We respect your privacy



Privacy Policy

Emmetros Limited Privacy Policy last updated on 11 December 2017.

This Privacy Policy describes the policies and procedures we adhere to regarding the collection and use of your personal information. It governs your interactions, including via email, with emmetros.com, memorysparx.com, the MemorySparx software and any related websites or applications (together, “the Services”). 

  1. By accessing the Services you agree to accept and be bound by this Privacy Policy and the Terms of Service.  

  2. If you do not agree with this Privacy Policy or the Terms of Service, you should not use the Service. 

  3. The protection of your sensitive personal information is our number one concern.  You own it.  It is yours.  We are doing everything we can to safeguard it. 

  4. When you access the Services we collect and process information, including personal information.  Our primary goal in doing so is to enhance your experience.   The personal information we collect may include:

    • Basic subscriber information collected when you open an account and make a purchase.  For example, an email address, billing address, or other payment information.  

    • Personal content received through your use of the Services.  For example, photos or health information that you add to MemorySparx One. 

    • Logs collected through cookies, crash reports, or analytics tracking tools.  This data helps us to understand how you and others interact with the service so that we can make improvements, provide features, and diagnose issues. 

    • Location information collected from your IP address or the location information provided by the device you use to connect to the Service. This data helps us to localize the service. 

    • Device information such as the type of device you use and the operating system of your device.  This helps us to ensure that the Service works as expected on your device.  

  5. Emmetros Limited (“Emmetros”, “we”, “us”) is based in Canada.  The laws of Canada are very strict regarding the collection and use of personal information.  The United States and the European Union have similar laws.  The Services meet or exceed all of these laws.

  6. To the extent practicable, we transmit and store your personal information in an encrypted form on professionally managed services located in secure storage facilities.  Encryption means that if someone tries to look at the information on our servers, instead of “Paul McCartney”, they will see something like “@%1,B4ss4Vq;j#y”. 

  7. When you use the Services on a mobile device, your data is stored locally on that device.  Data stored on your device is encrypted.  You should also set a device password to prevent unauthorized access to your apps.

  8. If you access the Services from a computer located outside Canada, the United States, or the European Union, you will be considered to have consented to us transferring your personal information from those jurisdictions to a country which may have lower standards regarding the protection of such information. 

  9. To get the most out of the Services, we encourage you to provide us with a wide range of information about you such as who you are, activities you enjoy, what medical conditions you have, and other information about you and your family and friends that you use during a normal day and you don’t want to forget.  You are providing us with this information so that the Services can enhance your independence.  The more information you provide us, the better able we will be able to assist you. 

  10. In order for us to provide you with a useful product, we may need to collect, transfer, modify, analyze, and store your personal information. And to the extent practicable, we encrypt and anonymize your information so no-one else can see it. 

  11. We may use and then disclose (in anonymized form) the information we derive from your interaction with the Services in order to enable us to adjust your user experience. 

  12. Upon request by email to privacy@emmetros.com we will notify you of the personal information which we store about you. Any exceptions provided by statutory law and the predominant legal interests of Emmetros or any third parties shall be reserved. You may also request that any incorrect or incomplete personal information stored about you be corrected or that the personal information stored about you be deleted. Emmetros does not take any responsibility for any consequences of you failing to provide accurate information to us or of you failing to keep it up to date.  The personal information stored about you and by which you are identifiable will be held by Emmetros unless and until you or a person you authorize has asked us to remove such personal information, subject to reasonable limits if there has been no activity on your account for an extended period of time. 

  13. Our services use tracking technology to report on who uses the services and what features or web pages they use within the service.  Some of this information might personally identify you, for example, we might see your name, email address, or location information. Most of the information collected by tracking technology is anonymous, such as the number of visitors to a webpage. Personal content that you add to the MemorySparx application is not collected by tracking technology.  You may choose not to accept cookies in your web browser but doing so can interfere with the functionality of the website.  By accessing the services, you agree to the transfer and storage of some information in the form of tracking technology, including browser cookies.

  14. Emmetros employees and other trusted parties will from time to time require access to some of your personal information in order to provide you with support and to maintain the functionality of the Services.  We will endeavor to access only the minimum information required to complete the task. 

  15. Emmetros uses a range of technologies to ensure the protection of your personal information.  Please note, however, that information transmitted unencrypted over an open network, such as the internet or email, is easier for others to access and we cannot guarantee, and are not responsible for, the confidentiality of any communication or information transmitted via such open networks. When disclosing your personal information via an open network, you should consider that it is potentially accessible to others, and consequently, may be collected and used by others without your consent.  In particular, while individual data packets are often encrypted, the names of the sender and recipient are not.  Even if both the sender and recipient are located in the same country, data may be transmitted via such networks to other countries regularly and without controls, including countries that do not afford the same level of protection as Canada.  Your personal information and other data may be lost during transmission or may be accessed by unauthorized parties.  We do not accept any liability for direct or indirect losses as regards the security of your personal information during its transfer via Internet. 

  16. We will not use your personal information for marketing purposes, including the distribution of promotion emails, and will not sell, rent or otherwise make available any personal information submitted by users to any third parties without the relevant user’s consent, except as otherwise allowed under this Privacy Policy or required by law. 

  17. You authorize us to de-identify your personal information and subsequently to copy, process, use, publicly disclose and distribute the personal information in anonymized form for research, academic and statistical purposes. Such anonymized information shall no longer be considered “personal” information.  We want to enable experts, such as university researchers, to study ways in which the lives of people affected by memory loss can be improved.  We think you probably do, too.

  18. You authorize us to receive, review and store technical usage information (such as crash reports) retrieved from the devices you are using to access the Services. 

  19. We reserve the right to disclose your personal information to the extent we reasonably believe it is necessary in order to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce Apple’s End User License Agreement (to the extent it governs your use of our applications) and this Privacy Policy, including investigations of a potential violation thereof, (iii) detect, prevent or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or to (v) protect the rights, property or safety of Emmetros, its users and the public. 

  20. Please note that we use encryption software that may be subject to export control regulations. 

  21. The Services may contain links to websites, applications or materials that are not operated by Emmetros. They are not subject to this Privacy Policy and Emmetros is not responsible in any way for their content or accuracy or their policies regarding the treatment of personal Personal Information and information. You access them at your own risk.  We recommend that you read their policies and check how they protect your personal information and confirm for yourself whether they are trustworthy. 

  22. This Privacy Policy shall in all respects be governed by Canadian substantive law. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Ontario, Canada, and you consent to such jurisdiction of and venue in such courts and waive any objection as to inconvenient forum. 

  23. We may revise this Privacy Policy from time to time. The most current version will be available at our website at https://emmetros.com/privacy.  The revised Privacy Policy shall become effective from the date of its publication on the website.  By continuing to access the Services after those revisions become effective, you agree to and accept to be bound by the revised Privacy Policy.

If you have questions or concerns about this Privacy Policy please contact us by email at privacy@emmetros.com or contact us by mail at:

Emmetros Limited
Accelerator Centre, West Entrance
295 Hagey Blvd.
Waterloo, ON, N2L 6R5