Memento Network AS is a Norwegian limited liability company («Memento U», «we» or «us»). Memento U is the team behind the Memento U application, the («Application»), the Memento Portal and the Memento Company Portal, collectively referred to as the («Memento Plattform»). We are committed to your privacy. We will make sure to keep your personal data private and secure. We will ensure that your privacy rights.
Memento U is the data controller of the processing of your personal data, as a service provider. We adhere to applicable Norwegian privacy law and meet the requirements according to applicable laws and regulations within the EU/EEAsuch asthe General Data Protection Regulation (“GDPR”)
- Legal basis and Purpose of the Processing
We collect, store and use personal data for several purposes and on different legal basis.
Legitimate interests. Memento U processes personal data on the basis of our legitimate interests, not overridden by your rights. The legal basis of handling your information is legitimate interest for the following purposes:
- To provide you with the website and the Memento Plattform
- To process and respond to your requests and inquiries
- To promote, develop and improve our services, products and content
- To inform you about new developments, features, terms, products, services or promotions, specials, special events, or other activities and to plan and administer the foregoing
- To ensure the technical functionality of the Sites
- To prevent fraud and perform other security measures
Contractual obligations. We process your personal data to fulfill our contractual obligations with you, which includes the following purposes:
- To provide you with the Memento Plattform.
- To administer and process payments.
- To administer and process your invitations to, and responses to invitations received by, others for splitting fees for an activity.
- To inform Memento suppliers of a future activity or session, activity and session preferences, activity and session experiences and past Memento supplier observations.
- To send important notices, such as communications about scheduled activities and sessions and other transactions through the Application and changes to our terms, conditions, and policies.
Legal obligation. Memento U must comply with applicable law and may therefore process your personal data. The basis of our processing is legal obligations for the following purposes:
Consent. In case any processing is not covered by our contractual obligations or your legitimate interests, Memento U will ensure to collect your consent for such processing. You can consent to processing for the following purposes:
- To collect data from your fitness watch or the information about your activities which you log manually, use the information collected from your watch, information about you and your activities, share the information in anonymized form with the technology from PAI Health, in order to generate a user ID, PAI score, fitness age, PAI eared per day, PAI History and VO2 Max
- To follow your explicitly request to share your PAI score with other users
- To generate statistics about the average PAI score of the employee users to the company user, based on anonymized information about the employee users and a set time period
- To send you announcements, promotions, and newsletters
- What Personal Data We Collect, how and from whom
Communication with Memento U. You may contact Memento U per email, telephone and at some occasions, communicate with us directly. Memento U may also contact you regarding our services.
Using our website and Memento Portal as a visitor. As a user of our websites we may collect information about your browsing data, either automatically or through cookies, and information you share through our costumer support service.
Registering as a user in the Application. Users are required to register some personal data when signing up to the Memento Plattform. The user may also choose to register additional information as described below.
Using the Memento Plattform. Different sorts of personal information may be collected and shared through your interactions in the Memento Plattform, as described below.
Automatically collected information. We automatically collect certain information about your computer or device hardware and software and your use of the Sites.
Cookies. We collect personal information through our own and third-party cookies that are on the Sites.
Surveys and questionnaires. We may perform surveys and questionnaires. These surveys and questionnaires are voluntary and normally anonymous, but you may need to disclose certain information that can be personally identifiable.
Communication with Memento U will normally commence at your initiative. In order to respond to your requests or inquires, we may collect and use some of your personal information which you share with us and that are accessible through the Sites.
Users of the Application. Memento U will transmit email or postal mail to you, telephone you or send messages through the Application if necessary, to fulfill a purpose as described in section 1. If we send any emails to promote our services, instructions for unsubscription will be included in each such promotional email from Memento U. Please note that unsubscribe requests may take up to ten (10) business days to become effective. You are not able to opt out from receiving messages in the Application regarding scheduled activities, payment and such.
Suppliers, subcontractors or partners. For communication with suppliers, subcontractors or partners will we, if necessary, to fulfill the purpose of the agreement, register and store contact information such as name and email address. For communication with potential suppliers, subcontractors or partners, we may also register and store contact information if it is likely that there will be a contractual relation.
