Privacy policy

Last Updated: December 30, 2025
Effective Date: December 30, 2025
Company: HONGKONG XGIMI INNOVATION TECHNOLOGY COMPANY LIMITED

Thank you for your interest in HONGKONG XGIMI INNOVATION TECHNOLOGY COMPANY LIMITED and its affiliates (“Qinglai,” “Company,” “we,” “us,” or “our”). This Privacy Policy (“Policy”) describes how we collect, use, disclose, and protect your personal information when you visit our website at www.memo-mind.com (“Site”), use our software applications, purchase our hardware products (such as smart glasses), or otherwise interact with our services (collectively, “Qinglai Products and Services”).

Quick Guide to This Policy:

What We Collect: We collect information to create your account, provide customer support, operate and improve our services, and conduct marketing.
How We Use It: We use your information based on legal grounds, including but not limited to fulfill our contract with you, with your consent, to comply with law, or for our legitimate interests (e.g., security).
Who We Share With: We do not sell your data. We share it only with essential service providers or as required by law. Tools like Google Analytics may involve “sharing” for advertising.
Your Rights: You have rights to access, correct, delete, or port your data. California residents can opt-out of “sharing.”
Contact Us: For privacy questions or to exercise your rights, email us at: support@memo-mind.com.

This is a summary. Please read the full Policy for complete details.

If you are located in mainland China, please refer to our dedicated Chinese website and privacy policy.

1. Information We Collect

We collect “Personal Information”, which is information that identifies, relates to, describes, or can be reasonably linked to you. We collect it in three ways:

A. Information You Provide to Us:

Account & Registration: When you create an account or register a product, we collect your email address, phone number, password, username, and profile information (e.g., gender, region, language). This may be collected directly or via third-party logins (e.g., Google, Facebook).

Communications: When you contact customer support, participate in surveys, or use AI chat features, we collect your contact details, communication content, and any information you choose to provide.

Marketing Preferences: When you subscribe to newsletters, we collect your email address.

B. Information Collected Automatically:

Technical Data: IP address, browser type, operating system, device identifiers, network provider.
Usage Data: Pages viewed, time spent, clickstream data, access times, browsing history.
Location Data: With your explicit consent (managed in device/app settings), we may collect approximate or precise geolocation to provide features like location tagging, safety notifications.
Cookies & Similar Technologies: We use cookies, pixels, and local storage. For details, see our Cookie Policy.

C. Information from Third Parties:

We may receive information about you from: advertising partners (e.g., campaign performance data), social media platforms (if you interact with our ads), data analytics providers, and publicly available sources, in accordance with their policies and applicable law.

2. How We Use Your Information

We process personal data only where we have a valid legal basis, including one or more of the following:

We need to perform our contract with you;
We have your prior consent to do so;
Processing is necessary for the purposes of the legitimate interests, including but not limited to:
- improving our products and services;
- ensuring network and information security;
- preventing fraud, managing our business operations;
- establishing, exercising, or defending legal claims;
- protecting your vital interests.
We have to take a task carried out in the public interest or in the exercise of official authority vested in us.

We use your Personal Information for the following business and commercial purposes:

Why We Use Your Information	What Information We Use
To run your account: This includes creating your account and handling prescriptions.	Account details, prescription data, your communications with us.
To keep our services safe and working well: This includes detecting fraud, fixing bugs, protecting our systems, and developing new features.	Usage data (like how you use our website), technical details (like IP address).
To send you important messages: This includes security alerts, and updates about our services.	Your email address, phone number.
To send marketing messages (with your permission): This includes news, promotions, and product updates. You can opt out anytime.	Your email address, account preferences, and general usage data.
To comply with the law: When required by regulations or legal authorities.	Any relevant information as needed.

3. How We Disclose Your Information

We do not sell your information to third parties. We may only disclose your information for lawful, legitimate, necessary, specific, and explicit purpose in the following circumstances:

Affiliates and Service Providers: We may disclose personal information to our affiliates and to trusted third-party service providers for legitimate business purposes and in accordance with applicable laws. Such third-party service providers are contractually obligated to protect your personal data, to process it solely on our behalf and in accordance with our instructions, and to retain it only for as long as necessary to provide the relevant services. These service providers include:
- E-commerce and Website Hosting providers.
- Cloud Storage and Computing Infrastructure providers.
- Analytics, Marketing, and Advertising partners.
- Customer Service and Communication platform providers.
- Email Marketing and Newsletter delivery services.
- Customer Review and Feedback collection services.
For Legal & Safety Reasons: We may disclose information if required by applicable law, regulation, legal process, or governmental request, or where such disclosure is necessary to protect the rights, property, or safety of us, our users, or the public.
Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, personal information may be transferred. We will notify you of any such change.
With Your Consent: We may share personal information with third parties with your consent or where you have directed us to do so, for example by choosing to post information publicly through our services.
Aggregated/De-identified Data: We may share aggregated or de-identified data that cannot reasonably be used to identify you for purposes such as research, analytics, or service improvement.

