Privacy Policy

1. Controller and Event Host Roles

For personal data we actually receive or decide how to process, Teineteine OÜ is the controller. You can contact us at info@everydayapps.eu. We have not appointed a data protection officer.

For guest recordings and event content created in Memo, the event host or device operator decides why and how that content is recorded, used, shared, kept, or deleted. Because Memo does not upload those recordings or event settings to us, we are generally not the controller or processor of that event content. The host or operator is responsible for privacy notices, consent or other legal basis, and requests from guests appearing in recordings.

2. Summary

• No account is required to use Memo.
• Recorded videos are saved to the device Photo Library and are not uploaded to our servers by Memo.
• Memo works offline for recording and saving videos. Network access is used for Apple App Store / StoreKit purchase flows and for links you choose to open, such as support or legal pages.
• We do not use third-party analytics SDKs, advertising SDKs, or cross-app tracking in Memo.
• Apple, iOS, iCloud Photos, email providers, or other apps and services you choose to use may process information under their own terms and privacy policies.

3. Information Processed on Your Device

Memo does not operate a backend that receives your videos, guest messages, event photos, prompts, or event settings. The following information is processed locally on the device to provide the app:

• Event setup data - questions, selected photos, language preferences, recording duration, and related settings configured by the host or operator.
• Recorded videos and audio - camera and microphone input used to create guest video messages. Finished recordings are saved to the device Photo Library. Memo may store the question prompt as video metadata so the host can see which question was answered.
• Device permissions - camera, microphone, Photo Library, and local device authentication permissions. Permission prompts and biometric or passcode checks are handled by iOS on the device.
• Purchase entitlement data - if you buy a pass, Memo stores local entitlement details such as product identifier, transaction identifiers, purchase date, expiry date, and a random device-bound identifier in the device Keychain to unlock the paid features on that device.
• App preferences and technical state - language choices, onboarding flags, local settings, and device storage checks needed to operate the app and warn about low storage.

4. Information We Receive

In normal use, we do not receive your videos, event setup data, guest identities, contact details, or payment card details. We may receive limited information if you choose to contact us for support, such as your email address, message content, screenshots, device or app details you provide, and any other information you decide to send us. Apple may provide us with App Store Connect sales, download, crash, and performance reports that are aggregated or otherwise limited according to Apple’s developer and privacy terms.

5. Purposes and Legal Bases

Where the GDPR or similar privacy laws apply, we rely on the following legal bases for personal data we process:

• Contract - to provide Memo, enable app features, manage local purchase entitlements, and respond to support requests related to your use of the app.
• Legitimate interests - to keep the app secure, prevent misuse or purchase bypass, understand aggregated App Store performance, and improve the app without tracking users.
• Legal obligations - to comply with accounting, tax, consumer protection, App Store, and legal request obligations where they apply.
• Consent - where iOS permission prompts or applicable law require consent, such as access to camera, microphone, or Photos. You can manage app permissions in iOS Settings.

6. Sharing and Third Parties

• Apple - processes App Store downloads, in-app purchases, refunds, device permissions, StoreKit, and related services according to Apple’s terms and privacy policy.
• iOS, Photos, iCloud, and sharing services - recordings saved to Photos may be backed up, synced, edited, exported, or shared through Apple or third-party services depending on the device owner’s settings and choices.
• Support and email providers - if you contact us, your message may be processed by the providers we use to receive and respond to email.
• Legal requirements - we may disclose information if required by law, a valid legal process, or to protect rights, safety, security, or the integrity of Memo.
• We do not sell personal data, share videos or event content with advertisers, or use Memo for cross-app tracking.

7. International Transfers

Because Memo does not upload event content to our servers, international transfers by us are limited. If you contact us or use Apple services, your information may be processed in countries outside Estonia or the EEA by Apple, email providers, or other services you choose to use. Where we are responsible for such transfers, we rely on appropriate safeguards or legal mechanisms required by applicable law.

8. Retention and Deletion

• Event setup data stays on the device until changed, deleted, or removed by deleting the app or erasing the device.
• Videos saved to the Photo Library remain there until the device owner deletes them from Photos or changes Photos/iCloud settings. Deleting Memo does not necessarily delete videos already saved to Photos.
• Local purchase entitlement data remains on the device for as long as needed to verify pass status, prevent duplicate transaction handling, and support device-bound access.
• Support emails are kept only as long as reasonably needed to handle the request, maintain business records, resolve disputes, or comply with legal obligations.
• Apple retains App Store and purchase information according to Apple’s own policies.

9. Security

Memo relies on iOS security features, local app storage, Keychain storage for purchase entitlement data, and device permissions. Admin settings can be protected with device authentication such as Face ID, Touch ID, or passcode where available. You should keep the device physically secure during events, use a device passcode, check storage and battery, and control who can access Photos. No security method is perfect, especially where guests can physically access a device.

10. Children and Guests

Memo is intended for event hosts and operators, not for unsupervised use by children. Guests of any age may appear in recordings if the host allows it. The host or operator is responsible for obtaining appropriate consent or other legal basis before recording children or other guests and for handling any guest requests relating to event recordings.

11. Your Rights

Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or receive a copy of personal data, and to withdraw consent where processing is based on consent. Because Memo stores event content locally and we do not receive it, most access, export, or deletion actions must be handled directly on the device, in the Photos app, or by the event host or operator. You can remove app data by deleting the app, and you can manage permissions in iOS Settings.

For privacy requests about information we actually hold, contact info@everydayapps.eu. We may need enough information to verify and process your request. You may also lodge a complaint with your local data protection authority. In Estonia, the supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee.

12. Changes and Contact

We may update this Policy when Memo, law, Apple rules, or our practices change. Changes apply when posted, unless a later date is stated. Questions: info@everydayapps.eu. See also our Terms of Service.