Last updated: October 2026 · MnemonX (mnemonx.ai)
Covers: GDPR (EU/EEA) · UK GDPR · CCPA/CPRA (California) · LGPD (Brazil, when available) · PDPA (Singapore/Thailand, when available)
MnemonX ("we", "us", "our") operates the MnemonX neural context engine at mnemonx.ai. We are committed to protecting your personal data and being transparent about how we collect, use, store, and transfer it.
This Privacy Policy applies to all users globally. Additional jurisdiction-specific rights and obligations are detailed in dedicated sections below. MnemonX is an interface to third-party AI models: what you send to the AI is passed to the model provider that answers it, as described in Section 13. By using MnemonX you agree to this policy. For questions: [email protected].
Controller: MnemonX
Website: mnemonx.ai
Privacy contact: [email protected]
DPO / EU Representative: [email protected]
For EU/EEA and UK users, every category of personal data we process has an identified lawful basis:
| Data | Lawful Basis | Detail |
|---|---|---|
| Phone number / OTP | Art. 6(1)(b) — Contract | Necessary to perform the service (authentication) |
| Encrypted wallet data | Art. 6(1)(b) — Contract | Core service delivery; encrypted at rest, decrypted only to serve your own authorized requests |
| SMS consent record | Art. 6(1)(c) — Legal obligation | A2P 10DLC / TCPA compliance requirement |
| Subscription tier | Art. 6(1)(b) — Contract | Necessary to manage your plan and billing |
| Re-engagement SMS | Art. 6(1)(a) — Consent | Explicit opt-in at registration; withdraw anytime via STOP |
| Visit statistics and signup source | Art. 6(1)(f) — Legitimate interest | Understanding which channels bring users; aggregate statistics; no profiling, no advertising |
| API access logs | Art. 6(1)(f) — Legitimate interest | Security auditing; retained 90 days only |
| Data region preference | Art. 6(1)(b) — Contract | Necessary to route your data to the correct regional DB |
When you register, MnemonX detects your location and stores your encrypted wallet in the nearest available data region. Your encrypted wallet and its key are stored only in that region. When you use an AI feature (chat, import, Memory Health, Twin, Studio), the content you send to it is decrypted for that request and passed to the AI provider that answers, which may process it in the United States or elsewhere (see Section 13).
Supabase us-east-1 (Virginia)
Serves: US, Canada, and all others not in EU
Supabase eu-central-1 (Frankfurt)
Serves: EU, EEA, UK, Switzerland, Israel, the Middle East and North Africa
Pipeline regions (coming soon): 🇦🇺 Australia & Pacific · 🇸🇬 Southeast Asia · 🇧🇷 South America. Users in these regions see a "coming soon" page at signup — we will not silently store your data in the wrong region.
Billing data (all regions): Your subscription tier, Stripe IDs, and account metadata are always stored in our US database, regardless of wallet region. Stripe processes payments on their global infrastructure. These records do not contain your wallet content.
Your stored EU wallet data stays in Frankfurt (eu-central-1). Your subscription/billing record is kept in the US. In addition, what you send to an AI, voice or video provider (for example a chat message, a file, a recording or a prompt) is passed to that provider, which is usually in the US, and a message sent through Twilio, Stripe, Resend or Vercel is handled by them as described in Section 13. These transfers are covered by EU Standard Contractual Clauses (SCCs, 2021 modules) incorporated in our DPA. A Transfer Impact Assessment (TIA) is available on request.
When we use third-party services (see the full list in Section 13), we have Data Processing Agreements in place. Twilio's A2P SMS delivery may route messages through US infrastructure for EU phone numbers; this is a delivery-side telecommunications requirement, not a data storage transfer.
If you are located in the EU, EEA, or a country treated as equivalent under GDPR (Iceland, Liechtenstein, Norway), you have the following rights under the General Data Protection Regulation:
Request a copy of all personal data we hold about you. Contact [email protected]; we will respond within 30 days.
Correct inaccurate personal data. Your wallet content can be edited directly in the app at any time.
Request deletion of your account and all associated data. Use the Delete Account function in wallet settings, or email [email protected]. Deletion is permanent and irreversible.
Request that we pause processing of your data while a dispute is resolved. Contact [email protected].
Receive your data in a machine-readable format. Your wallet exports as .txt / .md / .json from your wallet dashboard; your chats (with their files) from the chat export; designs and code projects can be downloaded from their own pages; and your account records (wallet, plan, connected-app access, recent API log) are available via GET /api/v1/user/export. For anything else we hold, write to [email protected] (Art. 15).
