Privacy Policy for MemoThis

Our privacy policy was last updated on November 3rd, 2026. 
See previous versions here.

1. Introduction.

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information if You use our Application MemoThis. The Policy tells You about Your privacy rights and how the law protects You. 

We use Your data to provide and improve the Services. When installing, running, and using MemoThis, You agree to the collection and use of information in accordance with this Privacy Policy. 

MemoThis is not intended for or designed to attract anyone under the age of 18.

2. Interpretation and Definitions

Interpretation
Unless otherwise stated in the context, the following terms have the following meanings, and they shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions
For the purposes of this Privacy Policy:

• “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to:
      Appvestor ApS
      DK37614904,
      Gladsaxevej 342, 2860 Soeborg
      Denmark
• “Country” refers to Denmark.
• “Device” means any device that can access the Service.
• “Data” is any information that relates to a User of any of Our Services.
• “Service” refers to the Application MemoThis and its features
• “Data Partner” means any natural or legal person to whom data is transferred making it possible for the Data Partner to – via Appvestor’s Services – provide advertising to the end-user.
• “Service Provider” means a third party whose technology the Service uses to deliver a feature to You (for example map tiles, address lookup or speech recognition) and who processes limited technical data for that purpose only.
• “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, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. You can be referred to as the Data Subject or as the User as You are the individual using the Service.

3. Data Collection and Processing

No account is required
MemoThis does not require You to create an account or to sign in. We do not ask for Your name, e-mail address, phone number, contacts or call history, and Appvestor does not operate a server that receives Your notes.

Your notes stay on Your Device
Everything You create in MemoThis – notes, checklists, voice recordings, favourite places, Your dictation words and correction rules, colour themes and other settings – is stored in the App’s private storage on Your Device. Appvestor does not have access to this content and does not upload it to any Appvestor server. Notes You delete are kept in the App’s Trash for 30 days and are then removed permanently.

Technical Information
When advertisements are shown in the free version of the App, Our advertising Data Partner may collect technical information from Your Device so that advertisements can be served and measured. Technical information may include, but is not limited to: IP-address, Your country, Usage Data, device language, device type and model, operating system version, and the Advertising Identifier (Advertiser ID) connected to the installed app. Appvestor may access and use the documentation of Your consent to personalised advertisements that You have given through the consent dialog in the App.

Location – place reminders
To be able to offer You place reminders, MemoThis may, only with Your explicit consent, request access to Your location data, which may include Your approximate location, precise location and background location. Location is used to pin a note or checklist to a place, to show where You are on the map while picking a place, and to remind You of the note when You arrive at that place – also while the App is closed, which is why background location is requested. The coordinates of the places You choose are stored in the note on Your Device, and the reminders (geofences) are monitored by Google Play services on Your Device.

The map in the place picker is provided by OpenStreetMap. When the map is shown, map tile requests are sent to the OpenStreetMap Foundation’s servers and include Your IP-address, an identifier of the App, and the area of the map You are looking at. Address search and the naming of a point You pick on the map use the geocoding service of Your Device (on most Devices Google Play services), which receives the text You typed or the coordinates of the chosen point.

MemoThis does not track or record where You go, and Appvestor does not receive Your location. Location data is never shared with Data Partners for advertising or analytics purposes. You can withdraw location permission at any time under “Permissions” in the App’s settings or in Your Device’s system settings; place reminders then stop working.

Microphone – dictation and voice recordings
MemoThis asks for microphone access, only with Your explicit consent, when You dictate a note or make a voice recording. Where Your Device supports it, dictation and the “smart correction” of dictated sentences are performed entirely on Your Device using Google’s on-device AI (Gemini Nano through ML Kit GenAI); no audio or text leaves the Device for these features. On Devices without on-device AI, dictation uses the speech recognition service installed on Your Device. That service processes audio on the Device when the chosen language is downloaded and may otherwise send the audio to Google’s speech servers, under Google’s privacy policy. Voice recordings are stored only on Your Device; transcribing a recording uses the same speech recognition as dictation. “Read aloud” uses the text-to-speech engine installed on Your Device.

