Welcome to Momento Software (hereinafter referred to as “This Software”). This Privacy Policy is designed to explain to you how we collect, use, store, transmit, and protect your personal information, as well as the personal information rights you enjoy. Please carefully read and fully understand the full content of this Policy before downloading, installing, registering, or using this Software. Your download, installation, registration, login, and use act are all considered as you have accepted the constraints of this Policy and agree to our processing of your personal information in accordance with this Policy.
This Policy applies to all services provided by you using this Software through any terminal device (smartphone, tablet, personal computer, etc.), including but not limited to video capture, editing, storage, sharing, account synchronization, etc. We will strictly comply with international general data protection principles and corresponding regional laws and regulations (such as EU GDPR, U.S. CCPA, etc.) to protect the security of your personal information and your legitimate interests.
1. Definition and Applicability Scope
1.1 Core Definitions
1.1.1 Personal Information
Means various information recorded electronically or in other ways that can identify a specific natural person individually or in combination with other information, including but not limited to account information, device information, location information, recording of filmed content and usage behavior, etc.
1.1.2 De-identification and anonymization
Deidentifying means processing to make personal information unable to identify a specific natural person individually or in combination with other information, and after processing the information can be restored; anonymizing means processing to make personal information unable to identify a specific physical person, and after processing the information cannot be restored, and after anonymizing the information no longer belongs to personal information.
1.2 Applicability Scope
This Policy covers all core services and extensions of this Software, excluding services provided by third parties through this Software. If you use third-party services through this Software, the privacy policies of the third-party services will apply separately, and we are not responsible for such third-party information processing behaviors.
2. Collecting Personal Information
2.1 Collecting Necessary Information
2.1.1 Device Information
To ensure the proper operation of this Software, optimize performance and ensure the security of your account, we collect information about device attributes when you use this Software, including hardware model, operating system version, unique device identifiers (such as IMEI, IDFA, OAID), device configuration, network device hardware addresses, etc., following the minimum necessary principle to collect only service-required fields.
2.1.2 Network Information
It collects your network connection information, including browser type, telecommunications carrier, language usage, IP address, network connection status, and more, to ensure video transmission stability, troubleshoot service failures, and prevent cyberattacks.
2.2 Optional information collection
2.2.1 Account Information
When you register and log in to this software account, you can optionally provide information such as your email address, nickname, avatar, and more, which is used to enhance your account profile, authentication, and cross-device synchronization services. You can also authorize login via third-party platforms such as Google, Apple ID, and more. We will obtain the public information (nickname, avatar, unique identifier) that you authorize on third-party platforms for account binding and login authentication, without obtaining non-public information from third-party platforms.
2.2.2 Capture and Content Information
When you shoot and edit Vlogs using this Software, if storage permissions are enabled, we will only store your shooting content and editing engineering files on your local device; if you select the cloud backup feature, we will encrypt your content to a designated regional server, with explicit notice and your consent before storage.
2.2.3 Location Information
If you use the geolocation marking feature, we will obtain your approximate location information (city level) after you authorize it, which is used to add a location label for you. You can revoke authorization at any time in your device settings, without affecting the use of other features.
2.3 Authorization Calling Explanation
All permissions in this software require your explicit consent to be activated. Permission requests are directly related to the corresponding functionality. You can revoke authorization at any time in your device‘s system settings. The specific uses of permissions are as follows:
2.3.1 Camera and Mic Permissions
Used to achieve video recording and audio recording functions, it is called only when you actively initiate the recording function, not silently capturing content in the background.
Storage Permissions
Used to save footage, edit engineering files, and cache temporary data, preventing unauthorized access to or reading other files on your device.
3. Use of personal information
3.1 Core Use Cases
3.1.1 Service Provision and Functional Implementation
Based on the collected information, we provide you with core services such as video capture, editing, saving, sharing, cloud backup, synchronization across devices, and more, ensuring the proper operation of various features, such as adapting software versions through device information and optimizing video transfer rates through network information.
3.1.2 Service Optimization and Experience Improvement
Analyze your usage behavior, device information, and feedback to optimize the performance of this software, interface design, and feature iteration, such as adjusting feature layouts to common editing tools, and remediating software vulnerabilities through failure logs.
3.2 Compliance Usage Requirements
3.2.1 Usage scope restrictions
We will only use your personal information within the scope of the purposes stated in this Policy, and if we need to use it beyond the original purposes, we will separately seek your explicit consent.
3.2.2 Automated Decision Explanation
To provide personalized recommendations based on your usage behavior (such as editing tool recommendations), you can turn off the feature in the software settings, and personalized content will no longer be generated based on your behavioral data.
3.2.3 Anonymizing Data Usage
The collected personal information can be deidentified and anonymized. The processed information can be used for statistical analysis, service optimization, academic research, etc. Such information no longer belongs to personal information and can be freely used without additional authorization.
4. Storage and Transfer of Personal Information
4.1 Storage Specifications
4.1.1 Location of Storage
Your personal information will be stored on servers that comply with the relevant regional regulatory requirements (such as EU user data stored on servers within the EU), ensuring that data storage complies with cross-border data compliance requirements.
4.1.2 Storage Period
We only store your personal information for the period necessary to achieve the purposes of the service, and after the period is exceeded, it will be automatically deleted or anonymized; all personal information that you voluntarily delete, when you log out of your account, we will immediately stop storing it and complete the cleanup within 30 natural days, except as otherwise stipulated by law and regulations.
