Nemlo is a voice assistant for remembering where things are kept. You tell it where something is — in the shed, in a box, on a shelf — and later you ask where it is. Your record is a map of where you keep your things: what you have, where each thing is, and how it got there. Nemlo is made by Bergmen Ltd, a UK company. You can reach us at tunca@bergmen.com.
Nemlo does not ask you to sign up. There is no email, no password, and no "sign in with" button. The first time you open the app it asks our service for a random id — not your name, not your Apple ID, just a long random string — and keeps it in your iPhone's Keychain. That id is what your record is filed under; nothing about who you are is attached to it.
Because that id is kept in your iCloud Keychain, it travels with your iCloud account: if you reinstall the app, move to a new phone, or use an iPad signed into the same Apple ID, your record is already there. A device that has iCloud Keychain turned off keeps its own, separate record instead — the export below is how you'd move that one by hand. If two of your devices briefly disagree about which id is "yours" (this can happen for a few minutes after a reinstall, before iCloud has caught up), Nemlo quietly combines the two records into one the next time it notices. Nothing you recorded on either device is lost when that happens.
This is the complete list. Nemlo's service stores:
Nemlo does not store your voice. Your phone talks to OpenAI's speech service directly to understand and reply to you; Nemlo's own servers never receive or keep an audio recording. Nemlo contains no advertising or tracking software from anyone else, and it never asks for the "Allow Tracking" permission, because there is nothing here to track you for.
So that this list can never quietly grow, the kinds of events Nemlo can record are a fixed, closed list enforced by the software itself — adding a new kind of event is a change to this document, not just a change to the code. In plain terms, Nemlo records:
Each of these is tied to your owner id, never to anything else about you, and none of it contains the contents of your record beyond what's listed above (for example, a changed-record count, not the record itself).
When you talk to Nemlo, your phone connects directly to OpenAI, which turns your speech into text, decides what to do, and turns the reply back into speech. OpenAI is a data processor acting on Nemlo's instructions for this; your words pass through their systems to make the conversation work. Bergmen Ltd, as the account holder, has checked what that means for Nemlo's account:
The record Nemlo stores about you — your inventory, your commands, the measurement events — is kept on a server in London, UK (AWS region eu-west-2). It does not leave the UK. This is a separate question from where OpenAI processes your speech, answered just above.
| What | Kept for |
|---|---|
| Your inventory — things, places, containers, history | Until you delete it |
| The wording of what you said or typed | 90 days, then the wording itself is permanently cleared (what happened stays in your history, just not your exact words) |
| The measurement events listed above | 13 months |
| An opted-in email | Until you delete everything, or ask us to remove it |
Settings has one button, behind one confirmation, that deletes your entire record: your inventory, your command history, your measurement events, and any email you gave us — from every device signed into your iCloud account, not just the one you're holding. Afterwards, every device behaves like a fresh install, with an empty record.
The live copy is deleted immediately — ask where something is straight afterwards, and it's gone. What takes longer is our backups, which exist so a server failure doesn't lose everyone's records, not just yours:
Live data is deleted immediately. Copies held for disaster recovery are deleted within 30 days. No copy older than 30 days exists.
One detail worth being honest about: if a backup from before your deletion is ever restored (for example, after a server failure), our restore process deliberately deletes your record again as its last step, using a one-way scrambled version of your old id kept for exactly this purpose. That scrambled value can't be turned back into your id, and it identifies nothing outside our own database — it exists only so that a restore can't quietly bring back a record you asked us to forget.
You can export your whole record at any time, as one file, through the share sheet. It contains everything listed above — your inventory with its full history, your command wording, your measurement events, and any opted-in email — and it's one JSON file you (or anyone you send it to) can open and read on a computer without the app, with a plain-English reading of your places and history written inside it alongside the raw data.
Because there's no account, "access, erasure and portability" work differently than you might expect, but they're not weaker for it:
The lawful basis for processing is providing the service you're actively using: you ask Nemlo to remember and recall where your things are, and that processing is what carries out the request you made, each time you make it. Nemlo does not use your data for anything beyond running the app and measuring its own use, as listed above.
Whether a record of processing activities is required at this size. UK GDPR's small-business exemption (Article 30(5)) applies only to processing that is occasional. Recording and recalling your inventory is the core, continuous purpose of the app, not an occasional side effect, so our reading is that the exemption likely does not apply even at this size — this is one of the points the qualified reviewer checks before release, alongside the lawful basis and controller statements above.
If what's hosted, processed or kept changes, this document changes with it before the change ships — not after.