Object to processing based on legitimate interests (Art. 6(1)(f)) — e.g. the signup-source record. We will honour your objection unless we have compelling legitimate grounds. Write to us and we remove your signup-source record.
MnemonX does not make automated decisions that produce legal or similarly significant effects about you, apart from automatic security and abuse checks that can block a website from being published or limit an account. You can ask a person to review any such decision by writing to [email protected].
Where processing is based on consent (re-engagement SMS), you may withdraw at any time by replying STOP or using the in-app opt-out. Withdrawal does not affect the lawfulness of processing before withdrawal.
Supervisory authority: If you believe we have violated your GDPR rights, you have the right to lodge a complaint with your national Data Protection Authority. In Germany: BfDI. In France: CNIL. Full DPA list: edpb.europa.eu.
UK users are covered by UK GDPR (the retained EU GDPR as incorporated by the Data Protection Act 2018). Your rights are substantially identical to those in Section 7. Key differences:
Supervisory authority: Information Commissioner's Office (ICO). File a complaint at ico.org.uk.
Data storage: UK users' wallet data is stored in the EU region (Frankfurt, eu-central-1) by default — adequacy decision under GDPR Art. 45 covers UK→EU transfers. Post-Brexit adequacy decisions are subject to UK government renewal.
UK→US transfers: Covered by UK International Data Transfer Agreements (IDTAs) and/or UK Addendum to EU SCCs. Available on request.
If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you the following rights:
Request disclosure of the categories and specific pieces of personal information we have collected, the sources, our business purposes, and the categories of third parties with whom we share it.
Request deletion of personal information we have collected, subject to legal exceptions (e.g. fraud prevention, legal obligation).
Request correction of inaccurate personal information we hold about you.
We do not sell personal information. We do not share personal information for cross-context behavioural advertising. No opt-out is required — we do not engage in these activities.
We collect phone numbers (sensitive PI under CPRA). Use is limited strictly to authentication and service delivery. No profiling, no inference.
We will not deny service, charge a different price, or provide a different quality of service because you exercised your CCPA/CPRA rights.
Exercise your rights: Email [email protected] with subject "CCPA Request". We will verify your identity and respond within 45 days (extendable by 45 days with notice). Authorised agents: provide a signed authorisation letter.
Categories collected (CCPA §1798.100): Identifiers (phone number) · Financial information (Stripe subscription ID, plan tier) · Commercial information (purchase history) · Content you create (chats, files, projects, memory) · Internet activity (security and service logs such as the API access log; we run no product analytics). We do not ask for or collect on our own: geolocation · biometric data · health data · racial/ethnic origin · sexual orientation. Anything of that kind that you choose to write into your wallet, a chat or a file is stored encrypted as your content and handled as described in this policy.
Brazil is a pipeline region — MnemonX will open a South American data residency option when our São Paulo Supabase instance launches. Until then, Brazilian users will see a "coming soon" page and will not be enrolled.
When the BR region launches, data will be processed under LGPD legal bases: execution of contract (Art. 7(V)) for authentication and wallet storage; legitimate interest (Art. 7(IX)) for security logging and fraud prevention; consent (Art. 7(I)) for promotional SMS.
ANPD: The Autoridade Nacional de Proteção de Dados (ANPD) is Brazil's supervisory authority. Complaints: gov.br/anpd.
MnemonX uses strictly necessary browser storage only. No third-party tracking or advertising cookies are set:
AI-powered analysis features
When you run Memory Health analysis (completeness scoring, gap suggestions, duplicate and conflict detection), your active wallet content is sent to our AI provider to generate that analysis, then discarded — we do not retain a copy of what was sent beyond the analysis result itself, which is stored in your own account the same as any other wallet data. This is separate from — and in addition to — the AI import processing described above. We do not use either feature to train any model; what a provider does with what it receives is governed by its own API terms and privacy policy, which we do not control and cannot guarantee.
MnemonX offers an optional Alexa skill, "Mox". Alexa, Echo devices and the Alexa app are made and operated by Amazon, not by MnemonX. By linking your MnemonX account to Alexa you choose to use an Amazon service, which is governed by Amazon's Alexa Terms of Use and privacy notice. Amazon is an independent controller of the data it collects through Alexa, and you are responsible for deciding to use it.
