shield-keyholePrivacy Policy

Memoo Privacy Policy

Placeholders to fill:

  • [LEGAL ENTITY NAME]

  • [JURISDICTION]

  • [DATE]

  • [CONTACT EMAIL]


Last Modified: 10th February 2026

[LEGAL ENTITY NAME] and our subsidiaries and affiliates (“Memoo,” “we,” or “our”) respect your privacy and commit to protecting it through our compliance with the practices described in this policy.

This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit, access or use memoo.funarrow-up-right, our applications, communications, or other digital properties that link or refer to this policy (our “Services”). This policy applies to the personal data collected through our Services, regardless of the country where you are located.

The Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully. By engaging with our Services, you acknowledge that you have read and understood this policy. Where we rely on your consent to process personal data, we will obtain such consent as required by applicable law. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued engagement with our Services after any revisions indicates that you accept and consent to them.

For the purposes of applicable data protection legislation, [LEGAL ENTITY NAME] is the data controller responsible for the personal data collected and processed as described in this policy. The term “personal data” as used in this policy describes information that can be associated with a specific person and can identify that person. Personal data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified.

1. Data We May Collect About You

We collect and use different types of data from and about you including:

Personal data that we could reasonably use to directly or indirectly identify you, such as your wallet address, email address, username, social media handles (e.g. X/Twitter account), profile information (avatar, bio), or any other identifier we may use to contact you (“personal data”).

Non-personal data that does not directly or indirectly reveal your identity, such as demographic information, statistics, or aggregated information. We may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific feature.

Technical information, including your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and device information.

Interaction data, including clickstream information to, through, and from our Services (including date and time), tokens viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

On-chain data, including wallet addresses, transaction history, token holdings, bonding curve participation, and migration events. This data is publicly available on the Solana blockchain and is collected and processed by Memoo to provide the Services.

If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

2. How We Collect Data About You

We use different methods to collect data from and about you including through:

Direct interactions. You may give us information by connecting your wallet, creating a profile, linking social accounts, participating in the MooPoints program, completing tasks, or corresponding with us by email or other means.

Automated technologies or interactions. As you interact with our Services, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies).

Third parties or publicly available sources. We may receive information about you from third parties including business partners, analytics providers, blockchain data providers, or publicly available on-chain data.

User Content. You may create or submit content for us to publish or display on or through the Services (collectively, “User Content”), including token names, descriptions, logos, and linked social accounts. You submit User Content at your own risk.

3. Cookies and Automatic Data Collection Technologies

Our Services use cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other users. This helps us deliver a better and more personalized service. It also allows us to improve our Services by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store your preferences so we may customize our Services according to your interests.

  • Speed up your searches.

  • Recognize you when you return to our Services.

Types of Cookies We Use:

Strictly Necessary: These cookies are necessary for the Services to work properly. They include essential authentication and authorization cookies.

Functionality: These cookies enable technical performance and allow us to remember choices you make while browsing, including any preferences you set.

Performance/Analytical: These cookies allow us to collect information about how you navigate the Services. They help us understand which areas you use and how we can improve them.

Targeting: These cookies are used to deliver relevant information to a device that has previously been used to visit our Services.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Services may become inaccessible and certain features may not work correctly.

Our Services may contain web beacons (small transparent embedded images or objects) that permit us to count visitors or compile similar statistics.

Cookies can be controlled, blocked, or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. If you use multiple browsers or devices, you will need to manage your cookie preferences across these environments. For more information about cookies and how to disable them, visit https://www.allaboutcookies.org. Please note that if you restrict, disable, or block cookies, the Services may not operate properly, and we are not responsible for any degraded functionality resulting from your cookie settings.

We may use Google Analytics to help analyze how you use our Services. Google Analytics generates statistical and other information about usage by means of cookies stored on your device. The information generated is used to create reports about the use of our Services. If you do not want your visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptoutarrow-up-right.

4. Third-Party Use of Cookies

Some content or applications on the Services are served by third parties, including content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. We do not control how these third-party tracking technologies operate. If you have any questions about targeted content, you should contact the responsible provider directly.

For the avoidance of doubt, we do not combine or link data gathered from cookies with third-party data for targeted advertising or advertising measurement purposes, nor do we share data collected about a particular end-user or device with a data broker.

5. How We Use Your Personal Data

We use your personal data to:

  • Provide, operate, and maintain the Services.

  • Process transactions and manage your participation in token launches, trading, and the MooPoints program.

  • Meet our obligations and enforce our rights arising from any contracts with you.

  • Fulfil the purposes for which you provided the data or that were described when it was collected.

  • Notify you about changes to our Services.

  • Ensure that we present content in the most effective manner for you.

  • Administer our Services and conduct internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.

  • Improve our Services, marketing, or customer relationships and experiences.

  • Protect our Services, employees, or operations.

  • Detect and prevent fraud, abuse, or violations of our Terms.

  • Calculate and distribute MooPoints, fee rewards, and other incentives.

  • Monitor and analyze user behavior for analytics and platform improvement purposes.

  • Comply with legal obligations and respond to enforcement requests.

We may use non-personal data for any business purpose.

We may process personal data relating to you if one or more of the following applies: (a) you have given your consent for one or more specific purposes; (b) processing is necessary for the performance of an agreement with you or for pre-contractual obligations; (c) processing is necessary for compliance with a legal obligation to which we are subject; (d) processing is necessary for the purposes of legitimate interests pursued by us or a third party, provided those interests do not outweigh your rights and freedoms. Where we rely on consent, you may withdraw your consent at any time by contacting us at [CONTACT EMAIL].

6. Disclosure of Your Personal Data

We may share your personal data with:

  • Any member of our corporate group, including subsidiaries and affiliates.

  • Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics providers, blockchain infrastructure providers, and hosting services).