4.2 Transfer Security
4.2.1 Encrypted Transfer
All personal information is encrypted using the TLS/SSL protocol during transmission to prevent man-in-the-middle attacks, data theft, or tampering, ensuring secure data transmission.
4.2.2 Cross-Border Transfer Requirements
In the event of cross-border transfers of personal information, you will be notified in advance through pop-ups, emails, etc., your separate consent will be obtained, and security measures that comply with international regulatory requirements (such as data encryption, compliance assessments) will be taken to ensure that the transfer process is compliant and controllable.
5. Sharing and Disclosure of Personal Information
5.1 Sharing Rules
5.1.1 Restrictions on sharing with third parties
We will not actively share your personal information with any third party, unless with your explicit consent. When sharing information with a third party, a data protection agreement will be signed with the third party, requiring them to comply with confidentiality obligations and data processing standards, limiting the scope of information use.
5.1.2 Required Sharing Scenarios
To ensure the delivery of services, you may share de-identified information with third-party partners providing server hosting, cloud storage, security protection, etc. This information cannot identify you personally and third parties are not authorized to use it for other purposes.
5.2 Public Disclosure
We will not publicly disclose your personal information unless the following conditions are met: by your express consent; as required by law, regulations, judicial authorities or administrative authorities; as necessary to safeguard the public interest, your legitimate interests or those of others.
5.3 Mergers and Transfers
If a merger, acquisition, asset transfer, etc. transaction occurs, your personal information will be transferred as an asset. We will notify you 30 days in advance through mail, notices, etc., that the new information controller will continue to fulfill the information protection obligations agreed in this Policy. If the purpose of processing information is changed, your consent will be separately sought.
6. Security Protection of Personal Information
6.1 Technical Assurance Measures
6.1.1 Data Encryption Storage
Personal information at rest (such as account information, cloud storage content) is encrypted and stored using the AES-256 algorithm, and keys are managed through hardware security modules (HSMs) to prevent database leaks from causing information leakage.
6.1.2 Access Control
Establish role-based access control (RBAC) models, assign minimum permissions on demand, limit the number of people who can access personal information, require secondary authorization for key operations, and maintain audit logs.
6.2 Management Assurance Measures
Establish a strict information security management system, conduct security training and confidentiality audits regularly, conduct compliance audits for the entire process of processing personal information, and address security vulnerabilities in time.
6.3 Security Incident Handling
In the event of a security incident such as personal information leakage, damage, or loss, we will immediately initiate an emergency plan, take corrective measures to prevent the risk from expanding, and inform you within 72 hours via email, on-site notification, and other means of incident details, treatment measures, and response recommendations. When it is difficult to inform you individually, alerts will be issued through public announcements.
7. Your rights to personal information
7.1 Basic Rights
7.1.1 Access and Correction Rights
You can view your personal information, such as your account information, cloud storage content, and usage history through the Personal Center in this software. If you need to correct any incorrect information, you can do so directly within the software or contact us for processing.
7.1.2 Right to Delete
You can at any time voluntarily delete personal information such as filmed content, edit recordings, usage traces, and so on. You can also request to log out of your account. After your account is logged out, we will delete all your personal information, except as otherwise stipulated by law and regulations.
7.2 Extending Rights
7.2.1 Revoking Your Consent
You can revoke your authorization to the camera, microphone, storage, location, etc. through the device system settings, or you can contact us to revoke your consent to the use and sharing of your personal information. After revoking your consent, we will stop processing the relevant information, without affecting the effectiveness of processing information previously based on legal authorization.
7.2.2 Data Export and Portability Rights
You can request us to export your account information, cloud storage content, editing engineering files, and other personal information. We will provide you with an export service within 30 natural days, supporting common formats that are easy to use across platforms.
7.2.3 Rights for Complaints and Suggestions
If you have any objections to the processing behavior of personal information, you can contact us with a complaint or make a suggestion, and we will promptly review and respond to the processing results.
8. Information Protection for Minors
8.1 Protection Principles
We value the protection of information of minors and do not actively collect personal information from minors (under 16 years of age). If you are a minor and need to use this software in the company of a guardian, the guardian should assist them in managing their personal information.
8.2 Guardians‘ Rights
When guardians discover that personal information of minors has been collected, they can contact us to request the deletion, correction or cancellation of the relevant information, and we will actively cooperate with the processing and provide necessary authentication assistance.
9. Revisions to the Privacy Policy
9.1 Revised Rules
As laws and regulations are updated and services are optimized, we may amend this Privacy Policy. After amendments are made, you will be notified through this software pop-up window, in-site notice, user registration email, etc., and the amended policy will take effect from the effective date indicated in the notification.
9.2 Feedback Requests
If the revised content involves your core interests, we will announce the draft revisions seven natural days in advance and seek your opinion, fully considering your reasonable recommendations before determining the final revised content.
10. Contact Us
If you have questions about this Privacy Policy, need to exercise your personal information rights, or report information security issues, you can contact us by:
Contact email: thewangs1688@gmail.com
We will respond to and process your request within 30 natural days after receiving it.
This Privacy Policy is in effect from the date of publication.
Momento Operations Team