Privacy Policy

This Privacy Policy describes how N5 LLC, a limited liability company incorporated under the laws of Delaware, USA, and Our subsidiaries and affiliated companies (collectively, "N5," "We," "Us," or "Our") collect, use, disclose, and otherwise process personal data when You access or use Memo by N5 (“Memo”), including the Site at https://get-memo.io , Our mobile and desktop applications, and any related application or service that links to this Privacy Policy (collectively, the "Services"). This Privacy Policy also describes how We process personal data when You interact with Us, such as through Our sales and customer support channels.

Where a business customer uses the Services to record, transcribe, or document its own interactions, N5 processes the content of those Meetings on that customer's behalf and under its instructions, and that customer — not N5 — determines the purposes and means of that processing. Our processing of that Content is governed by Our Terms of Use, available at https://get-memo.io/legal/terms, Our Data Processing Addendum, available upon request at support@get-memo.io, and any other applicable agreement covering that customer's access to and use of the Services. Sections 1.3 and 10.2 below describe that role and explain what it means for individuals whose personal data is contained in that content.

This Privacy Policy should be read together with Our Terms of Use. Capitalized terms not defined in this Privacy Policy have the meaning given to them in the Terms of Use.

N5 has appointed a Data Protection Officer and, for the purposes of the LGPD, an Encarregado. Their contact details, and the way in which N5 handles requests received from a Contact, are set out in Section 15 (Contact Us).

1. Who We Are, and Our Role as Controller or Processor

1.1 Roles under applicable data protection laws. Certain data protection laws and regulations distinguish between two main roles for parties processing personal data: the party that determines the purposes and means of the processing, and the party that processes personal data on that party's behalf and under its instructions. The names given to these two roles differ from one jurisdiction to another. The table below identifies the laws of the markets in which the Services are offered, the terminology each of them uses, and the role N5 holds under each, in each case to the extent that the relevant law applies to the processing in question. Where a law not listed below applies to You, the same allocation of roles applies under whatever terminology that law uses.

1.2 N5 as controller. N5 acts as the data controller for: (a) the registration and Account data of the individual or organization that creates an Account and subscribes to the Product, and of its Admins and Authorized Users; (b) usage, device, and cookie data collected automatically through the Services; (c) communications You send to Us for support, feedback, or other correspondence; (d) billing and subscription records, it being understood that payment card and transaction data are collected and processed directly by the Payment Provider, as described in Section 6.1; (e) marketing communications and marketing preferences; and (f) business contact data of prospective customers, customer contacts, suppliers, and partners of N5. N5 determines the purposes and means of processing this data, as described throughout this Privacy Policy.

1.3 N5 as processor for Meeting Data and User Content. The Services are offered solely for business and professional use, as set out in Section 2 of the Terms of Use. Accordingly, where You use Memo so that Your Authorized Users can document, follow up on meetings, calls, and visits with Your own customers, prospects, or other contacts (each, a "Contact"), You — not N5 — are the controller of the personal data generated or captured through those Meetings, including transcripts, AI-generated summaries and action items, Geolocation Data, Evidence (such as photographs, or document images), and any related CRM Data (together, "Meeting Data"). You are also the controller of any User Content that an Admin or Authorized User uploads to Your Account, including any personal data it contains. This is true whether the personal data relates to an Authorized User or to a Contact. N5 processes Meeting Data and User Content solely on Your behalf and under Your instructions, as Your processor.

A Contact does not have an Account and has no direct contractual relationship with N5.

As between You and N5, You are responsible for determining whether and how You use the Services. You are responsible for ensuring that Your Authorized Users, and all individuals whose personal data may be included in Meeting Data or User Content, have been given the notice, or have given the consent, that Section 5 of the Terms of Use and applicable law require before a Meeting is transcribed or otherwise processed, including any notice or consent required in the context of Your employment relationship with Your Authorized Users. You are responsible for ensuring that all legal requirements applicable to the collection, and other processing of data through the Services are met, as further set out in Section 5 of the Terms of Use. You are also responsible for handling requests from Your Authorized Users and from Contacts to exercise their data protection rights, as described in Section 10.2 below.

