Website Privacy Policy for Memiri
Last Updated: July 10, 2026
Introduction
This Website Privacy Policy explains how Memiri Srl ("we", "our", or "us"), an Italian single-member company with registered office at Via Giovanni Arcangeli, 2 — 56124 Pisa (PI) — Italy, VAT and tax number 02545410504, PEC memirisrl@pec.it, acts as the data controller and processes personal data through the Memiri website at memiri.it (the "Website").
This policy applies only to the Website. Separate privacy information applies to the Twalkie iOS application.
We process personal data in accordance with the General Data Protection Regulation (GDPR), the Italian Personal Data Protection Code (D.Lgs. 196/2003 as amended), and other applicable data protection laws.
Legal Bases for Processing (GDPR Article 6)
| Processing Activity | Legal Basis |
|---|---|
| Responding to contact or feedback requests | Legitimate interest — Art. 6(1)(f) GDPR: responding to requests and improving our products |
| Sending waitlist or product-launch communications | Consent — Art. 6(1)(a) GDPR |
| Storing cookie choices needed to document and respect consent | Legal obligation — Art. 6(1)(c) GDPR: demonstrating and applying the user's privacy choice |
| Essential local storage used for form rate limiting | Legitimate interest — Art. 6(1)(f) GDPR: preventing spam and protecting Website forms |
| Measuring Website usage with optional analytics | Consent — Art. 6(1)(a) GDPR |
| Protecting Website forms and infrastructure | Legitimate interest — Art. 6(1)(f) GDPR: security, spam prevention, and service integrity |
Where processing is based on consent, you may withdraw that consent at any time.
Information We Collect
1. Contact, Feedback, and Waitlist Data
When you submit a Website form, we collect the information you provide, which may include:
- Name
- Email address
- Message, feedback, or inquiry content
- Waitlist consent and submission timestamp
2. Cookie Preferences and Essential Local Storage
We store your cookie choices in your browser so the Website can remember whether you accepted or rejected optional cookies.
We also use local browser storage to remember recent form submissions for rate limiting and abuse prevention. These counters remain in your browser and are not sent to us.
3. Analytics Data
If you consent to analytics cookies, we may use Google Analytics 4 to understand how visitors use the Website. Analytics may include page views, events, device/browser information, approximate location derived from IP address, and referral information.
Google Analytics 4 uses IP addresses transiently to derive approximate location and route requests, then discards them before the address is logged in Analytics. We do not use analytics for advertising, profiling, or automated decision-making.
4. Technical and Security Data
We may process technical data needed to operate and protect the Website, such as IP address, request metadata, security signals, and Firebase App Check data. App Check uses Google's reCAPTCHA v3 provider on the Website to assess whether form requests come from a legitimate browser and to prevent abuse.
5. Optional Microphone Visualizer
The Pisa acoustics page includes an optional microphone visualizer. If you activate it, your browser asks for microphone permission and analyzes the audio stream locally to draw the visualization. Memiri does not record, upload, store, or receive the microphone audio. The stream stops when you stop the feature or leave the page, subject to the browser's permission controls.
6. Interactive Map Requests
If you activate the Pisa map, your browser requests map styles and tiles directly from OpenFreeMap and its delivery providers. Those requests may include IP address, browser/device information, referring page, and request timestamps. OpenFreeMap states that it does not store IP addresses in regular logs but may temporarily enable IP logging during a security incident.
How We Use Your Information
We use Website data to:
- Respond to your messages and requests.
- Manage waitlist or launch-related communications when you consent.
- Improve Website content, performance, and usability.
- Remember and enforce your cookie preferences and local form rate limits.
- Protect the Website, forms, and infrastructure from spam, abuse, or unauthorized activity.
- Comply with legal obligations and enforce our rights.
We do not sell your personal data or share it with third parties for their own marketing purposes.
Cookies and Tracking
The Website uses:
- Essential cookies/storage: required for basic functionality and security, such as remembering cookie preferences and applying local form rate limits.
