Privacy Policy

Version 2.2 · Last updated: 31 October 2026 · Applies to the phone app memovu (Android, com.memoshow.memoshow_mobile), the TV app memovu for Fire TV (com.memoshow.receiver), the memovu receiver for Google Cast, and this website including the purchase of license codes. This is a translation; the German version prevails.

1. Controller

Further details are in our imprint. We have not appointed a data protection officer because the legal requirements for doing so (Art. 37 GDPR, § 38 BDSG) are not met.

2. Summary

3. What stays on your phone and your TV

The app processes the following data only on your device or on your local network. We have no access to it.

4. How your media is transferred on your home network

To show a photo or video, the phone app starts a small media server that can only be reached on the local network. The TV fetches the files from there. Here is honestly what is encrypted and what is not:

What this means for you: someone recording the traffic on the same Wi-Fi could read the transferred images and the access key. On your own password-protected Wi-Fi the risk is low. On open or third-party networks (hotel, venue) we recommend your phone's hotspot. We are working on encrypting the media path to the Fire TV app as well and will update this policy when we do.

5. Google components in the app

These components come from Google and send data to Google themselves. We do not receive this data. Google's processing is governed by Google's privacy policy. Google may transfer data to countries outside the EU, such as the USA; Google LLC is certified under the EU-US Data Privacy Framework.

5.1 Purchases via Google Play

You buy Pro (monthly or yearly subscription, one-time purchase) through Google Play. Google is the contracting party and merchant for these purchases. Payment runs through your Google account; we receive no payment data and run no purchase server of our own. Google Play only tells the app whether a purchase is active; the app stores this locally. You cancel and manage subscriptions in Google Play. On payments: Google Payments privacy notice. The app on your phone manages the 48-hour Pro trial, without an account and without payment data. So that reinstalling the app does not restart it, the memovu app on a Fire TV remembers a non-reversible checksum of your phone's device ID and the trial start time; the ID itself never leaves your phone. This data stays on the TV in your home network (section 3).

5.2 Google Cast (Chromecast, Google TV)

For Chromecast and Google TV the app uses the Google Cast SDK. According to Google, it logs device discovery and session events as well as information about the phone and the app, in order to monitor SDK usage and performance and to detect bugs. According to Google, the data is encrypted in transit, not shared with third parties and contains no identifiers that can be traced back to a specific user. According to Google, this cannot be switched off. (Source: Google Cast – Data disclosure.)

By default, the app uses Google's standard receiver on Chromecast devices. If the memovu receiver is active instead, the Chromecast loads its program files from our web server (section 12) and the Cast library from Google (www.gstatic.com). Even then it loads your photos only from your Wi-Fi.

5.3 QR scanner (zxing-cpp, without Google)

The app reads the QR code on the TV with the open-source decoder zxing-cpp (package flutter_zxing) and Android's camera interface. Recognition runs entirely on the phone; the camera image is neither stored nor transmitted, and this component sends no data to Google or any other third party. (Until October 2026 the app used Google ML Kit for this; it has been removed.) If you prefer not to use the camera, you can pair the TV without scanning: the app finds it on your Wi-Fi and you confirm the security code shown on the TV.

5.4 Web video browser (Android WebView with Google Safe Browsing)

The app's web video browser uses the Android WebView, in which Google Safe Browsing is switched on (the Android default, which we keep for security reasons): the addresses you visit are checked against Google's list of dangerous sites so you are warned about scam and malware sites. Google describes how this works at developers.google.com/safe-browsing.

6. Permissions of the phone app

The app asks for permissions only when you use the feature:

• Photos and videos (READ_MEDIA_IMAGES, READ_MEDIA_VIDEO, READ_MEDIA_VISUAL_USER_SELECTED): to show media from your gallery on the TV. From Android 14 you can also grant access to selected photos only. In event mode the app optionally saves approved guest photos to your gallery.
• Music (READ_MEDIA_AUDIO): only when you choose your own music for a slideshow.
• Camera (CAMERA): only for scanning the QR code on the TV.
• Microphone (RECORD_AUDIO): only when you turn on sound while mirroring. Android requires this permission so that device audio (e.g. from a video) can be forwarded. Your surroundings are not recorded.
• Notifications (POST_NOTIFICATIONS): for the Memories reminder and the notice that something is playing on the TV.
• Network (INTERNET, ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE, CHANGE_WIFI_MULTICAST_STATE): for the connection to the TV on the local network and to find it on your Wi-Fi. Only the Google components named in section 5 and the web video browser go to the internet.
• Run at startup (RECEIVE_BOOT_COMPLETED): restores the Memories reminder after a reboot.
• Foreground services (FOREGROUND_SERVICE, …_CONNECTED_DEVICE, …_MEDIA_PROJECTION): keep a running slideshow, video or mirroring session alive while the screen is locked. A notification is shown.

