Gizlilik Politikası
Son güncelleme: June 2, 2026
Vocabulous US Inc. (“us”, “we”, or “our”) operates the Memora mobile application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Definitions
- Service — Service is the Memora mobile application operated by Vocabulous US Inc.
- Personal Data — data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data — data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies — small files stored on your device (computer or mobile device).
- Data Controller — the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
- Data Processors (or Service Providers) — any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User) — any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you. For example, we collect information directly from you when you create an account, fill out a form, request Services or customer support, or otherwise communicate with us. We also collect certain information from you or your device automatically when you interact with our Services, such as activity or usage information. We use this information to provide you Services and for other business purposes. The types of information about you that you provide and that we collect automatically are listed below along with our uses of that information.
Types of Data Collected
1. Personal Data
- Identifiers: includes name, user name, email address, online identifier.
- Transaction Data: includes details about payments to and from you and details of in-App purchases.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
2. Usage Data
When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).
Use of Data
Vocabulous US Inc. uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To communicate with you
- For direct marketing
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
Purposes for which we will use your personal data
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To install the App and register you as a new App user | Identity, Contact, Financial, Device | Your consent |
| To process in-App purchases and deliver Services including managing payments and collecting money owed to us | Identity, Contact, Financial, Transaction, Device, Marketing and Communications, Location | Your consent; Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you including notifying you of changes to the App or any Services | Identity, Contact, Financial, Profile, Marketing and Communications | Your consent; Performance of a contract with you; Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/Services); Necessary to comply with legal obligations |
| To enable you to participate in a prize draw, competition or complete a survey | Identity, Contact, Device, Profile, Marketing and Communications | Your consent; Performance of a contract with you; Necessary for our legitimate interests |
| To administer and protect our business and this App including troubleshooting, data analysis and system testing | Identity, Contact, Device | Necessary for our legitimate interests (running our business, administration and IT services, network security) |
| To deliver content and advertisements, make recommendations, measure advertising effectiveness, and monitor trends to improve the App | Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, Location | Consent; Necessary for our legitimate interests (to develop our products/Services and grow our business) |
Legal Basis for Processing Personal Data under the GDPR
The legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Vocabulous US Inc. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data
Vocabulous US Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.
Vocabulous US Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 1 (one) year then we will treat the account as expired and your personal data may be deleted.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Vocabulous US Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If Vocabulous US Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
Disclosure for Law Enforcement
Under certain circumstances, Vocabulous US Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Vocabulous US Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Vocabulous US Inc.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
Our Service does not respond to “Do Not Track” (DNT) signals.
Your Data Protection Rights under the GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Vocabulous US Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Vocabulous US Inc. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
- Google Analytics — a web analytics service offered by Google that tracks and reports website traffic. Google Privacy Policy
- Firebase — an analytics service provided by Google Inc. Google Privacy Policy
- Amplitude — a digital optimization service that monitors the use of our Service. Amplitude Privacy
- AppsFlyer — an analytics service that provides measurement, analytics, engagement, and fraud-protection technologies. AppsFlyer Privacy Policy
Advertising
- AdMob by Google — provided by Google Inc. Opt-out instructions · Google Privacy Policy
- Axon (AppLovin) — AppLovin’s advertising platform, including Axon AI, an advertising optimization engine that collects device and network information, app usage data, and engagement signals. AppLovin Privacy · About Axon AI
- Meta Audience Network — Meta’s advertising tools may serve ads and collect device identifiers, in-app actions, and purchase activity. Meta Privacy Policy
Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing.
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.
The payment processors and subscription management platforms we work with are:
- Apple Store In-App Payments — Privacy Policy
- Google Play In-App Payments — Privacy Policy
- Adapty — a subscription and paywall management platform that enables in-app purchase infrastructure, subscription analytics, and A/B testing of paywalls. We are the Data Controller; Adapty acts as a Data Processor on our behalf. End-users Privacy · Adapty Privacy
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: lexi@vocabulous.us
- By post: Vocabulous US Inc., 650 Northeast 9th Avenue, Boynton Beach FL 33435, United States