Memorandum Unlimited Oy (”Memorandum” or “We”) respects Your privacy and is dedicated to protecting the privacy of those persons using (“User(s)” or “You”) game(s) and other services provided by Memorandum on a mobile or other platform (“Service”). This Privacy Policy helps You to understand what personal information (data) and anonymous/aggregate information Memorandum collects, and how We use it.

This Privacy Policy shall apply to Your use of the Service and we encourage You to read this document before using it. If You do not agree to the terms of this Privacy Policy, please do not use the Service.

Memorandum will not knowingly collect personal information from anyone under the age of 13. If You are under 13, please do not attempt to access or take in use our Service or send any information about yourself to us, including Your name, address, telephone number, or email address; if you are a minor in Your country of residence, please seek parental consent before use of the Service. If you believe that we might have any information from or about a child under the age of 13, please contact us at info@memorandum.fi

Personal information refers to information, which allows Users to be specifically identified as individual persons. We may also collect “non-personal information” meaning it can’t be used to specifically identify any persons. Non-personal information may also be result of removing the personally identifiable parts from the information. We collect and use both types of information and combinations of both types.

Memorandum shall not be responsible for the actions of third parties (including people, companies or services), the content of third-party websites, the use of information User provides to them, or any products or services they may offer.

1. Purpose of Processing Personal Information

Memorandum will only collect such personal information that is relevant for the purposes described in this Privacy Policy.

Personal information may be processed for the purposes of creating Service accounts, using, maintaining, customizing and developing the Service, contacting Users, providing services, sending customer and marketing information to Users, enabling communication in the Service, conducting research and creating reports. Memorandum may use collected information also to create a user profile.

Memorandum commits to adhere to the provisions of the Finnish Personal Data Act (Henkilötietolaki) and other such applicable laws and regulations pertaining to processing of personal information, as well as process personal information in compliance with good processing practice. All personnel processing personal information are obliged to keep such information strictly confidential.

2. Collected Information and Sources of Information

We collect several categories of information:

– Information You give to us

– Technically gathered information when You use our Service

– Information from third parties (including social networking sites without being limited to those) in relation to our service.

 

We will collect information that You give to us, for example when you sign up for or use our Service. This information can include your user name or e-mail address.

We will also collect information that is technically gathered when You use our Service. This information may include Your Internet Protocol address, time of your requests or actions in the service.

In order to enhance the service Memorandum may use tools or third-party analytical tools to collect and use non-personal information. IP-addresses, operating system, device information, access times, browser type and language and referring Web site addresses might be collected automatically. Memorandum may use this information to monitor and analyze the use of the services.

Memorandum may collect information on Users’ activities in the Service.

Memorandum may, at its own initiative or upon a User’s request, complement, correct or delete incomplete, inaccurate or outdated personal information.

3. Disclosing and Transferring Information

Memorandum will not disclose personal information stored in the register to third parties for direct marketing, market research, polls or public registers without User’s consent. Memorandum is not responsible for any processing of personal information by third parties. The information or profiles might be used for targeted in-Service marketing and other similar purposes.

In exceptional circumstances personal information may be disclosed to third parties if required under any applicable law or regulation or order by competent authorities, or in order to enforce the Terms and Conditions of the Service and to investigate possible infringing use of the Service as well as to guarantee safety of the Service.

Memorandum may share Your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business. Aggregate or anonymous information about You may be shared with advertisers, publishers, business partners, and other third parties.

Memorandum may use external service providers to provide technical solutions or services for processing stored information and access the stored information by using a technical interface. Memorandum may use third party service providers, such as e-mail service providers, credit card processors, information analyzers and business intelligence providers. Memorandum has right to share personal information as necessary for the aforementioned service providers to provide their services to Memorandum. Memorandum is not liable for the acts and omissions of these third parties. Memorandum may host the service in and transfer information for this purpose to countries outside the European Union or the European Economic Area in accordance with mandatory legislation and this Privacy Policy.

4. Protection of Information

The register will be maintained in external service providers’ servers with appropriate safeguards, such as password protection, granting the access to the stored information only to Memorandum. The register is protected by appropriate industry standard, technical and organisatory safety measures. The database will be accessible only to those persons expressly authorized by Memorandum. Although We make good faith efforts to store the information collected on the services in a secure operating environment that is not available to the public, We cannot guarantee the absolute security of that information during its transmission or its storage on our systems.

5. Cookies and Tracking Technologies

A cookie is a string of information or a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Memorandum uses cookies to help it identify and track visitors, their usage of the Service and website, and their website access preferences, improving quality, tailoring recommendations, and developing the Service. Users who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Service and/or website, with the drawback that certain features of the website may not function properly without the aid of cookies. In addition to cookies, We may use other now and later developed tracking technologies. Tracking technologies may set, change, alter or modify settings or configurations on Your device.

The cookies will not enable Memorandum to access and review information stored on a User’s computer. Memorandum may feature advertisements served by third parties that deliver cookies to User’s computer/device or use other tracking tools so the content accessed and advertisements can be tracked by using your device identifier, MAC address, IMEI, locale, geo-location information, and IP address.

These third party services shall be governed by separate privacy policies and this Privacy Policy does not apply and Memorandum shall not be responsible for such third party data collection.

6. Information on the processing of personal information

Users are entitled to review any information collected on him/her and stored in the register. When User wishes to use the above right to review stored information, User should send a signed request thereof to Memorandum using the contact details below.

Users may opt-out of receiving promotional emails by following the instructions in those emails. If You opt- out, Memorandum may still send You non-promotional customer information, such as emails about Your account or Memorandum’s ongoing business relations.

7. Changes to the Privacy Policy

Memorandum may change this Privacy Policy from time to time, and at Memorandum‘s sole discretion. All changes hereto will be made available on this website, which is why Memorandum encourages Users to frequently check this page for any changes to this Privacy Policy. Changes hereto will not prejudice Users’ rights without their consent.

8. Controller and the person in charge

The User may at any time contact Memorandum at the address here below.

Memorandum Unlimited Oy
Business ID: 2893104-2

Address:
Kotamäenkuja 6 As. 7,
40800 VAAJAKOSKI,
Finland

Email: info@memorandum.fi
www.memorandum.fi

Contact person: Elina Rauhala, CEO