Privacy Policy
Because we care

Memaxi ehf

Privacy Policy

Effective date and version: May 25, 2018, version 2.0

We at Memaxi ehf ("us", "we", or "our") are committed to providing quality service to you. We appreciate that you are trusting us with information that is personal and important to you and we want to do our best to safekeep and use the information in your best interest. Memaxi is primarily designed to help people in need of assistance in their daily lives. Most of the information you and your carers provide us with through Memaxi is information you are asking us to store to help you go about your daily life and we take that very seriously.

In this Privacy Policy we describe the privacy practices for (here called the ‘Services’). We will inform you about the data we collect, how we use it, disclosure of information when you use our Services, the choices you have associated with that information and the measures we take to keep it safe.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Here is what we cover in this Privacy Policy:

1. Definitions

2. Information Collection and Use

3. Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

4. Retention of Data

5. Transfer of Data

6. Disclosure of Data

7. Security of Data

8. “Do Not Track” Signals

9. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

10. Service Providers

11. Links to Other Sites

12. Children’s Privacy

13. Changes to This Privacy Policy

14. Contact Us

 

1. Definitions

Carer

A registered Memaxi user who has been authorised by the Display Profile owner to help manage the Display Profile.

 

Services

Services means our devices, applications, software, websites, APIs, products and services, including but not limited to the website www.memaxi.com and its sub-sites, the Memaxi Display, Memaxi Connect and Memaxi Lock mobile applications operated by Memaxi ehf

 

Personal Data

Personal Data means 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

Usage Data is data collected automatically either generated by using the Services or from the Services infrastructure itself (for example, the duration of a page visit).

 

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

 

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way 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)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers to process your data more effectively.

 

Data Subject (or User)

Data Subject is any living individual who is using our Services and is the subject of Personal Data.

 

Display Profile

A Display Profile is the collection of information relating to a Data Subject. It may hold calendar events, notes, photos, guestbook entries and other information relating to the daily life of the person the Display Profile is intended for.

 

2. Information Collection and Use

When you user our Services we collect several types of information for various purposes to provide and improve our Services to you.

2.1      Types of Information Collected

 

Information you provide us with:

 

2.1.1        User Account Information

Some personally identifiable information that can be used to contact or identify you (“Personal Data”) is required to create an account on our Services, such as your name, email address and password. This is the only information you must provide to create an account with us. You may also choose to provide other types of information, such as an account photo and your mobile telephone number for you to enable certain account features, for example, for login verification and mobile notifications from the Services. By removing your mobile number, you will opt out of these account features. Further, we may request postal address, state, province, ZIP/postal code, city and country as part of your Personal Data, so we can send you information about our Services, to market to you and to help prevent spam, fraud, or abuse.

 

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

 

If you email us, we may keep your message, email address, and contact information to respond to your request.

 

 

2.1.2   Display Profile information  

To create a Display Profile in Memaxi, you need to supply a name as a minimum and associate your Display Profile with a registered Memaxi user account. Optionally, you can provide a profile photo for the Display Profile.

 

2.1.3        Private, health and other special categories of personal data

As part of the Memaxi Display profile you or a Memaxi registered user as authorised by you may enter, upload and store information relating to your daily schedule, life events, assistance needed for daily living and so forth. We do not process this information in any way other than to communicate it to Memaxi registered users as authorized by you, in your best interest.

 

2.1.4   Exchange of personal data

We may share or disclose your information at your direction, such as when you authorize a third-party web client or application such as official health care or welfare software systems to access your Display Profile. Such exchange will be based on means of electronically identifiable information relating to your person.

 

Information we receive from your use of our Services includes:

2.1.5   Usage Data

We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device ("Usage Data").

 

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 

When you access the Services by or through a mobile device, this Usage Data may include information about your download and installation of our Services and 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.

 

2.1.6   Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Services, to improve and customise our Services.

 

You can enable or disable location services when you use our Services at any time, through your device settings.

 

2.1.7   Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.

 

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Services.

 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

 

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Services.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

 

2.2      Use of Data

Memaxi ehf uses the collected data for various purposes:

  • To provide and maintain our Services
  • To notify you about changes to our Services
  • To allow you to participate in interactive features of our Services when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Services
  • To monitor the usage of our Services
  • To detect, prevent and address technical issues
  • To provide you with news, exclusive offers and general information about other goods, services and events which we offer that are like those that you have already purchased or enquired about unless you have opted not to receive such information

 

3. Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Memaxi ehf 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.

Memaxi ehf 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's not overridden by your rights
  • For payment processing purposes
  • To comply with the law

 

4. Retention of Data

Memaxi ehf 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 (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Memaxi ehf will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

 

5. 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 than those from your jurisdiction.

If you are located outside Iceland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Iceland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Memaxi ehf will take all 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 organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

6. Disclosure of Data

6.1      Business Transaction

If Memaxi ehf is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

6.2      Disclosure for Law Enforcement

Under certain circumstances, Memaxi ehf 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).

6.3      Legal Requirements

Memaxi ehf 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 Memaxi ehf
  • To prevent or investigate possible wrongdoing in connection with the Services
  • To protect the personal safety of users of the Services or the public
  • To protect against legal liability

 

7. 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.

 

8. "Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

9. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Memaxi ehf 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 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 to 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 Memaxi ehf 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. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

10. Service Providers

We engage third party companies and individuals to facilitate our Services ("Service Providers"), to perform functions, provide the Services on our behalf, to perform Service-related services or to assist us in analysing how our Services are used. These service providers are based in Iceland, the United States and other countries and are bound by a contract with us that ensures your data is managed in accordance with EU Data Protection laws.

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.

10.1    Hosting

Our Services are SaaS services (Software-As-A-Service) and are centrally hosted in a network of data centres. Our hosting provider runs, supports and backs up our Services as requested by us.

10.2    Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

We use Google Analytics as a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

10.3    Payments

We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors).

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, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

  • Apple Store In-App Payments, their Privacy Policy can be viewed at

https://www.apple.com/legal/privacy/en-ww/

  • Google Play In-App Payments, their Privacy Policy can be viewed at

https://www.google.com/policies/privacy/

  • PayPal or Braintree, their Privacy Policy can be viewed at

https://www.paypal.com/webapps/mpp/ua/privacy-full

10.4    Video calls

We may provide video calls through third-party video services or third-party components built into our Services.

10.5    Text messaging and notifications

We may provide text messaging and notifications through third-party messaging services or third-party components built into our Services.

 

11. Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click on 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.

 

12. Children's Privacy

We do not knowingly allow children under the age of 18 to create a user account in Memaxi to serve as carers. We base a person’s age on the date of birth provided to us during the registration process.

When a Display Profile is created for a person under the age of 18 we do our best to seek consent from the parent or guardian of that person. We base the age on the date of birth provided to us during the Display Profile creation process. If the person for whom the Display Profile is intended is under the age of 18 we ask the parent or guardian to first create a user account in Memaxi and then confirm that this user is the parent or guardian before collection any personal information for the child. If we do not receive this consent, it will not be possible to use the Display Profile and we take steps to remove that information from our servers.

If you believe Personal Data is being collected in Memaxi relating to your child and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at info@memaxi.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. If we make changes to this policy that, in our sole discretion, is material we will notify you of those changes. We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on our public website www.memaxi.com and corresponding language versions of that site.

 

14. Contact Us

If you have any questions about this Privacy Policy, please contact us by email on info@memaxi.com