- Analytics cookies: optional cookies used only with your consent to help us understand Website usage.
You can manage cookie preferences through the Website cookie banner or footer cookie settings. Rejecting analytics cookies does not prevent you from using the Website.
Third-Party Services
Firebase / Google Cloud and reCAPTCHA v3
- Purpose: storing Website form submissions, protecting forms with Firebase App Check and reCAPTCHA v3, and operating Website infrastructure.
- Data Shared: form submissions, IP address, request metadata, and technical/security signals required for the service.
- Privacy Policy: https://firebase.google.com/support/privacy
Google Analytics 4
- Purpose: optional Website analytics, only with your consent.
- Data Shared: analytics events and technical usage data.
- Privacy Policy: https://policies.google.com/privacy
OpenFreeMap / Hyperknot Software Kft. and delivery providers
- Purpose: delivering the optional interactive-map style and tiles after the visitor activates the map.
- Data Shared: map requests and related network/technical metadata, which may include IP address as described above.
- Privacy Policy: https://openfreemap.org/privacy/
Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Waitlist email addresses | Deleted within 30 days after the relevant launch notification is sent, or earlier upon request | Consent and data minimization |
| Contact and feedback messages | Retained for 12 months after the request is resolved | Legitimate interest in follow-up and service improvement |
| Cookie preferences and essential local storage | Stored until you change preferences, clear browser storage, or the preference expires; local form rate-limit counters expire from the rolling anti-abuse window used in your browser | Respecting privacy choices and protecting Website forms |
| Analytics data | Retained in Google Analytics for no longer than 14 months according to our current GA4 data retention setting; aggregated reports may be retained longer without directly identifying visitors | Consent-based analytics |
| Security and abuse-prevention data | Retained only as long as needed to protect the Website and document abuse | Legitimate interest in security |
| Microphone audio used by the visualizer | Not received or retained by Memiri | Processed locally in the visitor's browser |
| Interactive-map request data | Retained by OpenFreeMap or its delivery providers under their published retention rules | Delivery and security of the optional map |
International Data Transfers
Memiri Srl is based in Italy (EEA). OpenFreeMap is operated from Hungary, within the EEA, but it may use delivery providers that operate internationally. Google/Firebase and Google Analytics may process data in the United States or other countries outside the EEA.
Where such transfers occur, they rely on appropriate safeguards, including the EU-U.S. Data Privacy Framework, adequacy decisions, and/or Standard Contractual Clauses where applicable.
Your Rights (GDPR)
If you are in the European Economic Area, United Kingdom, or another jurisdiction with data protection rights, you may have the right to:
- Access your personal data.
- Correct inaccurate or incomplete data.
- Request deletion of your personal data.
- Request data portability.
- Restrict processing.
- Object to processing based on legitimate interests.
- Withdraw consent at any time.
- Lodge a complaint with a supervisory authority.
To exercise these rights, contact us at dpo@memiri.it with the subject line "GDPR Request" and specify which right you wish to exercise.
We may need to verify your identity before fulfilling a request. We will respond within 30 days of receipt, unless an extension is permitted by law.
Children's Privacy
The Website is not directed to children below the applicable age of digital consent. If you believe a child has provided personal data through the Website without appropriate consent, please contact us at dpo@memiri.it.
Changes to This Policy
We may update this Website Privacy Policy from time to time. When we do, we will update the "Last Updated" date above.
Contact Us
For questions, concerns, or requests regarding this policy or your personal data, contact us:
Email: dpo@memiri.it
PEC: memirisrl@pec.it
Mailing Address: Via Giovanni Arcangeli, 2 — 56124 Pisa (PI) — Italy
Supervisory Authority
As Memiri Srl is established in Italy, our lead supervisory authority is:
Garante per la Protezione dei Dati Personali
Piazza Venezia 11 — 00187 Roma — Italy
Website: www.gpdp.it
Email: garante@gpdp.it
If you are located in another EEA member state or in the UK, you may alternatively contact your local authority.