Privacy Policy

This Privacy Policy describes how Lorelingo, a French SAS company (985 186 907 R.C.S. Paris), acting as the data controller within the meaning of the EU General Data Protection Regulation (GDPR), collects, uses, and shares your personal information when you use the Remember AI application and website (collectively, the "Service"). By using Remember AI, you agree to the collection and use of information in accordance with this policy.

1. Definitions

• Account means a unique account created for you to access our Service.
• Application means Remember AI, the software program provided by the Company.
• Company (also referred to as "we", "us", or "our") refers to Lorelingo, a French SAS company (985 186 907 R.C.S. Paris), located at 78 Avenue des Champs-Elysees, Office 326, 75008 Paris, France.
• Country refers to France.
• Device means any device that can access the Service such as a smartphone, tablet, or computer.
• Personal Data means any information that relates to an identified or identifiable individual, as defined in GDPR Article 4(1).
• Service refers to the Remember AI application and the website at rememberai.app.
• Sub-processor means a third-party service provider that processes Personal Data on our behalf.
• Usage Data refers to data collected automatically when using the Service.

2. Information We Collect

Personal Data

When you create an account or use Remember AI, we may ask you to provide certain personally identifiable information, including but not limited to:

• Email address
• First name and last name

Usage Data

Usage Data is collected automatically when using the Service. This may include:

• Your Device's Internet Protocol (IP) address
• Device type and operating system version
• Pages and features you visit within the app
• Time and date of your visits
• Time spent on pages and features
• Unique device identifiers and other diagnostic data

Usage Data is collected through the following analytics services:

• Facebook SDK (Meta Platforms, Inc.) — used for analytics purposes only (not for advertising). The SDK may access the Identifier for Advertisers (IDFA) on iOS, subject to your App Tracking Transparency (ATT) consent.
• Statsig (Statsig, Inc.) — used for product analytics and feature flag management to improve app performance and user experience.
• Google Analytics (Google LLC) — used on the Remember AI website (rememberai.app) to analyze website traffic and usage patterns.

User Content

Remember AI stores the content you create, including text memories. You may also submit voice recordings and images through the app. Voice audio and images are transmitted to OpenAI's API for processing (speech-to-text transcription and image-to-text extraction, respectively). Only the resulting text output is retained — original audio files and images are not stored on our servers. This data is not used for biometric identification or any biometric purposes. The retained text content is stored securely and used solely to provide and improve the Service.

Third-Party Authentication

You may sign in to Remember AI using third-party services such as Google or Apple. When you do, we may collect information associated with your third-party account, such as your name and email address, in accordance with that service's privacy policies.

3. How We Use Your Information

We may use your Personal Data for the following purposes:

• To provide and maintain the Service, including monitoring usage and performance.
• To manage your Account, including registration and access to features.
• To fulfill subscriptions, including managing purchases and payments.
• To contact you with updates, notifications, and information related to the Service.
• To provide personalized content, including AI-generated flashcards, spaced repetition quizzes, and memory connections.
• To improve the Service, including analyzing usage patterns and developing new features.
• To handle your requests and provide customer support.

4. Legal Basis for Processing

Under GDPR Article 6, we process your Personal Data on the following legal bases:

Where we rely on legitimate interest, our interest is in understanding how users interact with our Service to improve functionality and user experience. You may object to processing based on legitimate interest at any time (see Section 10).

5. Sharing Your Information

We do not sell your Personal Data. We may share your information with the following sub-processors and in the following circumstances:

Sub-processors

Other Circumstances

• For legal reasons: We may disclose your information if required by law or in response to valid legal requests.
• To protect rights and safety: We may share information to protect the rights, property, or safety of the Company, our users, or others.
• With your consent: We may share your information for any other purpose with your explicit consent.

6. International Data Transfers

Your Personal Data may be transferred to and processed in the United States by our sub-processors listed in Section 5. The United States does not benefit from an EU adequacy decision for all data transfers; however, these transfers are protected by the following mechanisms:

• EU-US Data Privacy Framework (DPF): Our key processors (OpenAI, Meta) are certified under the EU-US Data Privacy Framework, which has been recognized by the European Commission as providing adequate protection.
• Standard Contractual Clauses (SCCs): Where the DPF does not apply, we rely on the European Commission's Standard Contractual Clauses to ensure adequate data protection for international transfers.

