Privacy Policy for Memoryca

Last updated: August 17, 2026

1. Introduction

This Privacy Policy describes how Memoryca (hereinafter: "we", "us", or "our app"), with registered address at Put Vrila 9, 21400 Supetar, collects, processes, stores, and protects your personal data.

By using our app, you agree to the collection and processing of data as described in this Policy, in accordance with:

• General Data Protection Regulation (GDPR) (EU) 2016/679
• Croatian Implementation Law of the General Data Protection Regulation
• Electronic Communications Act (for cookies and similar technologies)

Data Controller: Memoryca
Contact Email: MemorycaSupport@gmail.com

2. What Data We Collect

2.1. Data you provide voluntarily:

• Account data: name, email address, profile photo
• Activity data: completed tasks, points, badges, level
• User content: photos submitted as task proof

2.2. Data we collect automatically:

• IP address (for security and fraud prevention)
• Device type and operating system (for optimization)
• Date and time of use (for activity limits and history)
• Advertising ID (Google Advertising ID / IDFA) and ad interaction data, collected by Google AdMob to show rewarded video ads
• Push notification device token (Firebase Cloud Messaging token), generated by your device so we can send push notifications
• Cookies (for functionality and user experience)

3. Why We Collect Your Data

We use your data exclusively for:

• Enabling registration and login
• Storing and displaying your tasks, points, and badges
• Administrative processing of tasks (review, approve/decline)
• Generating reward redemption codes
• Using your photos for promotional purposes (social media, website, ads) – you give this consent during registration
• Preventing abuse and fraud
• Fulfilling legal obligations (e.g., accounting records)
• Sending push notifications (daily reminders, reward messages, and app updates) through Firebase Cloud Messaging
• Showing rewarded video ads through Google AdMob and processing ad-related rewards

4. How We Use Your Photos

By using this app, you agree that:

• All photos you submit as task proof may be visible to other users within the app (on profiles, task history, stories)
• No one except administrators can download your photos (right-click and long-press are disabled)
• Photos may be used for marketing and promotional purposes (social media, website, promotional materials). You give this consent by checking the box during registration.
• If you wish to withdraw consent for promotional use, contact us at MemorycaSupport@gmail.com

5. Age Restriction – Children's Protection

This app is NOT intended for persons under 13 years of age:

• Date of birth field is mandatory during registration
• If you are under 13, you CANNOT register
• For users aged 13-18, we recommend use with parental/guardian supervision

6. Who We Share Your Data With

We do NOT sell your data to third parties. We share only with:

• Vercel – app hosting (EU servers)
• Supabase – database and image storage (EU servers)
• Google – authentication (only if you use "Login with Google")
• Google AdMob – advertising identifier and ad interaction data, to serve rewarded video ads. Google may use this data to personalize ads; you can opt out of ad personalization in your device settings.
• Google Firebase Cloud Messaging – device push token, to send push notifications to your device.

All partners have signed Data Processing Agreements (DPA) in accordance with GDPR.

6.1. Advertising ID and Google AdMob

To show rewarded video ads, our app uses Google AdMob. AdMob may collect your device's advertising identifier (Android Advertising ID or Apple's IDFA) and ad interaction data.

• You can reset or opt out of personalized advertising in your device settings (Settings → Google → Ads → Opt out of Ads Personalization, or Settings → Privacy → Tracking on iOS).
• We do not receive the advertising ID ourselves; Google processes it on our behalf under its privacy policy.
• Rewarded ads are voluntary; you choose to watch them to earn in-app rewards.

6.2. Push Notifications and Firebase Cloud Messaging

We use Firebase Cloud Messaging (FCM) to send push notifications, such as daily reminders and reward messages.

• When you grant notification permission, your device generates a unique FCM token that we store so we can target notifications to your device.
• You can disable push notifications at any time in your device settings (Settings → Apps → Memoryca → Notifications).
• We do not sell or share your FCM token with other advertisers.

7. How Long We Keep Your Data

• Account data: while account is active + 30 days after deletion
• Task history and points: while account is active
• Notifications (except those with reward codes): 10 days
• Notifications with reward codes: permanently
• Push notification device tokens: while the app is installed and you are opted in; deleted when you log out, disable notifications, or delete your account
• Advertising IDs: not stored by us; managed by Google on your device
• Accounting records: 11 years (in accordance with tax regulations)
• Photos: while account is active + 30 days after deletion

8. Your Rights

Under GDPR, you have the right to:

• Access – know what data we process about you
• Rectification – correct inaccurate or incomplete data
• Erasure ("right to be forgotten") – request deletion of all your data
• Restriction of processing – limit processing in certain cases
• Data portability – receive a copy of your data in a machine-readable format (JSON)
• Object – object to processing based on legitimate interest
• Withdraw consent – withdraw consent at any time (e.g., for photo usage)

How to exercise your rights:

• Email us at: MemorycaSupport@gmail.com
• In the app: Profile → Settings → "Download my data" or "Delete my account"
• You will receive a response within 30 days

Right to lodge a complaint: You have the right to lodge a complaint with the supervisory authority – AZOP (Croatian Personal Data Protection Agency).

9. Data Security

We have implemented:

• TLS/SSL encryption for all data in transit
• Row Level Security (RLS) – users see only their own data
• Regular security reviews and updates
• Limited data access – only administrator has full access

Despite all measures, we cannot guarantee absolute security. In case of a data breach, we will notify you and AZOP within 72 hours.

10. Cookies

We use cookies only for:

• Maintaining login session (session cookies)
• Improving user experience (preferences)
• Analytics (user count, feature usage)

You can disable cookies in your device settings, but some app features may not work correctly.

11. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy periodically. Significant changes will be notified via:

• In-app notification
• Updated date at the top of this document

Changes take effect immediately upon publication, unless otherwise stated.

12. Contact

For all privacy-related questions, exercising your rights, or withdrawing consent:

📧 Email: MemorycaSupport@gmail.com
📮 Address: Put Vrila 9, 21400 Supetar