1. Introduction.

This Privacy Policy (the “Policy”) explains how Heirloom Media Technologies Inc., dba “Remento” (“Remento”, “we”, “us”, “our”) collects, uses, and discloses personal information through Remento’s website (the “Website”) and its memory recordation platform (the “Platform”, and collectively with the Website, the “Services”).  By using or accessing the Services in any manner, you acknowledge that you have read and understand the practices and policies outlined in this Policy.  Any capitalized terms that are not defined in this Policy are defined in our Terms of Service. 

2. Information collected and how we use it.  

In short: You and other Project Members will have the opportunity to provide us with certain personal information about you and others. In addition, we may collect certain personal information automatically through your use of the Services. The rest of this section provides a more detailed explanation of the personal information we collect, how we use that personal information, and our lawful bases for processing that personal information. 

1. Voluntarily Disclosed Information. The following table identifies the specific purposes for which you may voluntarily disclose personal information to us, along with our lawful bases for processing that personal information. 

2. Sensitive Information. To the extent you submit personal information that is considered “special” or “sensitive” under applicable law, you hereby consent to Remento’s use of that personal information as necessary to provide the Services. You may withdraw this consent at any time by emailing privacy@remento.co
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3. Automatically Collected Information
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   In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you use our Services.
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   ‍Whenever you interact with the Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” and pixel tag information, the type of device you’re using to access the Services, the amount of time spent on the Services, and the page or feature you requested. We use the data we automatically collect from you to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We also use the data to ensure our advertisements are seen by users who are interested in our Services. You can learn more about our use of cookies and related technologies in our Cookie Policy. We collect this information with your consent (to the extent the information is not strictly necessary for our performance of the Services), to perform our contract with you, and for our legitimate interest of providing a smooth user experience on the Services. If we rely on your consent for the use of cookies (for example, for cookies from third-party advertisers, you can remove your consent by updating your preferences on the cookie banner.  

3. Disclosure of personal information. 

In short: We may disclose your personal information as detailed in this section. 

1. Personnel and Third Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. For example, we use a third party payment processor to process payments on our behalf, so the payment processor will have access to your name, postal address, and billing information. As another example, all data that we receive is stored on servers hosted by Google. 
2. Project Members; Other Viewers. Please note that if you submit any personal information in your submissions (whether a prompt, Story, or comment), other Project Members will be able to see that personal information. In addition, if you or any other Project Member make a Story available to the public via a link, then anyone who obtains access to that link will be able to view the Story and any of your personal information that is included in that Story. 
3. Third Party Applications. If you import Your Content from Third Party Platforms, Remento will allow the Third Party Providers to access or use your personal information and User Content as required for the interoperation of the Third Party Platforms and Remento’s Platform. Any Third Party Provider’s use of your personal information and Your Content is subject to the applicable agreement between you and the Third Party Provider. Remento is not responsible for any access to or use of your personal information or Your Content by Third Party Providers. You are solely responsible for the decision to permit any Third Party Provider to use your personal information or Your Content.
4. Targeted Advertising.  Remento advertises its Platform on third-party platforms like Google, Meta, and TikTok. These platforms place pixels and other similar beacons on our Services to measure, optimize and build audiences for Remento advertising campaigns on the platforms. This ensures that Remento’s advertising is seen by those who are most likely to be interested in such advertising by analyzing which content a user has viewed and interacted with through the Services. You can disable these pixels by updating your preferences on the cookie banner. With respect to the Meta Pixel, Meta may receive certain of your personal information in a hashed format. Meta may link this information to its own information from your accounts on Meta services (like Facebook) and also use it for its own promotional purposes in accordance with Meta’s Privacy Policy. The Meta Pixel also allows Meta and its partners to show you advertisements on and outside of Meta properties. You can view and adjust your ad settings on Facebook by following the instructions at this Facebook help page.

5. Analytics Services. We use Google Analytics to understand how visitors engage with our Services. You can learn more about the information that Google has access to at the following website: https://policies.google.com/technologies/partner-sites. 
6. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.
7. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements. 

4. International Transfers.

We may transfer the personal information of users from the European Economic Area or United Kingdom to the United States. When doing so, we rely on adequacy decisions, data transfer agreements, or other legally compliant mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below. 

5. Security.

‍We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. 

6. Your rights. 

In short: You can access and control your personal information as set forth in this section. If you reside in certain jurisdictions, like the European Economic Area (EEA), you have certain specific rights with respect to your personal information. 

