Privacy Policy

Last updated: May 20th, 2026

Welcome to https://memmachine.ai/ ("Site"), a website owned and operated by MemVerge, Inc., a Delaware corporation, ("MemVerge," “we,” “us” or “our”). This Privacy Policy explains how we collect, use, share and protect personal information (used interchangeably with personal data) processed in relation to the Site and the services, including our products, e.g., Memory Machine Cloud Edition, MemoryViewer, MemMachine.AI, and CXL ("Services") (collectively, “Platform”) and other interactions (e.g., customer service inquiries, social media etc.) that you may have with MemVerge. It also tells you about your choices with respect to our collection, use and disclosure of your personal information.

We recommend that you read this Privacy Policy carefully as it provides important information about your personal information and your rights under the law.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are located in the European Economic Area ("EEA") or the United Kingdom ("U.K."), this entire Privacy Policy applies to you. However, please see the section titled Additional Information for Users in the EEA and the U.K., which provides more information about which rights you have regarding the processing of your personal data.

If you have any questions, comments, or concerns regarding this Privacy Policy, our Cookie Banner and/or our data practices, or would like to exercise your rights, do not hesitate to contact us at privacy@memverge.com or see our information directly below for other methods to communicate with us.

Who We Are and How to Contact Us

MemVerge is a Delaware corporation with the following contact information:

1525 McCarthy Blvd.
Milpitas, CA 95035
United States
408.212.7040
EMail: privacy@memverge.com

Changes to This Privacy Policy

This Privacy Policy was last updated on the date indicated above. Our business and/or the Platform may change from time to time, and as a result, at times it may be necessary for MemVerge to make changes to this Privacy Policy. MemVerge reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy or your rights, we will promptly notify you of those changes by either (i) sending you an email to the email address in our records, if any, or (ii) we will post a notification on the Site. We encourage you to review this Privacy Policy from time to time. Your continued use of the Platform after any changes or revisions to this Privacy Policy will indicate your agreement to the terms of any such revised Privacy Policy.

Children’s Privacy

Our Platform is not directed to or targeted for children. MemVerge does not knowingly collect information from children under the age of 16. If you are under the age of 16, please do not submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Platform without their permission.

If you have reason to believe that a child under the age of 16 has provided personal data to MemVerge through the Platform, please contact privacy@memverge.com and we will endeavor to delete that information from our databases.

To Whom Does This Policy Apply

Throughout this Privacy Policy, “personal information” (or “personal data” as used interchangeably) refers to any information that is unique to an individual, such as name, address, email address, phone number, IP address and other information that can reasonably identify an individual.

This Privacy Policy applies to personal information (that we collect, store, disclose or otherwise process) from or about visitors to our Platform, including those who do or do not register or fill out a form with personal information ("Visitors"), and individuals or businesses who register, fill out a form with personal information or otherwise contact us in order to obtain information regarding the Platform ("Customers").

We use the terms ‘controller’ and ‘processor’ and ‘service provider’ as they are commonly understood under applicable privacy laws. Where MemVerge collects personal information as a service provider or processor to its Customers in connection with the Services, this Privacy Policy does not apply to the processing of such personal information. We are engaged as processor or service provider because our Customers decide how or why the personal information is collected and processed. When our Customers process personal information through our Services, they are responsible for ensuring compliance with the applicable laws, including providing their users with transparent notices. Our customer agreements and along with the Customer’s own privacy policy, rather than this one, will be applicable to the personal information processed, and we direct individuals to review that policy if they have any questions around how their data is obtained or processed within the Services or wish to exercise their rights (if any) with respect to that personal information.

If you have any questions about how a Customer you engage with processes your personal information, you should contact them directly.

Personal Information That We Collect

We collect the following categories of personal information:

Identifiers, such as a real name, unique personal identifier, online identifier, IP address, email address, or account name
Personal information categories such as a name, signature or telephone number
Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Payment Data, such as payment card type, last four digits of your credit or debit card number, billing address, phone number, and email
Internet or other similar network activity, such as browsing history or information on a user’s interaction with a website or application
Geolocation data
Professional or employment-related information, such as Customer contact data
Content of communications
Inferences drawn from other personal information, such as profile information reflecting a person’s preferences
Other information, such as the user content you provide in the input to our Services, including your prompts, and other content you upload, including without limitation, files, images, and audio depending on the Services you use

Sources Of Personal Information That We Collect

Information We Collect Directly From You

You can generally visit our Platform without having to submit any personal information. However, if you wish to use our Services, you will be asked to provide information about yourself.

