Privacy Policy
Mementum aims to educate people on memory function and on the root causes of functional cognitive symptoms. This information does not replace the usual care from your doctor, who will keep following you up.
The concepts and strategies in this programme have been developed from evidence-based treatment, primarily Cognitive Behaviour techniques (CBT-based), but also some cognitive rehabilitation strategies, attention training programmes and techniques from occupational therapy and speech and language therapy.
We respect your privacy and are committed to being transparent about how we collect, use and share your personal information. Mementum was developed with Cogniss.
By using our App, you confirm you have agreed to the Terms of Use and have read and understood this Privacy Policy.
1. What personal information we collect
Depending on how you engage with the app, we collect different kinds of information from or about you and your symptoms.
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Account and profile information
We collect information about you when you register for an account, create or modify your prole, set preferences, or signup for our app. This includes your name and email address.
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Information you provide to us
We collect and store information you provide by responding to questions or filling in the symptom checkin and memory diary in the app. We also track how you engage with messages you receive in connection with our app, such as notifications to complete a learning activity.
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Your use of our app
When you access or use our app, we collect and store certain usage data. This includes the types of content you view or engage with, the frequency and duration of your activities, and your progression through content.
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Third-Party Services
If you use a Third-Party Service (such as Google or Facebook) to register for an account, the Third-Party Service may provide us with your Third-Party Service account information on your behalf, such as your name and email address. Your privacy settings on the Third-Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third-Party Service.
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Cogniss App Partners
Cogniss may collect information about your interest in, and engagement with Services from Cogniss App Partners. Cogniss App Partners are individuals or organizations that build apps on the Cogniss platform, like Mementum.
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Device information
We collect information from or about the computers, phones, or other devices where you install or access our Services. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Some examples of the device information we may collect include: Attributes such as the operating system, hardware version, device settings, le and software names and types, battery and signal strength, and device identiers. Device locations, including specic geographic locations, such as through GPS, Bluetooth, or WiFi signals. We will ask you to opt-in before we use GPS or other tools to identify your precise location. Connection information such as the name of your mobile operator or ISP, browser type, language and timezone, mobile phone number and IP address.
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Payment information
The Mementum app is free. We do not collect or process any information relating to payments.
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Other
We constantly strive to improve our Services, and often introduce new features that may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.
2. How we use your information
Our mission is to facilitate effective learning experiences that enrich people’s memory and quality of life. We use the personal information we collect about you to:
Provide and personalize our Services.
We create and manage your account, and personalize our Services by using information about how you interact with them. For example, we may use your memory diary results to provide you with customized insights to help you maintain or improve your experience and results.
Communicate with you.
We communicate with you about our Services and let you know about any changes to our policies and terms.
Improve our Services.
We conduct surveys and research in order to test, evaluate, and improve existing products and services, or develop new ones. We may also conduct audits and troubleshooting activities.
We send these communications through email, notices posted on the app or this website, and push notications. You may opt out of receiving these notications at any time.
Promote safety and security.
We help verify accounts and activities to promote safety and security on and off of our Services. This includes enforcing our Terms of Use and other legal terms and policies. Aggregate insights. We use your data to produce and share aggregated insights that do not identify you.
We process your personal information for the above purposes on the following grounds: Consent. By using our app you are consenting to the use of your personal information in a particular way. When you consent, you can change your mind at any time by contacting us.
Legal obligation.
We have a legal obligation to use your personal information.
Legitimate interests.
We have a legitimate interest in using your personal information in the following cases:
To operate the Cogniss business and provide you with tailored communications to assist you in better using Cogniss Services.
To analyze and improve the safety and security of our service, ensuring Cogniss is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
To provide and improve our Services, including any personalized services.
To anonymize and subsequently use anonymized information.
To protect your vital interests, or those of others.
Legal basis
The legal basis that Cogniss will use/process user data will typically be:
● GDPR article 6(1)(a) - the data subject has given consent to the processing of his or her personal data for one or more specic purposes;
● GDPR article 6(1)(b) - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
● GDPR article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
3. How we share information
Anonymized data (data with all user identiable information removed) may be made available to research organizations for the purposes of conducting research. We do not share information that personally identies you with advertising, measurement or analytics partners unless you give us permission, or if we have aggregated the information so that it does not personally identify you.
4. Your rights and choices
Data retention
We keep your personal data only as long as necessary to provide you with our Services.
Deleting your account
You can close your account at any time. When you close your account, you will no longer be able to access it. Things you have accumulated, such as your personalized avatars, badges and achievements, will be removed and archived. If you request, we will delete or anonymize your personal data so that it no longer identies you. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it.
Rights to access and control your personal data
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information. You can access, update, change or delete personal information either directly in your account or by requesting us to do so by using this page contact form or contacting veronica.cabreira@ed.ac.uk.
5. How we protect information we collect
While no App is completely secure, we are dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using rewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
7. Other important privacy information
All services either fully comply with GDPR regulations. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard its privacy. If you have a complaint about our privacy compliance, please contact us at veronica.cabreira@ed.ac.uk. You agree to this when you create an account in the App. If you later wish to withdraw your consent, you can delete your account.
Changes to this policy
We’ll update this Privacy Policy from time to time to reect changes in technology, law, our operations or any other reason we determine is necessary or appropriate. If we make material changes to it or the ways we process personal information, we will notify you before they take effect (by, for example, sending you an email and/or push notication).
How to contact us if you have questions, comments or complaints about this Privacy Policy or would like to exercise your rights and choices, please email us at veronica.cabreira@ed.ac.uk, contact us via our contact form at https://www.treat-fcd-study.com/contact.