Effective of: 01 March 2024
When you create a user on the Monesave app, you will be asked to provide Monesave with a variety of information about yourself and your family members. Monesave is responsible for processing your information. The processing of the information is necessary for Monesave to keep track of you and your children’s savings and budgeting status. Monesave also uses the information for continuous improvement and further development of the Monesave app. The information is anonymized whenever possible.
If you are a child, the processing of your data is based on the consent of your parents or guardian. Processing your information is done – if they are a family member of a child – on the basis of consent that you give in connection with the creation of your user profile. You can withdraw your consent at any time by deleting your user in the Monesave app. Monesave Terms and Conditions as well any legal documents is only between Monesave and the guardian and/or adult.
General Principles
We are committed to transparent and secure data processing. As a company incorporated in the USA we are committed to process any personal data in line with Regulations, standards and laws. In this privacy notice we provide you with information about what personal data we process and for what purposes, what are your rights and where you can contact us in case you have any questions or concerns about your personal data processing. We only process personal data where we have your consent or where we are entitled to do so based on other legitimate reasons, in particular where:
(a) processing is necessary for the performance of the Service and to enable us to contract with you in connection with provision of the Service,
(b) processing is necessary for compliance with a legal obligation to which we are subject;
(c) processing is necessary for the purposes of the legitimate interests pursued by us as the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you as the data subject and which require protection of personal data, in particular where the data subject is a child.
We do not process any special categories of personal data, i.e. we do not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
If you are not at least 16 years old, please seek advice of your parents, or other adult person who is the holder of parental responsibility and contractual terms before you start using the Wallet or any of the Services.
Children’s privacy
To provide services under this Monesave agreement we need to collect information about all Monesave Users. Under data protection law, we are what is known as the ‘controller’ of all Monesave Users’ personal data. For more information about how we use personal data for the Monesave app, please see our Privacy Notice.
Children under the age of 13 are not permitted to use the Monesave Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.
If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using our contact details below to request that it be deleted.
What information do we process about users and how is it collected?
We process identification personal data that you provide to us when you create an account and fill in forms during the registration process. To register into the Wallet, you are
required to create your username by providing us with your email which allows us to identify the registered User of our Wallet. You also need to create a password which protects your data inside the app. After login, you can update your personal information and add name, surname, date of birth and sex. This information helps us to provide you with our Services, including customer support and system alert notifications. Providing the name, surname, date of birth and sex is voluntary and you can use an alias as your name and surname.
When you choose to log into the Wallet using your Google or Apple account, we will receive some of your Google account information or Apple account information in the extent corresponding to your Google/Apple privacy settings. We are receiving from those services your email, name and surname.
Where you wish to obtain a Premium feature of our App, the payment service providers will collect information necessary in order to process the payment for our Services. We do not process information about your credit or debit card, as the payment is processed via the respective App Store. We identify you in our system via your respective App Store ID, which is a digital code. We do not obtain your identity information that you provided to the respective App Store.
When you use the Wallet we collect details as how you use our Wallet, in order to provide you with the Service those data are collected by analytical tools – Mixpanel, Fabric or Google Analytics.
When you use the Wallet and you will grant us a permission for that, we can:
- Track your location. The geodata allow us to provide you with a better Service. Unless you agree otherwise, we process this information in order to provide you with certain functionalities in our Wallet such as Smart Assistant or heatmaps, to better help you track your spending.
- Read Identity – helps us find accounts on the device and read your own contact card to allow us to offer easier Login services
- See Contacts – helps us find accounts on the device and read your contacts to provide you with better service with Debt and Sharing functionality
- Read and modify Photos/Media/Files to allow you to read content such as pictures of receipts or evidences of your spending
- Read, modify or delete your content in storage – allow us store your content on your device
- Use Camera – allow us to take picture of your receipts and add your own audiovisual content
- View Wi-Fi connection – which allows us to switch from offline to online mode to synchronize your content
The above permissions are opt-in and you can always change your setting in your mobile device in Settings – Apps – Permissions section.
When you use an App to track your finances, your transaction data are stored on our servers including income, expenses, categories, amounts, currency, labels, account type, date, time and other details provided by the User.
What we use your personal data for
Your data may be used for providing services you request in relation to your use of Wallet or other Services provided by Monesave. Sending communications or contacting you with relevant information regarding our services or with Offers. We use your data for statistical and marketing analysis, system testing, maintenance, and development or in order to deal with your request or claim through our customer service channel. Based on your data, we use your data to provide information we believe is of interest of you such as advices on financial behaviour or special offers from our partners.