1.4 Payment data. Payment and billing information related to Your Subscription is processed by the Payment Provider, which may act as an independent controller, as described in Section 6.1 below.

2. Definitions

For purposes of this Privacy Policy, the following terms have the meanings given below. Other capitalized terms have the meaning given to them in the Terms of Use.

"Account" means the individual or organizational account created for You to access the Product.

"Admin" means an Authorized User whom You designate to administer Your Account, including configuring Meeting notice/consent settings, managing Authorized Users, and reviewing Meeting Data through supervision dashboards.

"Affiliate" means any entity that, directly or indirectly, controls, is under common control with, or is controlled by a party.

"Authorized User" means Your or Your Affiliates' employee, contractor, agent, or other individual whom You authorize to access and use the Product through Your Account. Where You access and use the Product in the exercise of Your own trade, business, or profession, You are also an Authorized User for the purposes of this Privacy Policy and the Terms of Use.

"Contact" means a natural person, other than an Authorized User, who participates in, is present at, or is otherwise identifiable from a Meeting or Evidence, as defined in the Terms of Use.

"Controller" means the party that determines the purposes and means of the processing of personal data.

"CRM Data" has the meaning given in the Terms of Use.

"Device" means the computer, mobile telephone, tablet, or other device through which an Authorized User accesses the Product.

"Evidence" has the meaning given in the Terms of Use.

"Generated Content" means content generated by the AI Features in connection with Your use of the Product, as defined in the Terms of Use.

"Geolocation Data" has the meaning given in the Terms of Use.

"Meeting" has the meaning given in the Terms of Use.

"Meeting Data" means, for purposes of this Privacy Policy, the recording, transcript, Generated Content, Geolocation Data, Evidence, and CRM Data associated with a given Meeting, as described in Section 1.3.

"Order" has the meaning given to "Order Page" in the Terms of Use.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Processor" means a natural or legal person who processes personal data on behalf of a Controller.

"Product" means Memo by N5.

"Site" means the public websites and landing pages that N5 operates at https://get-memo.io/ , excluding the authenticated areas of the Product.

"Subprocessor" means a third party N5 engages to process personal data in connection with providing the Services, as described in Section 7.

"Transcript" has the meaning given in the Terms of Use.

"User Content" means any content, other than Meeting Data, that You or Your Authorized Users upload, post, or otherwise submit to the Services, including documents and other materials uploaded in connection with the Product. Meeting Data and User Content together correspond to what the Terms of Use define as "Content".

"You" means the company, organization, or other legal entity on whose behalf an individual accesses or uses the Product, or the individual who accesses or uses the Product in the exercise of that individual's trade, business, craft, or profession. Where an individual accesses or uses the Product on behalf of an entity, "You" means that entity. The Product is offered solely for business and professional use, and "You" does not include any individual acting for personal, family, or household purposes. "You" does not include a Contact.

3. Personal Data We Collect

3.1 Information provided by You or by Your organization's Admin to Us.

• Account and registration information, such as Your name, email address, phone number, and the username and password You use to access the Services.
• Organizational information, where You register on behalf of an organization, such as the organization's name and the identity and role (Admin or Authorized User) of the individuals You authorize to access the Product.
• Communications, such as information You provide when You contact Us for support, feedback, or other correspondence.
• User Content, including any documents or other materials an Admin or Authorized User uploads in connection with the Product, which may incidentally include personal data that the Admin or Authorized User chooses to include. N5 processes User Content on Your behalf, as described in Section 1.3.
• Payment and billing information, collected and processed directly by the Payment Provider, as described in Section 6.1. We do not collect or store Your full payment card details.
• Marketing preferences, such as Your email address and the topics for which You wish to receive updates, where You subscribe to Our newsletters or other communications. You may unsubscribe at any time by following the instructions in those communications.
• Business contact information, where You are a prospective customer, customer contact, supplier, or partner of N5, such as Your name, company, job title, business email address, phone number, business address, and the details of any order, quotation, or demonstration request. We process this information in the course of Our business relationship with You or Your organization.

