Privacy Policy for Easy Memory Item

Effective date: September 29, 2026

This Privacy Policy explains how Easy Memory Item (EMI) processes personal data when you use the EMI applications for iOS or Android and the services they connect to. It does not cover the separate processing that occurs when you browse the public EMI website.

1. Controller

The controller is:

Easy Memory Item UG (haftungsbeschränkt)
Stettiner Straße 28
57518 Betzdorf
Germany
info@easymemoryitem.com

2. Our approach

EMI does not sell personal data, use it for targeted advertising, or track you across other companies' applications or services.

The application keeps some information only on your installation. Other information is associated with your EMI Account and synchronized so that online functions, recovery, and use on more than one installation can work. An EMI Account may initially be anonymous and can later be linked to Apple or Google.

3. Personal data we process

Account, session, and identity data

When an installation first reaches the internet, EMI may automatically create an anonymous Account. We process an internal Account identifier, anonymous or linked status, session records, timestamps, IP address, user agent, and related security metadata.

If you choose Sign-in with Apple or Google, we receive and retain a provider-specific account identifier, identity token, email address and, where supplied, name and authentication tokens. An Apple address may be a private relay address. We use this information to link, recognize, display, manage, and revoke External Identities and to recover your Account. It is not used to train EMI's learning algorithms.

Service choices and acceptance records

We process your selected Usage Goals if you choose to provide them during Onboarding. We also record the version of the Terms you accepted, the acceptance time, application version, and locale. These records allow us to operate the service, understand how learners intend to use EMI, personalize and improve it, and demonstrate the agreement governing an Account.

Learner records

When you use Quiz, EMI records information such as the Quiz scope and content identifiers, Aircraft context, start and finish times, question or sequence type, whether an answer was correct, and the time of the result. EMI does not need to store the answer option you selected in order to record whether it was correct.

We use learner records to provide history, synchronization, progress-related features, and Learning Recommendations. We may also analyze learning activity, learner records, Usage Goals, and service-use data to operate, personalize, evaluate, and improve EMI, including training and evaluating algorithms that recommend or generate learning material.

EMI and service providers acting only on our instructions may perform this processing. We do not permit them to use EMI learner data to train their own general-purpose models. We use aggregated, anonymized, or pseudonymized information where appropriate. Pseudonymized information remains personal data and receives the protections described in this Policy.

Installation-local information

Your installation stores downloaded content, Aircraft selections, recently used Aircraft, checklist and Condition Statuses, Crew Focus, pending changes, and local Sync Issues. Some of this information is not Account-owned and does not synchronize.

Installation-local operational state may remain after Account Deletion because it is not Account-owned. Removing the application does not by itself delete your server-side Account. Use Account Deletion in the application if you want to delete the Account.

Purchases and subscriptions

Apple or Google handles payment details. EMI does not receive your complete payment-card details. EMI and its subscription provider process the internal Account identifier, product, store receipt or purchase token, transaction, subscription, entitlement, renewal, expiry, device, and application information needed to offer, verify, restore, and manage EMI Pro.

Account Deletion does not cancel a store subscription. You must cancel it through the Apple App Store or Google Play. The stores and subscription provider may retain purchase records under their own legal obligations and notices.

Diagnostics, updates, and connection data

Our systems and providers process technical information needed to deliver updates, synchronize data, authenticate requests, keep the service secure, and diagnose failures. This may include IP address, timestamps, application and operating-system version, device or runtime characteristics, update metadata, a randomized installation token, request status, error information, stack traces, a pseudonymous Account identifier, and restricted content identifiers.

The application also measures its own performance: how long it takes to start and become usable, and how long screens take to open. These measurements include the screen name, the content identifiers in that screen's address (for example an aircraft or checklist identifier), a session identifier, the device model, and the application and operating-system version. They contain no Account identifier and no checklist wording, notes, or answers.

EMI's diagnostic configuration disables screenshots, view hierarchy, request bodies, query strings, cookies, authorization headers, network breadcrumbs, console logs, and default collection of directly identifying information in diagnostic events.

Messages you send us

If you contact us for support, request an aircraft, or make a privacy request, we process the contact details, message, attachments, and related correspondence you choose to provide so that we can respond and handle the request.