We may use analytics technology to create reports and analysis of your preferences (geodata, purchase preferences, planned spending), which will enable us to provide you with better Service and make you personalized Offers. We use Google Analytics, Apple Analytics, and Fabric analytic services to be able to address you more relevant messages based on your behavior.
If you use an App provided by Monesave, we may from time to time send a push notification or in-app message directly to your Wallet, or an email, commercial communication. You may turn-off such communication within the Wallet or by unsubscribing from this service following instructions at the end of each of such email communication.
If you subscribe to our newsletter service, you authorize us to send you commercial communication to your e-mail or push notification or in-app message directly to your app, with third parties’ Offer of goods and services tailored to your interests until you turn off such communication within the Wallet or by unsubscribing from such communication following instructions at the end of each of such email communication.
If you subscribe to our newsletter service, you authorize us to send you commercial communication to your e-mail or push notification or in-app message directly to your app, with third parties’ Offer of goods and services tailored to your interests until you turn off such communication within the Wallet or by unsubscribing from such communication following instructions at the end of each of such email communication.
We do not share these aggregate data with any third party, unless it is anonymized or pseudonymized (e.g. by using only your Apple ID code or Google ID code, which does not allow third parties to identifying you), or unless you request us to share the data and provide us with consent to such sharing.
Recipients of your personal data
We may be required by law to grant access to personal data about you that we process for the purpose of investigating criminal activities and violations of the law, to judicial or other government agencies in particular law enforcement authorities subject to warrants, subpoenas or other governmental orders.
Your data may be also shared with third party social media providers – when you are registered with your social service account. Please refer to privacy policy of these social media providers to find out more about your account settings.
To provide you some Services such as Bank connection, we share your personal data with trusted 3rd parties or banks. Subject to your request and explicit consent with sharing of data, we may also share your data with an operator of a third party App.
Furthermore, we share your data with different data processors in our daily processing, i.e. our suppliers, mainly delivery companies, IT suppliers, hosting and marketing services providers, providers of statistical and database software tools, and also with other entities which provide services to us. In addition to data processors, we also transmit your personal data to third parties, who are not bound by our instructions. These are, for example, our consultants, lawyers or tax consultants who receive your data from us on the basis of a contract and process your personal data for legal reasons or to protect our own interests.
Because we use different data processors and other service providers and change them from time to time, it is not appropriate to identify specific recipients of personal data. However, if you are interested, we will disclose the name of the processor(s) in use at that time upon your request.
Bank Connection Users specific information
If you request Monesave to provide you with services, you agree to be bound by our Terms of Services and any Third party applicable licence or service terms (as the case may be and as will be notified to you).
All your Personal Information provided in connection with or accessed during your participation in the Bank Connection feature will be processed only in order to provide you with the account information service. Your Account Information and all other personal data accessed through the Bank Connection feature is transmitted through secured protocols in an encrypted mode and is temporarily stored on our servers. This information is temporarily cached in a way that it is not readable by Monesave.
The service is provided by Monesave based on your consent. Your consent will expire in 90 days and then you will be requested to re-create it in the same way that you originally gave consent.
You can withdraw such consent anytime by the following actions:
- You can cancel the provision of Monesave at any time by disconnecting your bank account (either within the respective App you use or within your respective bank account settings).
- You can notify Monesave that you withdraw the Information consent by at the email address stated below.
- You can delete all user data in your profile settings in the respective App which you use or delete your profile by sending your request Monesave at the email address stated below or to the email address of your respective Third party operator.
Please note that the withdrawal or expiration of your consent does not affect the actions of Monesave prior to the withdrawal or expiration.
Data Retention
We will maintain the personal information as long as you actively use your account in the Wallet. We will inactivate any account and delete any and all information entered by you
into our system, if you have not logged into the Wallet for longer than 24 months. We will also delete any data you provided us while using the Wallet if you request us to do so (for details see below Right to erasure). For technological reasons your account will be deleted from our servers within 1 month following your request. In the case of the company termination or discontinuation of service, your data will be permanently deleted.
Consent
If you granted us your consent to process your personal data, you can withdraw your consent any time without affecting the lawfulness of processing based on consent before its withdrawal by removing your consent inside Wallet – Settings – Personal data & privacy section or by unsubscribing from this service following instructions at the end of each of such email communication.
