Privacy policy

1. Who is responsible for your data?

The controller is the publisher of Memoback: Antoine LABORDERIE EI, 55 rue de la Peloue, 33127 Saint-Jean-d’Illac, France (“we”). Full details are in the legal notice.

For any question about your data: contact@memoback.app. We have not appointed a data protection officer.

2. What does this policy cover?

It covers the Memoback mobile app (iOS and Android) and the website memoback.app, including the account deletion page. It supplements the terms of use.

It does not cover the Apple, Google and Meta (Facebook) services you use to sign in, pay or dictate: these companies process your data under their own policies, listed in § 7.

3. What data do we process?

• Account

  Data

  Identifier assigned by Apple, Google or Facebook; email address (with Apple, possibly a relay address); name, or failing that a name derived from your email; sign-in method; creation and update dates.

  Source

  Your sign-in provider, with your agreement

• Thoughts

  Data

  Text of each thought (transcribed or typed); audio recording when the app attaches one; detected category, time reference and reminder date; dates.

  Source

  You; our processing

• Consent

  Data

  Version of the accepted texts, date and time, display language, date of any withdrawal.

  Source

  You

• Reminders

  Data

  Daily reminder time; your phone’s notification token.

  Source

  You; your phone

• Subscription

  Data

  Platform (Apple or Google), original transaction identifier, product identifier, expiry date, plan.

  Source

  Apple or Google

• Technical data

  Data

  IP address, date and time, request method and address (URL), response code and duration; error messages that may contain your account identifier.

  Source

  Your device; our servers

• Usage analytics

  Data

  On the website: pages viewed and referring page (without the parameters in their address, except utm_* campaign parameters), time on page, clicks on the App Store and Google Play buttons, browser, system, device type, screen size, language and time zone. In the app, only if you agree: screens opened and a few actions without their content (account created, sign-in and its method, thought saved and how it was entered, thought categorized and whether a reminder was found, Premium purchased, envie offered for sharing, shared or unshared and its kind, reminder opened and its type); phone model and system, app version, language, time zone; a random identifier and, once you are signed in, your account’s internal identifier. In both: IP address, from which PostHog infers an approximate country and city for the website only.

  Source

  Your device

Account data is needed to create an account: without it, you cannot use Memoback. What you put in a thought is of course up to you. We never receive your payment card details: payment is handled by Apple or Google. We do not collect your precise location, your contacts or any advertising identifier.

4. Sensitive data and explicit consent

Your thoughts are free-form. They may reveal information about your health, political opinions, religious or philosophical beliefs, sex life or sexual orientation, and concern other people. The AI may even file a thought under a health-related category. These are special categories of data under article 9 of the GDPR: we process them only on the basis of your explicit consent (article 9(2)(a)).

Before your first thought, the app shows a screen that summarizes this processing and asks you to read this policy, which explains in particular the use of your phone’s speech recognition (§ 6) and the transfer of text to an AI service outside the European Union (§ 8). You give your consent by ticking a box that is not ticked by default, and you accept the terms of use. To be able to prove it (article 7 of the GDPR), we record the version of the accepted texts (current version: 2026-11-04), the date and time, and the display language.

Without this consent, Memoback can neither save nor analyze a thought, since that is the very purpose of the service.

Information about other people. Your consent covers only your own data. When a thought mentions another person, we process that information only to provide the service to you, on the basis of our legitimate interest in providing the personal notebook you use (article 6(1)(f)). This basis does not cover sensitive data: as the terms of use require, do not record sensitive information (health, opinions, beliefs, sex life…) about another identifiable person. Identifying the people mentioned to inform them individually would require reading every thought, which would be a disproportionate effort and would breach the thoughts’ confidentiality (article 14(5)(b)). This policy is therefore public, and anyone who believes they are mentioned can write to contact@memoback.app: we will search for data about them and they can exercise their rights (§ 11), without disclosing the content of the thoughts or the identity of their author where that would adversely affect the author’s rights and freedoms (article 15(4)).

