This Policy describes what data Memora (the "Service") collects, how it uses and protects them.
Personal data operator: self-employed Esipov Maksim Mikhailovich (TIN 732898168128). Processing is performed in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and Federal Law No. 149-FZ of 27.07.2006 "On Information, Information Technologies and the Protection of Information".
1. Data We Collect
1.1. Telegram Account Data
Received from Telegram on first interaction:
- Telegram User ID;
- first name, last name, username (if provided);
- Telegram interface language;
- Telegram Premium status (used for limit tiers).
1.2. User Content
We store what the User explicitly sends to the bot or Mini App:
- text messages and notes;
- voice messages and their transcriptions;
- images, documents, videos;
- tasks, reminders, tags, links between notes.
1.3. Technical Data
- API access logs (anonymized);
- payment metadata (no payment credentials are stored);
- usage statistics for features.
2. Purposes of Processing
- providing Service features (storage, search, reminders);
- processing content with AI (OCR, transcription, semantic search);
- processing and confirming Telegram Stars and YooKassa payments;
- user support;
- improving the Service based on anonymized analytics;
- fulfilling legal requirements.
3. Sharing With Third Parties
3.1. The Service shares the minimum necessary data with the following categories of processors:
- Telegram — message delivery and Stars payment processing;
- YooKassa — external card payment and refund processing without exposing payment credentials to Memora;
- AI model providers — content processing for OCR, transcription, and semantic search (content is sent without User identifiers where technically possible);
- Cloud hosting — data storage and infrastructure;
- Monitoring and analytics systems — anonymized operational metrics.
3.2. The Service does not sell User personal data and does not share it with advertising networks.
3.3. The Service does not use User content to train its own or third-party models.
4. Data Retention
4.1. Data is stored while the User's account exists in the Service.
4.2. After account deletion ("Settings" section in the Mini App), data is deleted within 30 days.
4.3. Backups are rotated within 90 days.
4.4. Access logs are kept for no longer than 90 days.
5. Security
- HTTPS/TLS in transit;
- limited staff access to infrastructure on a least-privilege basis;
- regular dependency updates and security audits;
- application-level user data isolation.
6. User Rights
The User has the right to:
- obtain a copy of their data by contacting @Qwinty;
- request correction of inaccurate data;
- delete their account and associated data ("Settings" section in the Mini App);
- withdraw consent to processing (by ceasing to use the Service);
- file a complaint with a supervisory authority (for users in Russia — Roskomnadzor).
7. Children
The Service is not intended for individuals under 13 years of age (or the age of digital consent in the User's jurisdiction). The Service does not knowingly collect data from such individuals.
8. Policy Changes
8.1. The Service may update this Policy. The current version is published on the official page.
8.2. Material changes are communicated to Users via the bot at least 7 days in advance.
9. Contacts
Data protection requests: contact @Qwinty on Telegram.
Operator: self-employed Esipov Maksim Mikhailovich, TIN 732898168128.