1. Data Controller
Capelago SASU
9 rue Urbain Vitry, 31000 Toulouse, France
Email: memoricoapp@gmail.com
Capelago is the data controller responsible for processing your data.
2. Overview
The Application is designed to function primarily offline.
- No account is required
- No directly identifying data (name, email) is collected
- User-generated content remains stored locally on your device
However, limited pseudonymized technical and usage data is collected via analytics tools.
3. Data We Collect
The Application may collect the following categories of data:
3.1 Technical and Device Data
- Device model and manufacturer (e.g. iPhone 15)
- Operating system and version
- App version and build
- Screen size and resolution
- Locale and timezone
3.2 Usage Data
- Screens viewed
- Features used
- Interaction events (e.g. button clicks)
- Session duration and frequency
3.3 Pseudonymous Identifiers
- Session ID
- Pseudonymous device identifier
3.4 Approximate Location Data
Collected via IP address:
- Country
- Region
- City
The IP address is processed transiently by analytics providers and is not used to directly identify you.
4. How Data Is Used
Data is processed for the following purposes:
- Improve product usability and features
- Analyze usage patterns and retention
- Debug errors and improve performance
The Application does not:
- Sell data
- Use data for advertising
- Build user profiles
5. Analytics (PostHog)
The Application uses PostHog for analytics.
PostHog acts as a data processor on behalf of the Service Provider.
Collected data includes:
- Technical device data
- Usage events
- Approximate geographic data based on IP
Important limitations:
- No user-generated content is tracked
- No text inputs or personal content are recorded
- No session replay is currently used
- No autocapture is enabled
Data is pseudonymized and processed in a way that does not directly identify users.
PostHog may process data in the United States.
More information: https://posthog.com/privacy
6. Legal Basis (GDPR)
Processing of analytics data is based on our legitimate interest in improving the Application, ensuring performance, and understanding usage patterns.
This processing is limited to pseudonymized data and does not override users' fundamental rights and freedoms.
7. Consent and Controls
You may object to analytics processing at any time by contacting us at memoricoapp@gmail.com.
Where technically feasible, we may provide additional controls within the Application in the future.
8. Third-Party Services
The Application uses the following third-party processors:
- PostHog (analytics) — https://posthog.com/privacy
- Expo (infrastructure) — https://expo.dev/privacy
- RevenueCat (subscriptions) — https://www.revenuecat.com/privacy
These services process data on our behalf as processors.
9. Payments and Subscriptions
Payments are handled by Apple App Store and Google Play.
The Service Provider does not collect or store payment details.
RevenueCat may process subscription-related data (e.g. purchase status) to enable premium features.
10. Notifications
The Application uses local notifications only.
No notification data is transmitted to external servers.
11. Data Storage
- User content is stored locally on your device
- No backend server stores personal content
- Analytics data is processed by third-party services
12. International Transfers
Some data may be processed outside the European Economic Area (EEA), including in the United States.
These transfers rely on safeguards such as Standard Contractual Clauses approved by the European Commission.
13. Data Retention
Analytics data is retained for up to 12 months, after which it is deleted or aggregated.
Local data is deleted when the app is uninstalled.
14. Your Rights (GDPR)
If you are located in the EEA, you have the right to:
- Access your data
- Rectify inaccurate data
- Request deletion
- Restrict or object to processing
- Lodge a complaint with CNIL (France)
To exercise your rights, contact: memoricoapp@gmail.com
Because the Application does not use user accounts, we may not be able to directly identify you from analytics data.
In some cases, we may request additional information to help locate relevant data.
15. Children’s Privacy
The Application may be used by individuals under the age of 16.
However, it is not specifically directed at children, and we do not knowingly collect personal data from children.
If we become aware that personal data from a child has been collected, we will take steps to delete it.
16. Security
We implement reasonable technical and organizational safeguards.
However, no system is completely secure.
17. Changes
This Privacy Policy may be updated periodically.
18. Contact
Email: memoricoapp@gmail.com
Website: https://memorico.co/feedback/report
19. Consent
By using the Application, you acknowledge this Privacy Policy.