Withdrawal. You can withdraw your consent at any time in the app’s settings, as easily as you gave it. From then on, the app creates no new thought and we send no content to the transcription service or the AI service. Thoughts you already saved stay stored so that you can export them, delete your account, or get them back if you consent again. You can ask for their erasure at any time (§ 11), and they are erased with your account. Withdrawal does not affect processing carried out before it.

5. Why, and on what legal basis?

• Create your account and sign you in

  Data

  Account

  Legal basis (GDPR)

  Performance of the contract (terms of use), art. 6(1)(b)

• Save, transcribe, store and display your thoughts

  Data

  Thoughts

  Legal basis (GDPR)

  Performance of the contract, art. 6(1)(b), and your explicit consent for sensitive data, art. 9(2)(a)

• Categorize your thoughts and detect dates with AI

  Data

  Text of thoughts

  Legal basis (GDPR)

  Performance of the contract, art. 6(1)(b), and explicit consent, art. 9(2)(a)

• Process information about other people contained in your thoughts

  Data

  Thoughts

  Legal basis (GDPR)

  Legitimate interest in providing the service to you, art. 6(1)(f)

• Send you the reminders you scheduled

  Data

  Reminders, thought identifier

  Legal basis (GDPR)

  Performance of the contract, art. 6(1)(b)

• Manage your Premium subscription

  Data

  Subscription, account

  Legal basis (GDPR)

  Performance of the contract (terms of sale), art. 6(1)(b)

• Prove your consent and your acceptance of the terms

  Data

  Consent

  Legal basis (GDPR)

  Legal obligation, art. 6(1)(c) and 7(1)

• Answer your messages and help you

  Data

  Email, correspondence

  Legal basis (GDPR)

  Performance of the contract, art. 6(1)(b)

• Handle your rights requests and content reports

  Data

  Email, correspondence, thoughts concerned

  Legal basis (GDPR)

  Legal obligation, art. 6(1)(c) (GDPR art. 12; Regulation (EU) 2022/2065)

• Secure the service, prevent abuse and fix errors

  Data

  Technical data

  Legal basis (GDPR)

  Legitimate interest in protecting the service and your data, art. 6(1)(f)

• Keep our accounts

  Data

  Apple and Google sales reports

  Legal basis (GDPR)

  Legal obligation, art. 6(1)(c) (French Commercial Code, art. L. 123-22)

• Establish, exercise or defend legal claims

  Data

  Strictly necessary data

  Legal basis (GDPR)

  Legitimate interest, art. 6(1)(f), and art. 9(2)(f)

• Display the website and allow online account deletion

  Data

  Technical data, account

  Legal basis (GDPR)

  Legitimate interest, art. 6(1)(f); performance of the contract, art. 6(1)(b)

• Measure website audience to improve it

  Data

  Usage analytics (website)

  Legal basis (GDPR)

  Legitimate interest in understanding website traffic, art. 6(1)(f); measurement exempt from consent (art. 82 of the French Data Protection Act), which you can object to

• Measure app usage to improve it

  Data

  Usage analytics (app)

  Legal basis (GDPR)

  Your consent, art. 6(1)(a), which you can withdraw at any time in Settings

We do not sell your data. We do not use it for advertising, commercial profiling or training artificial intelligence models.

6. Transcription and artificial intelligence

Free plan: your phone’s speech recognition

Without an active subscription, your phone’s speech recognition turns your voice into text: Apple’s on iPhone, the Android speech service (usually Google’s) on Android. The app does not require this recognition to run only on the device. Depending on your phone, language and settings, the audio may therefore be sent to Apple’s or Google’s servers, which process it under their own rules (see Apple’s notice on dictation). You can also type your thought.

When your phone records the audio during recognition, the app attaches the recording to the thought so you can listen to it again. We store it with the thought.

Premium: transcription on our servers

With an active subscription, the recording is sent to our servers in France, where a speech recognition model that we run ourselves (Parakeet TDT 0.6B v3) transcribes it. No third party receives the audio. The temporary file created for transcription is deleted as soon as it is done; we keep the recording with the thought so you can listen to it again.

