Memorang, Inc. is dedicated to leveling the playing field in education through self-study, collaboration, community, and premium test-prep. When you share information with us we are able to improve our learning algorithms and content recommendations to make studying more efficacious and efficient. This Privacy Notice is meant to help you understand how we collect and use the personal information you provide on our website, www.memorang.com, and the two official Memorang iOS and Android mobile applications. This notice explains:

1. The information we collect and where we collect it from
2. The ways we use your information
3. The times where we might need to share information
4. Choices you have about we do and how to exercise your choices
5. How to contact us if you have questions

1. The information we collect and where we collect it from

We need to collect certain information about you to provide you with the Service or the support you request. The type of information we collect can vary depending on how you access and use our Service. Additionally, you can choose to voluntarily provide information to us. Below we have described the types of information we collect and from where we collect it.

a. Information you Provide to Us to Use the Service

• Account information: We collect the information you provide when you sign up for a Memorang account, log in to your account, communicate with us, answer our surveys, upload content, or otherwise use the Services. We request an email address in order to secure your account, and otherwise we are not be able to provide you with the Service.
• Transactional information: Users who engage in financial transactions with Memorang, for example to purchase an upgraded membership subscription, are asked to provide additional information in order to complete the transaction, such as a credit card number, billing address and full name.
• Visitors can always refrain from supplying certain information, but it may prevent them from engaging in certain Memorang services which require that information.

b. Information You Provide to Enhance Your Experience

You can choose to provide us with additional information in order to obtain a better user experience when using the Service. This additional information will be processed with your consent and/or to provide you with services you request. This information includes your survey responses, participation in contests, promotions or other marketing efforts, suggestions for improvements, referrals, or any other actions on the Service.

c. Information We Get Automatically When You Use the Service

We automatically collect information about you and how you use the Service, like when you create content, view and interact with your or other users’ content. This information we collect includes:

• Device information: Like most website operators, Memorang collects information about how users visit our site and the devices they use. We collect device-specific information (such as your hardware model, operating system version, device identifiers like IDFA and UDID, and mobile network information). Memorang may associate your device identifiers or other device information with your Memorang Account to help us provide consistent services across your devices.
• Geolocation information: We may use your IP address to generate a general approximation of where you are located in order to provide you with an improved experience. We do not request access to or collect location sensor information, such as GPS or Bluetooth beacons, from your mobile device while downloading or using our mobile apps or services.
• Log information: When you use Memorang, we automatically collect and store certain information about this activity. This data includes details of how you used our service, like your search queries, clicks and site navigation information, or study activity. It also may include data such as:
  • Browser type
  • Language preference and time zone
  • Referring site, and the date and time of each visitor request
  • Connection information like ISP or mobile operator
  • Internet Protocol (IP) address
  • Log-in and Log-out times
  • Learning analytics and performance (anonymized)

d. Information We Collect From Other Sources

We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties. The information we collect about you from third parties includes:

• Facebook Login, Apple Login, and Google Login: You have the option to log in to our site using sign-in services such as Facebook Login, Apple Login, and Google Login. These services authenticate your identity and provide you the option to share certain personal information with us, such as your name, date of birth, and email address, to pre-populate our sign-up form. You may, optionally, choose to provide additional information during the sign-up or linking process, such as a friends list, to enable certain features on Memorang.
• Other users: Memorang may receive information about you from other users. For example, if another user chooses to use our referral service to tell a friend about our website, we may ask that user for their friend’s name and email address so we can send the invites on their behalf. You may contact us at support@mail.memorang.com to request that we remove your information from our database.
• Other partners and companies: Memorang may also receive information about you from other sources, including our partners, service providers or other third parties.

