PRIVACY POLICY

Limemo

IMPORTANT PRIVACY INFORMATION

Limemo is an iOS productivity application that lets you record or provide audio, extract the audio track from video files, convert speech into text, generate summaries and notes, and organize information with AI-assisted features. To provide these functions, Limemo processes account information, User Materials such as recordings and transcripts, subscription information, and technical information about your device and use of the App.

When you use Limemo, we may also receive device and advertising identifiers, IP address and approximate location, usage and event information, attribution data, crash logs and diagnostics, and push-notification tokens. We use this information to operate and secure the Service, provide customer support, understand how the App performs, fix problems, manage subscriptions, measure paid-acquisition campaigns, and improve Limemo.

Some Limemo functions rely on third-party service providers. For example, Amazon Web Services supports hosting and storage; AssemblyAI and Deepgram support speech-to-text transcription; OpenAI supports AI-assisted summarization and note generation; Firebase, Amplitude and Sentry support analytics and diagnostics; RevenueCat supports subscription management; and AppsFlyer and advertising platforms help us measure paid acquisition. These providers receive only the categories of information relevant to the service they perform, subject to the arrangements applicable to our use of their services.

Neither Limemo nor the third-party AI service providers we use rely on User Materials to train or fine-tune AI models.

Limemo does not display third-party advertisements inside the App. We do, however, advertise Limemo through external platforms and use attribution and measurement technologies to understand which campaigns lead to installs, subscriptions or other relevant events. You can find more information about these practices and your choices in Section 3 and Section 12.4.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU) AND (III) ACCEPT OUR DATA COLLECTION AND PROCESSING PRACTICES DESCRIBED BELOW. If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple; and (c) delete the App from your devices.

To learn more about the information we collect, see Section 2; for the purposes of processing, see Section 3; for the parties with whom information may be shared, see Section 5; and for your privacy rights, see Section 6. Questions and privacy requests may be sent to support@orvanta.limited.

PRIVACY POLICY

This Privacy Policy explains how Orvanta Digital Limited (“Orvanta”, “we”, “us” or “our”) collects, uses, stores, discloses and otherwise processes personal data when you use the Limemo mobile application (the “App”), visit websites related to Limemo (the “Website”), or use the services and features made available through them (together, the “Service”).

The English-language version of this Privacy Policy is the primary version. We may make this Privacy Policy available in other languages for convenience. In the event of any conflict, inconsistency or discrepancy between the English-language version and any other language version, the English-language version will prevail.

Definitions

In this Privacy Policy, “personal data” or “personal information” means information that identifies, relates to, describes or can reasonably be linked to an individual or household, as defined under applicable law. “Process” includes collecting, using, storing, accessing, analyzing, transmitting, disclosing and deleting information. “GDPR” means Regulation (EU) 2016/679. “UK GDPR” means the GDPR as incorporated into United Kingdom law. References to the “EEA” mean the European Economic Area.

1. Personal Data Controller

2. Categories of Personal Data We Collect

3. Purposes for Which We Process Personal Data

4. Legal Bases for Processing Personal Data (EEA and UK Users)

5. Sharing of Personal Data

6. Your Privacy Rights

7. Age Limitation

8. International Data Transfers

9. How We Protect Your Personal Data

10. Data Retention

11. Changes to This Privacy Policy

12. U.S. States Privacy Notice

13. Contact Us

1. PERSONAL DATA CONTROLLER

Orvanta Digital Limited, a company registered under the laws of Cyprus under registration number HE 496479, with its registered office at Zinonos Kitieos, 15, Ypsonas, 4187, Limassol, Cyprus, is the controller of personal data processed for the purposes described in this Privacy Policy.

Certain third parties, such as Apple or advertising platforms, may act as independent controllers for specific processing that they determine themselves. Their processing is governed by their own privacy notices. Where a provider processes personal data on our behalf, we use the provider for the limited functions described in this Policy and under the contractual arrangements applicable to that service.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect information that you provide directly, information generated automatically when you use Limemo, and limited information received from Apple and other service providers. The categories collected depend on the features you use, your device and privacy settings, whether you have an active subscription, and the permissions you choose to grant.

2.1. Information you provide directly

2.1.1. Account and identifier information

Limemo supports Sign in with Apple. When you create or access an account using that option, we may receive an Apple account identifier and, depending on your Apple settings and choices, information such as your name or email address. We may also generate internal account, installation or entitlement identifiers needed to recognize your account, secure access and provide the Service.

2.1.2. User Materials: recordings, extracted audio, transcripts and notes

When you choose to use recording, transcription or AI-assisted functions, you may provide audio recordings or video files. Where you provide a video file, Limemo processes the audio track extracted from that file for transcription and related AI-assisted features. Limemo is not intended to analyze the video imagery or faces shown in the file for these functions.

