Privacy Policy
I. INTRODUCTION
MemoApp ("the Platform") is a digital document management and electronic signature service. Formerly operated by 917Ventures, the Platform is now owned and operated by ABSI ("the Company"). The transition of the Platform to ABSI ensures strict continuity of data governance; all personal data previously processed remains protected under equivalent or enhanced security controls, and your existing privacy choices have been fully preserved. We are committed to protecting your personal information and your right to privacy in accordance with the Data Privacy Act of 2012 (DPA).
II. INFORMATION WE COLLECT
To provide our electronic signature services, we collect:
● Identity Data: Name, email address, and signature.
● Audit Trail Data: To ensure the legal integrity of signatures, we collect IP addresses, device identifiers, and timestamps of every action taken on a document. ● Verification Data: Any government IDs uploaded for identity assurance.
● Service Usage Information: We collect information such as your rate of use and IP address to maintain service quality, security and to provide after-sales support.
III. PURPOSE AND LEGAL BASIS FOR PROCESSING
In accordance with the DPA, we process your personal information based on Contractual Necessity and Legitimate Interest, and your Sensitive Personal Information (such as government-issued IDs) based on your Explicit Consent or Legal Obligation to:
● Facilitate the execution of electronic contracts.
● Maintain a legally defensible audit log of signatures.
● Transition and maintain account records under ABSI ownership.
● Ensure platform security and prevent unauthorized access or fraud.
IV. DATA STORAGE AND SECURITY
● Governance Framework: Your data is hosted on secure enterprise-grade infrastructure managed under the Innovation and Product Group (IPG) framework to ensure systemic integrity.
● Encryption: We use industry-standard encryption (SSL/TLS) for data in transit and at rest
● Outsourcing: We may contract the processing of Personal Data to third-party service providers (e.g., cloud hosting) under strict contractual and technical safeguards to limit their use of such data.
V. DATA RETENTION
We retain signed documents and audit logs for a period of 10 years, (to be confirmed based on legal prescriptive periods for contracts), or as required by standard business record-keeping protocols and document preservation needs and a definitive list of our authorized sub-processors is available to users upon written request to our DPO.
VI. YOUR PRIVACY RIGHTS
As a data subject, you have the following rights under the DPA:
● Right to be Informed: To know how and why we process your data.
● Right to Access and Portability: To request a copy of your data in a commonly used format.
● Right to Object: To object to processing based on legitimate interest.
● Right to Rectify: To dispute and update inaccuracies in your records.
● Right to Erasure or Blocking: To order the removal of data that is no longer necessary.
● Right to Indemnity: To be indemnified for damages due to unauthorized use of personal data.
VII. CONTACT US
For any questions or concerns regarding our privacy practices, please contact:
The Data Protection Officer – ABSI
Email: privacy@absi.ph