Below are the individual processing activities with their purpose and legal basis under Art. 6 GDPR.
- User account
- Email address, phone number, password (stored exclusively as a cryptographic hash, never in plain text), language preference, and the confirmation status of email and phone number. Purpose: providing the account, login, and protection against misuse. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Bookings and day plans
- Booked services, dates, number of guests, special requests in free text, planned stations for a day, and the version of accepted terms you acknowledged. Purpose: processing the booking and providing proof of contract contents. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Date of birth for age restrictions
- For categories with statutory or contractual age restrictions, we collect and verify your date of birth before booking. For offers without age restrictions, we do not collect it. Legal basis: legal obligation and contract performance (Art. 6(1)(c) and (b) GDPR).
- Residency verification
- To unlock resident pricing we check your NIE number. The number is validated in memory only and discarded immediately afterwards — we do not store it. Only the result of the check is stored, as a yes/no value. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- View mode and travel dates
- Whether you use the platform as a visitor or as a resident and, in visitor mode, the travel dates you have entered. Purpose: tailoring the listings to your situation. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Payment processing
- Amount, currency, booking reference, and payment status. Card data are processed exclusively by our payment service provider and never reach our servers. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Booking notifications
- Emails for registration, confirmation, reminder, change, and cancellation, along with a transmission log. Purpose: performance of the contract. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Booking through a provider's website
- If an activity provider embeds our booking form on its own website or uses its booking page on memply.app, you book without a MEMPLY account. We process your name, email address, phone number, language, the booked offer with date and number of people, and a booking code. Payment goes through the provider's payment account; card data is processed by the payment service provider. The confirmation and reminder are sent in the provider's name from our address, and replies go to the provider. The seller is the provider, who is the controller for this data; we provide the booking system and process the data on the provider's behalf (Art. 28 GDPR). The website on which the form is embedded does not receive your details. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
- Location data
- When you add a location to a station or photo in the app, we primarily use the coordinates embedded in the image metadata, and otherwise — after explicit permission in your operating system — your current location. We request permission only at the moment you use the feature and do not track your location in the background at any time. Legal basis: consent (Art. 6(1)(a) GDPR), withdrawable at any time via system settings.
- Photos, videos, and notes in your travel journal
- Media you upload, together with optional location data, rating, and personal notes. Purpose: providing your travel journal. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Reviews
- Rating and text for a completed booking. Reviews are publicly visible; please do not publish information there that you do not wish to be public. Legal basis: contract performance and legitimate interest in comprehensible offer ratings (Art. 6(1)(b) and (f) GDPR).
- Points, badges, and membership
- Points collected, badges earned, and membership tier with expiry date. Purpose: providing the loyalty program. Legal basis: contract performance (Art. 6(1)(b) GDPR).
- Marketing communications
- If you have consented, we send notifications about offers. Consent is given separately for email and push notifications and is withdrawable at any time individually — via settings or the unsubscribe link in each message. Our newsletters contain a tracking pixel and route links through our server; this lets us record whether a message was opened and whether a link in it was clicked. If you do not load images in emails, you are not counted as having opened it. Legal basis: consent (Art. 6(1)(a) GDPR).
- Referral information at registration
- If you arrive through a referral or campaign link, we store the identifier contained in it to credit the referral and assess the effectiveness of our own outreach. Legal basis: legitimate interest (Art. 6(1)(f) GDPR); you may object at any time.
- Partner accounts and documentation
- For partner businesses, we process company and contact details, tax number, address, and uploaded business and license documentation. These documents are stored in a non-publicly accessible area and are intended exclusively for review by our team. Legal basis: contract performance and legal obligation (Art. 6(1)(b) and (c) GDPR).
- Partnership requests to businesses
- We contact businesses we would like to win as partners once by email. For this we process the business name, category, business email address, phone number, website, address and, where available, the name of a contact person. The data comes from publicly accessible sources such as the business’s own website; we record the source for each contact. To find out whether the message arrived, we record whether it was opened (via a counting pixel, which is imprecise because many email programs preload or block images), whether a link in it was clicked, which pages of memply.app were visited through that link, and whether a meeting was booked or a partner account was created. Nothing is stored on the device for this, and we do not record IP addresses. Anyone who objects via the unsubscribe link will receive no further messages of this kind; to ensure this, the address stays blocked as a checksum. Purpose: acquiring partner businesses. Legal basis: legitimate interest (Art. 6(1)(f) GDPR); for a booked meeting, steps prior to entering into a contract (Art. 6(1)(b) GDPR). If a business books a meeting through our booking page, we process the details entered there: name of the business, contact person and position, phone number, email address, the address for a visit and an optional message. The same applies to meetings booked without a personal invitation through the general booking link. The same applies to our other emails to businesses: the acknowledgement of a partnership request, our personal replies to it and the emails about a meeting. There, too, we record opening, clicked links, the pages of memply.app visited through such a link and whether this led to a request, an account or a meeting. Links to the legal notice and the privacy policy are not counted. We store the text of our replies with the request. If we write a reply in German and send it in another language, it is translated by our translation service (see recipients). We do not measure emails to guests, such as booking confirmations.
