Version: 1.0

Effective Date: 20/07/2026

1. Purpose

This Safeguarding & Emergency Escalation Policy (“Policy”) explains how Memo supports the wellbeing and safety of Primary Users and how the platform may respond to certain events that could indicate that a user requires assistance.

Memo has been designed to support individuals, families, carers and care professionals by providing care coordination, wellbeing support and communication tools.

Memo is not an emergency response service and must never be relied upon as the sole means of protecting a person’s safety.

This Policy forms part of the Memo Legal Framework and should be read together with the:

• Terms of Use
• Privacy Notice
• Authority, Capacity & Representation Policy
• Family & Carer Agreement
• Professional User Agreement
• AI Transparency & Responsible AI Statement
• Camera, Audio & Location Services Policy

2. Our Safeguarding Principles

The design and operation of Memo is guided by the following principles:

• promoting dignity, independence and autonomy;
• respecting the wishes of the Primary User wherever lawful and appropriate;
• supporting person-centred care;
• encouraging early intervention where concerns arise;
• supporting—not replacing—family members, carers and professionals;
• protecting privacy while balancing safeguarding responsibilities;
• acting proportionately and lawfully.

3. Memo’s Role

Memo provides technology that may assist with:

• care coordination;
• wellbeing reminders;
• routine support;
• communication;
• optional safety monitoring;
• authorised notifications;
• escalation to nominated contacts.

Memo does not:

• provide emergency medical care;
• continuously monitor users;
• guarantee detection of emergencies;
• guarantee delivery of notifications;
• replace carers or healthcare professionals;
• determine whether abuse or neglect has occurred.

Safeguarding decisions always remain the responsibility of appropriately authorised individuals and organisations.

4. Optional Safeguarding Features

Depending upon the subscription, device configuration and user permissions, Memo may include features such as:

• scheduled wellbeing check-ins;
• medication reminders;
• hydration reminders;
• appointment reminders;
• inactivity detection;
• geofence notifications;
• safe arrival notifications;
• optional distress phrase recognition;
• optional fall detection (where compatible hardware is used);
• emergency contact notifications;
• family messaging;
• location sharing where authorised.

Availability of these features may vary by subscription, device and jurisdiction.

5. Wellbeing Check-ins

Memo may invite users to confirm that they are safe or respond to a scheduled wellbeing check.

If a response is not received, Memo may:

• issue a reminder;
• repeat the request after a defined interval;
• notify nominated contacts where configured;
• record that a scheduled check-in was missed.

A missed check-in does not necessarily indicate that an emergency has occurred.

Users may miss check-ins for many reasons, including sleeping, travelling, technical issues or choosing not to respond.

6. Distress Indicators

Where enabled, Memo may recognise certain words, phrases or patterns that could suggest distress.

Examples may include expressions indicating:

• fear;
• confusion;
• requests for help;
• disorientation;
• emotional distress.

Recognition of such indicators is based on automated processing and may not always be accurate.

Memo may:

• offer reassurance;
• encourage the user to contact a trusted person;
• suggest contacting emergency services where appropriate;
• notify nominated contacts if configured to do so.

Memo cannot determine whether a genuine emergency exists.

7. Falls and Inactivity

Where compatible devices support these features, Memo may detect:

• prolonged inactivity;
• potential falls;
• unusual patterns of movement.

Detection depends upon:

• compatible hardware;
• battery status;
• network connectivity;
• sensor performance;
• user behaviour;
• environmental conditions.

False alarms and missed detections may occur.

Users and carers must not rely solely upon these features.

8. Location and Wandering Support

Where location services have been enabled with appropriate authority, Memo may provide:

• GPS location information;
• geofence alerts;
• safe arrival notifications;
• route assistance;
• location sharing with authorised contacts.

Location information:

• may be delayed;
• may be inaccurate;
• may become unavailable due to technical factors.

Location services are intended to support care coordination and should not be regarded as continuous real-time tracking.

9. Emergency Escalation

Where configured by the user or an authorised representative, Memo may attempt to notify one or more nominated emergency contacts when predefined trigger conditions are met.