Backup and restore
To protect Your notes against loss, the App keeps a copy of all notes in its own storage on Your Device a few seconds after every change, plus one copy per day for the last 7 days. In addition, You may choose a backup folder in the App’s “Backup & restore” screen, or export all notes to a file. If the folder or file You choose is on a cloud storage service (for example Google Drive), that service stores the backup under its own privacy policy. Appvestor does not host, copy or read Your backups.

MemoThis also takes part in Android’s own backup: Your notes database, settings and local snapshots are included in Android backup to Your Google account and in device-to-device transfer, so they come back when You reinstall the App or set up a new phone. Voice recordings are included in device-to-device transfer only. Android backup is provided by Google under Google’s privacy policy and can be turned off in Your Device’s system settings.

Advertising and consent
The free version of MemoThis shows advertisements delivered by Google AdMob. Before the advertising SDK is started, the App shows You a consent dialog (Google User Messaging Platform) where required by law, for example in the EEA, the United Kingdom and certain US states. You choose whether advertisements may be personalised; if You decline, only non-personalised advertisements are requested. You can change Your choice at any time under “Privacy & ad choices” in the App’s settings, and You can remove advertisements altogether by purchasing the premium version.

Purchases
Purchases of the premium version (a one-time purchase or a yearly subscription) are handled by Google Play Billing. Google processes the payment and Your payment details under its own privacy policy; Appvestor never receives Your payment card details. The App receives only the product identifier, a purchase token and the purchase status, which are kept on Your Device to unlock the premium features.

Notifications
With Your permission, MemoThis shows notifications for the place reminders You have set up. These notifications are generated on Your Device; We do not send marketing push notifications.

Reviews, feedback and sharing
If You choose to rate the App, the Google Play in-app review flow is used, which is operated by Google. “Send feedback” opens Your e-mail app with a message addressed to Us; what You write is sent only when You send it. When You share a note or a voice recording, its contents are handed to the app You select, under that app’s privacy policy.

4. Use of Your Data

Appvestor commits itself to the terms of the Google Play Developer Program Policies and reserves the right to use anonymous data for statistics and user support without restrictions regarding applicability in time.

Appvestor may use Your Data for the following purposes:

• To provide and maintain Our Service, including providing You with the Application features You use, such as place reminders, dictation, voice recordings and backup.
• To show advertisements: To show advertisements in the free version of the App and, only with Your consent, to personalise them.
• To process purchases: To unlock the premium version after a purchase made through Google Play.
• To manage Your requests: To attend to, and manage a request from You on the deletion of the App and all Your personal data.
• To comply with legal obligations: To fulfill obligations under applicable law, including GDPR, CCPA/CPRA, LGPD, and PIPA.

We may share Your Data in the following situations:

• With business partners (Data Partners): We may – with Your consent – share Your information with Our advertising partner in accordance with its stated purposes in its privacy policy.
• With Service Providers: Only the technical data necessary to deliver a feature You are using (for example map tiles, address lookup or speech recognition) is sent to the Service Provider, as described in section 3.
• With authorities: Where required by applicable law or valid court order, We may disclose Your data to public authorities.

We do not sell Your personal data to third parties for monetary compensation. We do not share Your personal data for cross-context behavioural advertising without Your explicit consent.

5. Legal Basis for the Processing of Your Data

Appvestor processes personal data to pursue Our legitimate interest in managing Our business – including being able to handle contracts and purchases of various products and licenses for Our business and to improve, develop and market Our Services, and comply with Our legal obligations. The legal basis for Our processing is thus the following articles in the GDPR:

• Article 6(1)(a): Personal data may be processed with express consent.
• Article 6(1)(b): Personal data may be processed if necessary to fulfill a contract.
• Article 6(1)(c): Personal data may be processed if this is necessary to comply with a legal obligation.
• Article 6(1)(f): Personal data may be processed if necessary to pursue a legitimate interest unless the interests of the data subject precede this.
• Article 9(2)(a): Where processing involves Sensitive Personal Data (e.g. precise location data that may indirectly reveal sensitive characteristics), processing is based on explicit consent only.