To fulfil the purpose for which you provide it.

For any other purposes that we disclose when you provide the data.

With your consent.

We may also disclose your personal data to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.

  • To a buyer or successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets.

  • In connection with any assignment or transfer of our rights and obligations under our Terms of Use, including without restriction and without notice to you.

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.

  • To enforce or apply our Terms of Use and other agreements.

  • To protect the rights, property, or safety of our business, our employees, our customers, or others.

We may share non-personal data without restriction.

On-chain data, including wallet addresses and transaction history, is inherently public on the Solana blockchain. Memoo does not control the visibility of on-chain data.

We are based in [JURISDICTION]. We may process, store, and transfer the personal data we collect in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

By submitting your personal data or engaging with our Services, you consent to this transfer, storing, or processing.

Any such transfer of personal data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognized by relevant data protection authorities as providing an adequate level of protection to the personal data we process.

8. Data Retention

We will only keep your personal data for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law.

We determine data retention periods based on the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

Personal data collected for purposes related to the performance of a contract between you and us will be retained until such contract has been fully performed. Personal data collected for our legitimate interests will be retained as long as needed to fulfil such purposes. We may retain personal data for a longer period where you have given consent to such processing, as long as such consent is not withdrawn, or where required by law or order of an authority.

When we have no ongoing legitimate business need to process your personal data, we will delete such data.

However, not all of your personal data may be able to be deleted; see Section 11 (Blockchain Transactions) below.

9. Data Security

We take reasonable measures to protect your personal data from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is 100% secure.

We employ administrative, technical, and physical safeguards designed to protect the personal data we collect. These include encryption, access controls, and regular security assessments. The safety and security of your information also depends on you. We ask you not to share any of your personal security information, wallet credentials, or private keys with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Services. Any transmission of personal data is at your own risk.

10. Your Personal Data Use Choices

We strive to provide you with choices regarding certain personal data uses. If you do not want us to:

Use your contact information to promote our own or third parties’ products or services;

Share your personal data with unaffiliated third parties for promotional purposes; or

Use, process and/or disclose your personal data for all or any of the purposes listed in this privacy policy, you can opt-out by sending us an email at [CONTACT EMAIL]. We may require reasonable time for your request to be processed.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of the Services may become inaccessible or not function properly.

11. Blockchain Transactions

Your use of Digital Assets through the Services may be recorded on a public blockchain, in particular the Solana blockchain. Public blockchains are distributed ledgers intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.

As blockchains are decentralized or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data recorded on such networks. This means that certain rights relating to personal data (such as the right to erasure or the right to rectification) cannot be fulfilled with respect to on-chain data. By using the Services, you acknowledge and accept this limitation.

12. Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by visiting your account profile page on memoo.funarrow-up-right. You may also send us an email at [CONTACT EMAIL] to request access to, correct, or delete personal data that you have provided to us. In some circumstances, we may not be able to delete your personal data except by also deleting your user account.

If you delete your User Content from the Services, copies may remain viewable in cached and archived pages or because other users may have copied or stored them. On-chain data cannot be deleted as it is permanently recorded on the Solana blockchain.

13. Jurisdiction Specific Rights

Where you are a resident of the European Union or the United Kingdom

Data transfers to legal entities in countries outside the European Union or the United Kingdom take place as long as: (i) it is necessary for the purpose of providing you with the Services; (ii) it is required by law; or (iii) you have granted us your consent.

The General Data Protection Regulation (“GDPR”) and United Kingdom GDPR require us to explain the valid legal bases we rely on to process your personal data. We may rely on the following:

Consent. We may process your data if you have given us permission for a specific purpose. You can withdraw your consent at any time by contacting us.

Performance of a Contract. We may process your personal data when necessary to fulfill our contractual obligations to you.

Legitimate Interests. We may process your data when reasonably necessary to achieve our legitimate business interests, provided those interests do not outweigh your rights and freedoms.

Legal Obligations. We may process your data where necessary for compliance with our legal obligations.

Your Rights Under GDPR. If you are a resident of the EEA or UK, you have the following rights with respect to your personal data:

  • The right to access and obtain confirmation of the personal data we process about you.

  • The right to rectify inaccurate personal data.

  • The right to request erasure of your personal data, subject to exceptions provided under the law (including on-chain data limitations described in Section 11).

  • The right to restrict certain processing of your personal data.

  • The right to receive your personal data in a structured, commonly used, and machine-readable format (data portability).

  • The right to object to the processing of your personal data, including the right to object to automated decision-making and profiling.

  • The right to withdraw your consent where you have previously given it for the processing of your personal data.

You also have a right to complain to a supervisory authority.

Where you are a resident of California

California Civil Code Section 1798.83 (“Shine The Light” law) permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal data disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at [CONTACT EMAIL].

California residents can exercise their CCPA rights by contacting us at [CONTACT EMAIL].

14. Children’s Online Privacy

We do not direct our Services to minors and we do not knowingly collect personal data from children under 13 or as defined by local legal requirements. If we learn we have collected personal data from a child without appropriate consent, we will delete it. If you believe we collected any information from or about a child, please contact us at [CONTACT EMAIL].

15. Changes to Our Privacy Policy

We will post any changes to our privacy policy on this page. Please check back frequently to see any updates or changes.

If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes, you should discontinue your access and use of the Services.

16. Complaints

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this privacy policy, please contact us at [CONTACT EMAIL] and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint and will notify you of the outcome of our investigation.

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may also contact your local data protection authority.

17. Contact Information

Please address questions, comments, and requests regarding this privacy policy and our privacy practices to: [CONTACT EMAIL].

When contacting us to exercise any of your rights, please provide (i) enough information to identify you and (ii) a description of what right you want to exercise and the information to which your request relates. Any personal data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

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