Job applicants. For anyone who applies for a job at Memento U, we may collect and evaluate their information in regards of potential hiring. Such information may consist the of applicant’s full name, date of birth, home address, e-mail, education, job experience and references, in addition to other information voluntarily given
Customer Support Service by Hubspot:
Users of the website and Memento Portal may use the chat function for coustumer service provided by Hubspot. The chat function may be used in case there is any problems with the Sites or you have other concerns, questions or feedback. In order to reach us through the customer support service you need as a user of the website or Memento Portal, to enter the following information:
- Full name
- Email address
- Information about your concerns, questions or feedback
- Upload up to five attatchments regarding your concerns, questions or feedback
Minimum Personal Data needed to Register as a User:
In order to register as a user of the Application, you must register a minimum personal data. These are:
- Email address
- Full name
- Telephone number
- Country and place of residence
Please be aware that your first and last name and your profile picture will be visible on your profile. Your full profile is not public and cannot be viewed by other users accessing the Application. Your first and last name, and profile picture will be visible for other users in the friend and group functions, chats and user to user interactions. Memento suppliers will have access to view your profile once a booking has been made.
When logged in you will be asked to supply the following required information:
- Payment details (third party, asked for upon first booking)
Optional User Personal Data:
Users can choose to add the following additional information:
- Favorite activity location (will be used in map positioning in searches)
- Photo / Cover photo
- Activity goals (e.g weight loss, social, rehabilitation etc.)
- Activity preferences (e.g. strength training, conditioning, yoga etc
- Trainings per week (e.g. 1, 2-3 etc.)
- Current fitness level (e.g untrained, exerciser, trained etc.)
- A text on the profile where you write something about yourself
- Other pictures than your profile picture (background picture, group chat pics etc.)
Please be aware that if you do add such information, it will be visible for Memento suppliers on your profile together along with your full name and your profile picture. Your profile is not public and cannot be viewed by other users accessing the Application.
Mandatory Personal Data for Memento Suppliers:
In order to register as Memento supplier in the Application, there are certain mandatory personal data you must register. These are:
- Profile picture
- Full name
- Telephone number
- Place of residence
- Information about you as a Memento supplier that you write about yourself
- Areas of expertise (e.g strength training, rehab/prehab etc.)
- Work experience documentation
- Areas of expertise
- A certificate of your liability insurance as Memento trainer
Please be aware that the Memento supplier’s full name, profile picture, other pictures, gender and any text provided will be visible on the Memento supplier profile. The profile is public and may be viewed by anyone accessing the Application.
Optional Personal Data for Memento Suppliers:
Supplemental Information regarding your competence as a Memento supplier, such as:
- Cover photo
- Work zones and schedule
- Certificates, courses etc.
- Affiliations, e.g.
- Clinic or fitness center which you are affiliated.
- Merits regarding sports or fitness.
- Languages mastered.
Please be aware that such optional personal data will be visible on the Memento supplier’s profile together with the Memento supplier's full name and profile picture. The profile is public and can be viewed by anyone accessing the Application.
Personal Data collected while Using the Application:
- Location data (you will be asked to accept the tracking of location data)
- Information about your mobile device
- Email address
- Mobile phone number
- Service provider, etc.
- Usage information and statistics
- Personal data you disclose in the chat or message functions
- Personal data you disclose when writing reviews of Memento suppliers and bookings
Sensitive Personal Data (Special Categories):
Special Categories of personal data or sensitive personal data is information about:
- Racial or ethnic origin
- Political opinions or philosophical or religious beliefs
- Trade union membership
- Genetics and biometrics, for the purpose of uniquely identifying a natural person
- Sex life or sexual orientation
When using PAI Health Technology as described below, Memento U are able to calculate a PAI score, fitness age and VO2 Max, which is considered as data concerning health.
The Application has a chat and message function and other communication tools that enable users and Memento suppliers to communicate. We urge you to not disclose any sensitive personal data, such as information about your health, unless the information is of importance for the performance of an activity or session. If you disclose any sensitive personal data in the chat or messaging functions or other Application functions, we will process such information as described below.
Chat, Messages and Reviews:
The Application has a chat and messaging function that enables communication between users and memento suppliers. The communication is encrypted, which prevents unauthorized access.
We will not monitor the information from our users and Memento suppliers, except if there is reason to believe that there is a vialotion of the user terms, misconduct or if this is necessary for security reasons.
The Application also has other communication tools, like the ability for users to write reviews of health resources and activities.
We urge both users and Memento suppliers to not disclose any sensitive personal data through the chat, message or review function. Sensitive personal data may be shared with the Memento supplier through chat or message if the information is of importance for the performance of an activity or session.
Users may login to the Memento Plattform on their account by entering their username and password in the application or login through Google or Facebook. By pressing the Google or Facebook logo, the user will be redirected to the login page of Google or Facebook. If the user is already logged in on the Google or Facebook platform, the user will automatically be logged in to the Application or Memento Portal.
If you choose to login through Facebook or Google, information about your profile and login will be shared with either Facebook or Google.
Activities and Sessions:
Memento trainers may accept booking requests, schedule and participate in different sessions with users of the Application. Information about sessions is private between the user and the memento trainer that are part in the activity.