- Location for restaurant search
- If you search for restaurants near you, the app sends your current location to our server along with the search, once you have allowed it in your operating system. We use it only to calculate distances and sort the results and do not store it, not even in our server logs. Legal basis: consent (Art. 6(1)(a) GDPR), which you can withdraw at any time in your system settings.
- Spots
- If you publish a spot, the photo or video, the exact place where it was taken (coordinates and place name), your text, your display name and your profile picture are visible to everyone who uses the app. The location comes from the file itself or from a recording made directly in the app; a spot cannot be published without it. You can delete your spots at any time. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
- Comments and voice messages
- Comments on spots and shared routes are visible to other users, together with your display name. On spots you can also leave a voice message; for this the app records once you have allowed microphone access, and the recording is stored and played back like a comment. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
- Push notifications
- If you allow notifications, we store the device identifier your operating system assigns for this purpose, together with platform and language. Purpose: reminders of upcoming reservations and bookings. Push notifications are delivered through your operating system’s service (Apple Push Notification Service or Google’s Firebase Cloud Messaging); as long as this service is not yet connected on our side, we do not send push notifications. Legal basis: consent (Art. 6(1)(a) GDPR), which you can withdraw at any time in your system settings.
- Usage measurement in the app
- On our own server we record which areas and features of the app are used, for example which offer was viewed or whether a search was started; for searches only the length of the search term, not the term itself. This includes platform, language, a session identifier that exists only in the app’s memory and is not stored on your device, and, if you are signed in, your account identifier. We do not store IP addresses for this, and no data is passed to third parties. Purpose: finding errors and improving the app. Legal basis: legitimate interest (Art. 6(1)(f) GDPR); you can object at any time by email.
- Memy, the assistant in the partner portal
- In the partner portal, businesses can ask Memy questions and hand over tasks. For this we process the messages, attached photos and PDFs, the business data Memy retrieves to answer (such as offers, time slots or booking figures) and the account identifier. Messages, attachments and retrieved data are sent to Anthropic to generate the answer (see "Recipients of your data"). Memy only makes changes after the account has confirmed a proposal with a click. Anthropic also reads uploaded restaurant menus; the result is a draft that the business reviews. If a message to Memy is dictated, we convert the recording into text on our own server in Germany; it is not passed to any third party and is discarded after conversion, not stored. The text first appears in the input field and only becomes a message once it is sent. Purpose: helping to set up and maintain the business. Legal basis: contract with the business (Art. 6(1)(b) GDPR).
- Creator profile (Creator Corner)
- If you create a creator profile, we process your display name, your description, the categories you chose and, if you upload one, your profile photo. Approved partner businesses see these details in the marketplace of the partner portal for as long as your profile is set to visible. The profile photo is stored on our own server and can be retrieved via its address. Purpose: partners should be able to find and assess you for collaborations. Legal basis: performance of a contract (Art. 6(1)(b) GDPR). You can replace or remove the photo and hide your profile at any time; we delete a replaced or removed photo from storage, and also when you delete your account.
- Connecting Instagram (Creator Corner)
- If you connect your Instagram account as a creator, MEMPLY sends you to Instagram to log in. We receive only your username, account ID and follower count; we do not access posts, messages or comments. We also store the access token Instagram issues to us, encrypted only. Each token is valid for about 60 days; while the connection exists, we renew it automatically and fetch the follower count again about once a day. If the token can no longer be renewed, the connection counts as expired until you reconnect. Purpose: to confirm the account is yours, to show your reach as verified and to check proof of collaborations. Legal basis: consent (Art. 6(1)(a) GDPR). You can disconnect the account at any time in MEMPLY or remove the app in your Instagram settings under "Apps and websites"; in both cases we delete the Instagram data we hold. You can also request deletion through Instagram.
- Connecting Facebook, TikTok or YouTube (Creator Corner)
- If you connect a Facebook Page, a TikTok account or a YouTube channel as a creator, MEMPLY sends you to that provider to log in. From this we store only the name or username, the ID of the account, Page or channel and the number of followers or subscribers, where the provider shares it; we do not access posts, videos, messages or comments. On Facebook you connect a Page you manage, not your personal profile. We store the access and refresh tokens the provider issues to us encrypted only. While the connection exists, we renew the TikTok and YouTube tokens automatically and fetch the count again about once a day. If a token can no longer be renewed, the connection counts as expired until you reconnect. Purpose and legal basis are the same as for Instagram (consent, Art. 6(1)(a) GDPR). You can disconnect at any time in MEMPLY; we then delete the stored details and tokens. You can also withdraw MEMPLY's access in the settings of the provider concerned. For YouTube we use the YouTube API Services; the Google Privacy Policy (https://policies.google.com/privacy) applies, and you can revoke access at https://myaccount.google.com/permissions.
- Logs and security
- We log security and billing-relevant changes to records with timestamp and triggering account, and also log login attempts to prevent automated attacks. Purpose: auditability, abuse prevention, and troubleshooting. Legal basis: legitimate interest in secure operations (Art. 6(1)(f) GDPR).