Version: 1.0

Effective Date: 20/07/2026

1. Introduction

This Privacy Notice explains how Memry Corporation Limited (“Memry”, “we”, “our” or “us”) collects, uses, stores, protects and shares your personal information when you use the Memo platform, including the Memo mobile application, web services, connected devices, the Memry Vault, and any related services (collectively referred to as the Service).

We are committed to protecting your privacy and handling your personal information fairly, lawfully and transparently in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Please read this Privacy Notice carefully before using the Service.

2. Who We Are

Data Controller

Memry Corporation Limited is the data controller responsible for the personal information processed through the Service, except where another organisation (such as an NHS body or care provider) acts as the data controller for information processed on its behalf.

Contact Details

Memry Corporation Limited

Registered Office: [Insert Registered Office]

Email: [Insert Privacy Email Address]

Website: [Insert Website]

If appointed, details of our Data Protection Officer (or Privacy Lead) will be published on our website.

3. Scope of this Privacy Notice

This Privacy Notice applies to:

• Primary Users
• Family members
• Informal carers
• Professional carers
• Care organisations
• NHS organisations
• Healthcare professionals
• Website visitors
• Mobile application users
• Memry Vault users
• Individuals whose personal information is processed through Memo

Separate agreements may apply to organisational customers.

4. Personal Information We Collect

Depending on how you use the Service, we may collect:

Identity Information

• Name
• Date of birth
• Contact details
• Account credentials
• User profile information

Care Information

• Care preferences
• Daily routines
• Reminder schedules
• Support requirements
• Emergency contacts

Health and Wellbeing Information

Where necessary to provide the Service, we may process limited health and wellbeing information supplied by you or an authorised representative.

This may include information relating to:

• memory support
• medication reminders
• mobility
• wellbeing
• accessibility requirements
• care preferences

Memo is not intended to create or maintain formal medical records.

Location Information

Where enabled by the user or an authorised representative, Memo may process:

• GPS location
• geofence events
• safe arrival notifications
• emergency location information

Location services may be disabled at any time unless managed by an authorised organisation.

Voice Information

Memo is designed as a voice-first platform.

When you interact with Memo we may process:

• spoken requests
• voice commands
• transcribed speech
• AI prompts
• voice recordings where expressly enabled

Memo is not designed to continuously record conversations.

Device Information

We may collect:

• device identifiers
• operating system
• browser type
• application version
• IP address
• diagnostic information
• security logs

Memry Vault Content

Where you choose to use the Memry Vault, we may securely store:

• photographs
• videos
• audio recordings
• documents
• letters
• family memories
• messages
• certificates
• other content uploaded by authorised users.

5. Special Category Data

Some information processed by Memo may constitute Special Category Personal Data under Article 9 of the UK GDPR.

Where this applies, we process such information only where permitted by law and only where an appropriate lawful basis and Article 9 condition applies.

We limit the amount of sensitive information collected to that reasonably necessary for providing the Service.

6. How We Use Your Information

We use personal information to:

• create and manage user accounts;
• deliver Memo’s features and services;
• provide reminders and routines;
• support communication between authorised users;
• provide AI-powered interactions;
• enable wellbeing and safety features selected by users;
• improve accessibility;
• maintain security;
• investigate misuse;
• comply with legal obligations;
• improve and develop the Service.

We do not sell personal information.

7. Lawful Bases for Processing

Depending upon the circumstances, we process personal information under one or more of the following lawful bases:

• your consent;
• performance of a contract;
• compliance with legal obligations;
• protection of vital interests;
• legitimate interests pursued by Memry or authorised organisations;
• where applicable, the provision of health or social care services.

Where consent is relied upon, it may be withdrawn at any time without affecting processing already carried out lawfully.

8. Artificial Intelligence Processing

Memo uses artificial intelligence to assist users by generating conversations, reminders, summaries and responses.

AI processing may involve analysing information that users provide to deliver personalised support.

AI-generated responses:

• are intended to support users;
• may occasionally contain inaccuracies;
• should not replace professional judgement;
• should not be relied upon for medical diagnosis or emergency decision-making.

AI systems are continually monitored and improved to enhance safety, quality and reliability.

9. Sharing Your Information

We may share personal information with:

• authorised family members;
• authorised carers;
• professional care providers;
• NHS organisations where appropriate;
• trusted technology suppliers;
• secure cloud hosting providers;
• payment providers;
• identity verification providers;
• emergency services where legally justified;
• regulators or law enforcement where required by law.

We require service providers to protect personal information and process it only on our documented instructions.

We never sell personal information to third parties.

10. International Transfers

Where personal information is transferred outside the United Kingdom, we will ensure that appropriate safeguards are in place.

These safeguards may include:

• UK International Data Transfer Agreements;
• International Data Transfer Addendums;
• adequacy regulations;
• other safeguards recognised under UK data protection law.

11. Data Security

We use appropriate technical and organisational measures designed to protect personal information against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure;
• destruction.

Security measures may include:

• encryption in transit and at rest;
• role-based access controls;
• authentication measures;
• security monitoring;
• audit logging;
• vulnerability management;
• regular security reviews.

Although we work hard to protect information, no online service can guarantee absolute security.

12. Cookies

Our websites and online services use cookies and similar technologies to:

• operate essential website functions;
• remember user preferences;
• improve performance;
• analyse website usage.

Further information is available in our separate Cookie & Tracking Policy.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• restrict processing;
• object to certain processing;
• receive a copy of your information in a portable format;
• withdraw consent where consent is relied upon;
• complain about our handling of your information.

Some rights may be limited where exemptions under data protection legislation apply.

14. Retention of Information

We retain personal information only for as long as necessary to provide the Service, comply with legal obligations, resolve disputes and protect legitimate business interests.

Retention periods for different categories of information are set out in our separate Data Retention & Deletion Policy.

15. Children’s Privacy

Memo is intended primarily for adults.

Where information relating to children is processed, it will normally arise because a family member includes information about relatives within the Memry Vault or other authorised family features.

We process such information only where lawful and appropriate.

Further details are provided in our Children’s & Visitors’ Privacy Statement.

16. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect legal, technical or operational changes.

Where changes are significant, we will provide appropriate notice through the Service or by other suitable means.

The latest version will always be available on our website.

17. Contact Us

If you have any questions about this Privacy Notice or our use of your personal information, please contact:

Privacy Team

Memry Corporation Limited

Email: Team@Memry.io

Website: www.Memry.io

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

18. Your Right to Complain

If you are dissatisfied with the way we have handled your personal information, we encourage you to contact us first so that we have the opportunity to resolve your concerns.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent authority for data protection matters.

Information about making a complaint can be found on the ICO’s website at www.ico.org.uk.