Version: 1.0

Effective Date: 20/07/2026

1. Purpose

This Children’s & Visitors’ Privacy Statement (“Statement”) explains how Memry Corporation Limited (“Memry”, “we”, “our” or “us”) handles personal information relating to children and visitors who may be present when the Memo platform is being used.

Memo is designed primarily to support adults, particularly older people and individuals living with dementia, mild cognitive impairment or other memory-related conditions. It is not intended to be used as a service for children.

This Statement forms part of the Memo Legal Framework and should be read alongside the:

• Privacy Notice
• Terms of Use
• Camera, Audio & Location Services Policy
• Memry Vault Privacy Policy
• Authority, Capacity & Representation Policy

2. Who This Statement Applies To

This Statement applies to:

• children who may interact with or be mentioned within Memo;
• grandchildren and other young family members;
• visitors to a Primary User’s home or care setting;
• individuals who may be incidentally captured through authorised use of Memo’s optional features;
• parents, guardians and others acting on behalf of children.

3. Memo Is Not Directed at Children

Memo is intended primarily for adults.

We do not knowingly provide Memo directly to children as a standalone service, nor do we intentionally collect children’s personal information except where it arises as part of authorised family, care or legacy features.

4. Children’s Information

Children’s information may be processed where it is reasonably necessary for features such as:

• family contact lists;
• emergency contact details;
• family messaging;
• the Memry Vault;
• family photographs;
• family videos;
• family stories;
• greetings and recorded messages;
• family relationship information.

Only the minimum information reasonably necessary should be included.

5. Parents and Legal Guardians

Where children’s personal information is uploaded to Memo by a parent, guardian or another authorised adult, that individual is responsible for ensuring they have the legal authority to provide the information.

Parents and legal guardians may exercise applicable privacy rights on behalf of children in accordance with relevant data protection legislation.

6. Schools and Educational Organisations

Memo is not designed as an educational platform.

If a school, educational organisation or youth service contributes information to Memo for a lawful purpose, it remains responsible for ensuring that it has the appropriate legal authority and complies with applicable legislation and its own safeguarding and privacy obligations.

7. Family Visitors

Memo may be used in private homes, supported living accommodation, residential care settings or healthcare environments where family members, friends or visitors are present.

Visitors should be informed, where reasonably practicable, if optional Memo features capable of processing personal information are active.

Visitors should avoid sharing confidential information through Memo unless they understand how the Service is being used.

8. Incidental Recordings

Where optional voice, camera or wellbeing features are enabled, it is possible that children or visitors may be incidentally included in:

• voice interactions;
• photographs;
• video content;
• family recordings;
• messages stored in the Memry Vault.

Memo is not designed for continuous surveillance or continuous recording.

Any incidental capture should be limited to what is reasonably necessary for the operation of the Service.

9. Consent

Where consent is required by law, users are responsible for obtaining any necessary permissions before uploading information relating to another person, including a child.

Nothing in this Statement removes the obligation to comply with:

• UK GDPR;
• the Data Protection Act 2018;
• safeguarding legislation;
• other applicable legal requirements.

10. Restricted Processing

Memry seeks to minimise the processing of children’s information.

Unless required for an authorised feature or another lawful purpose, we do not intentionally:

• create behavioural profiles of children;
• use children’s information for advertising;
• use children’s information for marketing;
• make automated decisions affecting children;
• sell children’s personal information.

Processing is limited to what is reasonably necessary for the operation of the Service.

11. Family Photographs and Memories

The Memry Vault is intended to preserve family history and memories.

Users may upload photographs, videos, audio recordings and other materials that include children where they have the appropriate authority to do so.

Users remain responsible for ensuring that uploaded material:

• is lawful;
• respects the privacy of others;
• does not infringe copyright or other legal rights;
• is appropriate for long-term family storage.

12. Artificial Intelligence

Where children’s information is lawfully included within Memo, AI may process that information solely for authorised functions, such as:

• retrieving family memories;
• responding to authorised user requests;
• assisting with reminiscence activities;
• supporting communication.

Memo is not designed to profile, assess or make decisions about children.

13. Data Security

Children’s and visitors’ information is protected using the same technical and organisational security measures applied throughout the Memo platform, including:

• encrypted transmission;
• encrypted storage;
• authenticated access;
• role-based permissions;
• security monitoring;
• audit logging where appropriate.

Access is limited to authorised users.

14. Retention

Information relating to children or visitors will be retained only for as long as reasonably necessary in accordance with the:

• Privacy Notice;
• Data Retention & Deletion Policy;
• Memry Vault Privacy Policy.

Users may request deletion of information where they are entitled to do so under applicable law.

15. User Responsibilities

Users of Memo agree to:

• upload children’s information only where authorised;
• respect the privacy of visitors;
• avoid unnecessary collection of children’s information;
• use Memo responsibly around children and visitors;
• comply with all applicable safeguarding and privacy laws.

16. Changes to this Statement

Memry may update this Statement to reflect changes in legislation, regulatory guidance or the development of the Memo platform.

Material changes will be communicated through the Service or by other appropriate means.

17. Contact

Questions regarding this Statement or the handling of children’s or visitors’ personal information should be directed to:

Memry Corporation Limited

Privacy & Information Governance Team

Email: Team@Memry.io

Website: www.Memry.io

Registered Office: The Towers Building, 6 Brincliffe Crescent, Sheffield, S119AW UK