Privacy Policy

Emmetros Limited Privacy Policy last updated on June 18, 2018.

This Privacy Policy describes the policies and procedures we adhere to regarding the collection and use of your personal information. This Privacy Policy together with the Terms of Service govern your access to and use of MemorySparx and Emmetros applications, websites, services, and other digital properties (collectively, “the Services”) operated by Emmetros Limited of Ontario, Canada (“Emmetros”, “we”, “our” or “us”).

By using or accessing the Services, you signify your agreement to be bound by our Privacy Policy and our Terms of Service. If you do not agree to this Privacy Policy or Terms of Service, you should not access or otherwise use the Services.

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. We may update this Privacy Policy from time to time so we encourage you to periodically review the Services for the latest information on our privacy practices. If you object to any changes we make, you should cancel your account, otherwise you consent to these changes by continuing to use the Services.

  1. The protection of your sensitive personal information is important to us. 

  2. When you access the Services, we collect and process information, including personal information. Our primary goal in doing so is to enhance your experience. The personal information we collect may include:

    • Basic subscriber information collected when you open an account and make a purchase. For example, an email address, billing address, or other payment information.  

    • Personal content received through your use of the Services. For example, photos or health information that you add to a MemorySparx app. 

    • Logs collected through cookies, crash reports, or analytics tracking tools.  This data helps us to understand how you and others interact with the Services so that we can make improvements, provide features, and diagnose issues. 

    • Location information collected from your IP address or the location information provided by the device you use to connect to the Services. This data helps us to localize the Services. 

    • Device information such as the type of device you use and the operating system of your device.  This helps us to ensure that the Services work as expected on your device.

    • When you ask for help from our customer support team, we will collect and store the information you provide (for example, your name, phone number and email address).  We will store the communications you have with the customer support team and any information in those communications. 

  3. To the extent practicable, we transmit and store your personal information in an encrypted form on professionally managed services located in secure storage facilities. Encryption means that if someone tries to look at the information on our servers, instead of “Paul McCartney”, they will see something like “@%1,B4ss4Vq;j#y”. 

  4. When you use the Services on a mobile device, your data is stored on a cloud-based server. Data stored on the server is encrypted. You should also set a device password to prevent unauthorized access to your apps.

  5. We may process your information outside the country where you live. By using the Services, you consent to the transfer of information outside the country you live in. You understand that if your information is processed in a foreign country, it may be accessible to law enforcement and national security authorities within that jurisdiction.

  6. To get the most out of the Services, we encourage you to provide us with a wide range of information about you such as who you are, activities you enjoy, what medical conditions you have, and other information about you and your family and friends that you use during a normal day and you don’t want to forget.  You are providing us with this information so that the Services can enhance your independence. The more information you provide us, the better able the Services will be able to assist you. 

  7. In order for us to provide you with useful services, we may need to collect, transfer, modify, analyze, and store your personal information. And to the extent practicable, we encrypt and anonymize your information so no one else can see it. 

  8. We may use and then disclose (in anonymized form) the information we derive from your interaction with the Services in order to enable us to adjust your user experience. 

  9. Non-personally identifying information or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you. We may also use tracking information and other non-personally identifying information for the purposes described in this Privacy Policy, such as to serve interest-based advertising content to you and for any other business purposes permitted by law.

  10. We may permit our vendors and subcontractors to access your personally identifiable information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

  11. We may disclose personally identifiable information (i) as required by law or legal process or (ii) to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Services. We may transfer your personally identifiable information in connection with a bankruptcy proceeding or the sale, merger or change of control of Company or the division responsible for the Services with which your personally identifiable information is associated. If we are acquired by or merged with another company, we may transfer information about you to the extent the personal information is necessary to carry on the business or activity that was the object of the transaction. We will give notice to affected users before personal information is transferred or becomes subject to a different privacy policy.

  12. Upon request by email to, we will notify you of the personal information which we store about you. Any exceptions provided by statutory law and the predominant legal interests of Emmetros or any third parties shall be reserved. You may also request that any incorrect or incomplete personal information stored about you be corrected or that the personal information stored about you be deleted. Emmetros does not take any responsibility for any consequences of you failing to provide accurate information to us or of you failing to keep it up to date.  The personal information stored about you and by which you are identifiable will be held by Emmetros unless and until you or a person you authorize has asked us to remove such personal information, subject to reasonable limits if there has been no activity on your account for an extended period of time. 