The Fire TV app uses only network permissions and a foreground service so that reception stays active behind the screensaver.

7. Memories reminder

The app can remind you of memories (e.g. "One year ago today"). The reminder is scheduled and shown on your phone only; no data is sent for it. You can switch it off in the app settings or in Android's settings.

8. Web video

When you open a website in the web video browser or send a web video to the TV, your phone or TV connects directly to that website. As with any browser, the website receives your IP address and device information, and its privacy terms apply. We are not involved in this connection and do not learn what you open. For Safe Browsing see section 5.4.

9. Event mode (guest photos at events)

In event mode, guests upload photos from their own phones to the host's live slideshow via a QR code. The following applies:

• The photos go directly to the host's phone over the Wi-Fi or hotspot on site (transfer: see section 4). No memo labs servers are involved; we receive neither photos nor any information about the event or the guests.
• During the event, the host's phone processes the local IP addresses of guest phones to enforce upload limits and, if the host wishes, to block individual guests. This stays in memory and is gone when the event ends.
• The host approves or rejects photos. Approved photos are optionally (default: on) saved to the album "memovu Event <date>" in the host phone's gallery. They stay there until the host deletes them.
• Until the event ends, guest photos are kept in the app's cache on the host's phone. If the connection to the TV drops, they stay there so the event can continue. "End event" deletes photos not yet approved immediately; approved photos that were not saved to the gallery are deleted as soon as the connection to the TV has ended as well. If the app is closed before that, it removes the leftovers at the latest when the next event starts; "Clear app data" removes them at any time.
• The controller under the GDPR for guest photos is the host. For purely private celebrations, the household exemption usually applies (Art. 2(2)(c) GDPR). Commercial hosts (e.g. photographers, event businesses) are themselves responsible for informing their guests under Art. 13 GDPR and for having a legal basis. For this the app has a "Note for guests" field that appears on the guests' upload page. This also applies to the photos in the gallery album: the host decides how long they are kept there and deletes them accordingly. Hosts who do not want to keep guest photos on their own phone switch off "Save approved photos automatically" in the event settings and choose "Don't keep" when ending the event.

10. License codes in the app

You redeem license codes for the professional license (Event Pro, memovu Business) and the event pass in the app. Each code carries a digital signature that the app checks on the device with a built-in key. No server request takes place; the app reports the redemption to no one. Validity and code ID are stored locally so the same code cannot be activated again on this device.

11. Support requests and error report

When you write to us, e.g. via "Contact" in the app's help, we process your e-mail address, your name (if given) and the content of your message to answer the request. The app opens your e-mail program and inserts an error report: app version and the app's latest events and error messages, without access keys. You see the text before sending and can change or delete it. Our e-mail runs on Google Workspace (section 13.6). The legal basis is Art. 6(1)(b) GDPR where your contract is concerned, otherwise Art. 6(1)(f) GDPR (our interest in answering requests). We delete requests once they are settled, at the latest after two years, unless statutory retention duties apply.

12. This website

This website is hosted by Hetzner Online GmbH (Industriestraße 25, 91710 Gunzenhausen, Germany) on servers in Germany. Hetzner processes data on our behalf (data processing agreement under Art. 28 GDPR).

• When you visit, the server necessarily processes your IP address, date and time, the page requested, the browser type and the amount of data transferred. Without this the page cannot be delivered. Access logs, where they occur, are deleted after 14 days at the latest. Legal basis: Art. 6(1)(f) GDPR (secure and stable operation of the website).
• No cookies, no analytics, no third-party content: the pages set no cookies, use no analytics or tracking services and load no fonts, scripts or images from third-party servers. The only exception is the checkout page for online purchase, once we offer it (section 13.4).

13. Buying license codes (businesses and organisations only)

13.1 Direct purchase by e-mail and invoice

If you order license codes (Event Pro license, 5-pack of event passes, memovu Business) directly from us, we process the data from your request, order and contract: name and address of the business or organisation, the contact person's name, e-mail and, if given, phone number, country of establishment, for memovu Business the site and number of TVs, VAT ID and the result of its check, your confirmation that you order for a business or organisation (with time), proof of business or non-profit status, purchase order number or routing ID, invoice and payment data, and the license code's ID and term.

