information
in
our
files
to
prevent
fraud,
troubleshoot
problems,
assist
with
any
investigations,
enforce
our
legal
terms
and/or
comply
with
applicable
legal
requirements.
Cookies
and
similar
technologies:
Most
Web
browsers
are
set
to
accept
cookies
by
default.
If
you
prefer,
you
can
usually
choose
to
set
your
browser
to
remove
cookies
and
to
reject
cookies.
If
you
choose
to
remove
cookies
or
reject
cookies,
this
could
affect
certain
features
or
services
of
our
Services.
To
opt
out
of
interest-based
advertising
by
advertisers
on
our
Services
visit
http://www.aboutads.info/choices/.
If
you
have
questions
or
comments
about
your
privacy
rights,
you
may
email
us
at
info@mementolanguages.com.
11.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
Most
web
browsers
and
some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
("DNT")
feature
or
setting
you
can
activate
to
signal
your
privacy
preference
not
to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At
this
stage
no
uniform
technology
standard
for
recognizing
and
implementing
DNT
signals
has
been
finalized.
As
such,
we
do
not
currently
respond
to
DNT
browser
signals
or
any
other
mechanism
that
automatically
communicates
your
choice
not
to
be
tracked
online.
If
a
standard
for
online
tracking
is
adopted
that
we
must
follow
in
the
future,
we
will
inform
you
about
that
practice
in
a
revised
version
of
this
privacy
notice.
12.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:
Yes,
if
you
are
a
resident
of
California,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
California
Civil
Code
Section
1798.83,
also
known
as
the
"Shine
The
Light"
law,
permits
our
users
who
are
California
residents
to
request
and
obtain
from
us,
once
a
year
and
free
of
charge,
information
about
categories
of
personal
information
(if
any)
we
disclosed
to
third
parties
for
direct
marketing
purposes
and
the
names
and
addresses
of
all
third
parties
with
which
we
shared
personal
information
in
the
immediately
preceding
calendar
year.
If
you
are
a
California
resident
and
would
like
to
make
such
a
request,
please
submit
your
request
in
writing
to
us
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
Services.
To
request
removal
of
such
data,
please
contact
us
using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and
a
statement
that
you
reside
in
California.
We
will
make
sure
the
data
is
not
publicly
displayed
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.,
backups,
etc.).
CCPA
Privacy
Notice
The
California
Code
of
Regulations
defines
a
"resident"
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
"non-residents."
If
this
definition
of
"resident"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
What
categories
of
personal
information
do
we
collect?
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
Category Examples Collected
A.
Identifiers
Contact
details,
such
as
real
name,
alias,
postal
address,
telephone
or
mobile
contact
number,
unique
personal
identifier,
online
identifier,
Internet
Protocol
address,
email
address,
and
account
name
YES
B.
Personal
information
categories
listed
in
the
California
Customer
Records
statute
Name,
contact
information,
education,
employment,
employment
history,
and
financial
information
NO
C.
Protected
classification
characteristics
under
California
or
federal
law
Gender
and
date
of
birth
NO
D.
Commercial
information
Transaction
information,
purchase
history,
financial
details,
and
payment
information
YES
E.
Biometric
information
Fingerprints
and
voiceprints
NO
F.
Internet
or
other
similar
network
activity
Browsing
history,
search
history,
online
behavior,
interest
data,
and
interactions
with
our
and
other
websites,
applications,
systems,
and
advertisements
YES
G.
Geolocation
data
Device
location
YES
H.
Audio,
electronic,
visual,
thermal,
olfactory,
or
similar
information
Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities
NO
I.
Professional
or
employment-related
information
Business
contact
details
in
order
to
provide
you
our
Services
at
a
business
level
or
job
title,
work
history,
and
professional
qualifications
if
you
apply
for
a
job
with
us
NO
J.
Education
Information
Student
records
and
directory
information
NO
K.
Inferences
drawn
from
other
personal
information
Inferences
drawn
from
any
of
the
collected
personal
information
listed
above
to
create
a
profile
or
summary
about,
for
example,
an
individual’s
preferences
and
characteristics
NO
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
Receiving
help
through
our
customer
support
channels;
Participation
in
customer
surveys
or
contests;
and
Facilitation
in
the
delivery
of
our
Services
and
to
respond
to
your
inquiries.
How
do
we
use
and
share
your
personal
information?
Memento
Languages
LLC
collects
and
shares
your
personal
information
through:
Targeting
cookies/Marketing
cookies
Social
media
cookies
More
information
about
our
data
collection
and
sharing
practices
can
be
found
in
this
privacy
notice.
You
may
contact
us
by
email
at
info@mementolangauages.com,
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
are
using
an
authorized
agent
to
exercise
your
right
to
opt
out
we
may
deny
a
request
if
the
authorized
agent
does
not
submit
proof
that
they
have
been
validly
authorized
to
act
on
your
behalf.
Will
your
information
be
shared
with
anyone
else?
We
may
disclose
your
personal
information
with
our
service
providers
pursuant
to
a
written
contract
between
us
and
each
service
provider.
Each
service
provider
is
a
for-profit
entity
that
processes
the
information
on
our
behalf.
We
may
use
your
personal
information
for
our
own
business
purposes,
such
as
for
undertaking
internal
research
for
technological
development
and
demonstration.
This
is
not
considered
to
be
"selling"
of
your
personal
information.
Memento
Languages
LLC
has
not
sold
any
personal
information
to
third
parties
for
a
business
or
commercial
purpose
in
the
preceding
twelve
(12)
months.
