PRIVACY POLICY

Effective Date: 15 June 2025
Last Updated: 15 June 20251. Who We AreThis Privacy Policy applies to the mobile application “Memora English” (App) developed and published worldwide by Magomed-Emin Arsmurzaev (Developer).2. No Personal Data CollectedThe App operates entirely offline. It does not:* collect, transmit, store, or share any personally identifiable information (PII);
* create user accounts or require log-in;
* use analytics, advertising, cookies, web beacons or device identifiers;
* access precise location, contacts, photos or camera.All lesson progress, settings, and other data remain solely on the user’s device and are erased when the user uninstalls the App.3. In-App PurchasesSubscriptions and purchases are processed exclusively by Apple Inc. via in-app purchase. We do not receive or store billing or payment data. For details, please see Apple’s Privacy Policy: https://www.apple.com/legal/privacy/.4. Children’s Privacy (COPPA / GDPR-Kids)The App is suitable for users aged 4 and older and is designed to be child-safe. Because no data is collected, the App complies with the U.S. Children’s Online Privacy Protection Act (COPPA) and Article 8 of the GDPR.5. International ComplianceBecause no personal data is processed, the App by its nature satisfies the core requirements of major data-protection frameworks, including but not limited to:* GDPR and UK GDPR: no personal data is processed, so obligations such as consent, lawful basis, user rights, and record-keeping do not apply.
* CCPA / CPRA (California): no personal information is collected or sold, so disclosure and opt-out rights are not triggered.
* CalOPPA (California): this Policy expressly states that no tracking occurs.
* COPPA (U.S.): no data from children under 13 is collected.
* LGPD (Brazil), PIPEDA (Canada), PDPA (Singapore), and similar laws: the same rationale applies—absence of data processing.If future versions of the App begin processing personal data, this Policy will be updated and all required user rights (access, deletion, portability, objection, etc.) will be honored.6. SecurityBecause no user data leaves the device, the primary risk vector is local. Users should secure their own devices with passcodes or biometrics.7. ContactFor any privacy question or concern, please contact:
Email: [email protected]