The Service may also process transcripts, notes, summaries, prompts, instructions and related content generated from or supplied with your recordings or other materials (collectively, “User Materials”). The content of User Materials depends on what you choose to record or submit and may include personal or sensitive information. Limemo does not use voice or face information for biometric identification or authentication.

You should submit only materials that you are legally permitted to process and should avoid including personal information that is not necessary for the feature you intend to use.

2.1.3. Purchase and subscription information

Payments for Limemo subscriptions are processed by Apple. We do not receive or store your full payment-card number. We may receive limited transaction and entitlement information such as the product or plan selected, subscription status, renewal or expiration status, transaction or receipt identifiers, purchase date, trial status and refund or cancellation information where made available to us. RevenueCat may help us receive and manage subscription and entitlement information.

2.1.4. Communications, support and feedback

If you contact us, we may process your email address or other contact details, the content of your message, attachments you choose to provide, account and transaction information relevant to the request, troubleshooting information, and our response history. This may include support questions, complaints, refund-related inquiries or feedback about the Service.

2.2. Information we receive from third parties

2.2.1. Apple

When you use Sign in with Apple or purchase a subscription through the App Store, Apple may provide us with the account, transaction, receipt and entitlement information described above. Apple determines what information is made available under its own terms and your Apple settings.

2.2.2. Analytics, attribution and other providers

Our analytics, diagnostics, attribution, advertising and subscription-management providers may return information generated from their services, such as campaign attribution, installation or event identifiers, subscription status, crash or performance information, and analytics results. We use that information for the purposes described in Section 3.

2.3. Information collected automatically

2.3.1. Referral and campaign information

We may record the advertisement, campaign, link, application or other source that referred you to Limemo, together with related campaign and attribution parameters. This helps us understand which paid-acquisition activities lead to installs, subscriptions or other relevant events.

2.3.2. Website and analytics information

When you visit the Website, we may collect information about your visit and interactions, such as pages viewed, links or buttons selected, referral sources, campaign parameters, browser and device information, approximate location, and other analytics or event information. We may use cookies, pixels, cookieless events and similar technologies for these purposes.

We may use Google Analytics, Firebase, AppsFlyer, Amplitude and Meta Pixel to understand Website usage, measure traffic sources and campaign performance, and understand whether users proceed from the Website to the App Store. The information processed depends on the relevant technology and your browser, device and privacy settings.

2.3.3. Device, network and approximate-location information

We may collect IP address, device type or model, operating-system version, language, time zone, memory, carrier information and other technical characteristics made available by your device or integrated SDKs. We may infer an approximate country, region or city from an IP address. We do not collect precise GPS location for the processing described in this Policy unless a future feature specifically requests it and you grant the relevant permission.

2.3.4. Usage and event data

We record information about how you interact with the Service, such as screens viewed, features used, session duration, processing status, subscription events, relevant buttons or actions selected, and other product events used to operate, analyze and improve Limemo. Where feasible, analytics events use technical or account identifiers rather than the content of your recordings, transcripts or notes.

2.3.5. Advertising and device identifiers

Depending on your device settings and permissions, we and our providers may receive advertising or device identifiers, including Apple’s Identifier for Advertising (IDFA), Identifier for Vendor (IDFV), Firebase installation identifiers and other SDK-generated identifiers. These identifiers may be used for analytics, fraud prevention, attribution and advertising measurement. Where Apple’s App Tracking Transparency framework requires permission, tracking that requires such permission is subject to your choice.

2.3.6. Crash logs, diagnostics and performance data

We collect crash reports, error logs, diagnostic information, app-version information, performance measurements and technical context needed to identify and resolve failures, maintain reliability and protect the Service. Providers such as Firebase Crashlytics and Sentry may process this information on our behalf.

2.3.7. Push-notification tokens

If you enable notifications, we may receive a device push token and related technical information needed to deliver notifications. You can disable push notifications at any time in your iOS settings.

2.4. Sensitive and special-category information

Limemo does not require you to provide health information, political opinions, religious beliefs, sexual-orientation information or other special-category data in order to create an account. However, because User Materials contain information chosen by you, a recording, transcript or note may incidentally contain information that applicable law treats as sensitive or special-category data.

We process such information only as part of providing the function you request and do not use User Materials to infer sensitive characteristics for unrelated advertising or profiling. Voice recordings are used for transcription and related content-processing functions, not to create biometric identification templates or authenticate identity by voice.

2.5. Sources of personal data

The sources of personal data described in this Policy include: (a) you, when you create an account, provide User Materials or contact us; (b) your device, browser and use of the App or Website; (c) Apple, when you authenticate or make a purchase; and (d) service providers that return analytics, attribution, diagnostics, subscription-management, support, transcription, AI-processing or network information generated while providing services to us.

3. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We process personal data for the purposes described below. The information used for a particular purpose depends on the feature, your settings and the providers involved.

To provide and operate the Service

We process account identifiers, User Materials, subscription information, technical data and service events to create and maintain accounts; authenticate users; record or receive audio; extract audio from video files; create transcripts; generate summaries and notes; organize information; restore sessions; remember settings; synchronize subscription entitlements; and otherwise make the functions you request available.

We use Amazon Web Services (AWS) for cloud hosting and storage that support the operation of Limemo. AWS may process account information, User Materials and technical information necessary to provide hosting and infrastructure services.

To provide customer support

We use account, subscription, technical and communication information to answer questions, troubleshoot problems, investigate account or purchase issues, respond to complaints, and provide other assistance you request.

We may use Zendesk to organize, prioritize and respond to support communications. Zendesk may process contact details, message content, attachments and support history needed to manage a request.

To communicate with you about the Service

We may send transactional or service communications concerning account access, subscription status, receipts or purchase events, security, support, changes to the Service or legal terms, processing status, feature availability and other matters connected with your use of Limemo. Certain communications may be necessary to provide the Service and cannot be disabled while you maintain an account or subscription.

We may use eSputnik to deliver service-related or transactional email. Where notifications are delivered through iOS, you can disable push notifications through your device settings.

To analyze, maintain and improve Limemo

We process device, usage, transaction, diagnostic and performance information to understand how the Service is used; measure reliability; identify errors; monitor crashes; evaluate conversion and retention; test and improve features; plan product development; understand which features provide value; and improve usability, stability and customer experience.

For the Website, we may process analytics and measurement information to understand visits and interactions, evaluate traffic sources and campaign performance, understand whether users proceed to the App Store, and improve the Website and user-acquisition experience.

Analytics and diagnostics providers may include Google Analytics, Firebase Analytics and Firebase Crashlytics, Amplitude and Sentry. Depending on the integration, these providers may receive device or SDK identifiers, usage and event data, approximate location, crash logs, diagnostic information and other technical information. We do not intentionally send the content of recordings or transcripts to analytics providers merely for ordinary product analytics.

To advertise Limemo and measure paid acquisition

Limemo does not display third-party advertisements inside the App. We do advertise Limemo through external advertising platforms and use attribution and measurement tools to understand which campaigns lead to installs, subscriptions or other relevant events, evaluate campaign performance, reduce ineffective spending and improve paid user acquisition.

For these purposes, we and our advertising or attribution partners may process advertising or device identifiers, campaign parameters, attribution data and limited event information, such as whether an install or subscription event occurred. We do not provide the contents of your recordings, transcripts, notes or summaries to advertising platforms for paid-acquisition measurement.

Providers used for these purposes may include AppsFlyer, Meta, Google Ads / AdMob, TikTok Ads, Snapchat Ads, AppLovin and Apple Search Ads, which is subject to Apple’s Privacy Policy.

The Website may also use attribution and advertising measurement technologies, including AppsFlyer and Meta Pixel, to understand traffic sources, measure campaign performance and understand whether users proceed from the Website to the App Store. Depending on the technology and configuration, this processing may involve cookies, pixels, browser or device identifiers, cookieless events and similar technologies.

How to opt out of or influence personalized advertising

You can control certain advertising and tracking activity through iOS settings. Depending on the iOS version and the feature, relevant controls may include Settings > Privacy & Security > Tracking and Settings > Privacy & Security > Apple Advertising > Personalized Ads. Disabling or limiting tracking may reduce personalized advertising or cross-app attribution, although it may not prevent all measurement or advertising activities that are permitted without consent.

You may also obtain information about interest-based advertising choices through the Network Advertising Initiative, the Digital Advertising Alliance and DAA AppChoices. Advertising platforms may additionally provide account-level or device-level controls under their own privacy settings.

If you reside in a U.S. state that provides a right to opt out of a “sale”, “sharing” or targeted advertising, see Section 12.4 below.

To process subscriptions and administer paid access

We process purchase, subscription, receipt, transaction and entitlement information to activate paid features, recognize active subscriptions and trials, maintain access, respond to purchase-related support requests, identify duplicate or fraudulent entitlements, and keep records needed for accounting, legal or dispute purposes.

App Store transactions are handled by Apple under Apple’s Privacy Policy and applicable App Store terms. We use RevenueCat to help synchronize subscription and entitlement status across the Service. We do not receive or store your full payment-card number.

To provide speech-to-text and AI-assisted features

Certain Limemo functions use specialized providers to convert speech into text and generate requested summaries, notes or related outputs. The data sent to a provider depends on the function you choose and is limited to information reasonably necessary to perform that function.