Memento
Languages
LLC
has
disclosed
the
following
categories
of
personal
information
to
third
parties
for
a
business
or
commercial
purpose
in
the
preceding
twelve
(12)
months:
Category
A.
Identifiers,
such
as
contact
details
like
your
real
name,
alias,
postal
address,
telephone
or
mobile
contact
number,
unique
personal
identifier,
online
identifier,
Internet
Protocol
address,
email
address,
and
account
name.
Category
D.
Commercial
information,
such
as
transaction
information,
purchase
history,
financial
details,
and
payment
information.
Category
F.
Internet
or
other
electronic
network
activity
information,
such
as
browsing
history,
search
history,
online
behavior,
interest
data,
and
interactions
with
our
and
other
websites,
applications,
systems,
and
advertisements.
Category
G.
Geolocation
data,
such
as
device
location.
The
categories
of
third
parties
to
whom
we
disclosed
personal
information
for
a
business
or
commercial
purpose
can
be
found
under
"WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?".
Your
rights
with
respect
to
your
personal
data
Right
to
request
deletion
of
the
data
—
Request
to
delete
You
can
ask
for
the
deletion
of
your
personal
information.
If
you
ask
us
to
delete
your
personal
information,
we
will
respect
your
request
and
delete
your
personal
information,
subject
to
certain
exceptions
provided
by
law,
such
as
(but
not
limited
to)
the
exercise
by
another
consumer
of
his
or
her
right
to
free
speech,
our
compliance
requirements
resulting
from
a
legal
obligation,
or
any
processing
that
may
be
required
to
protect
against
illegal
activities.
Right
to
be
informed
—
Request
to
know
Depending
on
the
circumstances,
you
have
a
right
to
know:
whether
we
collect
and
use
your
personal
information;
the
categories
of
personal
information
that
we
collect;
the
purposes
for
which
the
collected
personal
information
is
used;
whether
we
sell
your
personal
information
to
third
parties;
the
categories
of
personal
information
that
we
sold
or
disclosed
for
a
business
purpose;
the
categories
of
third
parties
to
whom
the
personal
information
was
sold
or
disclosed
for
a
business
purpose;
and
the
business
or
commercial
purpose
for
collecting
or
selling
personal
information.
In
accordance
with
applicable
law,
we
are
not
obligated
to
provide
or
delete
consumer
information
that
is
de-identified
in
response
to
a
consumer
request
or
to
re-identify
individual
data
to
verify
a
consumer
request.
Right
to
Non-Discrimination
for
the
Exercise
of
a
Consumer’s
Privacy
Rights
We
will
not
discriminate
against
you
if
you
exercise
your
privacy
rights.
Verification
process
Upon
receiving
your
request,
we
will
need
to
verify
your
identity
to
determine
you
are
the
same
person
about
whom
we
have
the
information
in
our
system.
These
verification
efforts
require
us
to
ask
you
to
provide
information
so
that
we
can
match
it
with
information
you
have
previously
provided
us.
For
instance,
depending
on
the
type
of
request
you
submit,
we
may
ask
you
to
provide
certain
information
so
that
we
can
match
the
information
you
provide
with
the
information
we
already
have
on
file,
or
we
may
contact
you
through
a
communication
method
(e.g.,
phone
or
email)
that
you
have
previously
provided
to
us.
We
may
also
use
other
verification
methods
as
the
circumstances
dictate.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
To
the
extent
possible,
we
will
avoid
requesting
additional
information
from
you
for
the
purposes
of
verification.
However,
if
we
cannot
verify
your
identity
from
the
information
already
maintained
by
us,
we
may
request
that
you
provide
additional
information
for
the
purposes
of
verifying
your
identity
and
for
security
or
fraud-prevention
purposes.
We
will
delete
such
additionally
provided
information
as
soon
as
we
finish
verifying
you.
Other
privacy
rights
You
may
object
to
the
processing
of
your
personal
information.
You
may
request
correction
of
your
personal
data
if
it
is
incorrect
or
no
longer
relevant,
or
ask
to
restrict
the
processing
of
the
information.
You
can
designate
an
authorized
agent
to
make
a
request
under
the
CCPA
on
your
behalf.
We
may
deny
a
request
from
an
authorized
agent
that
does
not
submit
proof
that
they
have
been
validly
authorized
to
act
on
your
behalf
in
accordance
with
the
CCPA.
You
may
request
to
opt
out
from
future
selling
of
your
personal
information
to
third
parties.
Upon
receiving
an
opt-out
request,
we
will
act
upon
the
request
as
soon
as
feasibly
possible,
but
no
later
than
fifteen
(15)
days
from
the
date
of
the
request
submission.
To
exercise
these
rights,
you
can
contact
us
by
email
at
info@mementolangauages.com,
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
have
a
complaint
about
how
we
handle
your
data,
we
would
like
to
hear
from
you.
13.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short:
Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We
may
update
this
privacy
notice
from
time
to
time.
The
updated
version
will
be
indicated
by
an
updated
"Revised"
date
and
the
updated
version
will
be
effective
as
soon
as
it
is
accessible.
If
we
make
material
changes
to
this
privacy
notice,
we
may
notify
you
either
by
prominently
posting
a
notice
of
such
changes
or
by
directly
sending
you
a
notification.
We
encourage
you
to
review
this
privacy
notice
frequently
to
be
informed
of
how
we
are
protecting
your
information.
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
info@mementolanguages.com
or
by
post
to:
Memento
Languages
LLC
1309
Coffeen
Avenue
STE
1200
Sheridan,
WY
82801
United
States
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
You
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
change
that
information,
or
delete
it.
To
request
to
review,
update,
or
delete
your
personal
information,
please
visit:
info@mementolanguages.com.
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