Privacy Policy

Effective Date: June 17, 2025
Last Updated: June 17, 2025

Introduction
Poppo Inc. ("Poppo," "we," "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the MemChat Service ("Service").
1. Information We Collect
Category Examples Collection Method Legal Basis (GDPR)
Account Information Name, email address, phone number Provided by you at registration Performance of a Contract (Art. 6 (1)(b))
Uploaded Data WhatsApp chat logs (messages, media, timestamps, other metadata) File you upload Consent (Art. 6 (1)(a))
Usage Data IP address, device ID, OS version, interaction logs, crash reports Automatically collected Legitimate Interest (Art. 6 (1)(f))
Transaction Data Subscription status, Apple transaction ID Received from Apple Performance of a Contract (Art. 6 (1)(b))
Clone Data Model embeddings and parameters derived from Uploaded Data Generated on our servers Consent / Legitimate Interest

Important Note on Third-Party Data in Uploaded Data
Our Service processes "Uploaded Data" which may contain personal information of third parties (i.e., your chat partners). As stipulated in our Terms of Service, you warrant to us that you have obtained all necessary legal rights and explicit consent from such third parties to allow us to process their data on your behalf for the purpose of providing the Service. Our legal basis for processing this third-party data relies on the consent you have secured from them.

2. How We Use Information

We use the information we collect for the following purposes:

3. Sharing & Disclosure

We do not sell your personal information. We may share information with the following parties under strict conditions:

4. Cookies & Similar Technologies

Our website may use cookies, local storage, and similar technologies to remember your preferences, secure your account, and measure the performance of our services. You can typically disable cookies in your browser settings, but please note that some features of the Service may not function properly as a result.

5. Data Retention & Deletion

We are committed to not holding your data for longer than necessary.

6. Your Rights

Depending on your jurisdiction (e.g., GDPR, CCPA), you may have rights to access, correct, delete, restrict, or object to our processing of your personal information, and to request data portability. To exercise these rights, please email us at info@popporetronym-inc.com. We may need to verify your identity before processing your request.

7. Security Measures

We implement administrative, technical, and physical safeguards designed to protect your information, aligned with industry standards. These include using SOC 2 Type II-audited infrastructure and conducting annual third-party penetration testing. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

8. Children's Privacy

The Service is not directed to or intended for use by children under 18. We do not knowingly collect personal information from children under 18. If we learn that we have inadvertently collected such information, we will take steps to delete it promptly.

9. International Transfers

If you reside outside the United States, your information will be transferred to, stored, and processed in the United States and potentially other countries where our servers or service providers are located. For transfers of data from regions like the EEA, UK, and Switzerland, we rely on legally-provided mechanisms, such as Standard Contractual Clauses or comparable safeguards, to ensure your rights are protected.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If we make significant changes, we will notify you through the app or by email before they take effect, giving you the opportunity to review them.

11. Contact Us

If you have any questions, concerns, or requests, please do not hesitate to contact us.