AssemblyAI and Deepgram may receive audio recordings or audio extracted from video files, together with technical information required to generate transcripts. OpenAI may receive transcripts, prompts, instructions or related content needed to create summaries, notes or other AI-assisted outputs you request.

These providers process information in accordance with the contractual arrangements applicable to our use of their business services and their applicable privacy and retention practices. Neither Limemo nor the third-party AI service providers we use rely on User Materials to train or fine-tune AI models. We do not use recordings for voice identification or biometric authentication. AI-generated or automated output may be inaccurate, incomplete or unexpected; Limemo does not use these content-processing features to make eligibility, employment, credit, insurance or other decisions that produce legal or similarly significant effects about you.

To protect the Service, enforce agreements and prevent fraud

We process personal data to authenticate users; detect suspicious, automated, abusive or unauthorized activity; protect accounts and infrastructure; investigate security incidents and payment disputes; enforce our Terms of Use and other agreements; establish, exercise or defend legal claims; prevent fraud and misuse; and protect Orvanta, users, providers and third parties.

We may use SOAX as proxy and network infrastructure to route certain technical requests and support reliable connectivity. In connection with routed requests, SOAX may process limited network or request metadata such as IP addresses, timestamps, target domains, session or configuration information and performance data.

To comply with legal obligations

We may process, preserve or disclose information where necessary to comply with applicable laws, tax or accounting requirements, consumer-protection rules, data-protection obligations, court orders, subpoenas, lawful government requests, sanctions requirements or other binding legal process.

Corporate transactions and business administration

We may process or disclose information for audits, financing, insurance, due diligence, restructuring, merger, acquisition, sale of assets, insolvency or another corporate transaction, subject to appropriate confidentiality, security and legal safeguards.

4. LEGAL BASES FOR PROCESSING PERSONAL DATA (EEA AND UK USERS)

This section applies where the GDPR, UK GDPR or another applicable European data-protection law requires us to identify a legal basis. The applicable basis depends on the category of data and the purpose for which it is processed.

4.1. Performance of a contract

We rely on contractual necessity, including taking steps at your request before entering into a contract, to:

create and administer your Limemo account;
provide recording, audio extraction, transcription, AI-assisted summaries and notes, storage and organization functions that you request;
recognize and administer subscriptions, trials and paid entitlements;
provide customer support and essential service communications; and
perform our obligations under the Terms of Use and Subscription Terms.

4.2. Consent

Where consent is required, we rely on your consent for processing such as access to device permissions, optional push notifications, certain advertising or tracking activities subject to App Tracking Transparency, and any other processing for which applicable law requires consent. You may withdraw consent through the relevant device or App controls or by contacting us. Withdrawal does not affect processing that was lawful before the withdrawal.

4.3. Legitimate interests

We may rely on legitimate interests, balanced against your rights and reasonable expectations, to:

operate, secure, troubleshoot and improve Limemo;
analyze feature use, service performance, subscriptions and customer experience;
measure advertising campaigns and paid acquisition where consent is not legally required;
communicate about account or Service matters that are not based on contractual necessity;
prevent fraud, abuse, chargeback misuse and unauthorized access;
enforce agreements and protect legal rights;
respond to complaints, disputes and legal claims;
conduct audits, business administration and corporate transactions; and
use aggregated or de-identified information for research, planning and statistical purposes.

Where processing is based on legitimate interests, you may object in circumstances provided by law. We will stop the relevant processing unless we demonstrate compelling legitimate grounds to continue or the processing is required for legal claims.

4.4. Compliance with legal obligations

We process information where necessary to satisfy legal, regulatory, tax, accounting, security, consumer-protection, sanctions, law-enforcement or other obligations that apply to us.

4.5. Sensitive or special-category data contained in User Materials

Limemo does not ask you to provide special-category data as a condition of creating an account. If User Materials contain information treated as special-category data under the GDPR or sensitive data under another law, we process that information only as part of providing the function you request. Where applicable law requires explicit consent or another additional condition for such processing, the feature should be used only where that condition is satisfied. We do not use sensitive content to infer characteristics for unrelated advertising purposes.

5. SHARING OF PERSONAL DATA

We do not disclose personal data indiscriminately. We share information only as reasonably necessary for the purposes described in this Privacy Policy, under contractual or legal protections where appropriate. The categories of information a recipient receives depend on the function it performs and the configuration of the relevant integration.

5.1. Service providers and contractors

We use service providers to operate, support, analyze, secure and improve Limemo. These providers may process personal data only for the contracted service or as otherwise permitted by applicable law. Some platform or advertising providers may also act as independent controllers for particular processing and provide their own privacy notices.

Hosting and infrastructure. We use Amazon Web Services (AWS) for cloud hosting and storage. We may use SOAX for proxy and network infrastructure. Depending on the service, these providers may process account information, User Materials, network information and technical metadata needed to provide infrastructure functions.