Categories and date detection

The text of each new thought is sent, with today’s date, to the DeepSeek V4.1 Flash language model through the OpenCode Go service, operated by Anomaly Innovations, Inc. (United States). The model returns a category, any time reference (“tomorrow”, “next Thursday”…) and a reminder date. We do not send your name, email, account identifier or audio. The text of a thought may, however, itself contain information that identifies you or other people.

These results are automatic and can be wrong: wrong category, misread date, missing reminder. They have no legal effect and are not used to make any decision about you within the meaning of article 22 of the GDPR.

7. Who receives your data?

Within Memoback, only the publisher decides how your data is used and accesses it, to run and maintain the service; our host, OVH, accesses it only to maintain the infrastructure, on our instructions. We do not read your thoughts unless you ask us to for support, to handle a content report or a rights request, or where the law requires it. Your data is shared with the following recipients, each for its own part:

• OVH SAS (Roubaix, France)

  Role

  Processor: hosting of our servers

  Data

  All service data

  Location

  France

• Anomaly Innovations, Inc. (OpenCode Go)

  Role

  Processor: AI analysis of text

  Data

  Text of thoughts

  Location

  United States; model provider’s country not disclosed (§ 8)

• PostHog, Inc. (PostHog Cloud EU)

  Role

  Processor: usage analytics

  Data

  Usage analytics

  Location

  Germany (Frankfurt)

• Amazon Web Services EMEA SARL (Amazon SES)

  Role

  Processor: sending the confirmation email for your Premium subscription

  Data

  Account email, purchase details, contract texts

  Location

  France (Paris)

• Apple Distribution International Ltd and Apple Inc.

  Role

  Separate controller for Sign in with Apple, the App Store and iOS dictation; service provider for notifications (APNs) and purchase verification

  Data

  Sign-in identifier and email; purchases; dictated audio; notification token

  Location

  Ireland, United States

• Google Ireland Limited, Google Commerce Limited and Google LLC

  Role

  Separate controller for Google sign-in, Google Play and Android speech recognition; service provider for purchase verification

  Data

  Sign-in identifier and email; purchases; dictated audio

  Location

  Ireland, United States

• Meta Platforms Ireland Limited

  Role

  Separate controller for Facebook sign-in

  Data

  Identifier, name and email exchanged at sign-in

  Location

  Ireland, United States

• Public authorities

  Role

  Upon a request based on law

  Data

  Only the data requested

  Location

  France, EU

Notifications contain a generic text (“A thought is waiting for you in Memoback”, “Take a moment to revisit a past thought”) and, for a thought reminder, the thought’s technical identifier; never its content.

These companies’ policies: Apple, Google, Meta, OpenCode, PostHog, Amazon Web Services.

8. Transfers outside the European Union

AI analysis. The text of your thoughts is transferred to the United States, to Anomaly Innovations, Inc. For the DeepSeek model, this provider discloses neither the provider that runs the model nor its country: the text may therefore be processed outside the European Union and the United States. OpenCode states that it does not store request content and that it applies a zero data retention agreement with the model provider. Safeguard for this transfer: [TO BE COMPLETED: transfer safeguard (GDPR art. 46): standard contractual clauses signed with Anomaly Innovations, Inc., or replacement of this provider]. The consent screen points you to this policy before your first thought.

Usage analytics. PostHog hosts this data in the European Union, in Frankfurt (Germany). As PostHog, Inc. is a company established in the United States, access from that country cannot be ruled out. Safeguard for this access: PostHog, Inc. is certified under the EU–US Data Privacy Framework (European Commission adequacy decision of 10 July 2023, GDPR art. 45), and the data processing agreement signed with it on 5 November 2026 also includes the Commission’s standard contractual clauses (decision 2021/914, module 2, GDPR art. 46).