3.2 Meeting Data generated through use of Memo. Where an Authorized User conducts a Meeting using Memo, the Product generates and processes:

• Audio and transcripts. The audio of the Meeting, which the Product processes in order to generate a speech-to-text Transcript. N5 does not store the audio. The Transcript necessarily includes the words, and the audio from which it is generated necessarily includes the voice of the Authorized User and of any Contact who participates.
• Generated Content. AI-generated summaries, minutes, action items, and tags derived from a Meeting's transcript.
• Geolocation Data. The geographic location of the Authorized User's Device at or around the time of a Meeting, where this feature is enabled. Because this feature captures the location of an Authorized User — generally an employee or contractor of Your organization — during working activity, You are responsible for complying with any employment, labor, or works-council requirement applicable to that capture, in addition to applicable data protection law.
• Evidence. Photographs, or document images captured by an Authorized User to validate or document a Meeting or its context, which may include images of premises, storefronts, identification documents, corporate constitutive documents, powers of attorney, or signatures. Where Evidence includes a government-issued identification document or signature, it may be subject to additional protections under applicable law (for example, rules on national identification numbers); the legal basis and appropriateness of capturing it is Your responsibility as controller, as described in Section 5 of the Terms of Use.
• CRM Data. Any of the foregoing that is synchronized between the Product and Your own CRM or other business systems, where You configure such an integration. Once that data has been transferred into a system that You control, its further processing is governed by Your own agreement and configuration with the provider of that system, and this Privacy Policy does not apply to it.

Meeting Data is generated as a normal part of Memo's core functionality and, because You are the organization that determines when and how a Meeting is conducted, is processed by N5 on Your behalf as described in Section 1.3. The audio and image data in a recording or Evidence item are processed to generate the transcript, summary, and related Meeting Data described above; they are not used by N5 to identify or verify the biometric identity of a Contact or Authorized User (i.e., not for voice or facial biometric recognition). If N5 introduces a biometric identification feature in the future, N5 will update this Privacy Policy and notify You in advance; You will be responsible for providing any notice to, and obtaining any consent from, Your Authorized Users and Contacts that applicable law may require.

3.3 Information We collect automatically. When You use the Services, We and Our service providers may automatically collect:

• Device and usage data, such as Your IP address, browser type and version, operating system, device identifiers, referring URLs, pages viewed, features used, and the dates, times, and duration of Your activity.
• Cookies and similar technologies, as described in Section 9 below.

3.4 Information We obtain from third parties and from accounts You connect. Where You or an Authorized User signs in using, or connects to the Product, a third-party account — currently a Google account or a Microsoft account — We receive from that service only the data described below, and only to the extent authorized through that service's own permission and privacy settings. A connected account may be disconnected at any time.

Login and profile information. Where You or an Authorized User signs in using a Google or Microsoft account, We receive the basic profile information associated with that account — name, email address, and profile photograph — in order to create and authenticate the Account.

Calendar information. Where You or an Authorized User connects a Google or Microsoft calendar, We receive the events in that calendar, including each event's title, description, date and time, location, and the identity of its attendees and each attendee's response status, in order to identify the Meetings to be documented, display the Authorized User's agenda, associate a Transcript with the correct Meeting, and display the location of a scheduled Meeting.

Contact profile photographs. Where You or an Authorized User connects a Google or Microsoft contacts service, We receive the profile photographs associated with the contacts concerned, in order to display them in the Product.