Note: Because We process Your data partly on basis of Article 6(1)(f) (legitimate interests), You may in certain cases object to Our otherwise lawful processing of Your personal data, cf. Article 21 GDPR. 

6. Retention of Your Data

Data stored on Your Device – notes, voice recordings, places and settings – is retained until You delete it, or until You uninstall the App or clear its storage. Notes You delete are kept in the Trash for 30 days and are then removed permanently; the App’s local backup copies are kept for 7 days. Backups You saved to a folder or exported to a file stay where You saved them until You delete them.

Appvestor will process and retain anonymized Usage Data for analysis purposes. Your Data will be retained until the purpose of use is achieved or You choose to have it deleted.  As a general rule, personal data linked to a specific device or user is retained for no longer than 24 months from the date of collection, after which it is anonymized or deleted, unless a longer retention period is required by applicable law. We will delete your personal data in accordance with applicable law.

7. Transfer of Your Data

Your Data may be transferred to — and maintained on — servers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

If Your data is transferred to a country outside the EU/EEA, and if the country in question has not been approved by the European Commission as providing adequate protection, Our data transfers will be based on Standard Contractual Clauses (SCC) approved by the European Commission.

Where data is transferred to the United States, We rely on Standard Contractual Clauses (SCCs) as the applicable transfer mechanism in accordance with GDPR Chapter V. We conduct Transfer Impact Assessments (TIAs) where required.

We work with the following Data Partners and Service Providers, who all act as independent Data Controllers to whom Your data will be transferred:

Our Data Partners and Service Providers process the transferred information in accordance with their own stated privacy policies. Data is transferred to Data Partners for advertising only with Your specific consent; Service Providers receive only the technical data necessary to deliver the feature You are using. 

8. Other Disclosure of Your Data

Law Enforcement

Under certain circumstances, Appvestor may be required to disclose Your Data in accordance with law or in response to valid requests from public authorities (e.g. a court or a government agency). Appvestor will comply with all applicable data protection provisions, including section 5 of the Danish Act on Personal Data.

Opt-Out from Data Collection and Inquiries

Users have the right to ask Appvestor not to continue the processing of Personal Data. Users can exercise their rights to prevent processing by contacting Appvestor at privacy@appvestor.com, by changing Your advertising choices under “Privacy & ad choices” in the App’s settings, or by revoking the App’s permissions under “Permissions” in the App’s settings. 
California residents (CCPA/CPRA): You have the right to opt out of the “sale” or “sharing” of Your personal information for cross-context behavioural advertising. To exercise this right, contact us at privacy@appvestor.com or use the opt-out mechanism within the app settings.

MemoThis does not use user accounts. To delete Your notes and recordings, delete them in the App or uninstall the App – see section 19 below.

Security of Your Data

The security of Your Data is important to Us. We have implemented the appropriate technical security measures to ensure data protection in all contexts. We have further ensured contractual-based instructions to Our Data Partners regarding necessary security measures to supplement the Standard Contractual Clauses approved by the European Commission.

We implement appropriate Technical and Organisational Measures (TOMs) in accordance with GDPR Article 32, including encryption of data in transit, access controls, and regular security reviews. Your notes are kept in the App’s private storage, which other apps on Your Device cannot read.

9. SDK Data Collection and Consent Requirements

In accordance with Google Play Developer Program Policies and applicable data protection law (including GDPR and ePrivacy), Appvestor ensures that no third-party SDK integrated into Our Applications will collect, transmit, or process personal data before the user has been presented with a clear consent interface and has actively provided their consent.