2. The ways we use your information

We collect information about you when you use the Service for a variety of reasons in order to support Memorang and to enable our team to continue to create engaging experiences for our users.

a. Providing, Analyzing, Improving and Developing the Service

We process the data we collect about you to operate, improve and develop the Memorang Service, including providing, maintaining, securing and improving our services, developing new ones, and protecting Memorang and our users. We are able to deliver our services, personalize content, and make suggestions for you by using this information to understand how you use and interact with our services. We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

Here are some examples of how we use this information:

• Providing, maintaining and improving the Service: Account information we collect from you allows us to help you log in, host your content, and use the various study tools we have. It also allows us learn about how you and others use Memorang to help create new features and services.
• Improving, personalizing and facilitating your use of the Service: When you sign up and use a Memorang account, we may associate certain information with your new account, such as information about other Memorang accounts you had or currently have, and your prior usage of the Service. For example, we use information collected from cookies and other technologies, like pixel tags, to save your language preferences, so we will be able to have our services appear in the language you prefer. We do this in order to ensure that content from the Service is presented in the most effective manner for you.
• Measuring, tracking and analyzing trends and usage in connection with your use or the performance of the Service: In order to develop and enhance our products and deliver a consistent, secure and continuous experience, we need gather certain information to analyze usage and performance of the Service. We also use mobile analytics software to pursue our legitimate interests in operating and improving Memorang by allowing us to better understand the functionality of our mobile software on your device. This software may record information such as how often you use the application, the events and activities that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
• Fulfilling any other purpose disclosed to you in connection with the Service

b. Communicating with You About the Service

We also use your account information and information you provide to us to provide you with relevant information about the Service and to assist you in using the Service if required. These communications may include:

• Sending you information we think you may find useful or which you have requested from us about our products and services: We may send you information about the parts of Memorang you use or that may be relevant to you. While we primarily use our various product blogs to communicate this type of information and we expect to keep this type of email to a minimum, you may object to being contacted for these reasons using your personal contact information using the mechanisms provided in the Memorang service or using the information provided below.
• Conducting surveys and collecting feedback about the Service: We do this to evaluate the effectiveness of any updates we provide.
• Delivering assistance or answering support requests: We send you the information and support you request, including technical notices, security alerts, and other administrative messages to provide assistance for problems you may encounter with the Service or your Memorang account.

c. Protecting the Service and Maintaining a Trusted Environment

We use all categories of information we collect to maintain Memorang as a safe and secure platform for all our users, including appropriate enforcement of Memorang policies, as well as compliance with the law and applicable regulations. These efforts include:

• Preventing fraud, crime and abuse and the security and integrity of the ServiceThis includes investigating, detecting and preventing or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities or to otherwise help protect your account.
• Protecting our and third parties’ rights and property and enforcing our Terms of Service or other applicable agreements or policies, including our Community Guidelines
• Verifying your identity: In some cases, we may need to verify your identity in order to protect the security and integrity of the Service and your account.
• Complying with any applicable laws or regulations: This includes appropriately responding to lawful requests for information from the government or third parties through legal process.
• Contacting you to resolve disputes, collect fees and provide assistance with the Service

d. Advertising, Analytics and Marketing

In order to support the Memorang business and provide our users with relevant information regarding the Service and opportunities presented by partners, Memorang may use your personal information for marketing the Service. We may also communicate with you and others about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners. We may also displaying relevant advertising to you while using the Service. To learn more about how we display relevant advertising to you, and to exercise choices please read the Choices section below and our Ad and Cookie Policy.

e. Cookies and Other Similar Technologies

Technologies such as cookies, beacons, tags and scripts are used by Memorang and our partners' affiliates, or analytics or service providers, to collect and store data about our users in order to provide the Service in accordance with our agreement with you under the Terms of Service and are an essential technology for allowing Memorang to pursue our legitimate interests in operating and improving the Service.

Learn more about these tools and how you can control them in our Ad and Cookie Policy.

f. Information We Combine

We also collect some information from other sources and combine that with information we collect from you. To ensure a proper experience on Memorang, we combine information collected across devices, such as computers and mobile devices.

g. Other Uses

We may process data for any other purpose disclosed to you in connection with the Service from time to time. If we intend to process your personal data for a purpose other than that set out above and which is not compatible with the original processing purpose, we will provide you with relevant information prior to such processing and will obtain your consent where necessary.

