MONEMON PRIVACY POLICY:
LET'S KEEP IT REAL WITH YOUR DATA!
ver. 3.0 | Effective from Sep 23, 2026
1. What’s what (Definitions)
Here’s a quick lowdown on the important terms we’ll use. Some terms are already defined in our Service Rules, and unless we say otherwise, they have the same meaning here:
You / Your: That’s you - our awesome user.
We / Us / Our: That’s Monemon AS, the Estonian company running the show (Reg. No. 16573117).
App: The Monemon mobile app where you handle your digital cash (e-money).
GDPR: Fancy law from the EU that makes sure we protect your data right.
Monemon services: Everything we offer through the Monemon app, including managing your digital money, using your debit card, using saving tools such as Bag and Drop, receiving Weekly Wrapped summaries, interacting with Mo and accessing other Monemon features.
Money Management and Saving Features: The Bag, Drop, saving goals and related saving tools, Weekly Wrapped and Mo, as described in our Service Rules.
Partners: The cool third-party companies we work with. They help with stuff like processing payments, verifying your identity or giving you awesome deals. They’ve got your back (and your data’s back too).
Personal data: Anything that identifies you, like your name, email or even your selfie when you log in.
Transaction data: All the details about transactions on your Payment Account – like money you send or receive, card payments, cash withdrawals, amounts, dates and who the transaction was with?
2. Who are we?
Hey! We’re Monemon AS, an Estonian company (reg. # 16573117). Our HQ is at Telliskivi tn 60a/8, Tallinn 10412, Estonia. We’re all about keeping your data safe and this policy explains how we handle it while keeping everything transparent and secure.
3. What data do we collect and from where?
3.1 We only take what we need to give you the best Monemon experience, and nothing more. Here’s what we collect:
Personal data: This category may include things like your name, birthdate, ID and home address, as well as identity verification data such as your selfie, short video and biometric data used to verify your identity.
Device data: This could include your phone model, IP address and, where you choose to enable location-based features, your device location.
Transaction data: Every time money moves in or out of your Payment Account – like transfers you send or receive, card payments and cash withdrawals – we process details such as dates, amounts and who the transaction was with.
Preferences: This might include your settings in the Monemon app, like spending limits.
App usage data: We collect info on how you use the Monemon app – like which features you interact with, how often you use them and how long you spend in the app – to improve your usage experience.
Money Management and Saving Features: We process information about your Bag balance, saved amounts, saving goals, progress, Drop calculations, levels, streaks and other activity relating to Monemon’s Money Management and Saving Features.
Contact info: If you let us, we’ll sync your contacts from your device or social media accounts to show you which of your friends are also using Monemon. This makes it easier to connect and send payments to people you know.
3.2 We sometimes collect data from sources other than you to comply with the law and keep everything secure. This includes:
Population databases: We might access Estonia’s population registry or similar registries in other countries, depending on where you live to confirm your details and ensure compliance.
Risk databases: We check databases of people linked to money laundering, terrorism, criminal accusations and those under sanctions. Some of these databases are public and others are restricted.
Täitmisregister (Electronic arrest system): We access the e-arrest system to check if any legal restrictions or freezes have been applied to your accounts by state authorities. This helps us ensure that we're complying with legal regulations and keeping your account activity in check.
4. Why do we collect your data?
We collect and process your personal data for various important reasons that help Monemon function properly. Here’s why:
4.1 Compliance purposes: We’re bound by laws and regulations, so we collect your data to:
Prevent money laundering, terrorist financing, proliferation financing (AML/CFT/CPF) and fraud.
Meet international financial sanctions requirements.
Provide secure payment services and protect your account.
Cooperate with lawful inquiries from public authorities (e.g. courts, police, or tax agencies) and financial institutions.
4.2 Contractual purposes (making it official): To offer and maintain your Payment Account and Our services, we need your data to:
Create and manage your account.
Process your transactions (like sending or receiving money).
Provide you with services related to your Monemon debit card and loyalty points.
Fraud monitoring (keeping your funds safe): We use your data to detect, monitor and stop any fraudulent activities on your account. We want to keep your money safe!
Money Management and Saving Features: Helping you understand how you use your money and build better saving habits is a key part of Monemon services. To make this work, we use relevant information about your account, transactions and saving activity to organise your spending, spot patterns, calculate saving suggestions and create personalised summaries and insights through features such as Weekly Wrapped and Mo. When you chat with Mo, we also use your messages and instructions, relevant account and transaction context, uploaded content and the limited memory context needed to provide a useful response. We process this data because it is needed to provide the services covered by our agreement with you (Article 6(1)(b) GDPR). This processing isn’t based on your consent, so we don’t ask you for separate consent to provide these features.
4.3 Analytical purposes (we're always improving): We study general user behaviour to:
Make the Monemon app better for you and others.
Understand how our services are being used so we can improve them.
Create anonymous stats that help us make decisions (we don’t analyse individual preferences).
4.4 Marketing purposes: If you give us the green light, we'll use your data to:
Send you updates on new Monemon features, promos or offers that might interest you.
Share details on cool offers from our Affiliates or Partners.
Sync your contacts (to see who else uses Monemon.)