Contacting Us

If you contact us at the email addresses or phone numbers listed on our “Contact Us” page or otherwise contact us, we process any personal information contained in those communications, including name, contact information and any other information that you submit to us.

Signing up for or using our Services

If you sign up for our Services, including through third parties or you use our Services.

Other Information We Collect

We also may collect information from third parties for lead production and from you at tradeshows and events.

Information We Collect Indirectly

Automatically Collected Information

If you are browsing or interacting with the Platform, we collect the same basic information that many other websites collect. Even if you are not registered, we, or authorized third parties engaged by us, automatically collect information about your use of the Platform, which consists of:

Device Information - information about the devices and software you use to access the Platform - primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Platform, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size and other similar hardware and software information, and language preference.
Usage Information - information about your interactions with the Platform, including access dates and times, device event information, log data, crash data, and cookie data. This information allows us to understand the screens that you view, how you’ve used the Platform (which may include administrative and support communications with us), and other actions on the Platform. We, or our authorized third parties, automatically collect log data when you access and use the Platform for all Visitors, even if you have not created an account or logged in. We use this information to administer and improve the Platform, analyze trends, track users’ use of the Platform, and gather broad demographic information for aggregate use.
Use of ZoomInfo for Visitor Identification. We use services provided by ZoomInfo Technologies LLC (“ZoomInfo”) to help us better understand and engage with Visitors to our Platform. ZoomInfo may collect and process certain information about your visit, including your IP address, to help us identify the business or organization associated with that IP address. This process may involve correlating your IP address with publicly available or licensed business data to infer potential business contact information. This information is used for our business-to-business (B2B) marketing and sales purposes, such as tailoring our communications and improving our outreach efforts. For more information about how ZoomInfo collects and uses data, including your rights and choices, please visit ZoomInfo’s Privacy Policy.

We (and certain authorized third parties) use cookies and similar technologies in order to collect Device and Usage Information. Some cookies are necessary to make the Platform and our content available to you, while others are meant to improve the Site and enable us to analyze and measure audience and traffic. For more information on our use of cookies and the data that they collect, see below in the Advertising, Cookies and Tracking Technologies section and our Cookie Banner.

MemVerge has a presence on some social media platforms, including X, Facebook, YouTube and LinkedIn. Through our accounts on social media platforms, we may, in some instances, collect personal information when you interact with our accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.

More information as regards our legal relationship with some of those social media platforms is available here for users in the EEA and the U.K.

How Do We Use Personal Information We Collect

We use your personal information for a number of different reasons, as further explained below.

In addition, for users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. Generally speaking, the main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal data are:

Performance of a contract - When your personal data is necessary to enter into or perform our contract with you.
Consent - When you have consented to our use of your personal data via a consent form (online or offline).
Legal obligation - When we need to use your personal information to comply with our legal obligations.
Legal claims - When your personal information is necessary for us to defend, prosecute or make a claim.
Legitimate interests - When we use your personal data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights. The information does not concern any special categories of data nor does it include personal details about individuals’ private lives. Moreover, MemVerge provides adequate notice, access and choice.

Below are the general purposes and corresponding legal bases (in italics) for which we may use your personal information:

Providing, updating and maintaining the Platform - In particular, we will use your data to ensure that the Site loads and works for you or provide you with notices regarding the Platform or other important information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
Responding to your queries and requests, including to respond to rights requests and Customer support requests - In particular, if you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry. Our use of your personal information in this way is necessary to perform our customer service obligations to you. If you are a Visitor or are an individual using our Platform, we may process your personal information for these purposes where it is in our legitimate interests to do so for customer services purposes. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
To otherwise communicate directly with you - In particular, if you contact us or otherwise send as a communication, we may process your personal information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
Improving the content and general administration of the Platform, including to perform system maintenance and upgrades - In particular, we may use Device and Usage Information to make changes to certain features or improve the Site, or use other information derived from personal information to offer new Services or make upgrades to the Platform. Legitimate interests
Detecting fraud, illegal activities or security breaches - In particular, we may use information such as your IP address to help us prevent abuse of the Platform and investigate any potential unauthorized use of the Platform or other security breaches. Legitimate Interests
Interacting with individuals on social media via our social media accounts and marketing our Platform - This includes any data we collect when you interact with our social media handles, and any advertising or re-targeting that we may undertake as set forth in this Privacy Policy. Consent where required (e.g., third-party cookies) or legitimate interests
Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform - In particular, we do this internally or via third parties such as Google Analytics, and other partners. Consent where required (e.g., third-party cookies) or legitimate interests
Sending marketing communications and newsletters, in line with your communication preferences
Consent (depending on location and relationship) or legitimate interests
As required by applicable law, legal process or regulation - We may use your personal data to comply with valid court orders and similar legal or regulatory obligations which apply to us. This may include where we reasonably consider it is in our legitimate interests (or the legitimate interests of others) to comply, as well as where we are legally required to do so. Legal obligations or claims

Disclosure of Personal Information

We disclose your personal information as described below.

Third-Parties and Service Providers

MemVerge discloses users’ information to our third party agents, contractors or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly. Below is an illustrative list of functions for which we may use third-party service providers:

Hosting and content delivery network services
Analytics services
Lead generation partners
Marketing and social media partners
Customer support services
Hosting and content delivery network services
Functionality and debugging services
Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

Third Parties

Third parties, such as External Ad Partners, as defined below, may also receive information from us as set forth in the Targeted Advertising section below. Unless described otherwise in this Policy, MemVerge does not sell or share any of your personal information with third parties for their promotional or direct marketing purposes.

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. In order to evaluate or as part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which MemVerge participates, or to a purchaser or acquirer of all or a portion of MemVerge’s assets, bankruptcy included.

Anonymized Information

We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform.

Legal Obligations and Security

In addition, MemVerge will preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to protect the safety or security of our Platform or to prevent spam, abuse, or other malicious activity of actors with respect to the Platform; or (iv) to protect our rights or property, or the rights or property of those who use the Platform.

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a mutual legal assistance treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

Advertising, Cookies and Tracking Technologies

We use cookies, pixels and similar tracking technologies to track the activity on our Platform and store certain information. Tracking technologies are used to collect and track information and to improve and analyze our Platform. The technologies we use may include:

Pixels

Pixels are small transparent images embedded in a website, email or ad and may provide information to platforms such as LinkedIn, Google, Meta or TikTok, who may combine your information with other information they have about you. We use pixels to automatically collect information when you visit our Platform. These technologies usually track advertising preferences from site to site, and gather data about a users’ browsing habits to improve the user experience.

Cookies

A cookie is a small data file which our Platform leaves on your web browser, in order for the Platform to remember you and your personal preferences when you return to the Platform. We use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies under each consent category below. We use the following types of cookies:

Necessary cookies: These are cookies that are required for the operation of our Platform and under our terms with you. They include, for example, cookies that make use of certain Services offered through the Platform.
Analytics and Performance cookies: They allow us to recognize and count the number of Visitors and to see how Visitors move around our Platform when they are using it, the bounce rate and traffic source. This helps us for our legitimate interests of improving the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
Functional cookies: These are used to recognize you when you return to our Platform. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
Advertising cookies: These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Platform and the advertising displayed on it more relevant to your interests. Please see the Targeted Advertising section below for more details.

Targeted Advertising

We advertise our Platform by targeting (and measuring the performance of) ads to Visitors and/or potential Customers on other websites and platforms, directly or through a variety of partners, including third party advertisers, ad server companies, social networks, and ad networks (collectively, “External Ad Partners”). In order to advertise our Platform, we or our External Ad Partners use the following information, whether separately or combined:

Device Information collected via cookies and similar technologies on our Platform
Information provided directly by Customers or individuals who reach out to us directly
Usage Information from your use of the Platform
Information from External Ad Partners
Information inferred by the categories of information described above.

When we serve ads based on the foregoing information, it is referred to as “targeted advertising” because External Ad Partners track your activity on and off the Platform in order to deliver targeted advertising based on your activity, such as one of your visits to the Platform. In addition, as noted above, the information that External Ad Partners collect from our Platform may be combined with other information from other sources and be used to build profiles on you and other individuals for the purposes of delivering targeted advertising.