4. Purposes and legal bases

We process personal data on the following bases under Article 6 GDPR:

• Performance of a contract (Article 6(1)(b)): providing Accounts, synchronization, learning records, requested personalization and Learning Recommendations, identity functions, purchases, subscriptions, support connected with the service, and other EMI features you request.
• Legitimate interests (Article 6(1)(f)): protecting Accounts and systems; preventing abuse; diagnosing faults; delivering reliable services and updates; understanding learner needs; and evaluating, developing, and improving EMI and its learning algorithms. These interests support a useful, secure, and sustainable learning service without using personal data for advertising or sale.
• Legal obligations (Article 6(1)(c)): retaining and providing records where accounting, tax, consumer-protection, or other law requires it, and responding to lawful requests from authorities.

Where you do not provide optional information, the corresponding optional function may be unavailable. An Account Session is necessary for synchronization and other online Account functions. Apple or Google Sign-in is optional and enables recovery and access from other installations. Usage Goals and messages to us are optional. Quiz creates learner records; EMI Pro requires purchase and entitlement information.

5. Service providers and other recipients

We limit access to people and providers that need personal data for the purposes described above. Important recipients include:

Providers generally act as processors on our instructions when handling EMI service data. Apple and Google also process identity, store, and payment information as independent providers under their own privacy notices. Some providers process limited operational information for their own security, compliance, billing, or service-improvement purposes as described in their notices.

We may also disclose relevant information to professional advisers, contractors, competent authorities, courts, or another organization involved in a merger, restructuring, financing, or transfer of EMI, where permitted by law and subject to appropriate safeguards.

6. International transfers

We use European regions for our primary database, synchronization service, and diagnostic event storage. Application performance measurements are processed by Expo in the United States. Some providers, their affiliates, or subprocessors may nevertheless process personal data outside the European Economic Area.

Where required, these transfers rely on an applicable adequacy decision, including the EU–US Data Privacy Framework for participating recipients, the European Commission's Standard Contractual Clauses, or another lawful safeguard. You may contact us for more information about safeguards relevant to your data.

7. Retention and deletion

We retain Account, identity, acceptance, Usage Goal, and learner-record data while the Account exists or while the information is needed to provide the service. Removing an External Identity removes the information held for that identity, subject to limited operational copies and legal obligations.

Account Deletion is available in the application. It deletes the Account and active Account-owned service data, revokes linked Apple tokens where available, removes synchronized Account data from the initiating installation, and dissolves other Account Sessions. Another installation removes its synchronized Account data when it next connects. We cannot remotely remove data from an installation that never reconnects.

Deleted information may remain in restricted disaster-recovery backups for up to 30 days. Backups are not used for ordinary processing and are deleted through rotation.

Ordinary diagnostic and infrastructure records are normally retained for no more than 90 days. A particular record may be retained longer where necessary to investigate a specific security or reliability incident or meet a legal obligation.

Correspondence is deleted when it is no longer needed for the request. Purchase, accounting, transaction, correspondence, or claim-related records are retained longer only where and for as long as applicable law requires or permits. Genuinely anonymized aggregate statistics and models that cannot reasonably identify or reconstruct information about a learner may be retained because they are no longer personal data.

8. Automated processing and recommendations

EMI may automatically score Quiz responses and use learner records to select or recommend learning material. These activities do not make decisions that produce legal effects or similarly significant effects concerning you.

9. Your rights

Subject to the conditions and exceptions in applicable law, you may have the right to:

• request access to and a copy of your personal data;
• correct inaccurate or incomplete data;
• request erasure or restriction of processing;
• receive data you provided in a portable format;
• object to processing based on legitimate interests; and
• lodge a complaint with a competent data-protection authority.

An objection does not automatically require us to stop processing in every case. We may continue where applicable law permits, including where we demonstrate compelling legitimate grounds or require the information for legal claims.

You can delete your Account in the application. For other requests, contact info@easymemoryitem.com. We may request information needed to verify your identity. We will respond without undue delay and ordinarily within one month, subject to lawful extensions.

Our locally competent authority is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz
Hintere Bleiche 34
55116 Mainz
Germany
www.datenschutz.rlp.de

You may instead contact another competent supervisory authority.

10. Security

We use safeguards appropriate to the nature of the information, including encrypted transport, database row-level authorization, platform-secure session storage, operating-system application sandboxing and data protection, restricted administrative access, and privacy filtering for diagnostics. No storage or transmission method is completely secure.

11. Changes to this Policy

We may update this Policy to reflect changes to EMI, our processing, or applicable law. We will publish the current version at easymemoryitem.com/privacy-policy and update its effective date. Where required, we will provide additional notice of material changes through the application or another appropriate channel before they take effect.

12. Contact

For privacy questions or requests, contact:

Easy Memory Item UG (haftungsbeschränkt)
Stettiner Straße 28
57518 Betzdorf
Germany
info@easymemoryitem.com