Possible triggers may include:

• repeated missed wellbeing check-ins;
• repeated distress indicators;
• prolonged inactivity;
• geofence events;
• compatible fall alerts;
• activation of an emergency assistance function.

Notification methods may include:

• push notifications;
• SMS messages;
• telephone calls;
• email;
• in-app alerts;
• other communication methods supported by the Service.

Delivery cannot be guaranteed.

The order, timing and method of notifications may vary depending upon technical availability and user settings.

10. Emergency Services

Memo is not connected directly to emergency services unless expressly stated for a particular service or jurisdiction.

Where Memo believes there may be a serious risk, it may encourage users or carers to contact the appropriate emergency services.

Users must not assume that emergency services have been contacted simply because Memo has generated an alert.

In any emergency, individuals should immediately contact the appropriate emergency services using the local emergency telephone number.

11. Responsibilities of Family Members and Carers

Family members and carers remain responsible for:

• deciding what level of supervision is appropriate;
• maintaining accurate emergency contact details;
• responding appropriately to notifications;
• ensuring compatible devices remain operational where monitoring features are relied upon;
• reviewing user settings periodically.

Memo supports, but does not replace, personal supervision.

12. Responsibilities of Professional Organisations

Care providers, NHS organisations and other professional users remain responsible for:

• safeguarding assessments;
• risk assessments;
• professional judgement;
• emergency procedures;
• staff training;
• escalation decisions;
• statutory safeguarding duties.

Memo should be regarded as one source of information within a wider safeguarding framework.

13. User Responsibilities

Users agree to:

• provide accurate emergency contact information;
• maintain devices in working order where monitoring features are used;
• report technical faults;
• seek appropriate professional assistance when required;
• avoid relying solely upon Memo for personal safety.

14. Privacy and Safeguarding

Where necessary to protect an individual or comply with legal obligations, Memry may process and disclose relevant information in accordance with:

• the Privacy Notice;
• applicable safeguarding legislation;
• UK GDPR;
• the Data Protection Act 2018;
• lawful requests from authorised bodies.

Any disclosure will be limited to what is reasonably necessary in the circumstances.

15. Safeguarding Concerns Identified by Memry

Where Memry becomes aware of information suggesting a credible risk of serious harm, abuse, neglect or exploitation, we may, where lawful and proportionate:

• contact the account administrator;
• contact an authorised representative;
• contact the relevant care organisation;
• preserve relevant account information;
• restrict account access;
• cooperate with statutory authorities;
• take other reasonable safeguarding measures.

Memry is not responsible for investigating safeguarding concerns or determining whether abuse has occurred.

16. Technical Limitations

Safeguarding features may be affected by:

• network outages;
• internet failures;
• power failures;
• hardware faults;
• depleted batteries;
• software updates;
• sensor limitations;
• user error;
• environmental conditions;
• third-party service interruptions.

Accordingly, Memo cannot guarantee:

• continuous monitoring;
• uninterrupted operation;
• detection of every incident;
• successful notification delivery;
• immediate response.

17. Limitation of Responsibility

Memo is designed to support wellbeing and care coordination.

Nothing in this Policy should be interpreted as creating a duty for Memry to supervise, monitor or guarantee the safety of any individual.

Responsibility for personal care, supervision, safeguarding and emergency response remains with:

• the Primary User;
• authorised family members;
• carers;
• healthcare professionals;
• care organisations;
• emergency services;
• other appropriate authorities.

Nothing in this Policy excludes liability where exclusion is prohibited by law.

18. Review and Continuous Improvement

Memry continually reviews safeguarding features in light of:

• user feedback;
• technological developments;
• regulatory guidance;
• incident learning;
• advances in artificial intelligence;
• changes in legislation.

Updates may improve the way Memo identifies and responds to potential safeguarding concerns.

19. Changes to this Policy

This Policy may be amended from time to time to reflect changes in law, technology or the development of Memo.

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

20. Contact

Questions regarding safeguarding or emergency escalation should be directed to:

Memry Corporation Limited

Safeguarding & Privacy Team

Email: Team@Memry.io

Website: www.Memry.io

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