In addition to advertising our Platform, we use Customer data and content to market our Platform, promote additional features or encourage Customers to share our Platform.

Ads, Cookies and Tracking Technologies Choices

For more information about interest-based advertising, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance ("DAA") (see DAA’s AppChoices tool, please use this link) or Network Advertising Initiative ("NAI") (see http://www.networkadvertising.org/choices/). Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may also continue to receive advertising, but that advertising may be less relevant to your interests. You may have more options depending on your mobile device and operating system.

Most web browsers are set to accept cookies by default. You will not be able to opt-out of any cookies or other technologies that are essential for the Platform. However, if you prefer, you can usually choose to set your browser to remove or reject certain first and third-party cookies. If you do this, however, you may have to manually adjust some preferences every time you visit a website, including ours, and some services and functionalities may not work. Alternatively, you may choose to enable the Global Privacy Control to automatically communicate your opt-out preferences to us when you use said browser. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platform.

You can also opt out by clicking on our Cookie Banner. Also see the Your Choices section below.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies

Google Analytics

We use third-party analytics services, such as Google Analytics, to generate and process statistical or demographic data. These third parties use cookies to compile reports on the Platform’s activity and Visitors, and provide other services related to Platform activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return Visitor, and any referring website. To learn more about how to opt-out tracking by Google Analytics, please click here.

Google reCAPTCHA

We use Google reCAPTCHA to protect our Platform from spam and abuse. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, Visitor behavior, operating services information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service.

Links to Third Party Content

This Privacy Policy applies only to the Platform. The Platform may contain content from third parties and links to other websites owned and operated by third parties - and therefore not controlled by MemVerge ("Third Party Content"). For instance, we may post YouTube videos with information about our Services or about third party products and services. To the extent that Third Party Content collects any personal data when you click on any such Third Party Content or a link to their Third Party Content, they are responsible for informing you of their data collection and privacy practices, among other things. When you click on a link that takes you to a Third Party Content, we suggest reviewing their privacy policies to understand what information they collect and how they collect it.

“Do Not Track” and GPC

MemVerge does not respond to Do Not Track ("DNT") browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com. MemVerge honors the Global Privacy Control signal.

Your Communication Preferences

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all marketing emails from MemVerge. You may also send an email to privacy@memverge.com. Please note you may still receive transactional messages.

SMS Communications

By providing your phone number, you consent and agree to opt-in to receive text messages. Message frequency depends on the transactional messages and marketing, and other services provided. You may opt out of receiving text messages by texting “Stop” at the end of any message you receive, or you can opt out of these communications by contacting us at privacy@memverge.com and sharing the phone number that you would like to opt out. You may also reply “Help” for help. Messaging and data rates may apply.

We may disclose your SMS opt-in or consent status, with affiliates or third parties that help us provide our messaging, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages. We will not share or sell your phone number, your opt-in to the SMS with third parties for their direct marketing purposes or for purposes unrelated to our Site or Website.

Your Choices

You have choices about how to protect and limit the collection, use, and disclosure of your personal data. Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections or delete your information, as applicable

Accessing and Changing Your Information

You can access and change certain information by contacting us at privacy@memverge.com.

California Privacy Rights

If you are a California resident, you may have certain rights with respect to your personal information under the California Consumer Privacy Act (CCPA) which may include the:

Right to know the source of the personal information we have about you, our use of that information, and whether and with whom it is shared.
Right to request deletion of the Personal Information we have collected from you and retained, subject to certain exceptions.
Right to request correction of any inaccuracies in the personal information we have collected from you and retained.
Right to limit the use of sensitive personal information. We do not collect, process or use sensitive personal information to make inferences about you and we use sensitive personal information only as set forth in this Privacy Policy and as permitted by applicable law.
Right to opt out of the sale or sharing of your personal information with third parties.

Selling or Sharing of Your Personal Information

The CCPA defines “sale” as the transfer of personal information for monetary or other valuable consideration. Although we do not “sell” personal information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share (for behavioral advertising) of personal information under California law. This may include showing you targeted or customized advertisements on other websites. You may opt out of the selling or sharing of your personal information. We do not knowingly “sell” or “share” the personal information of consumers under 16 years of age.

Shine The Light Law

If you are a California resident and have an established business relationship with us, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to privacy@memverge.com with the subject line “Shine the Light Request.”