Additional Limits on Use of Your Google User Data. Notwithstanding anything else in this Privacy Policy, if You provide N5 with access to Your Google data — for example, when You sign in with Your Google account or connect Your Google Calendar or Google Contacts to the Product — N5's use of that data will be subject to these additional restrictions:

N5 will only use access to read Your Google profile information, Your Google Calendar events and their attendee information, and Your Google Contacts profile photographs to: (a) create and authenticate Your Account; (b) identify the Meetings to be documented, display an Authorized User's agenda, associate a Transcript with the correct Meeting, and display the location of a scheduled Meeting; and (c) display contact profile photographs within the Product; and will not transfer this Google data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.

N5 will not use this Google data for serving advertisements.

N5 will not use this Google data to develop, improve, or train generalized artificial-intelligence or machine-learning models.

N5 will not allow humans to read this Google data unless We have Your affirmative agreement for specific items, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for N5's internal operations and, when used for internal operations, only when the data have been aggregated and anonymized.

N5's use of information received, and N5's transfer of information to any other app, from Google APIs will adhere to the Google API Services User Data Policy, available at https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes, including the Limited Use requirements.

4. How We Use Personal Data

We use personal data for the following purposes:

4.1 To provide and operate the Services (legal basis: performance of a contract), including to create and manage Your Account, authenticate and grant You access to the Product, process Your Order, and provide customer support. Our processing of Meeting Data is described in Section 4.7.

4.2 To communicate with You, including to send administrative and transactional messages and respond to Your inquiries (legal basis: performance of a contract), and, where You have opted in, to send marketing communications about the Product (legal basis: consent, which You may withdraw at any time as described in Section 10).

4.3 To maintain and improve the Services (legal basis: legitimate interests, namely improving and securing Our Products), including to monitor performance, diagnose technical issues, and develop new features or products, using anonymized information, as described in Section 5.2.

4.4 To ensure security and prevent fraud (legal basis: legitimate interests, namely protecting the Services and Our users), including to detect, investigate, and prevent unauthorized access, breaches of the Terms of Use, and other harmful or unlawful activity.

4.5 To comply with legal obligations (legal basis: compliance with a legal obligation), and to establish, exercise, or defend legal claims (legal basis: legitimate interests).

4.6 For business transactions (legal basis: legitimate interests, namely facilitating a corporate transaction), as described in Section 6.5 below.

4.7 Where We process Meeting Data or User Content as processor under Section 1.3, We do so on the basis of, and to the extent of, Your instructions as controller; We use it solely to provide the Services as instructed by You, and not for Our own independent purposes, except as described in Section 5.2 and authorized under the Data Processing Addendum.

4.8 Where We process personal data on the basis of contractual necessity, failure to provide that personal data will result in Your inability to use some or all portions of the Services that require it.

4.9 We may also process personal data where necessary to comply with a legal obligation, to protect the vital interests of You or another individual, in each case to the extent permitted by applicable law.

4.10 Where We rely on legitimate interests as a legal basis, We have carried out an assessment balancing those interests against the rights and freedoms of the individuals concerned. You may request further information about that assessment by contacting Us as set out in Section 15.

5. Use of Personal Data to Train AI Models

5.1 No training on Your data. N5 does not use Meeting Data or other User Content, or any personal data contained in them, to train or improve N5's AI Features generally or for the benefit of other customers, and does not permit the underlying third-party AI infrastructure providers identified in the subprocessor list referred to in Section 7.1 to use that data to train their own models. Except as described in Section 5.2, N5 does not access, use, or retain personal data contained in Meeting Data for any purpose other than providing the Services to You under Your instructions.

5.2 Anonymized service information. N5 may create and use anonymized information derived from the operation of the Services, such as usage patterns and performance metrics, to maintain and improve the Services, as further set out in the Data Processing Addendum. Anonymized information does not identify, and cannot reasonably be used to identify, any individual or customer; does not include or reveal the content of any recording, transcript, Evidence, or Generated Content; and is not personal data under applicable data protection law. N5 will not attempt to re-identify anonymized information and will contractually prohibit any recipient from doing so. N5 may continue to use anonymized information after termination of Your Subscription.

