Privacy Notice

1. Who is responsible

The data controller is Klodu, a sole trader (enkeltmandsvirksomhed) registered in Denmark under CVR 28046901, at Jenstrup Huse 26, 4690 Haslev, Denmark. For anything in this notice, write to privacy@mementokeep.com.

We are small enough not to need a Data Protection Officer, which means these requests come to a person rather than a queue.

2. What we collect, and why

Account data — your email address, your name if you give one, and a hash of your password. Needed to give you an account and let you sign in. Lawful basis: performance of our contract with you.

Your content — the notes, links, files, pages, meeting recordings and chat messages you put into Memento, and what the agent writes from them. Held so the service can do its job. Lawful basis: performance of our contract.

Connected credentials — the AI provider credential you connect, stored encrypted, so the agent can run as you. Lawful basis: performance of our contract.

Operational data — server logs, error reports, agent run records and approximate usage counts, used to keep the service working, to enforce plan limits and to find bugs. Lawful basis: our legitimate interest in running a reliable, secure service.

Billing data — your subscription status and what Paddle tells us about it. Paddle collects your payment details; we do not see or store card numbers. Lawful basis: performance of our contract, and our legal obligation to keep records.

We do not run advertising trackers, we do not sell personal data, and there is no analytics pixel following you between sites.

3. What happens when the agent runs

Memento drives an AI coding agent using credentials you connect yourself — your own Anthropic (Claude), OpenAI (ChatGPT/Codex) or other provider account. When the agent works on your library, the content it reads is sent to that provider under your agreement with them, not ours.

This is the most important paragraph in this notice, so plainly: content leaves our systems for the AI provider you chose, and their terms — not ours — govern what they do with it. Choose a provider whose terms you are content with, and check whether their settings let you opt out of training. We do not use your content to train models, and we do not send it anywhere else.

Agent runs happen in an isolated sandbox with restricted outbound network access, so the agent cannot quietly send your library somewhere you did not approve.

4. Meeting recordings and transcription

Speech-to-text runs on our own infrastructure — audio is transcribed by a model we host ourselves and is not sent to any third-party transcription service. The resulting text is then treated like the rest of your content, which includes being sent to your AI provider if you ask the agent to work with it.

Recording other people may require their consent where you live. That is your call to make, not ours.

5. Who else processes your data

These are the only third parties involved, each under a data processing agreement and each limited to what its role requires:

• Hetzner Online GmbH — hosting and storage. Runs the servers holding the application, database and your files. (Germany (EU).)
• Cloudflare, Inc. — network, cdn and access control. Traffic to the site and app passes through Cloudflare, which also authenticates administrator logins. (Global, under EU Standard Contractual Clauses.)
• Paddle.com Market Ltd — payments and merchant of record. Sells the subscription to you, handles payment, invoicing, VAT and refunds. We never see or store your card details. (United Kingdom / EU.)
• Resend (Plus Five Five, Inc.) — transactional email. Delivers account email such as sign-in, password reset and beta invitations. Not used for marketing. (United States, under EU Standard Contractual Clauses.)

Notably not on that list: transcription and error tracking, both of which we host ourselves, and your wiki content store, which lives on our own servers.

We may also disclose data where the law requires it, or to establish or defend a legal claim. If we are ever compelled to hand over your data and are permitted to tell you, we will.

6. Where your data lives

Your account, your content and your files are stored in the European Union. Two processors above may handle limited data outside the EU; where they do, transfers rely on the European Commission’s Standard Contractual Clauses.

7. How long we keep it

• Your content and account — until you delete them, or until you close your account.
• After account deletion — removed from live systems promptly, and from rotating backups shortly afterwards.
• Operational logs — kept for a short period for debugging and security, then discarded.
• Billing records — kept as long as accounting and tax law requires, which in Denmark is five years from the end of the financial year.

8. Your rights

Under the GDPR you can ask us to:

• give you a copy of your personal data, or tell you what we hold;
• correct anything inaccurate;
• delete your data;
• restrict or object to how we process it;
• export it in a portable, machine-readable form;
• withdraw consent, where consent is what we relied on.

For export you do not need to ask: Memento has a built-in full export that gives you your pages as ordinary Markdown with your original files. That is deliberate — portability you have to request is not really portability.

Write to privacy@mementokeep.com and we will respond within one month. If you think we have handled your data badly you can complain to your local supervisory authority; in Denmark that is Datatilsynet.

9. Security

Traffic is encrypted in transit. Connected AI credentials are encrypted at rest. Passwords are stored hashed, never in plain text. Agent sandboxes are isolated from each other and from our infrastructure, with outbound network access denied by default. Administrative access is restricted and requires a second factor.

No system is perfect. If we discover a breach affecting your personal data we will notify the supervisory authority and, where the risk to you is high, tell you directly.

10. Cookies

The app sets one essential cookie to keep you signed in. It is not used for tracking, and there is nothing to consent to because there is nothing optional in it. The marketing site you are reading sets no cookies at all.

11. Changes

If we change this notice materially we will tell you before the change takes effect. The date at the top always reflects the last substantive revision. Questions go to privacy@mementokeep.com, or support@mementokeep.com for anything else.