1. Who To Exercise Your Rights With. You may have rights under data protection laws in relation to your personal information. You can learn more about your rights further down in this section. 
2. Rights of Users in the EEA, Switzerland, and UK. If you reside in the EEA, Switzerland, or the UK, you have the following rights:
   
   1. Request access to your personal information. You may request a copy of the personal information we hold about you and to check that we are lawfully processing it.  Where we have good reason, and where applicable law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so. 
   2. Request correction of your personal information. You may request that we correct any incomplete or inaccurate data we hold about you.
   3. Request erasure of your personal information. You may request that we delete or remove personal information where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.
   4. Right to Object to or Restrict Processing.  In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also restrict our processing of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.
   5. Request the transfer of your personal information to you or to a third party. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organization on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent. 
   6. Withdraw consent. You may withdraw your consent for our processing of your personal information where we are relying on consent to process that personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
3. Rights of All Users. Regardless of where you reside, through your account settings, you may access and modify your account information. If you would like us to modify or delete any personal information contained within Stories, or if you would like to exercise your rights under Section 6.2, you may submit the request to privacy@remento.co. Please understand, however, that it may be impossible to delete this information completely, due to backups and records of deletions. In addition, we may deny a deletion request if (i) the denial is necessary for us to comply with applicable law, or (ii) the information cannot be deleted without impacting the Services experience for Project Members. You may not request the removal of de-identified, anonymous, or aggregate data from our databases. 
   
   If you have authorized an agent to exercise your rights on your behalf, the agent may contact us at privacy@remento.co. Please note that to protect your personal information and the integrity of our Services, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request. 
   
   If you are not satisfied with any decision we make with respect to your request, you can let us know the reasons for your concern, and we will review your appeal. 

4. Supervisory Authorities. We welcome and appreciate the chance to address any concerns you may have about the Policy and our collection and use of your personal information. To the extent you feel like we have not addressed your concerns, and depending on your jurisdiction, you may have the right to make a complaint at any time to your data protection supervisory authority. For end users in the EEA, you can find contact information for each country’s supervisory authority here. For end users in the UK, you can find contact information for the Information Commissioner’s Office (ICO) on the ICO’s website here.

7. Retention of information.

‍Subject to your right to request deletion of your personal information in accordance with Section 6, we will retain your personal information as long as needed for your use of the Services, your approved receipt of marketing communications from us, our compliance with legal obligations, and to protect our or other’s interests.

8. How we respond to do not track signals.

We will honor your exercise of your rights with respect to your personal information in accordance with Section 6. Apart from those rights, we do not respond to “Do Not Track” signals.

9. Age of users.

Children under the age of 13 are not permitted to use, access or register for the Services in any way. We do not knowingly collect or solicit information from anyone under the age of 13. If we learn that we have collected personal information from a child under the age of 13, we will delete that information as quickly as possible. 

10. Changes to policy.

‍We’re constantly trying to improve the Services, so we may need to change this Policy from time to time as well. The date of the last modification will be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Services, you are indicating that you agree to be bound by the modified Policy.

11. Contact us.

‍If you have any questions or concerns regarding this Policy, please send Remento’s Data Privacy Officer a message at privacy@remento.co. You can send any other requests to support@remento.co, and we will try to resolve your concerns. 

Remento Cookie Policy

This Cookie Policy provides information about cookies, web beacons (also known as “tracking pixels”), and other tracking technologies (collectively, “Tracking Technologies”), how we and third parties use them on the Services, and how you can manage our use of these Tracking technologies with respect to your experience on the Services. 

What is a Cookie?

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Services. Cookies enable us to “personalize” the Services for users by remembering information about our users. 

Types of Cookies

Cookies can be categorized in different ways:

• Source:
  
  • First-Party Cookies: If we use first-party cookies, we put them on your device.
  • Third-Party Cookies: Third party cookies are placed on your device by a third party. 
• Duration: 
  
  • Session Cookies: Temporary cookies that expire once your session on the Services ends or your web browser is closed.
  • Persistent Cookies: Cookies that remain on your device for a longer period until you manually erase them or until their expiration date.
• Purpose:
  
  • Necessary Cookies - These cookies are necessary for us to operate the Services and their core features (e.g., account login).
  • Functionality Cookies – These cookies enable us to operate the Services in accordance with the choices you make. These cookies permit us to “remember” you in between visits. For instance, we will recognize your username and remember how you customized the Services (e.g., language preference, location), and these cookies allow us to provide you with the same customizations during future visits.
  • Analytical - These cookies analyze how the Services are used (e.g., browsing habits) and how the Services are performing. These cookies include, for example, Google Analytics cookies.
  • Marketing – These cookies track your online activity to help advertisers deliver more personalized content and targeted ads. These cookies can share that information with other organizations or advertisers. 

What is a Web Beacon?

A web beacon (also known as a tracking pixel) is an unobtrusive feature on web pages or emails that enables us to check whether a user has accessed some content. We may use web beacons to better understand how you and other users interact with the Service.

Tracking Technologies That We Use

We use third-party Tracking Technologies for the following purposes:

• To authenticate users of the Services
• Analysis of user activity on the Services
• Targeted advertisements on third-party platforms like Facebook, LinkedIn, and TikTok

How to Manage Tracking Technologies

You can manage your preferences for Tracking Technologies via the cookie banner on the Website. In addition, cookies are managed through web browsers, so please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. The National Advertising Initiative provides a helpful overview for disabling cookies. Please note that if you delete, or choose not to accept, cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.