3. The times where we might need to share information

a. Information You Choose to Share on Memorang

Certain information about you or activities you perform on Memorang may be displayed publicly, for example, information included on your user profile, folders you have collaborated on, high scores you have achieved, or sets you have studied may be visible to others. Whenever possible, we provide you with choices about the privacy of your information on Memorang.

b. How Memorang Shares Information

Memorang shares your information in the following circumstances:

• With your consent: We will share personal information with companies, organizations or individuals outside of Memorang when we have your consent to do so.
• For external processing: Memorang provides personal and non-personal information to our partners, trusted organizations, vendors and other affiliated organizations to process it on our behalf. Some of these contractors and affiliated organizations may be located outside of your home country. Our providers process data in accordance with our instructions, Privacy Notice and any other appropriate confidentiality, security or other requirements we deem necessary in order to comply with Memorang’s obligations. By using Memorang, you agree to allow these companies to process your data on our behalf, regardless of where they are located.
• To respond to legal and other requests and to prevent harm: Memorang will share all categories of personal information with companies, organizations or individuals outside of Memorang if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
  • Respond to or meet any applicable law, regulation, legal process or other enforceable governmental request.
  • Enforce our Terms of Service, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security or technical issues.
  • Protect against and prevent harm to the rights, property or safety of Memorang, our users or the public as required or permitted by law.
• With any successor to all or part of our business: If Memorang is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• For research purposes: From time to time, Memorang may release non-personal information in the aggregate or as part of anonymized datasets, for example, by publishing a report on trends in the usage of its website.

4. Choices you have about we do and how to exercise your choices

a. Promotional Communications

You may receive promotional email messages from Memorang when you first interact with the Service or by making a request to us. You can opt out of receiving promotional email messages from Memorang at the time we collect your information by following the instructions on screen, in those email messages, or by changing your notification settings in your Memorang account. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we will still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

b. Who Can View Information You Post

Comments you post on our blog or in testimonials may be viewable by other users of Memorang and the general public and you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from these areas, contact us at support@mail.memorang.com. We provide you the ability to control who can view and modify the content you have created on Memorang and to remove information about previous study sessions. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

c. Cookies and Tracking Tools

To learn how to manage cookies and other tracking tools, and to read our Do Not Track Policy, please read our tracking section linked above.

d. Managing Your Account

You remain in control of the information you provide to Memorang. You may review, edit or delete any information you submit to us at any time by signing into your Memorang account; however, deletion of this information may restrict your ability to effectively use the Service. You may also delete your account at any time. If you delete your account, all the study sets, folders, and classes that you've created will also be also deleted in accordance with our data retention practices.

e. EU Resident Rights

Memorang processes your personal data only when we have a lawful basis for doing so. For example, some of the information we collect from you we need to enable use to deliver the Services to you and fulfill our agreement under the Terms of Service, sometimes we collect and process your data when you have given us consent to do so, sometimes we are required by law and regulations to collect and process this information about you, and, at other times, we consider it to be in our legitimate interest to collect and process this information, taking into consideration your privacy rights. In rare cases we also may be required to process your data to protect your vital interests or for a task in the public good.

European users also have several rights under the General Data Protection Regulation in certain circumstances, including the right to access, update and remove your personal data, object to particular processing, or file a complaint with our privacy team or a supervisory authority. You can find out more about Memorang’s approach to the GDPR, including how to exercise these rights, here. Note we may need to verify your identity before granting access or otherwise changing or correcting your information.