4. How we transfer your information around the world

To provide fast and reliable service worldwide, your Personal Information is processed and stored in secure data centers located in Silicon Valley (USA), Frankfurt (Germany), and Tokyo (Japan). The primary location used depends on your region to optimize performance and comply with regional data guidance.

However, as a global company, we may engage our affiliates and service providers (as described in Section 3) that operate in jurisdictions outside your country of residence. Where we transfer your personal data from your home jurisdiction to a country that may not provide the same level of data protection (for example, when using a U.S.-based analytics provider), we implement appropriate legal safeguards to ensure an adequate level of protection for your personal data.

For transfers of personal data originating from the European Economic Area (EEA), United Kingdom (UK), or Switzerland to countries not deemed to provide an adequate level of data protection (such as the United States or Japan), we rely on legally recognized transfer mechanisms, primarily the European Commission’s Standard Contractual Clauses (SCCs).

5. Your Rights and Choices

Depending on your region of residence, you may have certain legal rights regarding your Personal Information, such as:

Access and Portability: Request access to or a copy of your personal information.
Correction: Request correction of inaccurate or incomplete information.
Deletion: Request deletion of your Personal Information, subject to certain legal exceptions (e.g., where we need to retain data to comply with a legal obligation or complete a transaction).
Restriction and Objection: Object to or restrict certain types of processing.
Opt-Out of Marketing: Unsubscribe from our promotional emails by following the link in any email. You may still receive transactional emails.
Cookies: Manage your cookie preferences through your browser settings or our cookie banner. See our Cookie Policy for details.

Identity Verification: For your security and to prevent unauthorized access to your data, we are required to verify your identity before processing certain rights requests. The verification method may vary depending on the nature of the request and the sensitivity of the information involved. We may require you to provide information matching what we have on file (e.g., email associated with your account) or, for more sensitive requests, additional proof of identity. We will only use the information you provide for verification purposes.

Consequences of Choice: Please note that if you choose to exercise certain rights (such as deletion of account information or objection to processing that is necessary for service delivery), it may impact our ability to provide you with the full functionality of our products and services. For example, deleting your account will result in the loss of access to your historical data and personalized features.

To exercise your rights, please contact us at support@memo-mind.com. We will respond in accordance with applicable law and verify your identity before processing your request.

6. Data Retention

We retain your Personal Information only as long as necessary for the purposes outlined in this Policy, unless a longer period is required or permitted by law (e.g., for tax, accounting, product safety, or prescription records). Retention periods vary based on data type, purpose, and legal requirements. We periodically review and securely delete or anonymize data that is no longer needed.

7. Data Security

We implement reasonable administrative, technical, and organizational measures designed to protect your personal information against unauthorized or unlawful access, disclosure, alteration, or destruction. Despite these safeguards, no method of electronic transmission or storage can be guaranteed to be completely secure.

8. Children’s Privacy

Our services are not directed to children, and we do not knowingly collect, use, sell, or disclose personal information relating to children as defined by applicable law. If you become aware that a child has provided personal information to us without appropriate authorization, please contact us so that we may investigate the matter and, where required, delete such personal information.

9. Region-Specific Addenda

The following addenda apply only to users residing in the specified jurisdictions and supplement the information provided in the main body of this Policy. In the event of any conflict between the provisions of the main Policy and the relevant addendum, the addendum shall prevail for users in that jurisdiction.

A. For Users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland:

Legal Basis: The legal bases for our processing are detailed in the table in Section 3.
Data Subject Rights: In addition to the rights in Section 6, you have the right to withdraw consent and to lodge a complaint with your local data protection authority.
International Transfers: As explained in Section 5, personal data of EEA/UK users is primarily stored in our Frankfurt, Germany data center. When data is accessed from or transferred to other locations (e.g., for support or analytics), we ensure compliance with GDPR transfer rules by implementing safeguards such as Standard Contractual Clauses. You can request more information about these safeguards by contacting us.

B. For California Residents:

Please see our separate California Privacy Notice below, which details our compliance with the California Consumer Privacy Act (CCPA) as amended by the CPRA, including the categories of Personal Information collected and disclosed, and your rights to know, delete, correct, and opt-out of “sharing” for cross-context behavioral advertising.

C. For Users in Australia:

Under the Australian Privacy Act, you have the right to access and correct your personal information. We will handle complaints in accordance with Australian law.

10. Cookies and Similar Technologies

We use Cookies for essential operation, analytics, and marketing. For a detailed description of the types of Cookies we use and how to manage your preferences, please see our Cookie Policy.

11. Changes and Updates

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. The “Last Updated” date will reflect changes. For material changes, we will notify you via the Site or email.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
HONGKONG XGIMI INNOVATION TECHNOLOGY COMPANY LIMITED
Unit 08, 15/F, Witty Commercial Building, 1A-1L
Tung Choi Street, Kowloon, Hong Kong
Email: support@memo-mind.com