Nature of Subscriber to the Memorandum of Assocation of a company.

Is a person who is subscribing to the Memorandum, whether the Company be limited by shares or limited by guarantee, deemed to be the Promoter of the Company?

I have this query because a promoter as defined in Section 2(69) of the Companies Act. 2013 does not include such an example. So can we say the subscriber need not be a promoter?