Privacy Policy

MyLife | Memory
Developed by GSDSI
EU Representative: Michael Belsky
EU Representative Contact: michael.belsky@idmap.ai
Privacy Contact: ash@gsdsi.com
Effective Date: 11.08.2026

1. Introduction

MyLife | Memory (“the App”) is designed to support individuals with memory impairments, including dementia, by helping them stay safe, connected, and organized.

GSDSI (“we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data may be collected through MyLife | Memory, why it is used, how it may be shared, how it is protected, and what rights you may have under applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy applies specifically to MyLife | Memory and describes the data processing associated with this application.

Where required under applicable data protection law, you may contact our EU Representative, Michael Belsky, at michael.belsky@idmap.ai regarding data protection matters.

2. Information We Collect

2.1 Personal Information

Depending on the features you use, the App may process:

• Name

• Date of birth

• Profile photo

• Emergency contact details, including name, phone number, and relationship

• Address or home location

2.2 Sensitive and Potentially Sensitive Information

Depending on the features you use, the App may process information that may be considered sensitive or special-category personal data under applicable law, including:

• Real-time location data, when enabled

• Health-related reminders, such as medication schedules

• Information relating to a user's care, safety, or memory-support needs

We process such information only where necessary to provide requested functionality and on an appropriate legal basis under applicable data protection law.

2.3 Usage and Device Data

We may process:

• App interactions, such as buttons used and reminders completed

• Device type

• Operating system and version

• Technical information necessary to operate, maintain, and secure the App

3. How We Use Your Information

We may use personal data to:

• Provide the App's core functionality, including SOS alerts, reminders, and contact management

• Share location with designated caregivers when the relevant feature is enabled

• Send notifications and reminders

• Maintain and improve App performance and functionality

• Protect users and help provide safety-related features

• Detect, prevent, and address technical or security issues

• Comply with applicable legal obligations

We do not use personal data for purposes that are incompatible with those described in this Privacy Policy without providing additional information or obtaining consent where required.

4. Location Data

Location tracking is:

• Optional and controlled by the user or an authorized caregiver where applicable

• Used for safety-related features such as SOS alerts and “Where am I”

• Shared only with authorized contacts when the relevant functionality is enabled

You can disable location sharing through the App or your device settings, where applicable.

Disabling location access may prevent certain safety features from functioning correctly.

5. Data Sharing

We do not sell your personal data.

We may share or disclose personal data only where necessary and permitted by applicable law, including with:

• Family members or caregivers authorized by the user

• Service providers necessary to provide App functionality, such as cloud hosting, notifications, or technical infrastructure

• Professional advisers or service providers where reasonably necessary to operate the App

• Government authorities, courts, or law enforcement where required by applicable law

Service providers may process personal data on our behalf and are required to apply appropriate contractual and security measures where applicable.

6. International and Third-Country Data Transfers

Some service providers or technical infrastructure used to operate the App may process personal data outside the European Economic Area (“EEA”), including in countries that may not provide a level of data protection equivalent to that of the EU.

Where personal data is transferred outside the EEA, we take appropriate measures required by applicable data protection law. Depending on the circumstances, these may include an adequacy decision of the European Commission, Standard Contractual Clauses approved by the European Commission, or other lawful transfer mechanisms and safeguards.

You may contact us using the details in Section 13 if you would like further information about applicable international data transfers and safeguards.

7. Data Storage & Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• Encrypted data transmission (HTTPS)

• Secure cloud storage

• Access controls and authentication

• Appropriate technical and organizational safeguards

Despite our efforts, no electronic system or method of transmission can be guaranteed to be completely secure.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide and maintain the App

• Provide requested safety and reminder functionality

• Comply with applicable legal obligations

• Resolve disputes and enforce applicable agreements

• Protect the security and integrity of our services

Where personal data is no longer required, it will be deleted or anonymized where reasonably possible.

Users or authorized caregivers may request deletion of personal data, subject to applicable legal requirements.

9. Your Privacy Rights

Depending on your location and applicable law, including the GDPR where applicable, you may have the right to:

• Access your personal data

• Request correction of inaccurate or incomplete data

• Request deletion of your personal data

• Request restriction of processing

• Object to certain processing

• Receive your personal data in a portable format where applicable

• Withdraw consent where processing is based on consent

• Lodge a complaint with a competent data protection authority

To exercise your rights or ask questions about the processing of your personal data, contact:

Privacy Contact:
ash@gsdsi.com

You may also contact our EU Representative:

Michael Belsky
michael.belsky@idmap.ai

We may need to verify your identity before completing certain requests.

10. Caregiver Access

Where the App allows caregiver functionality, caregivers may access or manage information such as contacts, reminders, or location information according to the permissions and functionality enabled by the user.

Caregivers are expected to use the information only for legitimate care and safety purposes and to respect the privacy and rights of the person using the App.

11. Children’s Privacy

MyLife | Memory is not specifically directed toward children under the age of 13.

We do not knowingly collect personal data from children under 13 without appropriate authorization where such authorization is required by law.

If you believe that a child has provided personal data to us inappropriately, please contact us so that we can take appropriate action.

12. Third-Party Services

The App may use third-party services to provide functionality such as cloud hosting, notifications, maps, analytics, or other technical services.

These providers may process certain information on our behalf or independently, depending on the service and its configuration.

Third-party services may have their own privacy policies and terms. Where applicable, we recommend reviewing those policies for additional information about their processing activities.

13. Data Controller and Contact Information

For personal data processed through MyLife | Memory, GSDSI is responsible for the processing described in this Privacy Policy, where it determines the purposes and means of processing.

Where another entity participates in determining the purposes and means of processing together with GSDSI, the respective responsibilities of the parties may be governed by an applicable data-sharing or joint-controller arrangement.

For privacy and data protection requests, you can contact:

GSDSI / Privacy Contact
ash@gsdsi.com

EU Representative
Michael Belsky
michael.belsky@idmap.ai

The above contacts may be used for GDPR-related requests, questions, and other privacy matters concerning MyLife | Memory.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the App, our data processing activities, or applicable legal requirements.

When we make material changes, we will provide appropriate notice through the App or other suitable means where required.

The updated version will include a revised effective date.

15. Consent and Legal Basis

Depending on the specific processing activity, personal data may be processed on different legal bases permitted under applicable data protection law, including:

• Performance of a contract or provision of requested services

• Compliance with legal obligations

• Legitimate interests, where applicable

• Consent, where consent is required

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Your use of the App does not by itself constitute consent to every possible processing activity. Where applicable law requires separate or explicit consent, we will request it through the App or another appropriate mechanism.

Effective Date: 11.08.2026