State Privacy Rights

A number of US states may provide their residents with certain privacy rights. Depending on how the applicable privacy law defines a “sale,” we may sell personal information to third parties. For instance, if you are a resident of Texas, Colorado or Connecticut, our use of cookies and tracking technologies constitutes a sale of personal information to third-party advertisers. We also use cookies to display advertisements about our products to you on non-affiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws.

Whether we are processing your personal information, access to that information and to receive a copy of your personal information.
Correction of your personal information that is inaccurate.
Deletion of your personal information.
Opt out of the processing of your personal information for the purposes of providing you with targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects for a consumer.
Opt out of processing of your sensitive personal information for purposes other than what is necessary to provide our Platform.

Right to appeal. At times we may be unable to process requests relating to your personal information, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request via emailing privacy@memverge.com.

Under the Nevada Revised Statutes Chapter 603A, we do not currently engage in the “sale” of personal information.

The exact scope of these rights may vary by state. To exercise any of these rights, or to appeal a decision regarding a consumer rights request please contact us at privacy@memverge.com.

Exercising Your Privacy Rights

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.

The verifiable consumer request must: 1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person; and 2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We seek to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will not discriminate against you for exercising your privacy rights.

How Long Do We Keep Your Personal information?

General Retention Periods

We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

For any questions about data retention, please contact privacy@memverge.com.

Anonymization

In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.

Data Security and Integrity

We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.

If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.

Notwithstanding our security measures, no Internet or email transmission is ever fully secure or error free. In particular, personal data sent to or from the Platform may not be secure. Therefore, take special care in deciding what information you send to us via email or the Platform. For any questions about the security of your personal information, please contact privacy@memverge.com.

International Transfers

We are located in the United States, and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.

By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Privacy Policy.

We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take in our discretion include, for instance, entering into the standard contractual clauses ("SCC’s") and/or international data transfer agreement/addendum ("IDTA") in connection with any onward transfers of personal information. If you are an entity that is providing us with personal information regarding other individuals and we are acting as a data processor, then you may make a request from MemVerge for the SCC’s and/or IDTA. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.

Additional Information for Users in the EEA and the U.K

If you are in the EEA or the U.K., please read this section for more information.

Staying In Control of Your Information: Your Rights

If you are in the EEA or the U.K., you have certain rights in relation to your personal data:

The right to be informed - our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy);
The right of access - your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’);
The right to rectification - your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your account settings);
The right to erasure (also known as the ‘right to be forgotten’) - under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you).
The right to restrict processing - your right, under certain circumstances, to ask us to suspend our processing of your personal data;
The right to data portability - your right to ask us for a copy of your personal data in a common format (for example, a .csv file);
The right to object - your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing);
Rights in relation to automated decision-making and profiling - our obligation to be transparent about any profiling we do, or any automated decision-making; and
The right to lodge a complaint at any time to the supervisory authority for data protection issues in your country of residence - however, we ask that you please contact us first so that we can first address your concerns.

These rights are subject to certain rules around when you can exercise them.

If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at privacy@memverge.com. If you are in the EEA, you may contact our representative in the EEA, as explained below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive.

Alternatively, we may refuse to comply with your request under those circumstances. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).

We will respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

Sometimes, MemVerge acts as a ‘joint controller’ with certain third parties, namely certain social media sites, such as Facebook, LinkedIn, X, and YouTube. When MemVerge and a partner act as joint controllers, you (as a data subject) may exercise your rights against MemVerge and/or the third party. See below for our joint transfer addendums with such sites.

Facebook

In order to market our Platform and stay in touch with users, we maintain a Facebook page ("Facebook Products"). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities ("Joint Processing"):

Facebook Ireland Ltd.,
4 Grand Canal Square, Grand Canal Harbor
Dublin 2, Ireland

Information about the personal data that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy. MemVerge and Facebook have entered into entered into an agreement in order to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.

Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.

It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc..

X.com

With respect to our X.com page, we are joint controllers of your personal data with X. You may find the joint controller addendum at https://gdpr.x.com/en/controller-to-controller-transfers.html.

YouTube

With respect to our YouTube page, we are joint controllers of your personal data with YouTube. You may find the joint controller addendum at https://business.safety.google/controllerterms/.