This means:

• No SDK initialises in a data-collecting mode prior to consent being obtained. The advertising SDK (Google AdMob) is only started after the Google User Messaging Platform consent flow has completed and Your choice allows advertisements to be requested.
• Consent is granular — users are offered individual choices per purpose and cannot be forced to accept all-or-nothing.
• If a user declines consent, no non-essential tracking or data collection takes place.
• Users may withdraw consent at any time under “Privacy & ad choices” in the App’s settings or by contacting privacy@appvestor.com.
• Consent records, including the timestamp, the version of the consent notice shown, and the user’s choice, are maintained in accordance with GDPR Article 7(1).

Appvestor accepts full responsibility as data controller for the data collection practices of all SDKs integrated into Our Applications.

10. Prominent Disclosure – Sensitive App Permissions

MemoThis may request access to certain sensitive device permissions in order to deliver its features. The App only asks for a permission when You use the feature that needs it, and shows a clear in-app explanation first. In accordance with Google Play Developer Program Policies and GDPR, We provide the following explicit disclosures:

Location Permissions

• ACCESS_FINE_LOCATION / ACCESS_COARSE_LOCATION: Used to show where You are on the map when pinning a note to a place, and to detect when You arrive at a place You set a reminder for.
• ACCESS_BACKGROUND_LOCATION: Used so that place reminders can trigger while the App is closed. A prominent in-app disclosure is shown before this permission is requested. Location is monitored by Google Play services’ geofencing on Your Device; the App does not record Your movements and does not send Your location to Appvestor or to any Data Partner.
• RECEIVE_BOOT_COMPLETED: Used only to re-register Your place reminders after the Device restarts or the App is updated.

Microphone Permission

• RECORD_AUDIO: Used to dictate notes by voice and to make voice recordings attached to a note. Audio is processed as described in section 3; recordings are stored only on Your Device. A foreground service with a visible notification keeps a recording going while the screen is off or the App is in the background.

Notification Permission

• POST_NOTIFICATIONS: Used to show the place reminders You have set up and to read them aloud on arrival. No marketing notifications are sent.

Location access, microphone access and notifications are always optional and consent-based. The App works without them; only the features that depend on them are unavailable. You can review and revoke each permission under “Permissions” in the App’s settings at any time.

11. Data Breach Notification

In the event of a personal data breach, Appvestor will act in full accordance with GDPR Articles 33 and 34 and any other applicable data breach notification requirements.

Notification to the Supervisory Authority (Datatilsynet)

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, Appvestor will notify Datatilsynet without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, in accordance with GDPR Article 33.

The notification will include: a description of the nature of the breach; the DPO’s contact details; the likely consequences; and the measures taken or proposed to address the breach.

Notification to Affected Users

Where a personal data breach is likely to result in a high risk to the rights and freedoms of the affected individuals, Appvestor will notify those individuals directly, without undue delay, via one or more of the following methods:

• In-app notification displayed prominently when the user next opens the Application
• Push notification to affected devices, where technically possible
• Publication of a prominent notice on legal.appvestor.com

The notification to affected users will be in plain language and will include: a description of the breach; the DPO contact details (John Lisek, dpo@appvestor.com); the likely consequences; steps Appvestor is taking to address the breach; and recommended actions the user can take to protect themselves.

Internal Breach Response

All suspected or confirmed breaches must be reported immediately to the DPO (dpo@appvestor.com) who is responsible for assessing the breach, determining notification obligations, and coordinating the response.

12. Changes to the 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.

Where changes are material — such as changes to the types of data collected, new third-party data sharing, changes to retention periods, or changes to user rights, We will provide prominent notice, which may include in-app notifications or, where required by applicable law, renewed consent will be sought.

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

13. Contact Us

If You have any questions, requests, or comments about this Privacy Policy, You can contact Us by sending an e-mail to: privacy@appvestor.com
Appvestor ApS, Gladsaxevej 342, 2860 Søborg, Denmark
We aim to respond to all privacy-related enquiries within 30 days as required by GDPR Article 12.