You may request a copy of the safeguards in place by contacting us (see Section 14).

7. Tracking Technologies and Device Identifiers

Mobile Application

• Facebook SDK: May collect device identifiers and app events for analytics purposes. On iOS, access to the IDFA requires your explicit consent via Apple's App Tracking Transparency (ATT) framework. If you decline ATT, the IDFA will not be collected.
• Statsig SDK: Collects anonymous usage events and device information for analytics and feature management. Does not use cookies.

Website (rememberai.app)

• Google Analytics: Uses cookies and similar technologies to analyze website traffic. You can opt out by installing the Google Analytics Opt-out Browser Add-on or by adjusting your browser cookie settings.

How to Opt Out

• iOS: Go to Settings → Privacy & Security → Tracking to manage App Tracking Transparency permissions for Remember AI.
• Browser cookies: Adjust your browser settings to block or delete cookies. Note that disabling cookies may affect website functionality.

8. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specific retention periods are as follows:

• User Content: Retained while your account is active. Upon account deletion, your User Content is permanently deleted from our systems within 30 days.
• Account data (name, email): Deleted within 30 days of account deletion.
• Analytics data: Retained in identifiable form for up to 24 months, after which it is anonymized or deleted.
• OpenAI processing: OpenAI retains zero data from API requests made on your behalf. Audio, images, and text sent for processing are not stored by OpenAI.
• Payment and invoice records: Retained for up to 10 years after the transaction as required by French commercial and tax law (Code de commerce, Art. L123-22).

Where retention is required by law (e.g., for tax or legal compliance), we will retain the minimum data necessary for the required period.

9. Data Security

The security of your Personal Data is important to us. We use commercially reasonable measures to protect your information, including encryption and secure storage. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

10. Your Rights

Under applicable data protection laws (including the GDPR), you have the right to:

• Access the Personal Data we hold about you.
• Rectification — request correction of inaccurate or incomplete data.
• Erasure — request deletion of your Personal Data ("right to be forgotten").
• Restriction — object to or restrict the processing of your data.
• Portability — request a copy of your data in a structured, machine-readable format.
• Object — object to processing based on legitimate interest or for direct marketing purposes.
• Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

You can exercise these rights through your account settings or by contacting us (see Section 14). We will respond to your request within 30 days.

Right to lodge a complaint: If you believe that our processing of your Personal Data infringes the GDPR, you have the right to lodge a complaint with the French data protection authority:

Commission Nationale de l'Informatique et des Libertes (CNIL)
3 Place de Fontenoy, TSA 80715
75334 Paris Cedex 07, France
Website: www.cnil.fr

11. AI and Automated Processing

Remember AI uses artificial intelligence to generate content and features for you, including:

• AI-generated flashcards and spaced repetition quizzes
• Semantic memory connections and search
• Speech-to-text transcription of voice recordings
• Image-to-text extraction
• Content summarization and enrichment

This processing is performed by OpenAI's API on our behalf. The following safeguards apply:

• No automated decision-making with legal effects: We do not use AI to make decisions that produce legal effects or similarly significantly affect you (GDPR Article 22).
• No AI training on your data: Your User Content is not used to train any AI models — neither by Lorelingo nor by OpenAI. OpenAI's API operates under a zero data retention policy for our usage.
• AI content accuracy: AI-generated content may contain inaccuracies. It is provided as a learning aid and should not be relied upon as the sole source of information.

EU AI Act transparency notice: In accordance with the EU AI Act (Regulation (EU) 2024/1689), we inform you that the features listed above are AI-generated. Remember AI uses general-purpose AI models provided by OpenAI to generate content. These systems are designed to assist with memory management and learning, and you always retain the ability to review, edit, or delete any AI-generated content.

12. Children's Privacy

Remember AI is not intended for children. We do not knowingly collect personal information from anyone under the age of 15 (the digital age of consent in France under Article 7-1 of the Loi Informatique et Libertes). Users between 15 and 18 years old must use the app under the supervision of a parent or legal guardian (see our Terms of Use).

If we become aware that we have collected Personal Data from a child under 15, we will take steps to delete that information promptly. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date. We will also notify you by email or through the app for significant changes. You are advised to review this policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, you can contact us:

• Online: Contact page or through the app's profile section.
• By post: Lorelingo — Data Protection, 78 Avenue des Champs-Elysees, Office 326, 75008 Paris, France.