Cookies
What are cookies used for? Cookies help identify application users and web site re-occurring visitors, they remember users’ custom preferences, help user complete tasks without having to reenter information when browsing from one page to another or when visiting the site later. Cookies can also be used to track user preferences when web browsing for online behavioral target advertising and to show adverts relevant to something that the user searched for in the past.
What type of cookies do we use? In order to provide you with a better service, we use cookies when you visit our website www.monesave.com or when you use our Wallet. We use different set of cookies. We use the term “cookies” to refer to pieces of information that are sent to your browser and stored on your computer or device to store and sometimes track information about your preferences in order to deliver behavioral advertising. System cookies enable us to provide you with services you have specifically asked for and are essential in order to enable you to move around the Website and application and use their features, such as cookies used to identify user once he or she has logged in. Without these cookies some services you have asked for cannot be provided to you. Apart from those we use cookies and third-party cookies that help us track your browsing history in order to serve you with behavioral advertising. We will only use these cookies if you grant us explicit consent on our website www.Monesave.com. You can disable or refuse some or all cookies, or delete the already set up cookies in the web browser you use. The cookies we use can be divided into the following:
- session cookie which is erased when you close the browser, it exists only in temporary memory of your device while you navigate the website;
- persistent cookie which remains on the user’s computer/device for a pre-defined period of time, these remain in operation, even when you have closed the browser, they remember your login details and password so you don’t have to type them in every time you use the site; and
- third-party cookies these are installed by third parties with the aim of collecting certain information to carry out various research into behavior, demographics etc.
- Persistent cookies and third-party cookies are deleted automatically if you are in-active and do not visit our web-site or use our application for more than 6 months. Also you can delete these cookies if you change your preferences.
- Web beacons are images (single-pixel gifs) embedded in a web page or email for the purpose of measuring and analyzing site usage and activity. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened or count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to our users’ Personal Information.
You can learn more about cookies at www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers. Please note, however, that blocking or deleting cookies used on the Website or the application may affect the availability and functionality of the Website and provision of service to you via our application.
Security policy
The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow strict security procedures in the storage and disclosure of your personal data. To comply with highest technical standards and to certify our internal procedures we are certified to ISO 27001 standard and our systems are regularly tested according to full OWASP methodology.
We require all 3rd parties to have appropriate technical standards in place to protect your personal data where we share your personal information with 3rd parties who act as personal data processors for Monesave as personal data controller.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us on the details below.
Where we store your data?
We may process your personal data on third party servers, with whom we concluded data processing agreement according to the required standards, securing your data privacy and safety. We do not process personal data of USA Users, outside the USA, i.e. we do not transfer personal data for the purposes of their data processing outside the USA. You may obtain the information about which data processors we use and where we store personal data by contacting our customer support at support@monesave.com.
Data protection
We employ 2 different database systems. One for user profile storage, the second for individual user data. Both databases are accessed through the secure SSL protocol.
Communications
All private data exchanged with Provider is always transmitted over SSL. We are not transferring your data outside USA..
Contact
You can contact Provider at the email address: support@monesave.com or via contact form on the Website https://www.monesave.com you request any information regarding personal data protection or if you would like to claim any of your rights, please contact our Data Protection Officer at support@monesave.com
Your Rights related personal data processing
Right of access to your data
You have right to request that we provide you with a confirmation as to whether or not we process your personal data and, where that is the case, grant you access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from you, any available information as to their source;
- the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you. If your data were transferred to a third country or to an international organization outside the European Union, you have the right to be informed of the appropriate safeguards relating to the transfer. If you request so, we shall provide you with a copy of your personal data we are processing. For any further copies requested by you, we may charge a reasonable fee based on administrative costs. If you made the request by electronic means, and unless otherwise requested by you, the information shall be provided to you in a commonly used electronic form. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Right to rectification
You have right to obtain from us without undue delay rectification of any inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
You have right to request that we erase your personal data without undue delay, if (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) we process your personal data on the basis of your consent and you withdraw your consent, and where there is no other legal ground for the processing; (c) you rise your objection on individual automated decision-making and there are no overriding legitimate grounds for the processing, or you objected to processing of your personal data for direct marketing purposes, including profiling to the extent that it is related to such direct marketing; (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in European Union or law to which we are subject; (f) the personal data have been collected in relation to the offer of information society services referred to a child younger than 18 years. This does not apply to the extent that processing is necessary: (a) for compliance with a legal obligation which requires processing by European Union or law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or (b) for the establishment, exercise or defense of legal claims.
