◗◗Privacy Policy

Because your privacy is a priority for Custom I.T., Inc. d/b/a momencio (“momencio”), we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device, and that enables your identification (the “Personal Information”).

This Privacy Policy describes our practices with information that we (or our service providers) collect through our mobile applications (collectively, the “App”). This Privacy Policy only addresses information collected directly through or from our App – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the App, such as from telephone, facsimile, postal mail, personal delivery, or other offline means or media.

By providing Personal Information to momencio or by using the App, you agree to the terms and conditions of this Privacy Policy.

The App is not intended for persons under the age of 13. We do not knowingly collect personal information online from persons in this age group. We reserve the right to delete any information identified as having been provided by or concerning such persons.

If you have any questions concerning this Privacy Policy or wish to exercise your rights as described in this Privacy Policy, please email us at info@momencio.com.

1. INFORMATION COLLECTION
   1. Information you provide: Some elements of the App may ask you to submit personal information for you to benefit from the specified features or participate in a particular activity. For example, we may request Personal Information from you when you create an account. You will be informed what information is required to utilize these features of the App, and what information is optional. We may combine the information you submit through the App with other information we have collected from you. We may also combine it with information we receive about you from other sources, including publicly available information sources (such as publicly available social media profiles) as well as our service partners and data licensors, all subject to applicable laws.
   2. Passive information collection, use, and choices: As you navigate the App, certain Personal Information may be passively collected, meaning it is gathered without you actively providing it. This is done using the following technologies in the following ways:
      
      • Through your device: Certain information may be collected about your device and related networks, including your device type, network service provider, and other identifiers. We may also collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the App. In addition,
      • Through your other apps and digital services: Certain features of the App may enable you to connect the App to other applications and digital services used by you, such as Google’s Gmail^® and Microsoft’s Outlook^®. We will notify you before the App communicates with and access data and information from these third-party applications and services, in which case the App may obtain information from or access data stored on your device or processed through these other applications and services, as necessary to provide services requested by you through the App. For example, the App may access: (1) the camera on your device so that you can utilize photographs via the App; (2) your call history, email history and labels, and calendar information so that you can utilize that information via the App; (3) your geographic location so that you can associate certain information on the App with particular locations; and (4) information related to your contacts so that you can sync that information with the App.
      • Using cookies and other analytics tools: Cookies are pieces of information stored directly on your device. We and our service providers use this information and other information gathered via usage analytics tools for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the App. More specifically, we may use cookies to (1) recognize your device to make your use of the App easier, such as to remember your locations of interest and other preferences with the App; and (2) gather statistical information about the use of the App to improve its design and functionality continually, understand how individuals use it, and to assist us with resolving questions regarding it.
   3. Suppose you are uncomfortable with the idea of your Personal Information being collected and used in these ways. In that case, most devices offer privacy settings and options, such as disabling cookies, resetting your IDFA, turning off location-based services, or opting for “Do Not Track” features. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the App, you may be required to provide us with certain information. If you do not wish to provide that information through the App or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the App.
2. HOW WE USE AND DISCLOSE INFORMATION
   1. Overview of use: We use Personal Information submitted by you or otherwise collected through the App and other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Specifically, we may use Personal Information from or about you:
      
      • To respond to your inquiries and fulfill your requests, such as sending information or documents that you request, and to performing requested services, including sending and syncing emails, sharing emails and contacts, sending alerts, and performing natural language processing via the App;
      • To send you important information regarding our relationship with you or regarding the App, changes to our terms, conditions, and policies, and other administrative information;
      • To promote our products and services and the products and services of our third-party business partners; and
      • For our business purposes, such as data analysis, audits, developing new products, enhancing the App, improving our products and services, identifying App usage trends, personalizing your experience on the App by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.
   2. We may use any information that does not personally identify you, your computer, or your device for any purpose.
   3. Overview of disclosure: To provide the features and services made available through the App and accomplish the goals described in this Privacy Policy or at the point when we collect the information, we may disclose your Personal Information as described below and as specifically described elsewhere in this Privacy Policy or at the point we collect information from you:
      
      • To our affiliates for the purposes described in this Privacy Policy;
      • To our third-party service providers who provide services to us, such as hosting, data analysis, payment processing, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, auditing services, and other services;
      • To unaffiliated third parties, including by sharing demographic information, usage statistics, and advertising and device identifiers, some of whom may use it to offer promotions to you for other products and services; and
      • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
   4. Compliance with laws: In addition, we use and disclose Personal Information collected through the App as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including educational institutions; (iv) to protect our operations and those of any of our affiliates; (v) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain.
3. THIRD-PARTY SERVICES
   1. The app may also contain links to or utilize the features of other third-party services for your convenience in locating information, products, or services that may be of interest, including as specified in Section 2.3 above. If you access a third-party service via the App, any information you disclose to that third party is not subject to this Privacy Policy. We are not responsible for the privacy practices of third parties, including other online services. It is your obligation to review and understand the privacy practices and policies of third parties. We do not control the collection of information by these third parties nor how they manage such information. The availability of, or inclusion of a link to or interface with, any third-party service on the App does not imply endorsement of it by us or by our affiliates. Your use of those other sites and services is subject to the privacy policies of those sites and services and not this Privacy Policy.
   2. App’s use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements.
   3. • To deliver and improve our services, momencio uses certain third-party service providers (“subprocessors”) to process personal data on our behalf. These subprocessors are carefully vetted to meet strict data protection and security standards.

                        Subprocessors Used by momencio:

      • Amazon Web Services (AWS)
        • Purpose: Cloud storage and data processing
        • Location: United States
        • More Information: AWS Data Processing Agreement
4. SECURITY
   The security of your Personal Information is important to us, and we are committed to handling that information carefully. We use reasonable and appropriate organizational, technical, and administrative measures to protect personal information that is under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of an account you have with us has been compromised), please immediately notify us of the problem.
5. CHOICES, ACCESS, AND RETENTION
   1. Opting out of collection and disclosure: The easiest way to stop the collection of Personal Information about you is to discontinue using the App, including by no longer using the App or by deleting it from your device. To uninstall the app, you may use the standard uninstall processes that may be available as part of your device or via the application marketplace or network for your device. In addition, except as necessary to obtain the services or information requested, you may opt out of having your Personal Information (that is within our control) prospectively retained by us or used by us for specific purposes by visiting the privacy settings in your account on the App or by deleting your account.
   2. Accessing, correcting, and updating your personal information: At your request, we will provide you with a summary of the Personal Information that we maintain in connection with your account with the App that you have voluntarily provided through email, registration forms, or other contact forms. You may contact us for any of the preceding at dpo@momencio.com. Upon your request and to the extent required by applicable law, we will update or correct that information. We will try to comply with your request as soon as reasonably practicable. You may also visit the App to update your online profile or change your password.
6. BASED IN THE UNITED STATES
   The App is controlled and operated from within the United States. We make no representation that the App is appropriate or available for use outside the United States, or that access and use of the App in accordance with this Privacy Policy complies with the laws of your jurisdiction. Those who choose to access the App from outside the United States do so on their own will and are fully responsible for compliance with applicable laws.
7. UPDATES TO THIS PRIVACY POLICY
   momencio reserves the right at any time to modify, alter, and update this Privacy Policy. Your use of the App following any changes means that you agree to follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall be effective as to any visitor who has visited the App before the change was made. It is the obligation of users of the App before the change to learn of changes to the Privacy Policy since their last use.