Memora | Privacy Policy

Cygnet Technology Inc. ("Memora", "we", "us" or "our") operates memora.systems, the Memora bridge application and its API, and the Memora documentation (the "Services"). This policy explains what personal information we collect when you use the Services or contact us, how we use and share it, and the rights and choices you have. Memora is the controller of that information.

This policy is part of the Terms of Use. Words defined there have the same meaning here.

Summary

We do not sell your personal information or use it for targeted advertising.
memora.systems does not use analytics or advertising cookies and does not track you across other websites.
When you use the bridge, your wallet addresses and transfers are recorded on public blockchains and on the Canton Network. We cannot change or delete those records.
We may screen wallet addresses against sanctions lists and other risk information, which can block a transfer.
You can ask to access, correct or delete the information we hold about you by emailing inquiries@memora.systems.

Information We Collect

Information You Give Us

Contact and support requests. Your name, email address, the content of your message, and any company name, role or transaction reference you choose to include.
Business relationships. If you are an issuer, partner or other organization working with us, business contact details and the information needed to verify your organization, such as corporate registration and ownership records. We may collect these directly or through verification providers.

Information From Your Use of the Bridge

Wallet addresses and Canton party identifiers. The addresses you connect and the destinations you choose on each origin chain, and the Canton parties that send or receive bridged tokens.
Transfer records. Amounts, fees, timestamps, transaction signatures and hashes, Canton contract identifiers, and the status of each transfer.
Screening results. Where we screen an address or transfer, the result and any decision we take.

Technical Information

When you visit the Services, our servers and hosting providers record technical information such as your IP address, browser and device type, the pages and API endpoints requested, and the time of each request. We may use your IP address to estimate your country or region, to secure the Services and to comply with sanctions law.

Information From Other Sources

We read public data from the blockchains and networks the bridge uses, and we may receive risk information about wallet addresses from blockchain analytics providers and from public sanctions lists.

Blockchain and Canton Data

Transactions on public blockchains, including every deposit into and release from a bridge vault, are visible to anyone and are permanent. Anyone can see the addresses, amounts and times involved, and others may be able to link an address to you. Neither Memora nor anyone else can alter or delete that data, so the rights described below cannot reach it.

On the Canton Network, a transaction is visible only to the parties involved in it and to the participant nodes that host those parties. For a bridge transfer, that includes your party and its host, the bridge's parties and the independent organizations that host them, and the attestors that confirm the transfer. Records on Canton are also retained by those participants and cannot be deleted by Memora.

Cookies and Browser Storage

memora.systems does not set analytics or advertising cookies and does not use tracking pixels. The bridge application keeps an activity log of your transfers, and your notification preference, in your browser's own storage on your device; we do not receive that log, and you can clear it at any time in your browser. The bridge application may also use strictly necessary cookies or similar tokens to keep your session secure. If we ever introduce analytics or other non-essential cookies, we will update this policy first and ask for your consent where the law requires it.

How We Use Information

We use personal information for the purposes below. Where the law requires a legal basis, the basis for each is shown in brackets.

To provide the Services, carry out and track your transfers, and support refunds and recovery (performing our agreement with you).
To answer your questions and requests (our legitimate interest in responding, or taking steps at your request before an agreement).
To keep the Services secure, and to detect and prevent fraud, abuse and attacks (our legitimate interests).
To comply with the law, including sanctions screening, record keeping and responding to lawful requests from authorities (legal obligation, and our legitimate interest in complying with laws that apply to us).
To operate, maintain and improve the Services, using aggregated or de-identified information where we can (our legitimate interests).
To tell you about changes to the Services, these terms or this policy (our legitimate interests).
To establish, exercise or defend legal claims (our legitimate interests).
For any other purpose with your consent, which you may withdraw at any time.

Screening can block a transfer automatically. If you believe that happened in error, contact us and a person will review the decision. We do not otherwise make decisions about you by automated means that have legal or similarly significant effects.

We share personal information only as follows:

Service providers that process it for us under contract, including our hosting providers (among them Vercel), our email delivery provider (Resend), blockchain infrastructure and RPC providers, blockchain analytics and sanctions screening providers, and business verification providers.
Network participants. The attestors and Canton participants described above receive the transfer details they need to confirm and settle your transfer.
Professional advisers such as lawyers, auditors and accountants, under duties of confidentiality.
Authorities. Law enforcement, regulators, courts and others, where we believe the law requires it, or where it is needed to protect the rights, property or safety of Memora, our users or others.
Corporate transactions. A buyer or successor in a merger, acquisition, financing, reorganization or sale of assets, under this policy.
With your consent or at your direction.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

International Transfers

Memora is based in the United States, and we and our service providers may process personal information in the United States and other countries whose laws may differ from those where you live. When we transfer personal information from the European Economic Area, the United Kingdom or Switzerland, we rely on an adequacy decision where one applies, or on the European Commission's Standard Contractual Clauses and their UK and Swiss equivalents.

How Long We Keep Information

We keep personal information only as long as we need it for the purposes in this policy. Contact and support records are kept for as long as needed to handle your request and any follow-up. Transfer and screening records are kept for as long as the law requires, and otherwise for as long as needed to operate the bridge, handle recovery and defend legal claims. Technical logs are kept for a limited period for security and troubleshooting. When information is no longer needed, we delete it or make it de-identified. Data recorded on public blockchains and on Canton is outside our control and is not deleted.

Security

We use administrative, technical and physical safeguards designed to protect personal information. No system is completely secure, and we cannot guarantee the security of information sent to or through the Services. If a breach affects your personal information, we will notify you and the authorities as the law requires. You are responsible for the security of your wallets and devices; Memora will never ask for your private key or recovery phrase.

Your Rights and Choices

Everyone

You can ask us for access to, or a copy of, the personal information we hold about you, and ask us to correct or delete it. Some requests have limits: we cannot alter or delete data on public blockchains or on Canton, and we may need to keep some records to comply with the law or defend legal claims. To make a request, email inquiries@memora.systems. We will verify your request, which may include asking you to prove control of a wallet address by signing a message, and respond within the time the law requires.

The European Economic Area, the United Kingdom and Switzerland

If data protection law in these regions applies to you, you also have the right to restrict our processing, to object to processing based on our legitimate interests, to data portability, and to withdraw consent at any time without affecting earlier processing. You also have the right to complain to the data protection authority where you live or work, although we would appreciate the chance to address your concern first.

United States

If you live in California or another state with a consumer privacy law, you may have the right to know what personal information we collect, use and disclose, to access it, to have it corrected or deleted, to receive it in a portable form, and to opt out of its sale, of its sharing for targeted advertising, and of profiling. We do not sell or share personal information for targeted advertising, and we do not use sensitive personal information for purposes that would give you a right to limit it. We will not discriminate against you for exercising your rights.

In the past 12 months, we have collected the following categories of personal information, from the sources and for the purposes described above, and disclosed each for business purposes to the service providers and others described in How We Share Information:

identifiers, such as name, email address, IP address, wallet addresses and Canton party identifiers;
commercial information, such as records of transfers;
internet or other electronic network activity, such as server logs;
approximate geolocation derived from IP address; and
professional or employment-related information, for business contacts.

You may use an authorized agent to make a request for you, and you may appeal our decision on a request by replying to our response. We treat a Global Privacy Control signal from your browser as a request to opt out of sale and sharing where the law requires it; because we do not sell or share personal information, no further change is needed. We do not respond to Do Not Track signals, because there is no common standard for them.

Company:: Cygnet Technology Inc.
Email:: inquiries@memora.systems

Memora Privacy Policy