Privacy Policy

Entity and scope

Memogadget Assist is provided by Memogadget, Unipessoal Lda., Portuguese company number 510007082. Contact for privacy, rights requests and support: comercial@memogadget.com. This policy covers the website, web platform, mobile application and Assist integrations. The registered address also appears in the Terms of Service. Registered office: Rua José Carlos Vieira Neves, no. 64, Maia, Portugal.

Who decides how data is used

Memogadget is the controller for its own customer account administration, contracting, billing, support and security. Where a customer uses Assist to process messages, contacts or other business data, that customer determines the purposes and lawful basis; Memogadget acts on its behalf under documented instructions and the applicable processing agreement. Channel providers may be independent controllers for their own services. These roles are separate from provider and deployer roles under the AI Act.

Data and sources

Depending on the features used, processing may cover identity and professional contacts, account and company information, permissions, billing and transactions, messages and attachments, CRM contacts, requests and projects, AI inputs and outputs, voice audio and transcripts, calendar information and technical and security logs. Sources include users, the customer company, its contacts and authorised integrations. Not all these categories are collected in every use.

Purposes and lawful bases

For processing controlled by Memogadget, contract performance or pre-contractual steps support account creation and services to an individual who is a contracting party. Legal obligations support billing and lawful responses to authorities. Managing customer staff contacts, preventing fraud and protecting the service rely on legitimate interests in the professional relationship and security, balanced against individual rights. Consent applies where required for an optional feature. Accepting terms or reading this policy is not blanket consent for marketing, AI training or customer processing.

Processing on behalf of customers

The customer company must establish and communicate the purposes and lawful bases for customer service, prospecting, advertising, employment and its other processes. Connecting a channel or finding a public contact does not itself authorise marketing or remove objection rights. Requests concerning such processing may be addressed to the company concerned; Memogadget provides the assistance required under the applicable agreement.

AI and service providers

Assist uses AI services including Google/Gemini and OpenAI according to the feature, configuration and restrictions applicable to the data source. A technical fallback does not authorise a new purpose. Content and context needed for a request may be sent to the provider processing it. The specific Google API rules below prevail over this general description. We do not promise a single model for every operation or zero provider retention.

Voice, messages and oversight

Interactions with AI agents must be identified as such. An agent may represent the customer company while keeping its AI nature clear. Voice requires audio processing and may produce transcripts and operational history; this does not mean every call is recorded. A company wishing to retain recordings must verify configuration and provide legally required information and authorisation. Automatic replies differ from messages reviewed and sent by a person. Human review does not remove other applicable synthetic content disclosures.

Recipients and access

Data may be accessible to company-authorised users and, as needed, Memogadget support and security teams, hosting, AI, communication and payment providers involved, and authorities where legally required. Sent or published content reaches the selected recipients and channels. Company permissions and sharing settings govern organisational access; a personal inbox does not itself exclude lawfully authorised administrative access.

Processing outside the EEA

Some third-party services may involve processing outside the European Economic Area. Their use must be supported by the relevant contract and transfer mechanism, such as a valid adequacy decision or standard contractual clauses with necessary assessments and safeguards. We do not guarantee that all data stays in the EU. Information on recipients and applicable safeguards can be requested from the privacy contact; the specific arrangements depend on the service actually used.

Retention and deletion

Data is retained as needed for its purpose, the contractual relationship, legal duties or defending rights. Duration depends on the category, contract, configuration and law; there is no single period for all messages, calls and backups in this policy. Disconnecting an integration prevents new authorised access but does not automatically erase imported data. At service end, return or deletion of customer data must follow the processing agreement, including backups and legally required retention. Confirm relevant periods before introducing data subject to specific limits.

Security and minimisation

Assist uses company and user access controls, encrypted communications, traceability and oversight mechanisms. These reduce risk but do not guarantee absolute security. Users should provide only necessary data, protect credentials and report unauthorised access. Source integration restrictions also apply to derived data and voice requests.