6. How We Share Personal Data

We may share personal data with the following categories of recipients:

6.1 Payment Provider, as an independent controller. Payment and billing information related to Your Subscription is collected and processed by the third-party payment provider, reseller, or merchant of record, if any, that N5 engages from time to time to process payments for the Services (the "Payment Provider"). Where the Payment Provider acts as merchant of record, it processes such information as an independent controller, for its own purposes, subject to its own privacy policy, which is made available at checkout. N5 does not control, and is not responsible for, the Payment Provider's processing of Your payment information.

6.2 Your organization. Where an Authorized User's Meeting Data is generated under an organizational Account, that data is visible to the Admins of that Account and to other Authorized Users to whom Your organization grants access, as part of the Product's core functionality — for example, so that a supervisor can review a Meeting's recording, transcript, Geolocation Data, or Evidence, monitor coverage and results by team or zone, or follow up on action items.

6.3 Subprocessors. N5 engages third-party Subprocessors to help deliver the Services, as described in Section 7 below.

6.4 Professional advisors and authorities. Lawyers, auditors, and other professional advisors, and law enforcement or government authorities, where necessary to comply with a legal obligation, respond to lawful requests, or protect N5's or others' rights, property, or safety.

6.5 Business transferees. Acquirers and other participants in a merger, acquisition, financing, reorganization, or sale of all or part of N5's business or assets, in which case personal data may be among the assets transferred, subject to standard confidentiality arrangements.

6.6 Sale and sharing of personal data. We do not sell personal data for monetary consideration, and We do not disclose personal data to third parties for their own independent marketing purposes. Where You consent to marketing cookies on the Site as described in Section 9, Our advertising partners collect online identifiers and browsing activity through the Site in order to measure Our advertising campaigns and to deliver advertising to You on other platforms. Under certain United States state privacy laws, including the California Consumer Privacy Act as amended, this may constitute a "sale" or "sharing" of personal data for cross-context behavioral advertising. You may opt out at any time by withdrawing Your consent through the cookie preference tool on the Site, and We honor Global Privacy Control signals transmitted by Your browser. We do not knowingly sell or share the personal data of individuals under 16 years of age, as that threshold is defined under applicable United States state privacy law. No Meeting Data — including recordings, transcripts, Generated Content, Geolocation Data, or Evidence — is ever disclosed to advertising partners or used for advertising purposes.

7. Subprocessors and International Transfers

7.1 N5 engages third-party subprocessors to provide the Services. A current list of N5's subprocessors, identifying each subprocessor's legal entity, location, and function, is available at https://get-memo.io/legal/subprocessors and forms part of this Privacy Policy.

7.2 N5 may add, remove, or replace subprocessors from time to time. Before a new subprocessor begins processing personal data on N5's behalf, N5 will update the list in the link referred to in Section 7.1. Customers may object to a new subprocessor on reasonable data protection grounds, and the consequences of an objection are set out in the Data Processing Addendum. N5 may engage a replacement subprocessor with shorter notice where necessary to maintain the security or continuity of the Services, in which case N5 will notify customers promptly thereafter.

7.3 All Subprocessors are contractually bound to process personal data only as instructed by N5, solely for the purpose of providing their service to N5, and with confidentiality and security obligations consistent with this Privacy Policy, including the restriction on using personal data to train their own models described in Section 5.1.

7.4 International transfers. The Services are hosted in the United States, and personal data processed through the Services is stored there and may be accessed from the other countries in which N5, its affiliates, and its Subprocessors operate. Where personal data is transferred from a country whose law restricts international transfers, N5 relies on standard contractual clauses or on another transfer mechanism permitted by that law, as further set out in the Data Processing Addendum, available upon request at support@get-memo.io.

7.5 Where N5 processes Meeting Data or User Content as processor under Section 1.3, any such transfer is made on the instruction of the customer, which remains responsible as controller for the lawfulness of the transfer under the law applicable to it.