5. How do we share your data?
Some of the companies we work with process your personal data on our behalf and under our instructions as our data processors, while others may process data as independent controllers where required by law or necessary to provide their own services. We don’t just hand out your info to anyone - here’s who we share it with (and why):
If the law says we have to: we share your data with government bodies or financial institutions for things like taxes or anti-money laundering (gotta stay legit).
Server hosts: The tech companies that keep Monemon running smooth and secure.
Payment processors & networks: We share the necessary information with banks, payment service providers and networks like Mastercard to process your transactions – your data moves with your money.
Identity verification services: To confirm you’re you, we share the necessary information with third parties that help us verify your identity and documents.
Screening and compliance services: We share the necessary information with service providers that help us carry out PEP, sanctions and other compliance checks.
Card manufacturers & couriers: When we need to send you your physical Monemon card, we share the info needed to get it made and shipped to your door.
Communication services: Companies that help us stay in touch via email, text or push notifications — so you’re always up to date.
Transfers outside the EEA: If we ever need to share data outside the EU/EEA, we’ll make sure it’s protected by the same solid rules, keeping your data safe wherever it goes.
AI technology service provider: AI helps to power Mo and Weekly Wrapped. To make these features work, we use a specialist third-party AI technology provider. It acts as Monemon’s processor, which means that it handles personal data for us, follows our instructions and must meet our contractual data-protection requirements.
When you use Mo, we may send the provider your messages and instructions, relevant account and transaction context, uploaded content and the limited memory context needed to generate a useful response.
For Weekly Wrapped, we may send relevant transaction and saving activity for the applicable period. This may include transaction amounts, dates, merchants, categories and saving progress.
We keep this data sharing to a minimum and only send what the relevant Money Management and Saving Features needs to work. We do not send payment authentication credentials, passwords, PINs, one-time passcodes, CVV codes or full card numbers to the AI provider.
One more important point: We don’t allow your messages, instructions or AI-generated responses to be used to train general AI models.
6. How long do we keep your data? (Spoiler: not forever)
We don’t keep your data longer than we need to. Here’s the deal:
Transaction data: We have to keep this for 7 years because of accounting rules. Yeah, we know... it’s a long time, but it’s the law.
Personal info: Once you close your Monemon account, we’ll hold onto your info for 5 years (just in case the regulators ask for it). After that, *poof* and it’s gone.
Device and preference data: These get deleted shortly after you stop using Monemon.
Money Management and Saving Features: We keep your chats and memory notes only for as long as needed to keep things working and the conversation going. The underlying transaction data follows our usual legal retention periods.
Legal stuff: If we have a reason (like a court case), we might keep your data longer.
7. Do we use your data for profiling or automated decision-making?
We don’t use your personal data for fully automated decision-making. However, we do need to assess the risks of money laundering, terrorist financing and fraud tied to you or your transaction data. This assessment is partly done with automated systems, which involve profiling – but don’t worry, it’s all to keep your account safe and comply with the law.
Money Management and Saving Features are here to give you information and insights, not to make decisions about you. We don’t use them, or anything they generate, to decide whether to open, restrict or close your account, set your fees or limits, approve or refuse a payment, or take action for AML, sanctions, fraud or security reasons.
8. Your rights (you're in control)
Here’s how you can take charge of your data:
Access: If you want to see what data we have about you, just ask and we’ll send you a copy.
Data updates: If anything seems incorrect, let us know and we’ll make sure it’s updated.
Erasure: You can ask us to delete your data if you’re done with Monemon (unless the law says we have to keep it for a bit).
Object to processing: Not cool with how we’re using your data? You’ve got the right to say no. However, if we’re required by law to hold onto certain data (like for regulatory or legal reasons), we’ll need to keep that information on file even if you object.
Data portability: Need your data elsewhere? We can move it in a commonly used format for you to use it with another service.
Withdraw consent: If you gave us permission to use your data for something specific (like marketing) and you’ve changed your mind, you can withdraw that consent anytime.
Complaint: If you think we’re not handling your data right, you can file a complaint with the Estonian Data Protection Inspectorate or your local data protection authority.
9. How do we protect your data?
We prioritise your data security - here's how we protect it:
Encryption: Your data is encrypted while it’s stored on our servers and during transfers (so no one can access it).
Access control: Only authorised Monemon crew members can access your info and we make sure they’re trained to keep it safe.
Regular checks: We run security audits and tests to keep everything airtight.
Third-party protection: When we share your data with service providers, we use contracts and other appropriate safeguards to make sure they protect your data and only use it for the agreed purposes.
10. Who's in charge of your data? (Spoiler: it's us)
The data controller for your personal info is none other than Monemon AS. We’re the ones making sure your data is handled right, from start to finish.
But it’s a two-way street - you're responsible for keeping your app usage secure by following safe practices, like not sharing your login details and keeping your device protected.
11. Changes to this policy
We may update this privacy policy occasionally and if we do, we’ll notify you through the app or email at least 2 months in advance. You can always find the latest version on the Monemon app or website.
12. How to contact us (We're here for you!)
Got questions? Reach out through the Monemon app! Just drop us a message and we’ll be there to help. You can also hit us up at:
Email: compliance@monemon.com
Address: Monemon AS, Telliskivi tn 60a/8, Tallinn 10412, Estonia.
Need more privacy-specific answers? Our Data Protection Officer is always available at dpo@monemon.com