Privacy Policy

Last updated: August 2026

1. Data controller

Andrea Libutti — sole proprietorship "LIBUTTI ANDREA"
Italian VAT number 18598921007
Registered office: Via Riva Ligure 44 — 00163 Rome (RM), Italy
Privacy contact and requests to exercise data subject rights: [email protected].

2. Data we collect

We collect: email, name (optional), deck content, study statistics (times, scores), and technical data (device type, OS, app version).

With your analytics consent only: anonymous app usage data and, on iOS, which Apple ad campaign an install came from (campaign and keyword identifiers, provided by Apple). We do not collect the device advertising identifier (IDFA) and we do not track you across other companies' apps or websites. You can decline: the app works exactly the same.

3. Purposes

• Provide and improve the service
• Sync your decks across devices
• Send study reminders (only if enabled)
• Respond to support requests
• Understand how the app is used and which campaigns installs come from, with your consent only (Art. 6.1.a GDPR)

4. Legal basis

Processing is based on the contract between you and the Controller (Art. 6.1.b GDPR) and, for marketing, on your explicit consent (Art. 6.1.a GDPR).

5. AI and flashcard generation

When you use AI Studio, your notes are sent to third-party AI models (Google Gemini) solely to generate the requested flashcards. Data is not used for model training and is deleted within 24 hours.

6. Your rights

You have the right to access, rectify, delete, restrict, port, and object. Write to [email protected] to exercise them.

7. Retention

We retain your data while your account is active. On deletion, data is removed within 30 days unless legally required otherwise.

8. Cookies

The memo.app website uses only functional cookies. The app uses no tracking cookies.