14. Data Protection Officer (DPO)

In accordance with Article 37 of the GDPR, Appvestor ApS has appointed a Data Protection Officer (DPO). The DPO is responsible for overseeing Appvestor’s data protection strategy and ensuring compliance with applicable data protection legislation.

Name: John Lisek
E-mail: dpo@appvestor.com
Organisation: Appvestor ApS, Gladsaxevej 342, 2860 Søborg, Denmark

You have the right to contact the DPO directly at any time regarding the processing of Your personal data, to exercise Your data subject rights, or to raise any concerns or complaints relating to data protection. The DPO operates independently and is bound by confidentiality.

The appointment of the DPO has been registered with the Danish Data Protection Authority (Datatilsynet) as required under GDPR Article 37(7).

15. For Users Within the European Economic Area (EEA)

Appvestor undertakes to respect the confidentiality of Your 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:

• Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
• Correct the Personal Data that We hold about You.
• Object to the processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data in a structured, commonly used, machine-readable format (data portability).
• Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data at any time.
• Restrict processing. You have the right to request that We restrict the processing of Your personal data in certain circumstances as set out in Article 18 GDPR.
• Lodge a complaint with your local data protection supervisory authority.

You may exercise Your rights by contacting Us at privacy@appvestor.com. Please note that We may ask You to verify Your identity before responding to such requests.

We will respond to all valid data subject requests within 30 days of receipt. Where necessary, this period may be extended by a further two months, and We will inform You of any such extension.

You have the right to complain to the Danish Data Protection Authority (Datatilsynet): 

Carl Jacobsens Vej 35, DK 2500 Valby | Tel: +45 33 19 32 00 | dt@datatilsynet.dk 

16. For Users Within State-Specific areas in the United States

California (CCPA / CPRA)

If You are a resident of California, You have additional rights under the CCPA as amended by the CPRA:

• Right to Know: What personal information we collect, use, disclose, and sell about you.
• Right to Delete: Personal information we have collected from you, subject to certain exceptions.
• Right to Correct: Inaccurate personal information that we maintain about you.
• Right to Opt Out of Sale / Sharing: You have the right to opt out of the “sale” or “sharing” of your personal information for cross-context behavioural advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
• Right to Limit Use of Sensitive Personal Information: You may limit Our use of sensitive personal information to purposes necessary to perform the services you requested.

Categories of personal information collected in the past 12 months: identifiers (device ID, IP address, advertising ID), internet and network activity information (interaction with advertisements), and inferences drawn from such information, collected by Our advertising partner when advertisements are shown. Precise geolocation used for place reminders is processed only on Your Device and is not transmitted to Us.

We do not knowingly sell or share the personal information of consumers under 16 years of age without affirmative authorisation.

To exercise your California privacy rights contact us at: privacy@appvestor.com or visit: /us_resident/

Other US States

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Montana (MCDPA), Oregon (OCPA) and other states with applicable privacy laws have rights including access, correction, deletion, data portability, and opt-out of targeted advertising. Contact us at privacy@appvestor.com to exercise these rights.

Supplemental information for US state residents is available at: /us_resident/

17. LGPD – For Users in Brazil

If You are a resident of Brazil, You have rights under the Lei Geral de Proteção de Dados (LGPD – Law No. 13,709/2018). Appvestor ApS acts as the data controller in relation to the processing of Your personal data.

Your Rights Under the LGPD

In accordance with Article 18 of the LGPD, You have the following rights regarding Your personal data:

• Confirmation of processing: The right to confirmation of the existence of processing of Your personal data.
• Access: The right to access Your personal data held by Appvestor.
• Correction: The right to correct incomplete, inaccurate, or outdated personal data.
• Anonymisation, blocking, or deletion: The right to request anonymisation, blocking, or deletion of unnecessary, excessive, or unlawfully processed personal data.
• Data portability: The right to receive Your personal data in a structured, interoperable format for transfer to another service provider, subject to commercial and trade secrets.
• Deletion of consented data: The right to request the deletion of personal data processed on the basis of Your consent, except where retention is required by law.
• Information about sharing: The right to information about which public and private entities Your personal data has been shared with.
• Information about consent: The right to information about the possibility of not providing consent and the consequences of refusal.
• Revocation of consent: The right to revoke Your consent at any time through a simple and free procedure, by contacting privacy@appvestor.com or through the in-app settings.
• Objection to processing: The right to object to processing carried out on grounds other than consent, where non-compliant with the LGPD.
• Review of automated decisions: The right to request a review of decisions made solely on the basis of automated processing of personal data that affect Your interests.