Confirmation email. Amazon SES sends this email from the European Union, in Paris (France). As Amazon Web Services EMEA SARL belongs to a group established in the United States, access from that country cannot be ruled out. Safeguard for this access: the AWS GDPR Data Processing Addendum, incorporated into the AWS Service Terms, includes the Commission’s standard contractual clauses (decision 2021/914, GDPR art. 46).

Apple, Google and Meta. These companies, responsible for their own processing, may transfer data to the United States, in particular under the European Commission’s adequacy decision on the EU-US Data Privacy Framework (decision 2023/1795) or standard contractual clauses. See their policies for details.

You can obtain a copy of the applicable safeguards by writing to contact@memoback.app.

9. How long do we keep your data?

• Account, subscription and consent

  Period

  As long as your account exists. Erased immediately when you delete it.

• Thoughts and audio recordings

  Period

  Until you delete them, or delete your account.

• Your category names

  Period

  Until you delete your account, even if the thoughts filed under a category were deleted.

• Temporary audio for Premium transcription

  Period

  A few seconds: deleted when transcription ends.

• Recording on your phone

  Period

  Deleted by the app once the thought is sent or abandoned.

• Text sent to the AI service

  Period

  Not kept by the provider, according to its commitments (§ 8).

• Notification token

  Period

  Until it is replaced; erased as soon as account deletion starts.

• Technical logs

  Period

  Erased automatically by rotation, and at the latest 12 months after creation.

• Usage analytics

  Period

  13 months, then erased automatically by PostHog. Data linked to your account is erased on request.

• Analytics identifier on your phone

  Period

  Until you sign out, withdraw your agreement, delete your account or uninstall the app.

• Your agreement to usage statistics, on your phone with your account’s internal identifier

  Period

  Until you withdraw it, delete your account or uninstall the app.

• Correspondence with us

  Period

  3 years after our last exchange; 5 years for proof of how a rights request was handled (French Civil Code, art. 2224).

• Apple and Google sales reports (without your name or email)

  Period

  10 years (French Commercial Code, art. L. 123-22).

• Backups

  Period

  Any backups are kept for 30 days at most. Deleted data disappears from them when they expire.

Deleting a thought or the account, in the app or online, is immediate and permanent in our active database and storage. Only these remain, for the periods in the table above: the category name of a deleted thought (until the account is deleted), any backups, technical logs, usage analytics, our correspondence with you and the stores’ sales reports. What is deleted and what is kept is detailed on the Delete your account page.

10. Security

• All traffic between the app, the website and our servers is encrypted (HTTPS).
• Our servers are hosted in France. The database is not reachable from the internet.
• Audio recordings are served only to their owner, once signed in.
• Apple, Google and Facebook sign-in tokens are verified by our servers. Your session is kept in your phone’s secure storage.
• Only the publisher administers the servers; the host works only on the infrastructure.
• If a data breach occurs, we notify the CNIL within 72 hours where the law requires it, and we tell you if it poses a high risk to you (articles 33 and 34 of the GDPR).

11. Your rights

You have the following rights over your data:

• Access (GDPR art. 15): get a copy of your data.
• Rectification (art. 16): correct inaccurate data.
• Erasure (art. 17): delete your data.
• Restriction (art. 18): freeze the use of your data in certain cases.
• Portability (art. 20): receive your data in a structured, machine-readable format.
• Objection (art. 21): object to processing based on our legitimate interest.
• Withdrawal of consent (art. 7(3)), at any time (§ 4).
• Instructions for after your death (article 85 of the French Data Protection Act): tell us what to do with your data after your death.

In the app’s settings, you can delete a thought, export your data, withdraw your consent and delete your account at any time. Your name and email come from your sign-in provider: to correct them, write to us.

12. How to exercise your rights

• In the app, from the settings.
• On the web, on the Delete your account page.
• By email to contact@memoback.app, preferably from the address linked to your account.

We may ask you to confirm your identity, for example by signing in to your account or replying from the linked address. We ask for an identity document only if we have reasonable doubts. We answer within one month, which may be extended by two months for a complex request; we will tell you within the first month if so. Exercising your rights is free.