Analytics, diagnostics and product improvement. We use Google Analytics, Firebase Analytics and Firebase Crashlytics, Amplitude and Sentry to understand use of the App and Website, measure performance, analyze interactions, detect errors and improve reliability. Depending on the relevant technology, these providers may receive browser, device or SDK identifiers, cookie or similar technology identifiers, usage and event data, referral information, approximate location, crash logs, diagnostic information and other technical information.

Customer support and service communications. We use Zendesk to manage support requests and may use eSputnik to deliver service-related or transactional email. These providers may process contact information, message content, support history and service-communication events as applicable.

Subscriptions, authentication and App Store services. We use Apple for Sign in with Apple, App Store purchases and Apple Search Ads; Apple’s practices are described in its Privacy Policy. We use RevenueCat to help manage subscription status and entitlements. Depending on the function, these services may process account identifiers, information shared through Sign in with Apple, subscription and transaction information, and relevant device identifiers.

Speech processing and AI. We use AssemblyAI and Deepgram for speech-to-text transcription, and OpenAI for AI-assisted processing such as summarization and note generation. These providers may receive audio, extracted audio, transcripts, prompts, instructions and related technical information needed to perform the feature you request.

Advertising, attribution and paid acquisition. We use AppsFlyer, Meta, Google Ads / AdMob, TikTok Ads, Snapchat Ads, AppLovin and Apple Search Ads to measure and optimize advertising for Limemo outside the App. The Website may also use AppsFlyer and Meta Pixel for attribution and campaign measurement, including to understand traffic sources and whether users proceed from the Website to the App Store. Depending on the relevant technology and configuration, these services may process advertising, browser or device identifiers, cookie or similar technology identifiers, attribution data, campaign information and limited event data, including through cookies, pixels, cookieless events or similar technologies. Limemo does not disclose User Materials to these providers for ordinary advertising measurement.

5.2. Affiliates

We may share information with entities that control, are controlled by or are under common control with Orvanta Digital Limited where reasonably necessary for administration, security, support, compliance or operation of the Service. Affiliates must process information consistently with this Privacy Policy unless they provide a separate notice and lawful basis.

5.3. Courts, regulators, law enforcement and other authorities

We may disclose information when we reasonably believe disclosure is required by law or legal process, necessary to protect rights or safety, needed to investigate fraud or security incidents, appropriate to enforce our agreements, or otherwise permitted by applicable law. Where legally permitted, we may review, challenge or seek to narrow requests that appear excessive or unlawful.

5.4. Business transfers and professional advisers

Information may be disclosed to prospective or actual purchasers, investors, lenders, insurers, auditors, lawyers or other advisers in connection with a merger, acquisition, financing, reorganization, sale of assets, insolvency or similar transaction. A successor may continue to process information subject to this Privacy Policy or a replacement notice provided as required by law.

5.5. Aggregated and de-identified information

We may use or disclose information that has been aggregated or de-identified so that it cannot reasonably be linked to an individual. We maintain de-identified information in de-identified form and do not attempt to re-identify it except to validate our de-identification measures or as otherwise permitted by law.

5.6. No public sharing by default

Limemo is designed around private productivity functions. The Service does not, by default, make your recordings, transcripts, notes or summaries publicly visible to other Limemo users. If a future feature allows you to intentionally share content, any disclosure initiated by you will depend on the recipient and method you select, and we will provide additional privacy information where required.

6. YOUR PRIVACY RIGHTS

Depending on your location and applicable law, you may have some or all of the rights described below. These rights are subject to legal conditions, limitations and exemptions.

Access and confirmation. You may request confirmation of whether we process your personal data and obtain access to relevant information or a copy.

Correction. You may ask us to correct inaccurate personal data and complete information that is materially incomplete.

Deletion. You may request deletion of personal data, subject to retention permitted or required for legal obligations, security, fraud prevention, transactions, disputes or other lawful purposes.

Restriction. You may ask us to limit certain processing while a request, objection or accuracy issue is reviewed, where applicable law provides this right.

Objection. You may object to processing based on legitimate interests in circumstances provided by law and may object at any time to direct marketing if we introduce such communications.

Portability. Where applicable, you may request personal data you provided in a structured, commonly used and machine-readable format and ask that it be transmitted to another controller where technically feasible.

Withdrawal of consent. Where processing relies on consent, you may withdraw consent without affecting processing that was lawful before withdrawal.

Complaint. You may lodge a complaint with a competent data-protection authority, particularly in the country or region where you live, work or believe an infringement occurred.

Non-discrimination. Where U.S. state privacy law applies, you have the right not to receive unlawful discriminatory treatment for exercising a protected privacy right.

6.1. Account deletion

Limemo provides a self-service account-deletion function in the App. Deleting your account initiates deletion of associated user data from our active systems as described in Section 10. Account deletion does not cancel an Apple App Store subscription; an active subscription must be cancelled separately through Apple’s subscription settings.