Legal Basis for Processing Under the LGPD

Appvestor processes personal data of Brazilian residents on the following legal bases as set out in Article 7 of the LGPD:

• Consent (Art. 7(I)): Where You have provided free, informed, and unambiguous consent for a specific purpose, such as personalised advertising or location-based reminders.
• Legitimate interest (Art. 7(IX)): For purposes such as fraud prevention, service improvement, and security, provided Your fundamental rights and freedoms are not overridden.
• Compliance with a legal obligation (Art. 7(II)): Where processing is necessary to comply with applicable law.

Supervisory Authority – ANPD

If You believe that the processing of Your personal data violates the LGPD, You have the right to lodge a complaint with the Brazilian National Data Protection Authority:

Autoridade Nacional de Proteção de Dados (ANPD)

Website: https://www.gov.br/anpd | E-mail: comunicacao@anpd.gov.br

To exercise any of Your LGPD rights, please contact Our DPO: John Lisek at dpo@appvestor.com or privacy@appvestor.com. We will respond within 15 days of receipt of Your request, as required under the LGPD.

18. PIPA – For users in South Korea

You have the right under this Privacy Policy, and by law, if You are within South Korea, to:

• Access Your Personal Data and update or delete the information We have on You.
• Correct the Personal Data We hold about You.
• Object to the processing of Your Personal Data.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Appvestor and Our Data Partners will not collect, process, share, or access any location data from South Korea. Location used for place reminders is processed only on Your Device.

You may exercise Your rights by contacting Appvestor at privacy@appvestor.com. 

19. Deletion of Your Data

All data that has fulfilled its purposes will be identified by Appvestor and deleted without delay in accordance with this privacy policy. Appvestor will take all commercially and technologically reasonable measures to ensure personal data will practically not be recoverable or reproducible. Digital documents containing personal data will be deleted via a technical method that will make it reasonably impossible to recover, retrieve, or become re-identifiable. Appvestor does not store personal data on non-digital documents or files.

MemoThis does not use user accounts, and Appvestor does not store Your notes. You are in control of the data on Your Device:

• Delete individual notes in the App; they can be removed permanently from the Trash, and are otherwise removed automatically after 30 days.
• Delete voice recordings from within the note they belong to.
• Remove everything the App stores by uninstalling it or by clearing its storage in Your Device’s system settings.
• Backups You saved to a folder or exported to a file remain where You saved them until You delete them. Android backup data in Your Google account can be managed and deleted through Your Google account settings.

To request deletion of any personal data Appvestor may hold about You (for example from correspondence with Us), contact privacy@appvestor.com.

20. Overseas Transfer of Data – South Korea (PIPA)

Appvestor may share personal data as described in this privacy policy with the following third-party service providers outside of Korea.

Users have the right to ask Appvestor not to continue overseas transfer of Personal Data by contacting Appvestor at privacy@appvestor.com or by changing Your choices under “Privacy & ad choices” and “Permissions” in the App’s settings.

개인정보보호법과 정보통신망 이용촉진 및 정보보호 등에 관한 법률에 따른 국내대리인의 정보는 다음과 같습니다.

–       명칭 및 대표자: 제너럴에이전트 주식회사 (대표이사: 김은미)

–       주소: 서울특별시 종로구 새문안로5가길 28, 1216호(적선동)

–       전화번호: (02) 735-8706

–       전자우편 주소: appvestor@generalagent.co.kr