8. Retention and Deletion

8.1 Personal data for which N5 is the controller. We retain the personal data described in Section 1.2 only for as long as necessary for the purposes for which it was collected, as follows:

• Account and registration information: for the duration of Your Subscription and for 12 months thereafter;
• Communications and support requests: for 12 months after the request is closed;
• Marketing preferences: until You withdraw Your consent or unsubscribe, after which We retain only the record necessary to honor that choice;
• Device, usage, and security logs: for up to 12 months, unless needed longer to investigate a security incident;
• Billing and transaction records: for the period required by applicable tax and accounting laws.

We may retain personal data for longer where required by law or where necessary to establish, exercise, or defend legal claims, and only for as long as that need persists.

8.2 Download window and deletion upon cancellation or termination. Upon cancellation or termination of Your Subscription or account, whether by You or by N5, You may, during the thirty (30) day period following the effective date of termination, download Your Meeting Data (including any transcripts of notices and consents generated through the Product) and other User Content. N5 will remind You before the end of that period. At the end of that period, or earlier upon Your written request, N5 will delete Your Account, Your Meeting Data, and Your other User Content, in each case as set out in the Terms of Use and the Data Processing Addendum.

8.3 CRM Data already synced. CRM Data that has already been transferred into a system You control prior to deletion is not affected by deletion under Section 8.2, because it no longer resides on N5's systems.

8.4 Legal holds. Notwithstanding the foregoing, N5 may retain specific data where required by law, by a competent authority, or to establish, exercise, or defend legal claims, only for as long as that requirement persists.

9. Cookies and Similar Technologies

9.1 We use cookies and similar technologies (such as local storage, web beacons and software development kits in Our mobile applications) to operate the Services, remember Your preferences, keep You logged in, and understand how the Services are used.

9.2 We use the following categories of cookies:

• Necessary cookies, which are required for the Services to function, such as authentication and session cookies. These are set without Your consent because they are strictly necessary to provide the Services You have requested.
• Functionality cookies, which remember Your preferences and settings.
• Analytics cookies, which help Us understand how the Services are used so We can improve them.
• Marketing cookies, which allow Us and Our advertising partners to measure whether a campaign brought visitors to the Site and to show You advertising on other platforms.

We set functionality, analytics, and marketing cookies only with Your prior consent where applicable law requires it. Where consent is required, no such cookie is set before You give it, and You may withdraw Your consent at any time through the cookie preference tool on the Site or, within the Product, through Your Account's privacy settings / Your device settings.

The necessary, functionality, and analytics categories are used both on the Site and within the Product. Marketing cookies are used only on the Site and are never used within the authenticated areas of the Product.

9.3 You can manage or disable non-essential cookies through the cookie preference tool on the Site or through Your browser or device settings. If You disable necessary cookies, some features of the Services may not function properly.

10. Your Rights and Choices

10.1 Depending on where You reside, You may have the following rights regarding personal data for which N5 is the controller (Section 1.2):

• Access a copy of the personal data We hold about You.
• Correction of personal data that is inaccurate or incomplete.
• Erasure of Your personal data, in the circumstances provided by applicable law, subject to Section 8.
• Portability, i.e., to receive Your personal data in a structured, commonly used, machine-readable format.
• Objection to certain processing of Your personal data, including processing based on legitimate interests.
• Restriction of processing of Your personal data, in the circumstances provided by applicable law.
• Withdrawal of consent, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
• Opt-out of marketing communications, by following the unsubscribe instructions in any marketing email We send You.

10.2 Requests regarding Meeting Data or User Content, and requests from Contacts or Recorded Individuals. Where N5 processes Meeting Data or User Content as a processor under Section 1.3 — including where the request concerns a transcript, Geolocation Data, or Evidence relating to You as an Authorized User, or as a Contact who does not have an Account — N5 does not decide or fulfil rights requests, because N5 does not determine the purposes of that processing and, in the case of a Contact, has no way to independently verify Your identity or relationship to a specific Meeting. N5 will acknowledge receipt of Your request and, where it can identify the relevant customer, refer the request to that customer as controller and inform You that it has done so. Please direct such requests to the organization that conducted the Meeting (the Admin or Account holder responsible for the Memo Account used), who is responsible, as controller, for responding to them. If You do not know which organization that is, or need help identifying it, contact Us at privacy@get-memo.io and We will assist You to the extent We reasonably can. N5 will provide reasonable assistance to that organization, consistent with the Data Processing Addendum, to help it fulfill Your request. If that customer's Account has been terminated and the associated Meeting Data has already been deleted under Section 8.2, N5 will inform You that it no longer holds the data to which Your request relates.

