Privacy

This Privacy Notice explains how MemoryBase collects, uses, stores, and shares your personal information when you use our AI chatbot context synchronization and management platform. We are committed to protecting your privacy and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

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1. Who We Are

MemoryBase ("we," "us," or "our") is operated by Unchained Technology Inc., a corporation organized under the laws of the State of Delaware, United States ("Unchained Technology"). Unchained Technology is the data controller responsible for your personal data for the purposes of the European Union General Data Protection Regulation ("GDPR") and is the "business" that determines the purposes and means of processing your personal information for the purposes of the California Consumer Privacy Act ("CCPA").

1.1 Corporate Affiliations

Unchained Technology is affiliated, through common ownership, with TX Labs, a separate legal entity organized under the laws of the British Virgin Islands ("TX Labs"). TX Labs operates products that are distinct from MemoryBase, including the Bless product and related services. The MemoryBase service and the products operated by Unchained Technology are maintained on separate technical infrastructure, with independent data systems, access controls, and engineering personnel. Personal data processed through MemoryBase is not shared with TX Labs and is not used in connection with any TX Labs-operated product. Use of MemoryBase does not constitute enrollment in, participation in, or consent to any service operated by TX Labs, including the Bless compute-sharing network.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, username, and password when you create an account.
• User Content: AI chatbot conversation context, prompts, preferences, configuration settings, and any other content you upload or synchronize through the platform.
• Communications: Information you provide when contacting our support team or responding to surveys.
• Payment Information: Billing details processed through our third-party payment processors (we do not store full payment card numbers).

2.2 Information Collected Automatically

• Usage Data: Features accessed, frequency and duration of use, interaction patterns, and synchronization activity.
• Device and Technical Data: IP address, browser type, operating system, device identifiers, and crash reports.
• Cookies and Tracking Technologies: We use cookies, pixel tags, and similar technologies to enhance your experience and analyze usage patterns.

2.3 Sensitive Data

Depending on the AI chatbot conversations you synchronize, your User Content may include sensitive personal information such as health data, financial details, or other special categories of data. We process this content solely to provide the synchronization and management services you request. We do not use sensitive content for advertising or profiling purposes.

3. How We Use Your Information

We use your information for the following purposes:

• Service Delivery: To provide, maintain, and improve the MemoryBase platform, including syncing and managing your AI chatbot context.
• Account Management: To create, authenticate, and manage your account.
• Security: To detect, prevent, and address fraud, unauthorized access, and other security issues.
• Communications: To send service-related notices, updates, and respond to your inquiries.
• Analytics: To understand usage trends and improve our platform (using aggregated or de-identified data where possible).
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.

4. Legal Bases for Processing (GDPR)

Under the GDPR, we rely on the following legal bases:

• Contract Performance: Processing necessary to provide you with the MemoryBase services you have requested (Article 6(1)(b)).
• Legitimate Interests: Processing for our legitimate business interests, such as improving the platform, ensuring security, and communicating with you, where these interests are not overridden by your rights (Article 6(1)(f)).
• Consent: Where required, we will obtain your explicit consent before processing, particularly for sensitive data or marketing communications (Article 6(1)(a)).
• Legal Obligation: Processing necessary to comply with legal requirements (Article 6(1)(c)).

5. How We Share Your Information

We do not sell your personal information. We may share your data with:

• Service Providers: Third-party vendors who assist with hosting, analytics, payment processing, and customer support, under strict data processing agreements.
• Legal Requirements: Law enforcement or regulatory authorities when required by law or to protect our rights and safety.
• Business Transfers: In connection with a merger, acquisition, or sale of assets. In any change of control of MemoryBase or Unchained Technology Inc.:
  • We will notify users at least 30 days before the transfer takes effect, via email and in-product notification;
  • Users will have a window to export their data or delete their account before the transfer;
  • The acquiring entity will be contractually bound by the privacy commitments described in this Notice as of the date of transfer;
  • Any material change to privacy practices by the acquirer will require your explicit opt-in consent, not passive acceptance through continued use.
• With Your Consent: In any other circumstances where you have given explicit consent.

6. International Data Transfers

Your information may be transferred to and processed in countries outside of the European Economic Area (EEA) or your country of residence. When we transfer data internationally, we implement appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your data receives an adequate level of protection.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services. After account deletion, we will securely delete or anonymize your data within 90 days, except where retention is required by law or for legitimate business purposes (such as resolving disputes). User Content associated with deleted accounts is purged from our active systems within 30 days, with backup removal completed within 90 days.

7.1 Service Discontinuation

In the event MemoryBase shuts down or discontinues service, we will:

Provide users with at least 30 days' advance notice via email and in-product notification before service ends; Make a one-click export of all your synced conversations, memories, and account data available during the notice period; Delete all user data from active systems within 30 days of service end, with backup removal completed within 90 days.

8. Your Privacy Rights

8.1 Rights Under GDPR (EEA Residents)

If you are in the EEA, you have the right to:

• Access your personal data and obtain a copy
• Rectify inaccurate or incomplete data
• Erase your data (right to be forgotten)
• Restrict or object to certain processing
• Data portability (receive your data in a structured, machine-readable format)
• Withdraw consent at any time (without affecting prior processing)
• Lodge a complaint with your local data protection authority

To exercise these rights, contact us at [email protected].

8.2 Rights Under CCPA (California Residents)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Delete your personal information
• Opt out of the sale or sharing of personal information (we do not sell your data)
• Non-discrimination for exercising your privacy rights
• Correct inaccurate personal information

To submit a request, email us at [email protected] or use the privacy controls in your account settings. We will verify your identity before fulfilling requests and respond within the legally required timeframe.

9. Data Security

We implement industry-standard technical and organizational measures to protect your data, including encryption in transit (TLS 1.2+) and at rest (AES-256), access controls, regular security audits, and incident response procedures. While no system can guarantee absolute security, we are committed to safeguarding your information and promptly notifying affected users and authorities in the event of a data breach as required by law.

10. Children's Privacy

MemoryBase is not intended for users under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If we learn that we have collected data from a child, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at [email protected].

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our platform. You can manage your cookie preferences through your browser settings or our cookie consent tool. For details on the cookies we use and their purposes, please refer to our Cookie Policy available on our website.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of material changes by email or by posting a prominent notice on our platform at least 30 days before the changes take effect. Your continued use of MemoryBase after the effective date constitutes acceptance of the updated notice.

13. Contact Us

If you have questions about this Privacy Notice or wish to exercise your rights, please contact us:

MemoryBase Privacy Team Email: [email protected]