Rights and requests

Subject to legal conditions, individuals may request access, correction, erasure, restriction, portability and objection, including objection to direct marketing, and withdraw consent where relevant. Contact comercial@memogadget.com with the request context. Identity checks will be proportionate. Requests are normally answered within one month, subject to a lawful extension that is communicated. You may complain to the Portuguese supervisory authority, CNPD, at www.cnpd.pt, without losing other remedies.

Automated decisions

AI answers and recommendations may be incorrect. Solely automated decisions producing legal or similarly significant effects on people require specific assessment and safeguards; an Assist subscription does not authorise them. Customers must ensure appropriate human oversight and contact. Sensitive uses may remain blocked pending assessment.

Sessions, cookies and device permissions

The service uses mechanisms necessary for authentication, security, preferences and chosen integrations. Device permissions such as microphone and notifications are requested for the relevant features. Optional cookies or technologies requiring consent need a separate choice; acceptance of these documents does not provide that consent.

Changes and contact

The published date and version identify this policy. Material changes will be communicated through available means where required. Use comercial@memogadget.com for questions, incidents or rights requests. This policy is an information notice, not an AI Act certificate or a substitute for a customer processing agreement.

Data from Google integrations

When you explicitly connect your Google account, Assist receives data covered by your consent: Gmail message headers, bodies and, where applicable, attachments, recipients and content of messages you authorise sending; titles, descriptions, times, status and other details of events in your primary calendar. OAuth tokens maintain the connection without collecting your Google password. New authorisation requests gmail.readonly, gmail.send and calendar.events.owned. Earlier grants may retain calendar.events; reauthorisation does not guarantee their reduction. The account holder can revoke the earlier access in Google Account permissions and reconnect to grant only the new scopes.

Specific purposes for Google data

We use this data exclusively for the user-facing email and calendar features you choose: displaying and searching messages, classifying and summarising email, preparing replies, carrying out authorised sends, displaying appointments and creating requested events in the primary calendar. Google API data is not used for billing, targeted advertising, prospect profiling, credit scoring or third-party databases. We do not sell it or transfer it to advertisers, data brokers or information resellers. The Gmail integration is not intended for email warming or unsolicited commercial outreach.

AI and Google data

AI features may process relevant message or event content to fulfil your request, including summaries, classification, drafts and voice assistance. For email and calendar features connected to Google APIs, and their tools used by private Meet, the company assistant and telephone assistance, inference uses the direct OpenAI API. Assist does not use Google API data, including raw, aggregated, anonymised or derived data, to develop, improve or train generalised or non-personalised AI or machine-learning models, nor transfer it to services for that purpose. Request inference and operational retention are separate from model training. The API may retain data for security and abuse prevention under the provider terms; we do not claim zero retention. The Gemini API may be used in other management and presentation features, outside the email and calendar tools described above. Content manually entered in those other features may be processed by Gemini.

Google Limited Use

Memogadget Assist's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. These limits also apply to derived data and take precedence over the general purposes described elsewhere in this policy.

Google API Services User Data Policy

Sharing and protecting Google data

Data is available to the account holder and people in their company with appropriate permissions for authorised features. Hosting providers and the OpenAI API process only what is necessary to deliver those features or protect the service. Human access by the operator for support requires user authorisation, except for the security, abuse investigation or legal obligations permitted by Google policy. We use HTTPS, access controls and company separation. OAuth tokens and connection configuration, message subjects and bodies, drafts, and calendar titles and notes are encrypted in storage. Operational metadata such as times, status, account address and Google identifiers is protected by access controls and is not all encrypted. When you send or forward a message, or explicitly authorise a reply automation, the selected content and attachments are delivered to that message’s recipients.

Retention, disconnecting and deletion

We keep synced messages, events, drafts and operational history while necessary to deliver the selected features or meet applicable legal obligations. Disconnecting in Assist or revoking access in Google Account permissions prevents further authorised access but does not automatically erase history already stored in Assist. Request access, correction or deletion through the account area or comercial@memogadget.com; the team verifies and processes requests, including company ownership and shared-record responsibilities. We do not store your Google Account password.