Privacy Policy

Last updated: 15 Feb 2026

This Privacy Policy explains how Display Group LTD ("MMENTO", "we", "us", or "our"), operating under the MMENTO™ brand and registered under company number 16102028, collects, uses, stores, and protects personal data in connection with the website mmentoapp.com (the "Website"), the MMENTO mobile application (the "App"), and related services (collectively, the "Services").

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights ("LOPDGDD"), and applicable consumer protection rules.

1. Data Controller

The data controller responsible for the processing of personal data is:

2. Categories of Data We Collect

2.1 On the Website

The Website is informational in nature. It may collect:

2.2 In the App

When you create an account and use the App, we may process:

3. Purposes and Legal Bases

We process personal data for the following purposes, on the indicated legal bases under Article 6 GDPR:

4. How We Treat Your User Content

User Content stored within the App is treated with particular care and forms the most sensitive category of data we handle. We make the following commitments:

User Content is stored in a logically isolated database, encrypted at rest and in transit, and protected by access controls that restrict it to authorised systems necessary to provide the Services to you.

For a more detailed explanation of our approach, please consult the Transparency section dedicated to MMENTO App.

Limited Access Conditions

User Content may only be accessed in the following circumstances:

5. Recipients of the Data

We do not sell, rent, or trade personal data. We engage trusted service providers who assist us in operating the Services. These providers act as data processors on our behalf, under written contracts that comply with Article 28 GDPR.

For privacy and security reasons, we describe these providers by category rather than by name. The following categories of processors may process personal data on our behalf:

An up-to-date list of our processors and the categories of data they handle can be requested at our contact form.

6. International Data Transfers

Personal data related to your account and User Content is primarily stored on infrastructure located within the European Union.

Some service providers may operate from, or transmit data to, countries outside the European Economic Area (in particular the United States). When this occurs, we rely on adequate transfer mechanisms permitted by the GDPR, including the European Commission's Standard Contractual Clauses, supplementary safeguards, and adequacy decisions where applicable.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

8. Your Rights

In accordance with the GDPR and the LOPDGDD, you have the following rights regarding your personal data:

To exercise any of these rights, please contact our contact form. We may request information necessary to verify your identity before responding.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es) or the supervisory authority in your country of residence.

9. Security

We apply technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption at rest and in transit, access controls based on the principle of least privilege, regular security reviews, and ongoing monitoring.

No system can guarantee absolute security. We commit to investigating and notifying users and the relevant authorities of any personal data breach in accordance with Articles 33 and 34 GDPR.

10. Minors

The Services are not directed at persons under the age of sixteen (16). We do not knowingly process the personal data of minors below this age. If we become aware that we have collected personal data from a minor below the applicable age threshold without verified parental consent, we will delete the data without undue delay.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the App, the Website, or via email. The "Last updated" date at the top of this document indicates the date of the most recent revision.

12. Contact

For questions related to this Privacy Policy or to exercise your rights:

our contact form