  13. The Services may use tracking technology to report on who uses the Services and the features or web pages they use within the Services. Some of this information might personally identify you; for example, we might see your name, email address, or location information. Most of the information collected by tracking technology is anonymous, such as the number of visitors to a webpage. Personal content that you add to the MemorySparx application is not collected by tracking technology.  You may choose not to accept cookies in your web browser but doing so can interfere with the functionality of the website.  By accessing the Services, you agree to the transfer and storage of some information in the form of tracking technology, including browser cookies.

  14. Emmetros employees and other trusted parties will from time to time require access to some of your personal information in order to provide you with customer support and to maintain the functionality of the Services. We will endeavor to access only the minimum information required to complete the task. 

  15. Emmetros uses a range of technologies to ensure the protection of your personal information.  Please note, however, that information transmitted unencrypted over an open network, such as the internet or email, is easier for others to access and we cannot guarantee, and are not responsible for, the confidentiality of any communication or information transmitted via such open networks. When disclosing your personal information via an open network, you should consider that it is potentially accessible to others, and consequently, may be collected and used by others without your consent.  In particular, while individual data packets are often encrypted, the names of the sender and recipient are not.  Even if both the sender and recipient are located in the same country, data may be transmitted via such networks to other countries regularly and without controls, including countries that do not afford the same level of protection as Canada.  Your personal information and other data may be lost during transmission or may be accessed by unauthorized parties.  We do not accept any liability for direct or indirect losses as regards the security of your personal information during its transfer via the internet. 

  16. We may communicate with you through email or other means. Communications may relate to events, registration confirmations, promotions, service availability or other service-related issues. We use your personal information for system purposes, including the distribution of emails that are important for your use of the system. For example, we will send you an email to notify you that your account is no longer active. You are not able to opt-out of certain communications, including those relating to functions or features of the Services, or technical or security notices. We will not sell, rent or otherwise make available any of your personal information to any third parties without your consent, except as otherwise allowed under this Privacy Policy or required by law.

  17. You authorize us to de-identify your personal information and subsequently to copy, process, use, publicly disclose and distribute the personal information in anonymized form for research, academic and statistical purposes. Such anonymized information shall no longer be considered personal information.  

  18. You authorize us to receive, review and store technical usage information (such as crash reports) retrieved from the devices you use to access the Services. 

  19. We reserve the right to disclose your personal information to the extent we reasonably believe it is necessary in order to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce Apple’s End User License Agreement (to the extent it governs your use of our applications) and this Privacy Policy, including investigations of a potential violation thereof, (iii) detect, prevent or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or to (v) protect the rights, property or safety of Emmetros, its users and the public. 

  20. Please note that we use encryption software that may be subject to export control regulations. 

  21. The Services may contain links to websites, applications, or materials that are not operated by Emmetros. They are not subject to this Privacy Policy and Emmetros is not responsible in any way for their content or accuracy or their policies regarding the treatment of personal information. You access them at your own risk.  We recommend that you read their policies and check how they protect your personal information and confirm for yourself whether they are trustworthy. 

  22. This Privacy Policy shall in all respects be governed by Canadian substantive law. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Ontario, Canada, and you consent to such jurisdiction of and venue in such courts and waive any objection as to inconvenient forum. 

  23. We may use email, mailings, phone calls, or internet conferencing to communicate with you, send information that you have requested, solicit feedback, or send information about other Services. We will not give your personal information to another party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy. Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like, are and will be treated as non-confidential and non-proprietary. Except to the extent expressly covered by this policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting.

  24. If you would like to opt out of promotional materials from us, you may indicate this preference by changing the communications setting within a MemorySparx account management screen or by following the unsubscribe instructions provided in our email communications. Please note that even if you opt out of promotional messages from us, if you have a MemorySparx account, then we will continue to send you important system-related information.

  25. The Services are designed for those 13 years of age and older. We do not knowingly collect information from anyone under the age of 13. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records. No part of this website is designed with the purpose of attracting any person under the age of 13.

If you have questions or concerns about this Privacy Policy please contact us by email at or contact us by mail at:

Emmetros Limited
Accelerator Centre, West Entrance
295 Hagey Blvd.
Waterloo, ON, N2L 6R5

If, having shared your concerns with us, you are still not satisfied, you may file a complaint with the Office of the Privacy Commissioner of Canada by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1 800 282 1376.