Privacy Policy

Last updated: 8 April 2026

EN FR

This Privacy Policy explains how CallMeLater and Memline collect, use, and protect personal data in accordance with the General Data Protection Regulation (GDPR) and Belgian data protection law.

1. Data Controller

Canell SRL (Belgian company number BE0778.716.691) is the data controller for both CallMeLater (B2B API) and Memline (mobile app).

Contact email: privacy@callmelater.io
Legal email: legal@callmelater.io
Company address: avenue de l'avenir 7, 1330 Rixensart, Belgium

2. Scope

This policy covers two products operated by Canell SRL:

  • CallMeLater — a B2B API for scheduling HTTP webhooks and reminders
  • Memline — a consumer mobile application for scheduling personal reminders

Canell SRL is the data controller for user account data. Where users submit recipient data (email addresses, phone numbers) to send reminders on their behalf, the user acts as data controller for that recipient data, and Canell SRL acts as data processor following the user's instructions.

3. Data We Collect

We collect and process the following categories of personal data:

3.1 Account Data

  • Email address
  • Name (optional)
  • Password hash (bcrypt)
  • Unique Memline ID (memline_id)
  • Timezone and locale preferences
  • Account creation and last login timestamps

3.2 Guest Account Data

  • Device identifier (via @capacitor/device plugin)
  • Device platform and app version
  • No email address until the user upgrades to a full account

3.3 Action and Reminder Content

  • Action name and description
  • Scheduled execution time
  • Metadata entities (dates, times, people extracted from content)
  • Confirmation gates and recurrence rules

3.4 Voice Recordings

  • Audio blobs recorded using device microphone
  • Transcribed text generated by AI providers (Anthropic or OpenAI)
  • Voice recordings are sent to AI providers for transcription when the user chooses to use the voice input feature

3.5 Photo Attachments

  • Images attached to reminders
  • Photos are sent to AI providers (Anthropic or OpenAI) for analysis only when the user taps "AI Suggest"
  • Photos are stored on Canell's servers for the lifetime of the reminder

3.6 Contacts

  • Names, email addresses, and phone numbers imported from the device or entered manually
  • These contacts are stored to facilitate sending reminders on the user's behalf

3.7 Recipient Data

  • Email addresses and phone numbers of people receiving reminders
  • Delivery status (sent, delivered, bounced, clicked)
  • Response tokens (single-use tokens for confirming or responding to reminders)

3.8 Forwarded Emails

  • Subject, body, and attachments of emails forwarded to the user's unique Memline inbox address (e.g., user123@inbox.callmelater.io)
  • Sender email address and timestamp

3.9 Push Notification Tokens

  • Firebase Cloud Messaging (FCM) tokens for Android
  • Apple Push Notification Service (APNs) tokens for iOS

3.10 Device Metadata

  • Platform (iOS, Android, web)
  • App version
  • Last active timestamp

3.11 Usage Logs

  • IP addresses (for security and anti-abuse)
  • Action timestamps (created, executed, failed)
  • Quota counters (actions created, executions, failures)

3.12 Payment Data

  • Payment data is processed entirely by Stripe (our payment processor)
  • We store only your Stripe customer ID and subscription status
  • We do not store credit card numbers, CVVs, or other sensitive payment information

4. How We Use Your Data

We process personal data for the following purposes:

  • Service Operation — to operate CallMeLater and Memline, execute scheduled actions, deliver reminders, and manage your account
  • AI Assistance — to provide optional AI-powered features (voice transcription, text analysis, photo analysis, smart suggestions)
  • Communication — to send reminders via email/SMS on your behalf, deliver transactional emails (password resets, receipts), and send service announcements
  • Security & Anti-Abuse — to detect and prevent fraud, spam, and abuse of the service
  • Billing — to manage subscriptions, process payments, and issue invoices
  • Customer Support — to respond to support requests and troubleshoot issues
  • Product Analytics — to understand how the service is used and improve product features (only if you opt in)

5. Legal Bases for Processing (GDPR Art. 6)

We rely on the following legal bases for processing personal data:

  • Contract Performance (Art. 6(1)(b)) — processing is necessary to operate your account, deliver reminders, and fulfill our contractual obligations
  • Legitimate Interest (Art. 6(1)(f)) — processing is necessary for security monitoring, fraud detection, anti-abuse measures, service reliability, and product improvements. We have balanced these interests against your rights and freedoms.
  • Consent (Art. 6(1)(a)) — we obtain your explicit consent before:
    • Processing voice recordings or photos with AI
    • Sending marketing emails
    • Using optional analytics tools (when available)
    You may withdraw consent at any time via Settings.
  • Legal Obligation (Art. 6(1)(c)) — processing is required to comply with tax law, accounting requirements, or lawful requests from authorities

6. AI & Automated Processing

Memline offers optional AI-powered features that use third-party AI providers:

AI Providers

  • Anthropic (United States) — Claude models for voice transcription, text analysis, and smart suggestions
  • OpenAI (United States) — GPT models for voice transcription and image analysis

What Data is Sent to AI Providers?