What Amazon keeps. When you speak to Alexa, Amazon records and keeps your voice request, a text transcript, and the response Alexa gives, including what Mox says back. Amazon uses these to run and improve its services, as described in its privacy notice. Facts from your wallet that Mox reads aloud therefore also become part of your Alexa history at Amazon. MnemonX cannot see, export or delete that history, and deleting your MnemonX data or account does not delete it. You can review and delete it at amazon.com/alexaprivacysettings.
What MnemonX does. The skill mainly reads. When you ask a question, Alexa sends MnemonX the question as text and your sign-in token; MnemonX looks it up in the wallet areas you allowed on the consent screen and returns a short spoken answer to Amazon. If you also allow writing on the consent screen, you can ask Mox to save a short note ("remember that …"): Mox reads it back and, only after you say yes, adds it as one new entry in Personal → "Notes added by voice". It never changes or deletes anything else, refuses to save passwords, card or ID numbers, and keeps each note in your version history. The words of a saved note are stored in your wallet (they are your data, encrypted like the rest). We do not receive your voice recording, and MnemonX does not store your questions or the answers.
Private areas and voice code. Health, money, legal and relationship areas, and details such as medical, income, insurance or licence information, are read aloud only after you say a 4-digit voice code that you choose when linking (or later at mnemonx.ai/alexa). We store only a salted, scrambled form of it, never the code, and it is never shown on a screen. After three wrong codes in a row the skill locks for private areas until you link your account again. Details such as passport, national ID, social security, bank account and card numbers and passwords are never read aloud, even with the code. Without a code, private areas stay silent.
Your choices. Use "Disconnect Alexa" at mnemonx.ai/alexa to revoke Alexa's access at once (it also deletes your voice code), or remove it under Connected Apps; change the areas it can read or write in the Alexa app by linking again; change or remove the voice code at mnemonx.ai/alexa. If you only disable the skill inside the Alexa app, Amazon may not tell us right away, so use Disconnect Alexa if you want to be certain access is cut off. Only use Alexa for facts you are comfortable having spoken in the room where your device is, and remember that others who can speak to the device may be able to hear or ask for them.
Community Skills are optional. If you do nothing, none of your skills are shared.
If you share a skill. A copy of its text (name, description, category, when it is used and the instructions) is sent to our central database and may be seen by our reviewers and, after approval, by other paying users. Other users do not see your name, phone number or account details. Do not put personal data, secrets or anything private in a skill you share. The central database is not in your regional data store, so a shared skill is stored outside your chosen region. Lessons you taught a skill and your chats are never shared with it.
If you install or use a community skill. We record that you installed it, and the first time you use it in a chat we record that use (your account id, the skill and the date) so the author can receive credit and so we can check for abuse. We do not send the author your chat, your name or any account detail; the author is only told how many people installed the skill.
Why. To run the library, pay credit to authors, prevent abuse and keep the library safe (contract and our legitimate interest). We keep these records while the skill and your account exist and for up to 7 years as financial and audit records where credit was paid.
Your choices. You can withdraw a shared skill or delete an installed one at any time. Deleting your account removes your shared skills from the library and deletes your installs and use records, except the record that credit was paid, which we keep as an accounting record. Contact [email protected] for any request.
All requests: [email protected]. We respond within 30 days (GDPR/UK GDPR), 45 days (CCPA/CPRA), or as required by applicable law.
Wallet data: AES-256-GCM encryption on your device before it is sent; your key is also stored on our servers so your wallet can sync and so we can serve requests you or your connected apps make (see the Security page for the limits on this). Transit: TLS 1.3. Auth: SMS OTP + optional passkeys (Face ID / Touch ID), with login attempts rate-limited by our authentication provider. Our admin dashboard additionally enforces a specific 5-failed-attempt / 15-minute lockout for staff access. Sessions: you are signed out automatically after 1 hour without activity (a warning shows first); the staff admin dashboard session lasts 8 hours at most. See our Security page for full technical details.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach (GDPR Art. 33). If the breach is likely to result in a high risk, we will also notify affected users directly without undue delay (GDPR Art. 34).
MnemonX is not directed to children under 13 (or the age of digital consent in your jurisdiction, whichever is higher). We do not knowingly collect data from children. Contact [email protected] if you believe a child has provided data.
We update the "Last updated" date when changes are made. For material changes (SMS, data sharing, new regions), we will notify you via the Service. Continued use constitutes acceptance.
Privacy & data subject requests: [email protected]
DPO / EU Representative: [email protected]
SMS opt-out support: [email protected]
Security vulnerabilities: [email protected]
Data Processing Agreement (enterprise): View DPA
MnemonX · mnemonx.ai