6.2. How to submit a privacy request

To exercise a right that is not available directly in the App, email support@orvanta.limited and describe the request. We may ask for information reasonably necessary to verify your identity, account ownership, authority and jurisdiction. Verification information is used only to process the request and for related recordkeeping. We will respond within the period required by applicable law and explain any denial or limitation where required.

6.3. Authorized agents

An authorized agent may submit a request on your behalf where permitted by law. We may require evidence of the agent’s authority and may ask you to verify your identity or confirm the request directly.

6.4. Automated decision-making

Limemo does not use solely automated decision-making to make decisions about you that produce legal or similarly significant effects. AI-assisted transcription, summarization and note generation are content-processing functions requested by you and are not used to determine employment, credit, insurance, housing, eligibility or comparable rights or benefits.

7. AGE LIMITATION

If you believe that a child has provided personal data contrary to these rules, please contact us at support@orvanta.limited. We will review the report and take appropriate steps, which may include deleting the relevant data or account where required.

Where we know that a user is under 18, we do not knowingly use that user’s personal information for targeted advertising in a manner prohibited by applicable law, and we do not knowingly sell or share such information where an opt-in would be required.

8. INTERNATIONAL DATA TRANSFERS

Limemo is offered internationally, and Orvanta and its service providers may process personal data in countries other than the country where the information was collected. Provider locations depend on the feature, infrastructure configuration and service availability. Such countries may have data-protection rules that differ from those in your jurisdiction.

Where personal data originating in the EEA is transferred to a country that is not recognized as providing an adequate level of protection, we use an appropriate transfer mechanism where required, such as the European Commission’s Standard Contractual Clauses, an applicable adequacy decision, a provider’s valid certification under an applicable data-privacy framework, or another lawful safeguard.

For transfers of personal data originating in the United Kingdom, we may use the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, an adequacy regulation or another lawful transfer mechanism, as applicable. We may also apply supplementary technical and organizational measures where appropriate.

You may contact us for additional information about transfer safeguards relevant to your personal data, subject to confidentiality and legal limitations.

9. HOW WE PROTECT YOUR PERSONAL DATA

We use reasonable administrative, technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. Measures may include access controls, authentication safeguards, encryption in transit where supported, logging and monitoring, role-based permissions, secure development and deployment practices, vendor-management procedures, and processes for investigating security incidents.

Access to personal data is limited to personnel and providers who need the information for legitimate business purposes and who are subject to appropriate confidentiality or contractual obligations. We also seek to minimize the information provided to a service provider to what is reasonably necessary for the selected function.

No method of transmission, processing or storage is completely secure. Accordingly, we cannot guarantee absolute security. You are responsible for protecting access to your Apple account and device and for avoiding the submission of information that is not necessary for your intended use of Limemo.

If we become aware of a personal-data breach, we will investigate and take the actions required by applicable law. Where legally required, this may include notifying a competent supervisory authority and affected individuals within the applicable timeframes.

10. DATA RETENTION

We retain personal data only for as long as reasonably necessary to provide the Service, fulfil the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements.

User content, including recordings, extracted audio, transcriptions, notes and summaries, is retained while the user maintains an account or until the user deletes such content, where this functionality is available. When a user deletes their account, the associated user data is deleted from our active systems, subject to limited retention where required by law or reasonably necessary for security, fraud prevention, dispute resolution, or other legitimate legal purposes.

Account, subscription and transaction records may be retained after account deletion where needed for accounting, fraud prevention, chargeback or dispute handling, legal claims, or compliance with legal obligations. Support communications may be retained to document requests, resolve disputes and maintain support history. Analytics, diagnostic and attribution information is retained according to the settings and schedules applicable to the relevant systems and providers.

Some information processed by our service providers may be retained in accordance with their applicable retention practices and our contractual arrangements with them. Data may also remain temporarily in backups or processing systems after deletion until those systems are overwritten or refreshed in accordance with ordinary operational procedures.

We may retain information for longer when it is relevant to a complaint, investigation, litigation, legal hold or other proceeding. When personal data is no longer required, we delete, anonymize or isolate it in accordance with reasonable operational procedures, subject to backup and legal constraints.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in Limemo, our service providers, technology, legal requirements or our privacy practices. The “Effective as of” date identifies the current version.

If a change is material and applicable law requires additional notice, we will provide notice before the change takes effect through an appropriate channel, such as an in-App notice, service communication or another method reasonably designed to reach affected users. Where the law requires consent to a change, we will request it.

You may contact us at any time for information about this Privacy Policy or previous versions.

