Privacy Policy: Let’s keep it real with Your data!
Effective Date: 01.03.2024
What’s what (Definitions)
Here’s a quick lowdown on the important terms we’ll use:
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 to simplify your life — managing your digital money, using our debit card, earning loyalty points with MOWO and more. It’s all part of the Monemon experience.
MOWO: A digital loyalty platform offered by Monemon Digital OÜ where users can create avatars, earn loyalty points through Monemon services, and redeem those points for rewards.
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 your payments — who, when and how much did you pay. Pretty straightforward, right?
Who are we?
Hey! We’re Monemon AS, an Estonian company (Reg. No. 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.
What data do we collect and from where?
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 (the basics).
Device data: This could include your phone model, IP address and sometimes your location (only with permission!).
Transaction data: Every time you spend or receive money — dates, amounts and who you sent it to.
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 most — to improve your usage experience.
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.
MOWO data: When you’re in the MOWO loyalty program, we also collect info on how you use Monemon services. It's all part of leveling up your experience.
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 register or similar registers 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.
E-arrest (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.
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:
Compliance purposes
We’re bound by laws and regulations, so we collect your data to:
Prevent money laundering, terrorist financing and fraud (AML/CFT).
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.
Contractual purposes (making it official): To offer and maintain your Monemon account, 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!
Analytical purposes (we’re always improving)
We study general user behavior 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).
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 subsidiaries or partners (again, only with your permission).
Sync your contacts (to see who else uses Monemon.)
Share your avatar and loyalty status in the MOWO ecosystem.
How do we share your data
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). Plus, when you make payments, we share the necessary info (like who paid and who’s getting paid) with financial institutions — your data moves with your money.
Server hosts: The tech companies that keep Monemon running smooth and secure.
Payment processors & networks: We share your info with banks and payment services like Mastercard to make sure your transactions go through without a hitch.
Identity verification services: To confirm you’re you (and not some fraudster), we share data with third parties that help verify your identity. This includes mandatory checks like seeing if you’re a Politically Exposed Person (PEP) or if you're on any sanctions lists.
Card manufacturers & couriers: When we need to send you your Monemon card, we share the info needed to get it made and shipped to your door.
MOWO fam: Since MOWO’s part of our crew, managed by our sister company Monemon Digital OÜ, we share some of your Monemon usage data to help you stack loyalty points.
Third-party services in MOWO: To enhance your experience in MOWO, we collaborate with external service providers. For avatar creation, gaming experiences or when you order physical products, certain data (like pictures you take to create your avatar or your address for shipping) may be shared with these partners to fulfill your requests.
Communication services: Companies that help us stay in touch via email, text or push notifications — so you’re always up to date.
Sources 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.
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 8 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.
Legal stuff: If we have a reason (like a court case), we might keep your data longer.
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.
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.
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.
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.
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.
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