10.3 Requests regarding Account or billing data. To exercise any of the rights above regarding data for which N5 is the controller (Section 1.2), please contact Us as set forth in the "Contact Us" section below. We may ask You to verify Your identity before responding to Your request. We will respond to Your request within one month, extendable by two further months where necessary, or within the shorter period required by the law applicable to You.

10.4 If You are not satisfied with Our response, You have the right to lodge a complaint with the data protection authority in Your jurisdiction.

10.5 Automated decision-making. N5, in its capacity as controller, does not make decisions based solely on automated processing that produce legal or similarly significant effects concerning You.

11. Data Security

We implement reasonable technical and organizational measures designed to protect personal data, including Meeting Data, Geolocation Data, and Evidence, from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and We cannot guarantee absolute security.

N5 will notify You without undue delay after becoming aware of any unauthorized access to, or unauthorized use or disclosure of, personal data processed on N5's information systems or on the systems of any Subprocessor, and will provide You with the information reasonably available to N5 that You need in order to assess the incident and to comply with any notification obligation applicable to You as controller, as further set out in the Terms of Use and the Data Processing Addendum.

12. Children's Privacy

The Services are not directed to, and are not intended for use by, individuals under the age of 18. We do not knowingly collect Account registration data from children. If We become aware that We have collected such data from a child without the consent required by applicable law, We will take steps to delete that information. Memo by N5 is intended for use in a business context to document meetings, calls, and visits with adult customers, prospects, and contacts; if Your use of the Services may involve a Contact who is a minor, You are responsible for ensuring that Your notice and consent practices under Section 5 of the Terms of Use are adequate for that circumstance under applicable law. If You believe a child has provided Us with personal data, please contact Us at the email address below.

13. Third-Party Links

The Services may contain links to third-party websites or services, including the Payment Provider's checkout pages and any CRM or other business system with which You configure an integration, that are not owned or controlled by N5. This Privacy Policy does not apply to those third-party websites or services, and We encourage You to review their privacy policies before providing any personal data to them.

14. Changes to This Privacy Policy

We may change this Privacy Policy from time to time. If We make changes, We will notify You by revising the "Last updated" date at the top of this Privacy Policy. If We make material changes, We will provide You with additional notice, such as by adding a statement to the Services or sending a notification to the email address associated with Your Account, at least thirty (30) days before the changes take effect. Where applicable law requires Your consent to a change, We will obtain it before applying the change. We encourage You to review this Privacy Policy regularly to stay informed about Our information practices and the choices available to You.

15. Contact Us

Data Protection Officer. N5 has appointed a Data Protection Officer, responsible for monitoring N5's compliance with applicable data protection law, advising on privacy matters, and acting as the point of contact for data subjects and supervisory authorities. The Data Protection Officer can be contacted at privacy@get-memo.io.

Brazil – Encarregado. For purposes of the LGPD, N5's Encarregado is Eliana Colombo, who can be contacted at privacy@get-memo.io.

Questions and complaints. If You have any comments or questions regarding this Privacy Policy, any concern regarding Your privacy, or wish to make a complaint about how Your personal data is processed by N5, please contact Us at privacy@get-memo.io. You may also lodge a complaint with a supervisory authority, as described in Section 10.4.

Requests from Contacts. Where N5 processes Meeting Data or User Content as processor under Section 1.3, N5 will acknowledge receipt of a request from a Contact and, where it can identify the relevant customer, refer that request to the customer as controller, as described in Section 10.2.