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Privacy Policy

Overview

This Privacy Policy describes how Samwise & Co (“we,” “us,” or “our”) collects, uses, and shares information when you use the Memeboard mobile application, including the Memeboard keyboard (the “App”). It applies to all users of the App regardless of location.

By using the App, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

Contact for privacy questions: samwisestudios01@gmail.com


1. Who We Are

The data controller for the Memeboard App is:

Samwise & Co Dubai, United Arab Emirates Email: samwisestudios01@gmail.com

We operate Memeboard under the laws of the United Arab Emirates, including the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), and respect privacy rights granted by laws of other jurisdictions including the European Union General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) for users in those regions.


2. Information We Collect

2.1 Information you provide directly

2.2 Information collected automatically when you use the App

2.3 Information collected through the Memeboard Keyboard

2.4 What we do NOT collect


3. How We Use Your Information

We use your information to:

We do not sell your personal data. We do not share your personal data for cross-context behavioral advertising.


We rely on the following legal bases for processing personal data:


5. Third-Party Services

Memeboard uses the following third-party services to operate. Each service has its own privacy policy that governs how it handles data we send to it.

Services we use

Services we DO NOT use

We will update this list before adding new third-party services to the App.

6. International Data Transfers

Memeboard is operated by Samwise & Co (Dubai, UAE) but our servers are located in Bangalore, India, hosted on the DigitalOcean BLR1 data center. Our application servers, primary database, and core storage all run in the same region. Media content (memes, thumbnails) is served through Cloudflare’s global content delivery network, which caches content at the geographic edge closest to you for performance.

Other service providers we use may store data in different regions:

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, your data is processed outside the EEA. We rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure your data receives an equivalent level of protection as it would within the EEA. By using our service, you consent to this international data transfer. Cloudflare’s data processing is governed by their Data Processing Addendum available at cloudflare.com/cloudflare-customer-dpa.

For users in the United Arab Emirates, transfers comply with the UAE PDPL by ensuring our service providers maintain adequate data protection standards.

For users in India, your data is processed within India by our primary infrastructure.

By using the App, you acknowledge that your data may be transferred to and stored in countries outside your country of residence.

7. How Long We Keep Your Data

We retain your data only as long as necessary to provide the service or meet legal obligations. Where deletion is supported, you can request it at any time as described in Section 8.

Data category Retention period
Account information (email, name, Firebase UID) Until you delete your account, then removed immediately
Favorites and recents Until you delete your account, or you remove them individually in the App
Search analytics (logged-in users) Until you delete your account, then anonymized (the search text is retained for service improvement but no longer linked to you)
Search analytics (anonymous users) Retained while the service is operational; deletion available on request via support email
Meme sharing events (telemetry) Anonymous by design — no user identifier stored; retained while the service is operational
FCM device tokens Until you uninstall the App, deauthorize push notifications, or the token is refreshed
Account deletion compliance record Retained indefinitely as a hashed identifier only (required by GDPR Article 30 and equivalent regulations); contains no recoverable personal data
Server-side operational logs Cycled out by log rotation (typically within 30 days)

We do not currently run automated retention/cleanup jobs for search analytics. Search analytics for logged-in users are anonymized immediately when an account is deleted. For other deletion requests, contact us at samwisestudios01@gmail.com and we will action your request within 30 days.

When you delete your account, your account data is removed immediately. The deletion is atomic — there is no soft-delete or grace period. If you sign back in with the same Google account later, a fresh account is created with no connection to the deleted one.


8. Your Rights

You have the following rights regarding your personal data. To exercise any right, email us at samwisestudios01@gmail.com or use the in-app account features described below.

8.1 GDPR rights (for users in the EEA, UK, Switzerland)

8.2 CCPA rights (for California residents)

8.3 UAE PDPL rights (for users in the UAE)

8.4 In-app account deletion

You can delete your Memeboard account at any time from within the App:

  1. Open the App
  2. Go to the navigation drawer → Account
  3. Select “Delete Account”
  4. Confirm

Deleting your account removes your favorites, recents, and account record from our backend. The deletion is permanent and cannot be undone.

You may also delete your account by emailing samwisestudios01@gmail.com.


9. Children’s Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal information from anyone under 13.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at samwisestudios01@gmail.com and we will delete the information promptly.

For users between 13 and 16 in the European Economic Area, where the GDPR sets a higher minimum age in your jurisdiction, parental consent may be required. We do not knowingly process data from users below the minimum age set in their jurisdiction.


10. Security

We use industry-standard security measures to protect your data, including:

No method of internet transmission or storage is 100% secure. While we work hard to protect your information, we cannot guarantee absolute security.

If we become aware of a data breach that affects you, we will notify you and the relevant authorities as required by applicable law.


11. Cookies and Tracking

The Memeboard mobile App does not use browser cookies. We do not use cross-site tracking or device fingerprinting.

If you visit our website (if any), please review the website’s separate cookie notice when available.


12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Your continued use of the App after the changes take effect means you accept the revised Privacy Policy.


13. Governing Law and Disputes

This Privacy Policy is governed by the laws of the United Arab Emirates. Any disputes arising from this Privacy Policy or your use of the App will be resolved in the courts of Dubai, UAE, unless mandatory consumer protection laws in your country of residence require otherwise.


14. Contact Us

For any privacy-related questions, requests, or concerns:

Samwise & Co Dubai, United Arab Emirates Email: samwisestudios01@gmail.com

We will respond to verifiable requests within 30 days, or sooner where required by applicable law.