13. Complaints to the CNIL

If you believe your rights are not respected, you can lodge a complaint with the French data protection authority, the CNIL (cnil.fr/fr/adresser-une-plainte), or with the data protection authority of your country of residence in the European Union. You can also write to us first: we will do our best to resolve the issue.

14. Minors

Memoback is intended for people aged 15 and over. Under 15, consent must be given jointly by the minor and the holder of parental authority (article 45 of the French Data Protection Act); the app cannot collect it, so people under 15 must not create an account. If you believe a child under 15 has given us data, write to us and we will delete it.

15. Cookies and trackers

On the website

The website sets no cookies and uses no advertising or social media buttons. Fonts are served by our own server.

It measures its audience with PostHog (§ 7) without storing anything on your device, except your refusal if you express it with the button below: your browser gets a random identifier kept in memory while the page stays open, then forgotten. This measurement only produces statistics on website traffic; it does not follow you on other websites and is not combined with your account. It is therefore exempt from consent (article 82 of the French Data Protection Act), and the website shows no banner. You can refuse it with the button below. The account deletion page measures nothing.

When online account deletion is enabled, the Delete your account page offers to sign in with Google, Apple or Facebook. These services load only if you click “Show sign-in options”. Your browser then contacts their servers, which may read or set their own cookies under their policies. Without that click, no third-party service is loaded. You can also delete your account in the app or by email.

In the app

The app keeps your session token in your phone’s secure storage, which is strictly necessary for it to work (article 82 of the French Data Protection Act).

It measures its usage with PostHog (§ 3) only if you agree, by ticking the “usage statistics” box, unticked by default, or in Settings. It then stores a random identifier on your phone and, once you are signed in, links these measurements to your account’s internal identifier, never to your email. You can withdraw your agreement at any time in Settings: sending stops and the identifier is erased from the phone. It never sends the text, audio or category of your thoughts, does not record your screen and uses no advertising identifier. It contains no advertising tools.

16. Changes to this policy

We may change this policy, for example if the service evolves or a provider changes. Each version has an identifier and a date. For a significant change (new purpose, new recipient, new transfer), we inform you in the app before it applies and, if it affects processing based on your consent, we ask for your consent again. Previous versions are available on request.

17. Memotogether: shared plans, without an account

A thought stays private until its author taps “Share”. The link shows only a sentence composed from the chosen kind of outing, timing and place, and the author’s first name. The raw thought text and audio are never published. Anyone with the link can open the page, which is not indexed by search engines.

If you answer with a 👍 or vote in the poll, we store a random identifier, your optional first name (up to 40 characters), optional day and time slot, any poll vote, and the date of your answer. No account or contact details are required. The author sees the answers and first names; people with the link also see the supplied first names and totals. You can change or remove your answer in the same browser.

The identifier is specific to this link and is created in your browser’s local storage (localStorage) only when you answer. It lets you retrieve, change and remove your answer, without cookies or tracking across plans. This storage is strictly necessary for the service you request and does not require consent (article 82 of the French Data Protection Act). You can clear it in your browser, but will then lose access to that answer. It is removed when you remove your answer or reopen a revoked or expired link.

This processing provides the outing coordination you request (GDPR article 6(1)(b)). Reactions are erased when the author revokes the link. The link and its reactions expire at most 30 days after the end of the target week, in Paris time. Technical data needed for security follows the rules in sections 3 and 9.

After your 👍, you can download a calendar file (.ics). It contains a 15-minute reminder on the Monday of the target week at 09:00 Europe/Paris, with an alarm at the start and the link in the description. You choose whether to import it into your calendar, whose provider applies its own rules. Revoking the link does not remove an event already imported. We send no email, SMS or web notifications.

Audience measurement counts page openings, likes, calendar clicks and poll votes, with only the kind of outing and language as properties of those actions. Neither the link token, your first name, the place nor the thought text is sent to PostHog. Addresses are replaced with a template such as /e/[token].