Data Deletion Policy
You have the right to request that your Personal Information be deleted from our primary production servers. You own your data. Anytime you want your data removed from our system, you can request us to delete your account from our production servers. As a result, your data will be excised permanently from our production servers and further access to your account will be impossible. Additionally, any connection we had established to your Account Information will be disconnected. However, for purposes of ensuring continued ability to serve you in case of malfunction or damage to our production servers, we retain backups of portions of your data derived from your Account Information on our production servers. Your aggregated data is stored in these servers indefinitely. We reserve the right to use any aggregated or anonymous data derived from or incorporating your Personal Information.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer want to use our Services, you may correct or delete inaccuracies, or amend information by making the change at any time via the Service. However, in some instances we cannot delete all information we hold about you.
In addition, unless requested expressly from you as a user, Monesave will retain your information for delete your information for 7 years as requested by the authorities.
Right to restriction of processing
You have right to request that we restrict processing where one of the following applies: (a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; (d) you objected to processing for the purpose of individual automated decision-making and there is pending the verification whether the legitimate grounds of us as the data controller override those of you as the data subject. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. You have right to be informed by us before the restriction of processing is lifted.
Right to data portability
You have right to receive the personal data concerning you, which were provided to us, while registering into our system or while using our application, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another service provider without hindrance, where: (a) the processing is based on your consent pursuant or on a contract; and (b) the processing is carried out by automated means. We will provide you these data in .csv, .xls or .pdf format by e-mail, which we use when using our system. You can request that we transmit the data directly to the other service provider, where it is technically feasible. Your exercise of the data portability right does not mean that you cancel using our services or that you withdraw your consent that we further process your personal data. This shall not affect the services we have been providing you prior to such request. We may reject your request for data portability if it shall adversely affect the rights and freedoms of others.
Right to object and automated individual decision-making
We carry our profiling only for direct marketing purposes. We do not analyze any personal data provided by you or which we collected about you while using our Wallet for any automated decision-making process nor we provide such tools or information to any third party. In case we process your personal data for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes. We as the data controller shall no longer process your personal data for this purpose unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You can change your consent by removing your consent inside the Wallet – Settings – Personal data & privacy section.
You, as the data subject, shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you, unless you granted us your explicit consent.
Complains
If you find or believe that your personal data is being processed in violation of your privacy or law, especially if personal data are inaccurate with regard to the purpose of processing, you may ask at support@monesave.com for explanation and demand that the resulting condition be removed.
In particular, it may be blocking, repairing, supplementing or disposing of personal data. We will grant the request if we find that the objection is justified. If, in the processing of personal data, there occurred any breaches of the obligations imposed by law on the controller or the data processor, these are jointly and severally liable for them. By law, in the case of a request for blocking, correcting, supplementing or disposing of personal data, we will inform other recipients, if there were any, and if it is possible and it would not require disproportionate efforts.
In case you are concerned about your data processing, and you have not obtained satisfactory information from us, you can file a complaint to the data protection office. This is without prejudice to your other rights, to file petitions to the court and seek civil law remedies.
Miscellaneous
The relationship between us in respect of your data protection is regulated by the laws of the USA and directly applicable Regulations of the USA. We may need to change the information contained in this Privacy Policy from time to time. We advise you to check our Privacy Policy regularly for the latest version. We will notify you about significant changes in the way we treat personal information by sending an email notice or by placing a prominent notice on our Website.and directly applicable Regulations of the European Union. We may need to change the information contained in this Privacy Policy from time to time. We advise you to check our Privacy Policy regularly for the latest version. We will notify you about significant changes in the way we treat personal information by sending an email notice or by placing a prominent notice on our Website.
Contact information is provided below:
- Our website is www.monesave.com.
- Email: support@monesave.com
- In writing: 1007 North Orange Street, 4th Floor Wilmington, DE 19801
- Phone: +1 302 803 5468
- Webite: www.monesave.com
Making savings and budgeting fun and social.
Monesave LLC (Registration Number 7607043). Address: 4th Floor, 1007 North Orange Street, Wilmington| DE 19801.
Contact: support (@) monesave.com