Memento suppliers may schedule and participate in different activities with users of the Application. All information available in public activities are visible for other users and Memento suppliers. Information available in private activitys is only visible for users and memento suppliers who have joined the activity.
We process the information about the creator of the activity or session and the participants.
After creating an activity, the creator may share the activity on Facebook, where the name of the activity, date and location of the activity will be shared.. Existing users of Facebook may join the event through Facebook. The creator may also share the activity by email.
Groups and Friends:
Users and Memento suppliers may create public and private groups. The administrator of the group may add information about the name of the group, a group picture, description of the group and category (professional, organization, friends/social/general activity, recreational, sports team, sports and workout). The administrator of the group may invite members to the group, delete and block users and posts.
Users and Memento suppliers may also join groups based on different categories. In order to access a private group, you need approval from the group administrator(s). You will access public groups simply by joining the public group and get access to the group information.
Members of a group may post information and pictures that are visible for the other group members. Group members may comment on posts. Group members are able to see the name and title of the other members of the group and who the administrator(s) of the group are.
In the friends section in the Application users and Memento suppliers will get an overview of suggested friends, existing friends and friend requests. Any user or Memento supplier may become your friend.
PAI Health Technology:
The Technology of PAI Health calculates a PAI score, fitness age and VO2 Max, and will help you keep track of daily accived PAI scores and previous PAI scores, using anonymized user information, data from a connected fitness device or manually tracked information about the users activity.
When registering to PAI Health, you as a user must fill in the following information:
- Date of birth
- Resting hear rate (per minute)
- Activity levels.
In step 3 of the registration, you are able to connect your fitness device to the Application and the PAI Health Technology, which means that Memento U will reccive the information collected through the device, from the service provider. Before we reccive your device data, you must give your consent to the service provider. We reccive information about your heart rate, activities that are being performed and time used in the different heart rate zones, from the service provider of your device.
You may disconnect your device at any time in your settings and we will no longer reccive information from your device.
If you don’t connect to any device, you need to log your activity manually, if you want a PAI score, fitness age and VO2 max calculated. Your activity history may be deleted if you wish to delete the information, which will also cause the different PAI calculations to disappear.
All information about you is anonymized before it is processed through the PAI Health Technology, and used to calculate the different parameters. PAI Health Inc. does not receive any information about you, which can identify you. This information is only accessible for Memento U and stored in Amazon Web Services on serveres in Frankfurt, Germany, before the information is anonymized.
You may share your PAI score with members in a group. Before sharing the PAI score, you must give your consent to the sharing, since the PAI score gives indications on your health and is therefore considered as sensitive personal data.
Memento Company Portal:
Memento U offers a Company Portal to companies who wants to engage their employees in fun activities and inspire to a more active lifestile.
In order to register as a company user, you, as a representant of the company, must register a minimum personal data. These are:
- Email address
- The name of your company
- The address of your company
You will also be asked to supply the following required information:
- Payment details (third party, asked for upon first booking).
Company users may add the email address of employees in the company in the employees section, in order to send them an invitation to use the Application. When recceving the invitation from the company, the employee is free to accept whether they want to use the Application and if they want to share their contact information, profile picture and PAI data with the company, through the Memento Company Portal.
As an employee user you may administrate what information you share with the company user in the sharing center and opt out from sharing your PAI data, profile picture and contact information. You may also choose to completely disconnect your profile from the Memento Company Portal. By pressing the “disconnect” button, the company user you are connected to, will no longer have access to your information.
Company users are responsible for their processing of the employee users personal information. Company users act as joint controller with Memento U, whereas Memento U is the contact point for the employee users.
Memento U offers a portal where you watch workout videos on subscription (UTV) or where you can find or make your workout program with the Premium subscription.
You can enter Memento Portal through the Application, you will then be redirected to mementoportal.com. You can also enter Memento Portal directly through mementoportal.com and browse the website as a visitor. When entering mementoportal.com you can login by using your existing user at the Application.
If you choose to register as user, trainer or activity partner in the Memento Portal, you must fill in the following information:
- Full name
- Email address
- Phone number
While browsing Memento Portal we collect the following information;
- Information about your device
- Information about your browsing
Surveys and Questionnaires:
We may perform surveys and questionnaires. These surveys and questionnaires are voluntary and normally anonymous, but you may need to disclose certain information that can be personally identifiable, such as:
- Relationship status
- Work status
- Activity levels
- Types of activity
- Subjective interpretations of activity, training and fitness
- Subjective interpretations of mental training and barriers
No sensitive data will be required to participate in our surveys and questionnaires.
For surveys and questionnaires we may use Google forms or send these directly to you as native in-app questionnaires – which means that all data is encrypted when you are logged in to the Application.