12. U.S. STATES PRIVACY NOTICE

Applicability and scope

This section supplements the rest of this Privacy Policy for residents of U.S. states with applicable comprehensive consumer privacy laws. For California residents, it also serves as a Notice at Collection. Terms such as “personal information”, “sale”, “sharing”, “targeted advertising” and “sensitive personal information” have the meanings assigned by the law that applies to you.

We do not sell personal information for monetary compensation. Certain disclosures of advertising identifiers, attribution data or usage information to advertising and measurement partners may nevertheless be treated as a “sale”, “sharing” or targeted advertising under some state laws.

12.1. Categories of Personal Information and Purposes of Processing

The types of personal information associated with your use of Limemo may vary depending on the features you use, the permissions you grant, your device settings and your interactions with the Service. These categories may include:

Account and identifying information. This may include your Apple account identifier, name or email address where shared through Sign in with Apple, IP address, and device, SDK or advertising identifiers. We use this information to recognize users, provide account access, support core Service functions, protect the Service, analyze usage and measure acquisition sources.
Account, support and subscription records. We may maintain information about your account status, preferences, settings, customer-support interactions, and subscription or entitlement status. This information helps us administer the Service, provide assistance, maintain appropriate records, protect accounts and enforce applicable terms.
Purchase and subscription activity. We may receive information relating to subscription plans, trials, purchases, renewals, cancellations, refunds and entitlement changes. We use this information to manage paid access, resolve billing-related issues, maintain accounting and transaction records, prevent misuse and support advertising or campaign measurement where applicable.
App, device and network activity. This may include information about screens or features used, session duration, referral and attribution events, crashes, diagnostics, device characteristics and network-related information. We use this data to operate and troubleshoot Limemo, evaluate performance, improve features, understand usage patterns, measure advertising effectiveness and protect against abuse.
General location information. We may determine an approximate location, such as your country, region or city, based on your IP address. This information may be used for security, analytics, localization and advertising or attribution measurement. We do not collect precise GPS location unless a specific feature requires it and you grant the relevant permission.
Recordings and other content processed through Limemo. Depending on the feature you use, this may include audio recordings, audio extracted from video files, transcripts, notes, summaries, prompts, instructions and other related User Materials. We process this information to provide transcription, AI-assisted functionality, storage, organization and related Service features.
Information that may be considered sensitive. The content you choose to record or submit may contain information that applicable law treats as sensitive personal information. Where this occurs, we process such information only as necessary to provide the function you requested, maintain security, comply with legal obligations or otherwise as permitted by law. We do not use the content of User Materials to build unrelated sensitive-interest profiles for advertising, and we do not use voice data for biometric identification or authentication.
Derived information and limited inferences. We may derive limited insights from product usage, event data or attribution information, such as patterns relating to feature use, product performance or campaign effectiveness. These insights are used for analytics, product development, fraud prevention and advertising measurement. They are not used by Limemo to make decisions that have legal or similarly significant effects on you.

12.2. Disclosure for business purposes

During the preceding 12 months, we may have disclosed the categories listed above to the service-provider and recipient categories described in Section 5 for business purposes. For example, identifiers and network-activity information may be disclosed to hosting, analytics, diagnostics, support, subscription-management, network-infrastructure and advertising-measurement providers; User Materials may be disclosed to hosting, transcription and AI technology providers only as needed to perform the selected function.

We may also disclose information to public authorities, advisers or transaction counterparties as described in Section 5. We do not disclose User Materials to advertising platforms for ordinary paid-acquisition measurement.

12.3. State privacy rights

Depending on the state in which you live and the law that applies, you may be entitled to exercise some or all of the following rights:

Request information about our data practices. You may ask us to explain the categories of personal information we collect, where that information comes from, why we use it, the categories of third parties to whom it is disclosed, and whether any information is sold, shared or used for targeted advertising.
Access your personal information. You may request access to personal information we maintain about you and, where applicable, receive a copy of that information, subject to identity verification and legal limitations.
Ask us to delete personal information. You may request deletion of eligible personal information. We may retain certain information where permitted or required for purposes such as security, fraud prevention, completing transactions, complying with legal obligations or resolving disputes.
Correct inaccurate information. You may ask us to correct personal information that is inaccurate, taking into account the nature of the information and the purposes for which it is processed.
Obtain a portable copy of your data. Where the law provides this right, you may request eligible personal information in a portable and, where technically feasible, readily usable format.
Opt out of certain data uses. Depending on your state, you may have the right to opt out of the sale or sharing of personal information, processing for targeted advertising, or certain forms of profiling.
Limit certain uses of sensitive personal information. Where applicable law provides this right, you may ask us to restrict particular uses or disclosures of sensitive personal information. As described in this Policy, Limemo processes sensitive information only where needed to provide requested features, maintain security, comply with law or otherwise for permitted purposes; we do not use sensitive User Materials to infer characteristics for unrelated advertising.
Withdraw consent. Where processing is based on consent and applicable state law permits withdrawal, you may withdraw that consent for future processing.
Exercise your rights without discrimination. We will not unlawfully deny services, charge a different price, reduce service quality or otherwise retaliate against you because you exercised a privacy right.
Appeal certain decisions. If we decline a privacy request and the law of your state provides an appeal right, you may ask us to review that decision.