Data Protection Officer Contact Information Memorang, Inc.
Attention: Data Protection Officer
3307 Pico Blvd #A
Santa Monica, CA 90405

support@mail.memorang.com

f. California and Nevada Resident Rights

California residents’ rights

If you reside in California and are not a job applicant, employee, or employee of another company interacting with us in your job role, you have the right to request what information we collect, use, and disclose. You also have the right to request that we delete your information. The easiest mechanism is to log in to your account and delete your account using the option available on your Settings page. To make a request through our support team, you can contact us at support@mail.memorang.com. For requests submitted through our support team, we may need to take additional steps to verify you are the owner of the account, including confirming certain account information and ownership of the email address linked to the account. We will not discriminate against you because you have exercised any of your privacy rights under the California Consumer Privacy Act. You can designate an agent to make a request by having them execute a notarized power of attorney to act on your behalf.

Sales of personal information

Under California law, we are required to tell California residents if we “sell” information as that term is defined by applicable law. “Sell” means to share personal information with a third party for monetary or other valuable consideration. California residents, we do not sell your personal information based on our understanding of that term. We also have disclosure obligations in Nevada. We do not exchange Nevada residents’ personal information for money with anyone so they may license or sell the personal information to additional parties. We do not sell personal information of minors under the age of 16. Nevada residents may opt out of the future sale of their information to a third party so that they may license or sell information by emailing us at: support@mail.memorang.com

g. We Store Information In the United States

While Memorang operates internationally, many of our systems are based in the United States which has different data protection standards than the European Union.

Memorang participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List available at: https://www.privacyshield.gov/list.

Memorang is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Memorang complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, United Kingdom and Switzerland, including the onward transfer liability provisions. For example, we may use standard contractual clauses when we transfer your personal data to third parties outside the EEA or adopt other means to ensure that adequate safeguards are applied to your personal data, such as a relevant third party’s Privacy Shield certification or binding corporate rules (approved by EU data protection authorities and put in place to protect your personal data).

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Memorang is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Memorang permits EU and Swiss individuals whose personal information has been transferred to us choices about whether their personal information may be used for purposes other than the purpose for which it was originally collected or which was subsequently authorized. Individuals can make these choices directly within the Memorang Service or by contacting us at support@mail.memorang.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, free of charge, using the information provided at https://www.jamsadr.com/eu-us-privacy-shield.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

In addition to Memorang’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, when we transfer personal data to our partners or service providers outside the European Economic Area (EEA), we may also make use of other transfer mechanisms which have been approved by the European Commission, including the use of model contracts and the standard contractual clauses.

h. How Long We Retain Your Information

Memorang retains your personal information for as long as your account is active, to fulfill our legitimate business purposes, or to comply with our legal obligations. When these conditions no longer exist, Memorang removes that information in accordance with our standard deletion processes. Memorang may retain and use non-personal information, including information which has been de-identified, aggregated, or anonymized, indefinitely.

We retain records of support tickets and other communications between Memorang and our users, for example support emails, survey responses, feedback submissions, or comments on our blogs or other posts, indefinitely in order to better manage our support processes, maintaining accurate business records, and identifying other trends. We reserve the right to publish these communications in order to help us clarify or respond to your request or to help us support other users.

i. How We Secure Your Information

The security of your personal information is important to us. Memorang takes measures reasonably designed to protect against the unauthorized access, use, alteration or destruction of personal information.

We use our best efforts to follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. For example, our website and apps are designed to be protected by HTTPS encryption. When you enter credit card information on our order forms, that information is intended to be encrypted and is designed protected by our third-party payment providers. However, the Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. If you have any questions about security on our website, you can contact us at support@mail.memorang.com.

j. Changes to This Notice

Memorang reserves the right to modify this Privacy Notice at any time, so please review it frequently. If we materially change how we use your personal information, we will notify, by email, and/or by means of a notice on our website prior to the change becoming effective. If you disagree with these changes, you can delete your account at any time and/or stop using the Service. Your continued use of the Service constitutes your acceptance of any changes to this Privacy Notice.

5. How to contact us if you have questions

If you have questions or wish to send us comments about this Privacy Notice, please contact us at support@mail.memorang.com or write us:

Memorang, Inc.
Attention: Privacy
3307 Pico Blvd #A
Santa Monica, CA 90405