Privacy policy
In-memory SAS, as part of its commercial activity, is required to process information about you.
When a User account is created on the In-memory application, certain information is stored for identification and use purposes.
This data concerns any information that directly or indirectly identifies a physical person: email address, first name, last name, address, date of birth, etc.
The purpose of this document is to provide transparent information on the conditions under which In-memory collects, processes, stores, archives and deletes the data of Prospects, Users and Customers.
1- Introducing In-memory
In-memory, a simplified joint-stock company, residing at 25 Rue de Verneuil 75007, Paris, provides the In-memory application available on app stores, which the User is free to download. By doing so, the User gains access to the In-memory messaging system that allows for the automatic transmission of messages and personal information solely and exclusively upon their death.
2- Personnal Data
Personal data collected directly from the User when registering for the In-memory service
Personal data collected online in connection with the operation of In-memory
Personal data collected in the form of a global study with a view to carrying out security audits
3- Use of personal data
Personal data is always used for specific and useful purposes, such as improving services, monitoring application activity or complying with legislation.
The data is used in the cases described below :
In using the service
– Account creation and validation
– Use profile management
– Contacting customer service
In service enhancement
– Adding contacts
– Real-time application management
– Application security
– Managing IT problems and incidents
– Fighting cyber-attacks of all kinds
In complying with legal and regulatory obligations
– Fighting against fraud
– Fighting against the use of the application for purposes contrary to the law and its use as mentioned in the general terms of sale
In user relations and communications
– For marketing communications
– Proposing new offers
– Production of usage statistics for app improvements
In retention periods for personal data
Retention periods are precisely defined and only until the completion of the proposed services.
The data collected by In-memory and their retention period concern.
Data entered by the User at creation :
– Email address
– Security phrase
– Last name
– First name
– Phone numbre
– PIN number
This data ensures the operation of In-memory and its services, and is kept for the duration of use, then archived for a period of one year.
Contact data :
Only if the contact is chosen to be used in In-memory. We do not store contact information when the app accesses the User’s directory.
– First and last name
– Email (if available)
This data ensures the operation of In-memory and its services, and is kept for the duration of use, then archived for a period of one year.
Data storage provided by the Paris-based cloud computing company OVH :
– Title
– Meta data
– File name
– Attachments : audio, video, images, documents, various file formats
This data ensures the operation of In-memory and services and is stored for the duration of use, then archived for a period of one year.
Visitor information :
– IP address
– User agent
This data is visitor data and is kept by In-memory for one year.
Canvassing or commercial relationship data is kept for the duration of use then archived for two years.
Invoicing data is legally retained for ten years.
In-memory also has access to data about user purchasing history on the app stores on which it is sold, but it does not have access to your payment information.
In-memory follows the recommandations of the CNIL (French data protection authority)
Personal data is never communicated to third parties. It is strictly confidential and encrypted from end to end.
4- The User's personal data rights
In-memory SAS is subject to regulations imposing a very high level of security and confidentiality for data, and the rules are very precise concerning conservation, exploitation or transmission.
Users have the right to access, rectify, oppose, limit, delete or move their personal data.
Users have the right to define instructions concerning the saving, delation and communication of their personal data after their death.
Users have the right to lodge a complaint with the CNIL.
Standard security procedures on the In-memory application :
– Full, secure end-to-end encryption of data added to In-memory
– Highly secure storage servers
– Permanent checks on data and application integrity
In the event of an incident affecting personal data, In-memory undertakes to notify the CNIL within 72 hours. In this case, following the instructions and advice of the CNIL, In-memory will warn its Users of the risks and actions to be taken, in accordance with the CNIL’s advice.
Right of access
To ask In-memory what personal data concerning you is processed by our services : contact@in-memory.fr specifying the subject of your request :
– Right of rectification – modification of your personald data
– Right to object – request that In-memory cease processing your data, in particuliar by unsubscribing you directly from our commercial mailings
– Right to be forgotten – total and definitive deletion of your In-memory account ; data archived for one year
Right to portability
– Declarative data collected directly from you is returned to you
– Data related to the operation of products and services is not returned
– Personal data obtained from public information will not be returned
– Personal data useful for an external audit will not be returned
The right to define instructions on what to do with your data after your death
The right allows you to define instructions concerning the retention, deletion and communication of your personal data after your death.
In-memory then retains the deceased’s personal data within the legal framework imposed by the judicial authorities.
Data protection officer
In-memory’s data protection officer ensures compliance with regulations, and is the main contact with the CNIL (French data protection authority) regarding data protection and compliance.
5- Data management and control
In-memory reserves the right to analyze the personal data collected in order to offer Users products and services.
In-memory may not prospect by electronic means without :
– Subscriptions to our services
– Voluntary action by the User for a subscritpion
– Prospecting for products or services similar to those already provided
– Non-commercial canvassing
– Providing users with the right to object to prospecting by simple request to contact contact@in-memory.fr
– Providing users with the right to object to commercial prospecting by telephone.