AI features are opt-in per action. Data is only sent to AI providers when you explicitly:

  • Record a voice note (audio is transcribed to text)
  • Tap "AI Suggest" on a reminder with photos (images are analyzed for content)
  • Use smart suggestion features (text is analyzed for dates, times, people)

If you do not use these features, no data is sent to AI providers.

AI Provider Data Handling

  • Content is sent under a Data Processing Agreement (DPA) with Standard Contractual Clauses (SCCs)
  • API data is not used to train public models (per Anthropic and OpenAI API data retention policies)
  • AI providers retain data for a maximum of 30 days for abuse monitoring, then delete it

No Automated Decision-Making

We do not use AI for automated decision-making that has legal or similarly significant effects on you. AI suggestions are always optional and user-controlled.

7. Sharing & Sub-Processors

We share personal data with trusted sub-processors to operate the service. A full list of sub-processors is available at /subprocessors.

Key Sub-Processors by Category

  • Hosting — OVH (France, EU)
  • Payments — Stripe (Ireland + US)
  • Transactional Email — Postmark (US)
  • SMS Delivery — Brevo (France, EU)
  • AI Processing — Anthropic (US), OpenAI (US)
  • Push Notifications — Apple APNs (US), Google FCM (US)
  • Analytics — None at launch. When added (Google Analytics, Meta Pixel), users will be notified 30 days in advance and analytics cookies will only load after explicit opt-in.
  • Error Tracking — None at launch

All sub-processors process data under GDPR-compliant Data Processing Agreements (DPAs) with appropriate technical and organizational measures.

8. International Transfers

Our primary infrastructure (OVH) and SMS provider (Brevo) are hosted in the European Union.

Data is transferred to the United States for the following processors:

  • Stripe (payments)
  • Postmark (transactional email)
  • Anthropic and OpenAI (AI processing, opt-in only)
  • Apple APNs and Google FCM (push notifications)

Safeguards for US Transfers

We rely on the following safeguards for transfers to the United States:

  • Standard Contractual Clauses (SCCs) — EU Commission Decision 2021/914
  • Supplementary Measures — encryption in transit (TLS 1.2+), pseudonymisation where feasible, contractual audit rights

A formal Transfer Impact Assessment (TIA) is planned post-launch to evaluate risks and document additional safeguards.

9. Data Retention

We retain personal data only for as long as necessary to provide the service or comply with legal obligations:

  • Active Accounts — data is retained for as long as your account exists
  • Deleted Accounts — data is purged within 30 days (backup retention: 90 days)
  • Guest Accounts — automatically purged after 180 days of inactivity
  • Action Execution Logs — retained for 365 days on Free plan, configurable up to 3 years for paid plans
  • Voice Recordings (on device) — stored until you delete the reminder
  • Voice Recordings (sent to AI) — deleted by provider within 30 days
  • IP/Security Logs — retained for 12 months

10. Your Rights (GDPR Art. 12-22)

You have the following rights under GDPR:

  • Right to Access (Art. 15) — request a copy of your personal data
  • Right to Rectification (Art. 16) — correct inaccurate data
  • Right to Erasure (Art. 17) — request deletion of your data ("right to be forgotten")
  • Right to Restriction (Art. 18) — limit how we process your data
  • Right to Portability (Art. 20) — receive your data in a machine-readable format (JSON)
  • Right to Object (Art. 21) — object to processing based on legitimate interest
  • Right to Withdraw Consent — withdraw consent for AI processing, marketing, or analytics at any time
  • Right to Lodge a Complaint — file a complaint with the Belgian Data Protection Authority

How to Exercise Your Rights

You can exercise your rights by:

We will respond to your request within 30 days.

11. Children

CallMeLater and Memline are not intended for users under the age of 16. If we learn that we have collected personal data from a user under 16 without parental consent, we will delete the account and associated data.

If you believe a child under 16 has created an account, please contact us at privacy@callmelater.io.

12. Security

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encryption in Transit — TLS 1.2+ for all HTTP connections
  • Password Hashing — bcrypt with per-user salts
  • Secure Token Storage — Capacitor secure storage for mobile app authentication tokens
  • Role-Based Access Control (RBAC) — backend access restricted by role
  • Security Monitoring — logging and alerting for suspicious activity

No security system is perfect. If you discover a security vulnerability, please report it responsibly to legal@callmelater.io.

13. Cookies

CallMeLater and Memline use only strictly necessary cookies for authentication and security. For details, see our Cookie Notice.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or data processing practices.

All policy versions are tracked with a version date (see top of page). If we make material changes, we will:

  • Notify you via email or in-app notification
  • Re-prompt you to accept the updated policy before you can continue using the service

15. Contact

For privacy-related questions, requests, or complaints, please contact us at:

Canell SRL
Belgium
Company number: BE0778.716.691
Email: privacy@callmelater.io
Mailing address: avenue de l'avenir 7, 1330 Rixensart, Belgium

16. Supervisory Authority

You have the right to lodge a complaint with the Belgian Data Protection Authority:

Autorité de protection des données (APD)
Gegevensbeschermingsautoriteit (GBA)
Rue de la Presse 35
1000 Bruxelles, Belgium
Email: contact@apd-gba.be
Website: https://www.autoriteprotectiondonnees.be