- Disclosure of Personal Data to Third Parties and Subcontractors
3.1 Subcontractors and Third Parties
Our subcontractors are mainly located within EU/EEA. We use external subcontractors for technical support, security reasons and accounting.
In case of any criminal or other legal proceedings against our costumers, users or suppliers, we may be obligated to overhand personal data and use this data for the establishment, exercise or defence of legal claim.
We may also use subcontractors outside the EU/EEA for processing personal data for the purposes of data storage, data analysis, marketing, payment, webinar and live chat solutions.
Subcontractors in the U.S
On our website mementoyou.com, we have a customer support form by Hubspot Inc. You must you must agree to their legal agreements and the regulations regarding your personal data in order to submit your your information in the support form.
We use Amazon Web Services (AWS) by Amazon inc. for storage of all data that is shared, collected and generated in the Application. The servers are located in Frankfurt, Germany.
“In app” Subcontractors:
Subcontractors in the U.S
When you use the login through Google, you have already agreed to their legal agreements and the regulations regarding your personal data in order to use the Application. You may administrate how your personal data is being processed through Google, such as their cookies.
When you use the Facebook login, you have already agreed to their legal agreements and the regulations regarding your personal data in order to use the Application. You may administrate how your personal data is being processed through Facebook, such as their cookies.
When you use Stripe and their payment service, you must agree to their legal agreements and the regulations regarding your personal data in order to use the Application. You may administrate how your personal data is being processed through Stripe, such as their cookies.
- Your Rights
Withdrawal of consent. If our personal data processing is based on your consent, you can withdraw your consent regarding our use of your personal data at any time in your sharing center or by contacting us. If you want to withdraw your consent, we will stop the processing.
Objection. You may object to the processing of your personal data which is based on legitimate interest and automatic processing of your personal data. You may also object to direct marketing.
Restriction. You can request that we temporarily or permanently restrict the processing of your personal data. Note that restrictions regarding mandatory personal information may prevent or complicate the usage of the Application.
Access. You can request access, free of charge, to the personal data we have collected at any time by contacting Memento U. You can also request information about how we collect personal data. You will be given access in the extent that is reasonable.
Copies. You can request copies of the personal data that we have stored in a machine readable format.
Erasure and rectification. You can request that we erase (delete) and rectify any collected personal data concerning you at any time. Note that if you want to continue using the Sites, erasure may prevent or complicate the usage of the Sites. If terminating or closing your Memento U account, any information contained will be quarantined for 50 days. This quarantine period applies to prevent fraudulently or mistakenly terminated or closed accounts by third parties. Upon expiration of the quarantine period, all personal data is deleted or anonymized. Some personal data may be retained for accounting purposes as required by law.
Complaint to the supervisory authority. Complaint about breach of privacy laws may be lodged to the supervisory authority of privacy in Norway, Datatilsynet.
- Privacy Settings
Users and Memento suppliers may administrate their privacy settings at any time.
Visibility. Memento suppliers and users may change their profile visibility and what information they want to share with other users.
PAI Health Technology. Users are free to choose if they want to use the PAI Health Technology and to withdraw their consent. Users are also free to disconnect their fitness watch from the PAI Health Technology in the settings “manage device”.
Memento Company Portal. Employee users are free to choose what information they want to share with company users in the Memento Company Portal and can administrate the sharing in the sharing centre. Employee users may opt out from sharing anonymized PAI data, their contact information and profile picture. Employee users are also free to completely disconnect from the access to the Memento Company Portal.
Deletion. Users and Memento suppliers are free to delete information shared in chat, groups and their own account. Users may also delete the information about their manually logged activities, under “PAI manual history” in the settings.
- Data Storage
All data shared or generated through the Application is stored on servers in Frankfurt, Germany, provided by Amazon and their Amazon Web Services.
We retain your personal data for as long as it is necessary to complete the purpose of the processing, or otherwise for as long as it is required according to applicable law.
We will delete personal data which are no longer necessary in relation to the purposes for which they were collected or otherwise processed. For example, if you withdraw your consent to receive news letters releases from us, we will delete your email address.
There is only a limited number of employees and subcontractors that have access to your personal data. We perform all necessary and reasonable technical and organizational precautions to prevent unauthorized access or disclosure of your personal information. These measures include both physical and logical measures, such as encryption, risk assessments, and routines for handling data and following up requests about access to and deletion of personal data. We will store all personal information on secure servers in Frankfurt, Germany, provided by Amazon.
If you have any questions or concerns about the processing of your personal data, or you wish to plead one or more of your privacy rights, please contact our customer service. Please note that we may ask you to verify your identity before responding to such requests.
MEMENTO NETWORK AS