How to Submit a Privacy Request

To exercise an applicable privacy right, email support@orvanta.limited and describe the request you would like us to process, together with your state of residence where relevant. We may ask for information reasonably necessary to verify your identity and match the request to our account, subscription or support records. We will limit verification requests to information appropriate for confirming the request and maintaining required records.

Where permitted by law, an authorized agent may act on your behalf. In that case, we may request written authorization or other evidence of the agent’s authority and may also ask you to verify your identity or confirm that you authorized the request.

If we deny a request and the law applicable in your state gives you a right to appeal, you may ask us to review the decision by replying to our response or by emailing support@orvanta.limited with the subject line “Privacy Request Appeal.” We will review the appeal and provide our response within the timeframe required by applicable law.

12.4. Sale, sharing and targeted advertising

We do not sell personal information for money. We may disclose advertising identifiers, attribution data, Internet or electronic activity, approximate location and limited commercial-event information to advertising, analytics and measurement partners for paid acquisition and campaign measurement. Under some state laws, these activities may be considered a “sale”, “sharing” or targeted advertising even though no monetary payment is made for the data.

For advertising, attribution and campaign measurement purposes, we may disclose limited categories of personal information to relevant partners. The categories involved may include:

Device and identifying information, such as advertising or device identifiers and IP address, which may be disclosed to advertising networks, analytics providers, attribution and measurement services, and social-media platforms.
App and interaction data, including attribution events and limited information about how you interact with the Service. This information may be shared with advertising, analytics, attribution and measurement partners, as well as social-media platforms.
Subscription-related events, such as whether a subscription, trial or other relevant conversion event occurred. We may provide this information to advertising, attribution and measurement providers and social-media platforms for campaign analysis.
Approximate location information, such as country, region or city inferred from an IP address. This information may be processed by analytics, attribution, advertising, security and fraud-prevention providers.

We do not disclose the contents of your recordings, transcripts, notes, summaries or other User Materials to advertising partners for these purposes.

Where applicable, you may opt out of sale, sharing or targeted advertising by emailing support@orvanta.limited with the subject “Opt Out of Sale, Sharing, or Targeted Advertising.” You may also use iOS privacy and tracking settings and the provider or industry controls described in Section 3.

We do not knowingly sell or share the personal information of individuals under 18 for targeted advertising where applicable law requires an opt-in or otherwise prohibits that processing.

12.5. Do Not Track and other privacy preference signals

Browser “Do Not Track” signals generally do not control processing inside the App. This is separate from device privacy controls, App Tracking Transparency and legally recognized opt-out preference mechanisms.

On the Website, you can manage your preferences for non-essential cookies and similar technologies through the cookie-preference tool and may also use privacy controls available through your browser.

Where a legally recognized opt-out preference signal or universal opt-out mechanism can be applied to a relevant interaction or supported technology, we will process the signal as required by applicable law. You may also use browser, iOS privacy settings or contact us directly to exercise an applicable opt-out right.

12.6. California-specific information

California residents may have rights under the California Consumer Privacy Act, as amended, including rights to know, access, correct and delete personal information and to opt out of sale or sharing, subject to legal exceptions. We do not use or disclose sensitive personal information for purposes that would require a separate “Limit the Use of My Sensitive Personal Information” mechanism based on the processing described in this Policy.

California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits eligible California residents to request information once a year about certain disclosures of personal information to third parties for those third parties’ direct-marketing purposes. To make such a request, email support@orvanta.limited with “Request for California Privacy Information” in the subject line and include your state of residence and email address.

12.7. Nevada residents

Nevada residents may submit a verified request to opt out of a covered sale of certain personal information under Nevada law by contacting support@orvanta.limited. We do not sell personal information for monetary compensation as described in this Policy.

12.8. Financial incentives and consumer health information

We do not currently offer a financial incentive or price or service difference in exchange for personal information. Limemo is not a health service and is not designed to collect consumer health data as a separate product category. User Materials may nevertheless contain health or other sensitive information that you choose to record. Such information is processed to provide the feature you request and is not used to build a consumer health profile for unrelated purposes.

13. CONTACT US

For questions about this Privacy Policy, previous versions, your account or the processing of personal data, contact Orvanta Digital Limited at support@orvanta.limited. Registered office: Zinonos Kitieos, 15, Ypsonas, 4187, Limassol, Cyprus. Registration number: HE 496479.

Effective as of: September 28, 2026