• Purpose: checking the order, quote, contract, invoice, matching payments, license code, support and bookkeeping.
• Legal bases: Art. 6(1)(b) GDPR where you are the contracting party yourself (e.g. as a sole trader); Art. 6(1)(f) GDPR for contact persons at businesses and organisations (our legitimate interest is communicating with our customers); Art. 6(1)(c) GDPR for tax and commercial retention duties (§ 147 German Fiscal Code, § 257 German Commercial Code, § 14b German VAT Act) and VAT ID checks with the German Federal Central Tax Office (§ 18e German VAT Act).
• Recipients: sevDesk GmbH, Im Unteren Angel 1, 77652 Offenburg, Germany (invoicing and bookkeeping, processor under Art. 28 GDPR); Qonto (Olinda SAS, 18 Rue de Navarin, 75009 Paris, France; our business bank, independent controller); Google Workspace for e-mail (section 13.6); tax authorities. We check VAT IDs with the German Federal Central Tax Office.

13.2 Reminder before expiry

About four weeks before an Event Pro or memovu Business license expires we send you a reminder with a renewal quote (Art. 6(1)(f) GDPR, § 7(3) German Unfair Competition Act). You can object at any time, e.g. by e-mail to support@memolabs.de, at no cost other than basic transmission costs.

13.3 Online purchase via Paddle

Once we offer online purchase on the website, license codes are sold by our reseller Paddle.com Market Limited (30 Old Bailey, London EC4M 7AU, United Kingdom). Paddle is then your contracting party for the purchase and handles payment, invoicing, VAT, refunds and chargebacks. For this, Paddle processes as an independent controller your name, e-mail address, country and possibly postcode, payment data, possibly your VAT ID, your IP address (among other things as tax evidence of your country of residence) and fraud prevention data. The Paddle privacy policy applies. The EU Commission has issued an adequacy decision for the United Kingdom (Art. 45 GDPR). Before the checkout opens, our purchase page asks for your business name and your confirmation that you order as a business; we pass both, with a timestamp, to Paddle and keep them as evidence (Art. 6(1)(b) and (f) GDPR). We never see card numbers or bank details.

13.4 Paddle checkout on the purchase page

Only the purchase page loads Paddle's payment window (Paddle.js), and only after you click "Continue to payment". Your browser then connects to Paddle's servers; Paddle receives your IP address and browser information and may store data in your browser that is needed for payment and fraud prevention. This is strictly necessary for the purchase you requested (§ 25(2) no. 2 TDDDG); the legal basis for the processing is Art. 6(1)(b) GDPR. No other page of this website loads anything from Paddle.

13.5 What we receive from Paddle

After an online purchase Paddle sends us your name, e-mail address, country, company, your business confirmation with time, product, price, order number and order date. We use this data to create your license code, send it to you, help you with questions and keep our accounts. Legal bases: Art. 6(1)(b) GDPR (contract) and Art. 6(1)(c) GDPR (tax and commercial retention).

13.6 Delivery by e-mail (Google Workspace)

We send quotes, invoices and license codes by e-mail. Our e-mail runs on Google Workspace from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) as processor (Art. 28 GDPR). A transfer to the USA cannot be ruled out; it is based on the EU-US Data Privacy Framework and the EU Commission's standard contractual clauses.

13.7 Retention

Requests and quotes that do not lead to an order are deleted after six months. Accepted quotes, order confirmations and business letters are kept for six years, invoices and accounting records for eight years, books and annual accounts for ten years (§ 147 German Fiscal Code, § 257 German Commercial Code, § 14b German VAT Act). License code data is kept for the term and afterwards as long as we need it for renewals and support, at most until the end of the retention period. Then we delete it.

14. Recipients at a glance

Beyond that, we only pass on data where we are legally obliged to, e.g. to tax authorities.

15. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on Art. 6(1)(f) GDPR (Art. 21). Write to us at support@memolabs.de. Data in the app is only on your device; you can delete it yourself at any time (clear app data or uninstall). For data held by Google Play or Paddle, you can also contact these providers directly.

You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin, Germany, www.datenschutz-berlin.de.

16. Obligation to provide data

You do not have to give us any data to use the app. To buy a license code we need the data listed in section 13.1 for direct purchases; for online purchases Paddle needs the details marked as mandatory in the payment window. Without them no purchase is possible. We do not use automated decision-making, including profiling (Art. 22 GDPR).

17. Children

The app and the license codes are not aimed at children. We sell license codes to businesses and organisations only.

18. Changes

We update this policy when the app, the website or the law changes. The current version is on this page; the app links to it under Settings → Privacy.